EX-99.1 4 efc19-641_ex991s3.htm GSMBS PJ3-2019 EXCEPTIONS GRADES
Exception Grades
       
Run Date - 10/9/2019 9:01:49 AM
     

AMC Loan ID
Customer Loan ID
Seller Loan ID
Loan Exception ID
Exception ID
Exception Date
Exception Type
Exception Category
Exception Subcategory
Exception
Exception Detail
Exception Information
Compensating Factors
Applying Party
Follow-up Comments
Cleared Date
Cured Date
Waived Date
Exception Level Grade
Exception Level Rating
Note Date
Property State
Occupancy
Purpose
Exception Remediation
Overall
Initial Loan Grade
Overall
Final Loan Grade
Credit
Initial Loan Grade
Credit
Final Loan Grade
Compliance
Initial Loan Grade
Compliance
Final Loan Grade
Property
Initial Loan Grade
Property
Final Loan Grade
Originator QM ATR Status
TPR QM ATR Status
Is Curable
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Finance Charge
TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan. (Final/XXXXX)
CD reflects finance charge of $XXXXX.  Calculated finance charge is $XXXXX.  Variance is $XXXXX. CD is incorrect as finance charges calculated correctly and finance charges included match amounts lender included per page XXXXX
   
Reviewer Comment (2018-05-16): Waterfall method approved by outside counsel to apply lump sum lender credit to non-APR affecting settlement fees then remaining credit towards APR affecting settlement fees applied on this  loan per XXXXX instructions to XXXXX .
 
 
Reviewer Comment (2018-05-10): Escalated
 
 
Seller Comment (2018-05-10): We do not apply credits to specific charges but we do employ a general policy that provides a waterfall of how lender credits are applied to a loan. We apply lender credit (as a whole) to any settlement charges first, then any remainder is applied (as a whole) to any finance charges, and then if any remains beyond that we apply to other charges such as escrows and taxes. There is no specific allocation to a fee, just an underlying approach so we can calculate APR accordingly and with purpose.
 
 
Reviewer Comment (2018-05-01): TRID regulations specifically provide that credit for specific fees are to be itemized within the paid by seller or paid by others column.
XXXXX has been advised that to have credits apply to specific charges, the specific fee on page 2 of the CD should be listed as paid by other or paid by seller in the appropriate column.
 
 
Seller Comment (2018-05-01): Please ensure that the final CD issued XXXXX (which has been uploaded) is being used and when calculating, any lender credit is applied to settlement charges first and then finance charges.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission if Applicable
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - Wholesale Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name). (Final/XXXXX)
Lender contact name and XXXXX were not provided on final CD.
   
Reviewer Comment (2018-04-24): XXXXX waived the exception.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing. (Type:Primary/XXXXX)
     
Reviewer Comment (2018-04-24): XXXXX elected to waive the exception.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
 
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller - Closing Costs Financed
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed Closing Costs Financed that does not match actual amount of closing costs financed. (Final/XXXXX)
CD disclosed closing costs financed as blank
   
Reviewer Comment (2018-12-05): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Interim Closing Disclosure Without Seller - Closing Costs Financed
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Closing Disclosure provided on XXXXX disclosed an inaccurate Closing Costs Financed amount. (Initial/XXXXX)
CD disclosed closing costs financed as blank
   
Reviewer Comment (2018-12-05): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Good Faith Redisclosure
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Loan Estimate Estimated Closing Costs Financed Without Seller
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Loan Estimate provided on XXXXX disclosed Estimated Closing Costs Financed that does not match the actual closing costs financed calculation. (Initial/XXXXX)
LE disclosed closing costs financed as $XXXXX
   
Reviewer Comment (2018-12-05): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Good faith redisclosure
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Loan Estimate Estimated Closing Costs Financed Without Seller
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Loan Estimate provided on XXXXX disclosed Estimated Closing Costs Financed that does not match the actual closing costs financed calculation. (Interim/XXXXX)
LE disclosed closing costs financed as $XXXXX
   
Reviewer Comment (2018-12-05): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Good faith redisclosure
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Property - Appraisal
Appraisal Reconciliation
Missing secondary valuation product required for securitization.
       
Reviewer Comment (2018-12-17): Received a XXXXX desk review dated XXXXX which provided a value of $XXXXX a 0.00% variance from the appraised value of $XXXXX, value supported.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
Loan did not meet income documentation for most recent year for self- employed borrower.
   
Reviewer Comment (2018-12-31): All income documentation was provided to meet QM requirements.
 
 
Seller Comment (2018-12-28): app date XXXXX, funding date XXXXX; XXXXX guidelines at that time indicated that we needed XXXXX & XXXXX tax returns, XXXXX P&L and balance sheet, and XXXXX YTD P&L and balance sheet.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Lender to provide updated ATR/QM status
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
S-Corp Income Documentation Test
Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (S-Corp). (XXXXX)
Most recent year business (XXXXX) and personal returns not in file.
   
Reviewer Comment (2018-12-31): All returns were provided to support income to QM guidelines.
 
 
Seller Comment (2018-12-28): app date XXXXX, funding date XXXXX; XXXXX guidelines at that time indicated that we needed XXXXX & XXXXX tax returns, XXXXX P&L and balance sheet, and XXXXX YTD P&L and balance sheet.
 
 
Reviewer Comment (2018-12-14): Missing most recent two year 1120s business returns for co-borrower. File only contains transcripts. Exception remains.
 
 
Seller Comment (2018-12-11): Per our guidelines dated XXXXX, the XXXXX tax returns were not needed.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Income / Employment
Income Documentation
Income Docs Missing:
Borrower: XXXXX
XXXXX Transcripts or XXXXXTranscripts - No Results Returned was not provided.
   
Reviewer Comment (2019-01-09): Loan closed XXXXX with an application date of XXXXX. Most recent transcript would be XXXXX. XXXXX and XXXXX transcripts in file. Guidelines requirement met. Exception cleared.
 
 
Reviewer Comment (2018-12-20): Lender guidelines dated XXXXX state The most recent 2 years federal tax transcripts are required for all borrowers. If the most recent year shows no record found, a copy of the attempt to pull the transcript showing no records found, plus the previous 2 years transcripts are required. Exception remains.
 
 
Seller Comment (2018-12-20): Application date XXXXX, funding date XXXXX; XXXXX guidelines at that time indicated that we needed XXXXX &XXXXX tax returns; XXXXX P&L and Balance Sheet and XXXXX YTD P&L and Balance Sheet.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Closing Disclosure Timing without Waiver
TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/XXXXX)
Initial Cd provided on XXXXX
   
Reviewer Comment (2019-01-17): XXXXX received XXXXX CD with receipt the same day. Exception Cleared.
 
 
Seller Comment (2019-01-17): The electronic signature on the CD is time stamped on XXXXX.  This provides proof that the borrower, in fact, did receive the initial CD on XXXXX.
 
 
Reviewer Comment (2019-01-04): Please provide proof of receipt for initial cd to clear.
 
 
Seller Comment (2019-01-04): The initial CD was XXXXX and the closing date was XXXXX. There is no violation.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
No Defined Cure
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
Binding LE did not disclose Appraisal Re-Inspection Fee of $XXXXX disclosed on Consumer's Final CD.  Consumer's Final CD disclosed a Lender Credit of $XXXXX for increase in Closing Costs above legal limit which is sufficient to cure 0% tolerance violation.
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Final CD evidences Cure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Prepaid Property Tax Months
TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXX did not disclose number of months for Property Tax under Prepaids.
The number of months of prepaid property taxes disclosed in section F of the final CD was blank.
   
Reviewer Comment (2019-03-13): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Finance Charge
TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.
Final CD disclosed a Finance Charge of $XXXXX, however, calculated amount is $XXXXX.
   
Reviewer Comment (2019-03-27): The lender provided a PCCD, re-opened the ROR with evidence of proof of delivery, LOE to borrower and evidence of mailing on XXXXX which would deliver on XXXXX.
 
 
Seller Comment (2019-03-26): Please clear exception - rescission expired on XXXXX. Thank you
 
 
Reviewer Comment (2019-03-19): PCCD, LOE, Copy of Refund check in the amount of $XXXXX and XXXXX shipping label provided.  Per XXXXX tracking package has not yet shipped.  New Right to Cancel has been opened and will expire on XXXXX.  Will cure after expiration of RTC and evidence of POD.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission if Applicable
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Closing Disclosure Timing without Waiver
TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.
Initial CD provided on XXXXX was received on XXXXX which is not at least 3 business days prior to closing date of XXXXX.
   
Reviewer Comment (2019-03-19): Evidence of earlier receipt provided.
 
 
Reviewer Comment (2019-03-14): XXXXX received snapshot of Disclosure Tracking. Please provide the eDisclosure Tracking tab to determine if exception can be cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
No Defined Cure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Credit Exception:
 
Pending Internal XXXXX Final Collateral Package Review.
   
Reviewer Comment (2019-06-06): Received
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-06-06): Received
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Credit Exception:
 
Pending Internal XXXXX Final Collateral Package Review
   
Reviewer Comment (2019-04-25): The client has reviewed and accepted the collateral. Exception cleared
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Non Escrowed Property Costs Year 1
TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of $XXXXX on Final Closing Disclosure provided on XXXXX not accurate.
Valuation indicates HOA is $XXXXX lender has HOA at $XXXXX. There is a special assessment listed on the appraisal however that value of $XXXXX plus the HOA cost does not equal $XXXXX
   
Reviewer Comment (2019-04-18): Letter of Explanation & Corrected Closing Disclosure provided.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
The loan signed on XXXXX.   The initial CD declares a closing date of XXXXX,   The Final CD declares a closing date of XXXXX which matches the notes and security instrument dates.   The loan signed on XXXXX per the security instruement notory and all other signed clolsing documents.
   
Reviewer Comment (2019-04-08): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Esign Consent Agreement Status
ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $XXXXX and disclosure timing violations.
Not in file.
   
Reviewer Comment (2019-04-05): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
No Defined Cure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $XXXXX exceeds tolerance of $XXXXX plus 10% or $XXXXX.  Insufficient or no cure was provided to the borrower.
Document was delivered electronically and the file did not contain authorization from the borrower to receive files electronically.
   
Reviewer Comment (2019-04-10): XXXXX received PCCD moving XXXXX to section C and LOE. Exception Cured.
 
 
Reviewer Comment (2019-04-08): XXXXX received E Consent. The exception is firing as the XXXXX Fee is located in Section B and was not initially disclosed. It appears Fee should be located in Section C as it is not paid to SSPL, but chosen provider. Please provide corrected CD and LOE to cure.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Document was delivered electronically and the file did not contain authorization from the borrower to receive files electronically.
   
Reviewer Comment (2019-04-08): XXXXX received E Consent dated XXXXX. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Document was delivered electronically and the file did not contain authorization from the borrower to receive files electronically.
   
Reviewer Comment (2019-04-08): XXXXX received E Consent dated XXXXX. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Document was delivered electronically and the file did not contain authorization from the borrower to receive files electronically.
   
Reviewer Comment (2019-04-08): XXXXX received E Consent dated XXXXX. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Document was delivered electronically and the file did not contain authorization from the borrower to receive files electronically.
   
Reviewer Comment (2019-04-08): XXXXX received E Consent dated XXXXX. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Document was delivered electronically and the file did not contain authorization from the borrower to receive files electronically.
   
Reviewer Comment (2019-04-10): XXXXX received PCCD moving XXXXX to section H and LOE. Exception Cured.
 
 
Reviewer Comment (2019-04-08): XXXXX received E Consent. The XXXXX Fee was not initially disclosed or added with a valid change of circumstance. Please provide corrected CD, LOE, Refund Check, and Proof of Delivery to cure. If fee was optional it should be in section H and would required PCCD and LOE to cure.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Document was delivered electronically and the file did not contain authorization from the borrower to receive files electronically.
   
Reviewer Comment (2019-04-08): XXXXX received E Consent dated XXXXX. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
Document was delivered electronically and the file did not contain authorization from the borrower to receive files electronically.
   
Reviewer Comment (2019-04-05): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
COC or cure was not provided.
   
Reviewer Comment (2019-04-05): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Esign Consent Agreement Status
ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $XXXXX and disclosure timing violations.
Missing E-sign Consent Disclosure.
   
Reviewer Comment (2019-04-05): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
No Defined Cure
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $XXXXX exceeds tolerance of $XXXXX plus 10% or $XXXXX.  Insufficient or no cure was provided to the borrower.
Missing E-sign Consent Disclosure.
   
Reviewer Comment (2019-04-09): XXXXX received E Consent dated XXXXX. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Missing E-sign Consent Disclosure.
   
Reviewer Comment (2019-04-09): XXXXX received E Consent dated XXXXX. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Missing E-sign Consent Disclosure.
   
Reviewer Comment (2019-04-09): XXXXX received E Consent dated XXXXX. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Missing E-sign Consent Disclosure.
   
Reviewer Comment (2019-04-09): XXXXX received E Consent dated XXXXX. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Missing E-sign Consent Disclosure.
   
Reviewer Comment (2019-04-09): XXXXX received E Consent dated XXXXX. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for HOADues.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Missing E-sign Consent Disclosure.
   
Reviewer Comment (2019-04-18): Letter of Explanation to go with PCCD provided.  A refund is not required nor is POD.
 
 
Reviewer Comment (2019-04-18): PCCD provided with evidence of mailing via US mail.  A refund is not required.  Please provide Letter of Explanation provided to the Borrower to cure.
 
 
Reviewer Comment (2019-04-16): PCCD dated XXXXX provided moved the HOA dues to Section H which excludes this fee from Zero percent tolerance testing, the XXXXX is still disclosed in Section B and needs to be moved to Section H as well to exclude from Zero testing.  Provide a Corrected CD along with a letter of explanation provided to Borrower to cure.
 
 
Seller Comment (2019-04-15): Based on the PC CD please advise why a LOE, check, and proof of delivery are still required? All other documents sent should suffice.
 
 
Reviewer Comment (2019-04-12): PCCD was received.  The LOE, copy of any refund check and proof of delivery required in order to address the exception.
 
 
Reviewer Comment (2019-04-11): XXXXX is unable to address the exception.  The trailing documents uploaded are not related to the CD or subject fee.
 
 
Reviewer Comment (2019-04-09): XXXXX received E Consent dated XXXXX. The fee of HOA Dues is in Section C indicating it is required fee of lender however borrower shopped. It appears fee should be located in section H of optional fees. Please provide corrected CD and LOE to cure.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Missing E-sign Consent Disclosure.
   
Reviewer Comment (2019-04-09): XXXXX received E Consent dated XXXXX. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Sole Proprietorship Income Documentation Test
Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Sole Proprietorship).
Missing third party VOE for sole proprietor income, XXXXX YTD P & L and XXXXX Balance Sheet
   
Reviewer Comment (2019-04-11): Per the lender correspondence and borrower LOE there is no income from schedule C as this was just some freelance work done and is no longer producing income. Per the lender this income source was not used to qualify and should not have been included.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
General Ability To Repay Provision Employment - Schedule C Test
Ability-to-Repay (Dodd-Frank 2014): Unable to verify current Sole Proprietorship status using reasonably reliable third-party records.
Missing third party VOE for sole proprietor income, XXXXX YTD P & L and XXXXX Balance Sheet
   
Reviewer Comment (2019-04-11): Per the lender correspondence and borrower LOE there is no income from schedule C as this was just some freelance work done and is no longer producing income. Per the lender this income source was not used to qualify and should not have been included.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
NonQM ATR
Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.
Missing third party VOE for sole proprietor income, XXXXX YTD P & L and XXXXX Balance Sheet
   
Reviewer Comment (2019-04-11): Per the lender correspondence and borrower LOE there is no income from schedule C as this was just some freelance work done and is no longer producing income. Per the lender this income source was not used to qualify and should not have been included.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of ATR Fail.
Missing third party VOE for sole proprietor income, XXXXX YTD P & L and XXXXX Balance Sheet
   
Reviewer Comment (2019-04-11): Per the lender correspondence and borrower LOE there is no income from schedule C as this was just some freelance work done and is no longer producing income. Per the lender this income source was not used to qualify and should not have been included.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Income / Employment
Income Documentation
Income Docs Missing:
-
Missing third party VOE for sole proprietor income.
   
Reviewer Comment (2019-04-11): Per the lender correspondence and borrower LOE there is no income from schedule C as this was just some freelance work done and is no longer producing income. Per the lender this income source was not used to qualify and should not have been included.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-04-16): Secondary product provided supporting the origination value
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Capital Gains Tax Returns
Qualified Mortgage (Dodd-Frank 2014): Three (3) years tax returns to evaluate Capital Gains or Losses requirement not met.
Missing XXXXX 1040's.
   
Reviewer Comment (2019-04-11): The capital gains and losses are in flux, the borrower received gains in XXXXX and a minor loss in XXXXX. The borrower also has assets in excess of 1.3MM to support further income that was not used to qualify.
 
 
Reviewer Comment (2019-04-11): In the event the loss is a one time event, then the additional documentation is not required.  If the loss is not a one time event, then, Appendix Q requires 3 years returns. Did the UW/lender perform an analysis to document the loss was not ongoing and thereby not requiring three years tax returns? Exception remains.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM Employment History - Current Employment Documentation lacks Date Info
Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two years current employment.
Third party verification of business license does not include start date.
   
Reviewer Comment (2019-04-05): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
Two years employment not verified for borrower.
   
Reviewer Comment (2019-04-11): both a bio and company website for IBCLC (which is an international board) was provided to support both the business and continuation.
 
 
Reviewer Comment (2019-04-10): Exception is due to not having explicitly defined dates for 2 year history, however documentation in file meets requirement for QM. Non-material. Exception remains
 
 
Seller Comment (2019-04-10): Tax returns show borrower has been self-employed for 2 years and meets Appendix Q requirements. Proof of SE is required to show income still exist. Therefore current license and borrower website provided to show income still exist.  Start date of self-employment is not required to be documented if 2 years has been documented. Please advise.
 
 
Reviewer Comment (2019-04-09): IBLCE lookup in file only shows that Borrower is currently licensed to 2023.  It does not confirm the borrower was actually licensed during the duration listed on 1003.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Lender to provide updated ATR/QM status
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Esign Consent Agreement Status
ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $XXXXX and disclosure timing violations.
E-sign consent missing from loan file.
   
Reviewer Comment (2019-04-05): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
No Defined Cure
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
Consent agreement signed and dated by Consumer(s) to authorized electronic delivery of documents including initial LE was not provided at the time of review.
   
Reviewer Comment (2019-04-08): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $XXXXX exceeds tolerance of $XXXXX plus 10% or $XXXXX.  Insufficient or no cure was provided to the borrower.
Consent agreement signed and dated by Consumer(s) to authorized electronic delivery of documents including initial LE was not provided at the time of review.
   
Reviewer Comment (2019-04-09): XXXXX received E Consent dated XXXXX. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Consent agreement signed and dated by Consumer(s) to authorized electronic delivery of documents including initial LE was not provided at the time of review.
   
Reviewer Comment (2019-04-09): XXXXX received E Consent dated XXXXX. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Consent agreement signed and dated by Consumer(s) to authorized electronic delivery of documents including initial LE was not provided at the time of review.
   
Reviewer Comment (2019-04-09): XXXXX received E Consent dated XXXXX. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Consent agreement signed and dated by Consumer(s) to authorized electronic delivery of documents including initial LE was not provided at the time of review.
   
Reviewer Comment (2019-04-09): XXXXX received E Consent dated XXXXX. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Consent agreement signed and dated by Consumer(s) to authorized electronic delivery of documents including initial LE was not provided at the time of review.
   
Reviewer Comment (2019-04-09): XXXXX received E Consent dated XXXXX. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
(Missing Data) Last Rate Set Date
Last Date Rate Set and Initial Rate Lock Date not provided.  Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing.
Date the rate was locked was not evidenced in loan file.
   
Reviewer Comment (2019-04-05): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-04-16): Secondary product provided supporting the origination value
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
Only 1 appraisal required per guidelines when loans < $1,500,000 on a Purchase transaction.
   
Reviewer Comment (2019-04-16): Secondary product provided supporting the origination value
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
     
Reviewer Comment (2019-04-05): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Credit Exception:
 
Lender did not include previous primary mortgage in DTI due to pending sale on the same day as subject property.  Missing closing disclosure for previous primary address.
   
Reviewer Comment (2019-04-12): Closing disclosure provided supporting funds to close and the sale of the primary home.
 
 
Reviewer Comment (2019-04-11): Provided was the XXXXX amendatory clause and purchase agreement for the sale of XXXXX showing the closing was agreed upon for XXXXX however there is no closing statement support the closing and the funds to the borrower needed to complete the purchase transaction. The exception remains.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Asset
Asset Calculation / Analysis
Available for Closing is insufficient to cover Cash From Borrower.
 
Missing settlement statement from sale of departing residence.
   
Reviewer Comment (2019-04-12): Closing disclosure provided supporting funds to close and the sale of the primary home.
 
 
Reviewer Comment (2019-04-11): Provided was the XXXXX amendatory clause and purchase agreement for the sale of XXXXX showing the closing was agreed upon for XXXXX however there is no closing statement support the closing and the funds to the borrower needed to complete the purchase transaction. The exception remains.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
Secondary valuation product is missing from the file.
   
Reviewer Comment (2019-04-16): Secondary product provided supporting the origination value
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
State Compliance
XXXXX Disclosure Timing Test
XXXXX: Borrower not provided with a document, at time of application, specifying the agency designated to receive complaints or inquiries about the origination and making of the loan.
Disclosure issued/signed XXXXX, which is not within 3 days of application date. No evidence of earlier receipt was not found.
   
Reviewer Comment (2019-04-12): Provided was the disclosure to the borrower at the time of application
 
 
Reviewer Comment (2019-04-11): Provided was the Esign and 1003 however the Esign lists 31 pages but does not identify the XXXXX as being included in the initial package. The current disclosure was provided dated XXXXX, missing is an initial disclosure or a document list from the Esign at application showing the XXXXX as included. Exception remains.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
Closing costs exceeds limit due to lack of e-sign consent agreement prior to XXXXX; initial loan estimate e-signed XXXXX.
   
Reviewer Comment (2019-04-05): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Loan Estimate Esign Consent Agreement Timing
ESIGN Act - Loan Estimate provided on XXXXX was electronically provided prior to borrower's consent to receive electronic disclosures.  Disclosure will not be used to rebaseline for tolerance purposes and may result in disclosure timing violations.  Initial LE sent electronically prior to esign consent may result in a fee tolerance violation of up to $XXXXX.
Loan Estimate provided on XXXXX was electronically provided prior to borrower's consent to receive electronic disclosures.  Disclosure will not be used to re-baseline for tolerance purposes and may result in disclosure timing violations.  Initial LE sent electronically prior to e-sign consent may result in a fee tolerance violation of up to $XXXXX. (Initial/XXXXX)
   
Reviewer Comment (2019-04-05): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
No Defined Cure
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $XXXXX exceeds tolerance of $XXXXX plus 10% or $XXXXX.  Insufficient or no cure was provided to the borrower.
Evidence of earlier borrower receipt of E-Sign Consent was not found; therefore disclosure reflecting issue date of XXXXX was not used for testing.
   
Reviewer Comment (2019-04-11): Esign provided dated XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
Evidence of earlier borrower receipt of E-Sign Consent was not found; therefore disclosure reflecting issue date of XXXXX was not used for testing.
   
Reviewer Comment (2019-04-11): The initial LE dated XXXXX was used for testing as the Esigned confirmed delivery
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Provided Prior to Date Performed
ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.
Appraisal was emailed to the borrower on XXXXX, after effective date of XXXXX; however, prior to the report/signature date of XXXXX.
   
Reviewer Comment (2019-04-05): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
Evidence of earlier borrower receipt of E-Sign Consent was not found; therefore disclosure reflecting issue date of XXXXX was not used for testing.
   
Reviewer Comment (2019-04-11): Esign provided dated XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
one appraisal done
   
Reviewer Comment (2019-05-01): 0% variance
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
A
A
B
A
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
true borrower signed on XXXXX and note was on XXXXX
   
Reviewer Comment (2019-04-26): Post close CD reflects correct dates.
 
 
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
A
A
A
B
A
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Property - Appraisal
Appraisal Documentation
Missing Document: Appraisal not provided
 
Appraisal waiver option used, however appraisal required for securitization.
   
Reviewer Comment (2019-05-15): Loan was a PIW. Appraisal not required.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
C
D
A
B
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
The Final CD issued XXXXX reflected a closing date of XXXXX instead of the actual date of consummation XXXXX.
   
Reviewer Comment (2019-05-02): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
D
C
D
A
B
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Flood Certificate not provided
       
Reviewer Comment (2019-04-24): Received Flood Cert.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
The Final Closing Disclosure disclosed that the Loan Closing Costs exceeded the legal limit by $XXXXX.  This exception will be re-tested when signed E Consent Agreement is received for earliest Loan Estimate.
   
Reviewer Comment (2019-04-24): Cured at closing
 
 
Reviewer Comment (2019-04-24): Revised LE issued XXXXX removed XXXXX Fee of $XXXXX. Missing Valid COC for final fee charged of $XXXXX.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
The XXXXX Fee was not disclosed on the original loan Estimate.  However, the lender gave a $XXXXX credit to the borrower to cure this violation.  This can not yet be cured due to other tolerance exceptions.
   
Reviewer Comment (2019-04-24): XXXXX received required documents, exception is cleared.
 
 
Reviewer Comment (2019-04-24): Cure reflected on final CD, however, other tolerance violation must be addressed first.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
Update- Revised LE issued XXXXX removed XXXXX Fee of $XXXXX. Missing Valid COC for final fee charged of $XXXXX.
   
Reviewer Comment (2019-04-24): XXXXX received required documents, exception is cleared.
 
 
Reviewer Comment (2019-04-24): Update- Revised LE issued XXXXX removed XXXXX Fee of $XXXXX. Missing Valid COC for final fee charged of $XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Loan Estimate Esign Consent Agreement Timing
ESIGN Act - Loan Estimate provided on XXXXX was electronically provided prior to borrower's consent to receive electronic disclosures.  Disclosure will not be used to rebaseline for tolerance purposes and may result in disclosure timing violations.  Initial LE sent electronically prior to esign consent may result in a fee tolerance violation of up to $XXXXX.
Missing E-Consent Agreement signed by the borrower  for the Loan Estimate dated XXXXX signed electronicly by the borrower. Earliest E Sign Agreement is XXXXX. Per XXXXX update, absence of e-consent signed by the borrower is the equivalent of the disclosures never being sent. Fee tolerance will be re-tested when signed  E-Consent Agreement is received.
   
Reviewer Comment (2019-04-24): Received additional disclosure tracking, eConsent received XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
No Defined Cure
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Loan Estimate Esign Consent Agreement Timing
ESIGN Act - Loan Estimate provided on XXXXX was electronically provided prior to borrower's consent to receive electronic disclosures.  Disclosure will not be used to rebaseline for tolerance purposes and may result in disclosure timing violations.  Initial LE sent electronically prior to esign consent may result in a fee tolerance violation of up to $XXXXX.
Missing E-Consent Agreement signed by the borrower  for the Loan Estimate dated XXXXX signed electronicly by the borrower. Earliest E Sign Agreement is XXXXX. Per XXXXX update, absence of e-consent signed by the borrower is the equivalent of the disclosures never being sent. Fee tolerance will be re-tested when signed  E-Consent Agreement is received.
   
Reviewer Comment (2019-04-24): Received additional disclosure tracking, eConsent received XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
No Defined Cure
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Loan Estimate Esign Consent Agreement Timing
ESIGN Act - Loan Estimate provided on XXXXX was electronically provided prior to borrower's consent to receive electronic disclosures.  Disclosure will not be used to rebaseline for tolerance purposes and may result in disclosure timing violations.  Initial LE sent electronically prior to esign consent may result in a fee tolerance violation of up to $XXXXX.
Missing E-Consent Agreement signed by the borrower  for the Loan Estimate dated XXXXX signed electronicly by the borrower. Earliest E Sign Agreement is XXXXX. Per SFIG update, absence of e-consent signed by the borrower is the equivalent of the disclosures never being sent. Fee tolerance will be re-tested when signed  E-Consent Agreement is received.
   
Reviewer Comment (2019-04-24): Received additional disclosure tracking, eConsent received XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
No Defined Cure
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $XXXXX exceeds tolerance of XXXXX plus 10% or XXXXX.  Insufficient or no cure was provided to the borrower.
Fee tolerance will be re-tested when signed  E-Consent Agreement is received
   
Reviewer Comment (2019-04-24): Received additional disclosure tracking, eConsent received XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
Fee tolerance will be re-tested when signed  E-Consent Agreement is received
   
Reviewer Comment (2019-04-24): Received additional disclosure tracking, eConsent received XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
Fee tolerance will be re-tested when signed  E-Consent Agreement is received
   
Reviewer Comment (2019-04-24): Received additional disclosure tracking, eConsent received XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
Fee tolerance will be re-tested when signed  E-Consent Agreement is received
   
Reviewer Comment (2019-04-24): Received additional disclosure tracking, eConsent received XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
Fee tolerance will be re-tested when signed  E-Consent Agreement is received
   
Reviewer Comment (2019-04-24): Received additional disclosure tracking, eConsent received XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
Fee tolerance will be re-tested when signed  E-Consent Agreement is received
   
Reviewer Comment (2019-04-24): Received additional disclosure tracking, eConsent received XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
Fee tolerance will be re-tested when signed  E-Consent Agreement is received
   
Reviewer Comment (2019-04-24): Received additional disclosure tracking, eConsent received XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX Fee.  Fee Amount of $XXXXX exceeds tolerance of XXXXX.  Sufficient or excess cure was provided to the borrower.
Cured at closing
   
Reviewer Comment (2019-04-24): Cured at closing.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower.
     
Reviewer Comment (2019-04-24): XXXXX received required documents, exception is cured.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
S-Corp Income Documentation Test
Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (S-Corp).
QM requires 2 years of individual tax returns, however lender's guidelines only require business returns.  Only XXXXX 1040s were provided.
   
Reviewer Comment (2019-04-24): Received XXXXX 1040.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
S-Corp Income Documentation Test
Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (S-Corp).
QM requires 2 years of individual tax returns, however lender's guidelines only require business returns.  Only XXXXX 1040s were provided.
   
Reviewer Comment (2019-04-24): Received XXXXX 1040.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
QM requires 2 years of individual tax returns, however lender's guidelines only require business returns.  Only XXXXX 1040s were provided.
   
Reviewer Comment (2019-04-24): Received XXXXX 1040.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Guideline Requirement: PITIA reserves months discrepancy.
Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.
Guides require 6 months reserves for each property financed for a total 18 months.
   
Reviewer Comment (2019-05-20): The reserves required are $XXXXX and the borrower has a total of $XXXXX in reserves available.
 
 
Seller Comment (2019-05-17): Disagree. It appears that the seller is using aged documentation in their reserve calculation.
 
Reviewer is using the initial CD issued XXXXX that shows funds from the borrower of $XXXXX. The Post Consummation CD dated XXXXX reflects funds from borrower of $XXXXX . Reviewer's reserves calculation is therefore understated by $XXXXX, based on using the wrong CD.
 
XXXXX account #XXXXX with a balance ending XXXXX has a balance of $XXXXX. Reviewer's figure is from the same account however dated XXXXX. Reviewer's reserves calculation is therefore understated by $XXXXX ($XXXXX security deposit and 1st month rent).
 
Please see the attached
 
 
Reviewer Comment (2019-05-08): Per CD dated XXXXX ( final used for testing) $XXXXX  cash to close.  Available assets $XXXXX  (XXXXX  $XXXXX + XXXXX  $XXXXX  (after $5k withdrawal) + XXXXX  $XXXXX  + Life insurance cash value $XXXXX ).  + Gift Funds $XXXXX  + EMD $XXXXX . Total Assets $XXXXX  - $XXXXX  - $XXXXX  - $XXXXX  - $XXXXX (paid before close) ($XXXXX )= $XXXXX
 
 
Seller Comment (2019-05-08): XXXXX: Disagree: Reserves required: $XXXXX
Subject $XXXXX ($XXXXX x6); XXXXX  $XXXXX  ($XXXXX  x6); XXXXX : $XXXXX  ($XXXXX  x6).  Per CD $XXXXX  cash to close + Gift funds $XXXXX = $XXXXX .  Available assets $XXXXX (XXXXX  $XXXXX + XXXXX  $XXXXX (after $XXXXX withdrawal) + XXXXX  $XXXXX + Life insurance cash value $XXXXX ).  Total Assets $XXXXX- $XXXXX = $XXXXX- $XXXXX (required reserves)= $XXXXX remaining assets.  Please provide details of assets used in calculation.
 
 
Reviewer Comment (2019-05-07): Calculated reserves of $XXXXX  is less than required reserves $XXXXX - subject + $XXXXX - XXXXX + $XXXXX - XXXXX = $XXXXX
 
 
Seller Comment (2019-05-06): XXXXX:  Disagree:  # 8 states When borrower has financed properties in addition to the subject property, an additional 6 months of PITI reserves are required for each property meaning that 6 months of reserves is required for the subject and 6 months of reserves is required for each  additional financed property.  We have the subject which required 6, then the 2 financed properties which requires 6 months of reserves each. Please see the attached Guidelines for Jumbo.
 
 
Reviewer Comment (2019-05-03): The section of the guidelines provided show 6 months for the subject but line item 8 of the guidelines state an additional 6 months reserves are required for each financed property. Currently the total financed property is XXXXX
 
 
Seller Comment (2019-05-02): XXXXX Disagree with Finding
Reserves required: $XXXXX
Subject $XXXXX ($XXXXX x6)
XXXXX  $XXXXX  ($XXXXX  x6)
XXXXX : $XXXXX  ($XXXXX  x6)
The other two properties are free and clear and guidelines states that we only need to verify reserves for financed properties.
 
Available Assets $XXXXX  (Gift funds $XXXXX + Liquid assets $XXXXX  + Insurance policy cash value $XXXXX )
Funds to close: $XXXXX   ($XXXXX  cash from borrower + Gift funds $XXXXX ) + $XXXXX  required reserves = $XXXXX .
 
Available Assets $XXXXX - $XXXXX  = $XXXXX  (remaining assets).
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Signature Statement
TILA-RESPA Integrated Disclosure - Final Closing Disclosure provided on XXXXX does not contain the required signature statement.
The buyer final CD dated XXXXX is missing the signature line and comments
   
Reviewer Comment (2019-05-13): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
A corporate tax return extension dated XXXXX is in file for  XXXXX , extending the S-Corp return until XXXXX which is after the subject closing of XXXXX.
   
Reviewer Comment (2019-05-13): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Homeowner's Insurance Premium Months
TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.
Monthly Insurance escrow is $XXXXX ; however, annual insurance premium collected at closing was $XXXXX, when divided by 12 is $XXXXX. A difference of $XXXXX.
   
Reviewer Comment (2019-05-13): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
(Missing Data) Last Rate Set Date
Last Date Rate Set and Initial Rate Lock Date not provided.  Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing.
Missing copy of Rate lock.
   
Reviewer Comment (2019-05-13): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Guideline Requirement: Investor qualifying total debt ratio discrepancy.
 
Lender did not included monthly HOA fee of $XXXXX in DTI calculations and causing DTI to increase to XXXXX% exceeding maximum allowed of XXXXX%
   
Reviewer Comment (2019-05-24): The lender provided an updated taxing sheet which had lowered the tax rate due to homestead exemption and brings the DTI in line
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines
Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of XXXXX% moderately exceeds the guideline maximum of XXXXX%. (DTI Exception is eligible to be regraded with compensating factors.)
Lender did not included monthly HOA fee of $XXXXX in DTI calculations and causing DTI to increase to XXXXX% exceeding maximum allowed of XXXXX%
   
Reviewer Comment (2019-05-24): The lender provided an updated taxing sheet which had lowered the tax rate due to homestead exemption and brings the DTI in line
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018
TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of XXXXX on Final Closing Disclosure provided on XXXXX not accurate.
Estimated Property Costs over Year 1 of $XXXXX appears to be based on $XXXXX insurance, $XXXXX taxes, however, the lender did not use HOA of $XXXXX and the taxes should be $XXXXX per file documentation. Hazard $XXXXX is the same. so corrected CD needs to read XXXXX x 12 = XXXXX. Provided corrected PC CD along with LOE to borrower and evidence of deliver.
   
Reviewer Comment (2019-05-22): XXXXX received PCCD correcting total property costs and LOE. Exception Cured.
 
 
Seller Comment (2019-05-21): Please see the attached PCCD
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Seller Closing Disclosure
TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.
The seller's closing disclosure was not provied.
   
Reviewer Comment (2019-05-17): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Binding LE disclosed XXXXX of $XXXXX however, Consumer's Final CD disclosed $XXXXX  Cure for X% tolerance violation was not provided.
   
Reviewer Comment (2019-05-13): A cure provided at closing.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
General Ability To Repay Provision Investor Guidelines
Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.
Lender did not included monthly HOA fee of $XXXXX which caused the DTI to exceed maximum allowed of XXXXX%.
   
Reviewer Comment (2019-05-24): The lender provided an updated taxing sheet which had lowered the tax rate due to homestead exemption and brings the DTI in line
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of ATR Risk.
The subordinate financing is calculating on the fully indexed rate versus $XXXXX and the HOA dues were not included in the ratios on the AUS/1008. Therefore the DTI is exceeding XXXXX%.
   
Reviewer Comment (2019-05-24): The lender provided an updated taxing sheet which had lowered the tax rate due to homestead exemption and brings the DTI in line
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM DTI
Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds XXXXX% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.
The subordinate financing is calculating on the fully indexed rate versus $XXXXX and the HOA dues were not included in the ratios on the AUS/1008. Therefore the DTI is exceeding XXXXX%.
   
Reviewer Comment (2019-05-24): The lender provided an updated taxing sheet which had lowered the tax rate due to homestead exemption and brings the DTI in line
 
 
Seller Comment (2019-05-23): The Tax Assessor at XXXXX provided the attached that the new homeowner (XXXXX) has a homestead exemption which brings his tax amount down by $XXXXX per year. Can you please re-review the exception on this loan.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
The file was missing a copy of the Loan Originator Compensation disclosure.
   
Reviewer Comment (2019-05-17): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - Wholesale Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
Lender did not complete the required Lender Contact Information on Final CD.
   
Reviewer Comment (2019-05-17): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided Within 3 Business Days of Application
RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Organizations not provided to applicant within three (3) business days of application.
Application date of XXXXX with a disclosure date of XXXXX. Not within 3 day tolerance.
   
Reviewer Comment (2019-05-17): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
PCCD provided for cure.
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Final CD evidences Cure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
S-Corp Income Documentation Test
Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (S-Corp).
File is missing XXXXX 1040's. Missing XXXXX extension.
   
Reviewer Comment (2019-05-17): Transcripts provided
 
 
Seller Comment (2019-05-14): See attached XXXXX personal and business tax returns and XXXXX Tax Transcripts.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines
Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of XXXXX% moderately exceeds the guideline maximum of XXXXX%. (DTI Exception is eligible to be regraded with compensating factors.)
DTI in final 1008 reads XXXXX% and after auditing income DTI is not at XXXXX%
   
Reviewer Comment (2019-05-17): The final DTI moves to meet XXXXX requirements upon further review of the CPA letter and P&L
 
 
Seller Comment (2019-05-14): See attached letters of explanation from the CPA regarding the amended returns, the Schedule C showing spouse's name, and the Notes due in less than one year. All income worksheets are also attached. Income is supported.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of ATR Risk.
DTI in final 1008 reads XXXXX% and after auditing income DTI is not at XXXXX%
   
Reviewer Comment (2019-05-17): The final DTI moves under XXXXX%
 
 
Seller Comment (2019-05-14): See attached letters of explanation from the CPA regarding the amended returns, the Schedule C showing spouse's name, and the Notes due in less than one year. All income worksheets are also attached. Income is supported.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Lender to provide updated ATR/QM status
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM DTI
Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds XXXXX% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.
DTI in final 1008 reads XXXXX% and after auditing income DTI is not at XXXXX%
   
Reviewer Comment (2019-05-17): The final DTI moves to meet XXXXX requirements upon further review of the CPA letter and P&L
 
 
Seller Comment (2019-05-14): See attached letters of explanation from the CPA regarding the amended returns, the Schedule C showing spouse's name, and the Notes due in less than one year. All income worksheets are also attached. Income is supported.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Home Loan Toolkit Provided
Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.
Home Loan Toolkit not in file
   
Reviewer Comment (2019-05-17): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
No Defined Cure
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Demand Feature
TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXX incorrectly disclosed whether the loan contains a Demand Feature.
Both the initial and final closing disclosure did not confirm whether the loan contains a demand feature.
   
Reviewer Comment (2019-05-17): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Income / Employment
Income Documentation
Large deposits were not sourced and/or letter of explanation was not provided.
 
A large deposit in the form of a wire was made to the checking account on XXXXX $XXXXX, however, the source of this deposit was not documented in file. The exclusion of this deposit would result in insufficient funds.
   
Reviewer Comment (2019-05-17): Received LOE and CD to document large deposit. Exception cleared.
 
 
Seller Comment (2019-05-14): See attached letter of explanation and Closing Disclosure to support the funds were net proceeds from the sale of XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
The final Closing Disclosure reflected fees which were not disclosed on the initial Loan Estimate. As a result, Calculating Cash to Close: Final Closing Disclosure provided on XXXXX failed to disclose an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
   
Reviewer Comment (2019-05-16): XXXXX received changed circumstance.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $XXXXX exceeds tolerance of $XXXXX plus 10% or $XXXXX.  Insufficient or no cure was provided to the borrower.
The final Closing Disclosure reflected fees which were not disclosed on the initial Loan Estimate. Total amount of $XXXXX exceeds tolerance of $XXXXX plus 10% or $XXXXX  Insufficient or no cure was provided to the borrower.
   
Reviewer Comment (2019-05-16): XXXXX received changed circumstance.
 
 
Seller Comment (2019-05-15): XXXXX Review COC History page 2 uploaded
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
S-Corp Income Documentation - YTD P&L
Qualified Mortgage (Dodd-Frank 2014): YTD P&L is dated before the quarter prior to creditor application date.  YTD Date = XXXXX, Creditor Application Date = XXXXX (S-Corp).
The Borrower's YTD P&L nor tax returns (end date) are not dated within 90 days of creditor application date.
   
Reviewer Comment (2019-05-20): Provided was the P&L, extension for XXXXX and P&L for XXXXX
 
 
Seller Comment (2019-05-15): Disagree. The file contains the required income documentation for XXXXX: P&L from XXXXX to XXXXX P&L for XXXXX business tax returns. The borrower filed an extension for the filing of the XXXXX personal and business returns (attached).
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
S-Corp Income Documentation - YTD P&L
Qualified Mortgage (Dodd-Frank 2014): YTD P&L is dated before the quarter prior to creditor application date.  YTD Date = XXXXX, Creditor Application Date = XXXXX (S-Corp).
The Co-Borrowers YTD P&L nor tax returns (end date) are not dated within 90 days of creditor application date.
   
Reviewer Comment (2019-05-20): Provided was the P&L, extension for XXXXX and P&L for XXXXX
 
 
Seller Comment (2019-05-15): Disagree. The file contains the required income documentation for XXXXX: P&L from XXXXX to XXXXX P&L for XXXXX business tax returns. The borrower filed an extension for the filing of the XXXXX personal and business returns (attached).
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
The Borrower's Self-employed income was not documented with the most recent tax return and the creditor application date > tax filing date.
   
Reviewer Comment (2019-05-17): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
The Co-Borrower's Self-employed income was not documented with the most recent tax return and the creditor application date > tax filing date.
   
Reviewer Comment (2019-05-17): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency - ATR
Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
The file failed to contain the most recent personal and business tax returns for the Borrower.  Tax returns were provided for XXXXX; however, the subject transaction occurred XXXXX and the XXXXX returns were required for review.
   
Reviewer Comment (2019-05-17): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency - ATR
Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
The file failed to contain the most recent personal and business tax returns for the Co-Borrower.  Tax returns were provided for XXXXX; however, the subject transaction occurred XXXXX and the XXXXX returns were required for review.
   
Reviewer Comment (2019-05-17): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
The accurate Originator Loan Designation was provided; however, due to missing the most current required self-employment income documentation, it does not match the Due Diligence Loan Designation of ATR Risk.
   
Reviewer Comment (2019-05-20): Provided was the P&L, extension for XXXXX and P&L for XXXXX
 
 
Seller Comment (2019-05-15): Disagree. The file contains the required income documentation for XXXXX and XXXXX: P&L from XXXXX to XXXXX P&L for XXXXX business tax returns. The borrower filed an extension for the filing of the XXXXX personal and business returns (attached).
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Lender to provide updated ATR/QM status
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - Wholesale Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
located & associated
   
Reviewer Comment (2019-05-17): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor
Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.
File submitted for review was missing the Anti-Steering Disclosure which was required to determine Safe Harbor.
   
Reviewer Comment (2019-05-17): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
File submitted for review was missing the Loan Originator Compensation disclosure which was required to determine if compensation was based on the term of the transaction
   
Reviewer Comment (2019-05-17): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Lender Exception(s) not provided
 
An exception was granted to waive the Tangible Net Benefit
XXXXX FICO, XXXXX% LTVCLTV, B1 XXXXX years SE, B2 XXXXX years
Aggregator
Reviewer Comment (2019-05-22): Client elects to waive.
 
 
Reviewer Comment (2019-05-19): Client to review
 
 
Seller Comment (2019-05-15): The loan meets QM guidelines; the program allows XXXXX  Bank to follow conventional guidelines. XXXXX  Bank management made an exception on this file due to the subject loan combining the prior first and second mortgages into one loan, low XXXXX% LTV, credit score 33 points greater than the minimum and an additional 7 months of reserves over and above the reserve requirement. The management exception is attached.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
File is missing documentation that the borrower was provided a copy of the appraisal at least 3 business days prior to closing.
   
Reviewer Comment (2019-05-08): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Finance Charge
TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.
Final Closing Disclosure provided on XXXXX disclosed a finance charge of $XXXXX, calculated finance charge are $XXXXX, resulting in a variance of -$XXXXX. To cure, provided corrected PC CD along with LOE to borrower and evidence of deliver.
   
Reviewer Comment (2019-05-09): XXXXX reviewed exception. Finance charge no longer under disclosed after applying lump sum credit waterfall. Exception Cleared.
 
 
Seller Comment (2019-05-08): The PCCD has been uploaded.
 
 
Reviewer Comment (2019-05-06): Please provide PCCD showing lender credit applied, and LOE to borrower.
 
 
Seller Comment (2019-05-06): The Prepaid Finance Charges worksheet can be found on page 8 of the attached document.  Please review which fees are listed as finance charges. XXXXX applies lender credits to the total of all the non-apr fees first which is $XXXXX and then the remaining credit of $XXXXX is then applied to the total of the APR fees. Please rerun finance charge test as provided.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission if Applicable
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Homeowner's Insurance Premium Months
TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.
The final disclosure showed a 12 month collection of homeowner's insurance totaling $XXXXX which does not match the annual premium.
   
Reviewer Comment (2019-05-08): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - Wholesale Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
No contact info for lender loan originator on NMLS for loan originator
   
Reviewer Comment (2019-05-08): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Missing Final 1003
       
Reviewer Comment (2019-05-08): Final 1003 provided. Exception cleared.
 
 
Seller Comment (2019-05-06): Attached is the final 1003 which was e-signed by the borrower with the rest of the non-compliance loan documents.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - Wholesale Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
The final Closing Disclosure issued on XXXXX page 5 did not disclose lender's contact information, which is required to provide to the borrower to have information to contact lender at any time.
   
Reviewer Comment (2019-05-08): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
There was no evidence in the loan file that the lender provided the borrower a copy of the appraisal prior to closing or signed an acknowledgement of receipt of the appraisal as required.
   
Reviewer Comment (2019-05-08): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Missing Final 1003
 
Missing a signed final 1003 dated on Note date XXXXX.
   
Reviewer Comment (2019-05-08): Final 1003 provided. Exception cleared.
 
 
Seller Comment (2019-05-06): Attached is the Final 1003 that was e-signed by the borrower along with the rest of the non-compliance closing docs.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-06-17): The client has accepted the collateral package
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
B
B
B
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
An amount was not disclosed.
   
Reviewer Comment (2019-06-13): Client Elects To Waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
B
B
B
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-06-17): Client has accepted the collateral package
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
On Final CD under Total Closing Costs Exceeds Limits the amount is blank.
   
Reviewer Comment (2019-06-13): Client Elects to Waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Closing Disclosure Timing without Waiver
TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.
Evidence of earlier borrower receipt was not found in file.
   
Reviewer Comment (2019-06-14): Evidence of earlier receipt provided.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
No Defined Cure
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
XXXXX fee increased on XXXXX LE, but was not included on VCC document.
   
Reviewer Comment (2019-06-14): Valid COC provided.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-06-26): Received per client
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
B
B
B
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
Fees on final CD not disclosed on LE
   
Reviewer Comment (2019-06-26): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
B
B
B
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
     
Reviewer Comment (2019-06-26): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
B
B
B
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-07-10): Per client collateral received.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
B
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Social Security Documentation
Qualified Mortgage (Dodd-Frank 2014): Social Security income documentation insufficient.
Award letter was not provided. The borrower is XXXXX years old and provided 2 years of 1040s to verify prior receipt and 2 months of bank statements to verify current receipt.
   
Reviewer Comment (2019-07-10): Received updated 1008 and ATR attestation removing XXXXX income as it is not needed to qualify.  Recalculated DTI is XXXXX%.  Issue cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
B
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
Missing income documentation
   
Reviewer Comment (2019-07-10): Received updated 1008 and ATR attestation removing XXXXX income as it is not needed to qualify.  Recalculated DTI is XXXXX%.  Issue cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
C
A
B
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-06-17): Client has accepted the collateral package
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Approval not provided
 
Approval letter not found in file (only commitment letter to borrowers in file)
   
Reviewer Comment (2019-06-14): Received loan approval.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Final CD shows closing date as XXXXX, but actual closing/disbursement date is XXXXX per consummation date of mortgage and closing docs.
   
Reviewer Comment (2019-06-13): Client elects to Waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-06-26): Received per client.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
B
B
B
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date
TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXX received on or after the date the Closing Disclosure XXXXX was received.
The file is missing evidence the borrower received the LE on XXXXX
   
Reviewer Comment (2019-06-26): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
No Defined Cure
B
B
B
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
XXXXX subject property. Closed in escrow.
   
Reviewer Comment (2019-06-17): The lender self corrected and provided a PCCD correcting the closing date
 
 
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
B
B
B
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-07-10): Per client collateral received.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
B
B
B
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
The borrower filed an extension for XXXXX tax filing.
   
Reviewer Comment (2019-07-08): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
B
B
B
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
XXXXX subject property. Closed in escrow, funded after closing.
   
Reviewer Comment (2019-07-05): PCCD provided correcting the closing date
 
 
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
B
B
B
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Legal / Regulatory / Compliance
Title / Lien Defect
Title Policy Coverage is less than Original Loan Amount.
       
Reviewer Comment (2019-06-03): Received updated title commitment.
 
 
Buyer Comment (2019-06-03): updated commitment matching final LA $XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
A
C
A
A
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM Employment History - Current Employment Documentation lacks Date Info
Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two years current employment.
Missing 3rd party verification of business existence.
   
Reviewer Comment (2019-06-03): Received Third Party Verification.
 
 
Buyer Comment (2019-06-03): Documentation supporting Borr's proof of S/E and in existence for > than 2 yrs.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Credit Exception:
 
Please provide inter-net search or other third party verification for XXXXX within 30 days of closing as required by guidelines.
   
Reviewer Comment (2019-06-03): Received Third Party Verification.
 
 
Buyer Comment (2019-06-03): Documentation supporting Borr's proof of S/E and in existence for > than 2 yrs.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Home Loan Toolkit Timing
Truth in Lending Act (2015): Creditor or broker did not provide the Home Loan Toolkit Disclosure to applicant within 3 business days of application.
Creditor or broker did not provide the Home Loan Toolkit Disclosure to applicant within XXXXX business days of application.
   
Reviewer Comment (2019-06-03): Evidence of earlier delivery was provided.
 
 
Buyer Comment (2019-06-03): HL Took kit delivery confirmation
 
 
Buyer Comment (2019-06-03): CoC delivery - Confirms delivery of Tool kit
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
No Defined Cure
B
A
A
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Guideline
Guideline Issue
Aged document: Primary Valuation is older than guidelines permit
#NAME?
verified date
   
Reviewer Comment (2019-06-03): Guidelines allow 120 days.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Guideline
Guideline Issue
Payment shock is greater than XXXXX%.
Payment Shock: ___
verified
   
Reviewer Comment (2019-06-03): Payment shock is not a parameter per guides.
 
 
Buyer Comment (2019-06-03): Prime guidelines do not require Payment Shock calculation
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
XXXXX  missing
   
Reviewer Comment (2019-06-03): Received XXXXX Report from Clear Capital. Value Supported.
 
 
Buyer Comment (2019-06-03): XXXXX uploaded
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: AUS not provided
       
Reviewer Comment (2019-06-03): This has already been cleared.
 
 
Buyer Comment (2019-06-03): Prime does not require AUS (Manual underwrite)
 
 
Reviewer Comment (2019-06-03): AUS not provided for JUMBO program.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Other not provided
 
Letter of explanation and attestation on whether or not the CD dated XXXXX XXXXX, XXXXX was provided to the borrower.
   
Reviewer Comment (2019-06-03): Received attestation stating Cd was a draft version issued by the title company.
 
 
Buyer Comment (2019-06-03): Attestation
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Asset
Asset Calculation / Analysis
Available for Closing is insufficient to cover Cash From Borrower.
 
Insufficient assets provided to cover cash from borrower $XXXXX.
   
Reviewer Comment (2019-06-03): Previous loan escrowed.
 
 
Reviewer Comment (2019-06-03): Final CD reflects $XXXXX paid prior to closing by borrower for Hazard Insurance premium. Provide documentation borrower had sufficient funds to pay, or that premium was paid by previous mortgagee from escrow account.
 
 
Buyer Comment (2019-06-03): Final CD from closing evidencing $XXXXX due from borrower
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
A
C
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
AUS Findings: All conditions were not met
 
No assets provided to cover closing cost $XXXXX.
   
Reviewer Comment (2019-06-03): Duplicate condition.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
A
C
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Esign Consent Agreement Status
ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $XXXXX and disclosure timing violations.
Missing E-sign disclosure
   
Reviewer Comment (2019-06-03): Received E-sign tracking.
 
 
Buyer Comment (2019-06-03): Certificate of Completion- E-sign acknowledgement
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
No Defined Cure
C
A
C
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
         
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Final CD evidences Cure
C
A
C
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
         
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Final CD evidences Cure
C
A
C
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Property Value
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed an Appraised Property Value that did not match the actual Property Value for the loan.
The borrowers purchased the property less than XXXXX months, therefore the lower of the sale price of $XXXXX was used.
   
Reviewer Comment (2019-06-03): XXXXX received PCCD correcting property value and LOE. Exception Cured.
 
 
Buyer Comment (2019-06-03): Corrected Appraised Value
 
 
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
C
B
B
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Guideline
Guideline Issue
Borrower does not have the minimum active tradelines per guidelines.
 
Borrowers do not meet the minimum tradeline requirements (XXXXX open for XXXXX months and reporting in the last XXXXX months and XXXXX open or closed for XXXXX months with activity in the last XXXXX months).  Credit report shows one tradeline reporting for XXXXX months and one closed account with XXXXXXXXXX closed XXXXX.  The borrower is required XXXXX tradelines.  Lender waived the exception for the minimum tradelines not being met.
Borrower on this full documentation loan has a disposable income of $XXXXX.
 
XXXXX% DTI on this full documentation loan < XXXXX% guideline max - XXXXX% below program guideline maximum
 
Borrower's have employment stability for >XXXXX years as a XXXXX.
Aggregator
 
Aggregator
 
Aggregator
Reviewer Comment (2019-06-03): Waiver in file with compensating factors provided.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
B
B
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-07-10): Per client collateral received.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
B
A
B
A
A
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-07-19): Per client received. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Partnership Income Documentation Test
Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Partnership).
Per the 1003 and UW income worksheet the income used to qualify was from XXXXX XXXXX however the P&L and balance sheet provided was for the borrower other business.
   
Reviewer Comment (2019-07-24): Provided was the completed and signed P&L
 
 
Reviewer Comment (2019-07-22): Provided was the signed balance sheet but the YTD Profit and loss is still missing. Please provide.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Partnership Income Documentation Test
Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Partnership).
Per the 1003 and UW income worksheet the income used to qualify was from XXXXX XXXXX however the P&L and balance sheet provided was for the borrower other business.
   
Reviewer Comment (2019-07-24): Provided was the completed and signed P&L
 
 
Reviewer Comment (2019-07-22): Provided was the signed balance sheet but the YTD Profit and loss is still missing. Please provide.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Revised Loan Estimate Issue and Received Date >  Closing Disclosure Issue and Received Date
TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on or after the date the Closing Disclosure was provided. (The Revised Loan Estimate was received on or after the Closing Disclosure.)
     
Reviewer Comment (2019-07-30): XXXXX received an attestation for initial CD issued on XXXXX was not provided to the Borrower.
 
 
Reviewer Comment (2019-07-24): No additional documents was provided
 
 
Reviewer Comment (2019-07-16): File contains an initial CD dated XXXXX with a closing date of XXXXX with a different loan ID# XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
No Defined Cure
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
Per the 1003 and UW income worksheet the income used to qualify was from XXXXX XXXXX however the P&L and balance sheet provided was for the borrower other business.
   
Reviewer Comment (2019-07-24): Provided was the completed and signed P&L
 
 
Reviewer Comment (2019-07-22): Provided was the signed balance sheet but the YTD Profit and loss is still missing. Please provide.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Lender to provide updated ATR/QM status
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Esign Consent Agreement Status
ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $XXXXX and disclosure timing violations.
Esign consent was not provided with loan documents.
   
Reviewer Comment (2019-07-19): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
No Defined Cure
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Homeowner's Insurance Premium Months
TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.
Fees match final CD signed by borrower.
   
Reviewer Comment (2019-07-19): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Letter of Explanation & Corrected Closing Disclosure
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXdisclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
No legal limit was provided on final signed CD.
   
Reviewer Comment (2019-07-19): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Letter of Explanation & Corrected Closing Disclosure
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
No cure provided for zero tolerance fee.
   
Reviewer Comment (2019-07-30): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower.
Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided.
   
Reviewer Comment (2019-07-30): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
 
Per Final Collateral Package Review.
   
Reviewer Comment (2019-08-05): received per client
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Partnership Income Documentation Test
Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Partnership).
Missing signed XXXXX Personal Tax Returns and no evidence of XXXXX Personal Tax Returns due to an extension in the loan file. Missing signature for XXXXX XXXXX XXXXX XXXXX and
   
Reviewer Comment (2019-08-07): The loan images contain the personal and business transcripts which are acceptable when there  is lack of signature on the returns.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Partnership Income Documentation Test
Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Partnership).
The loan file does not include XXXXX Tax Returns or updated K-1's for XXXXX XXXXX XXXXX, for the co-borrower's self-employment.
   
Reviewer Comment (2019-08-07): The loan images contain the personal and business transcripts which are acceptable when there  is lack of signature on the returns.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
General Ability To Repay Provision Employment - Partnership Test
Ability-to-Repay (Dodd-Frank 2014): Unable to verify current Partnership status using reasonably reliable third-party records.
The loan file does not include XXXXX Tax Returns or updated K-1's for XXXXX XXXXX XXXXX, for the co-borrower's self-employment.
   
Reviewer Comment (2019-08-07): The loan images contain the personal and business transcripts which are acceptable when there  is lack of signature on the returns.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
NonQM ATR
Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.
The most recent XXXXX year's personal tax returns and XXXXX tax return for XXXXX XXXXX XXXXX were not signed. In addition, the most recent year tax return (XXXXX) was not received for XXXXX XXXXX XXXXX.
   
Reviewer Comment (2019-08-07): The loan images contain the personal and business transcripts which are acceptable when there  is lack of signature on the returns.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of ATR Fail.
Loan designation does not match due to missing personal and business income documents.
   
Reviewer Comment (2019-08-07): The loan images contain the personal and business transcripts which are acceptable when there  is lack of signature on the returns.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Lender to provide updated ATR/QM status
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
The loan file does not include XXXXX Tax Returns or updated K-1's for XXXXX XXXXX XXXXX, for the co-borrower's self-employment.
   
Reviewer Comment (2019-08-26): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency - ATR
Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
The loan file does not include XXXXX Tax Returns or updated K-1's for XXXXX XXXXX XXXXX, for the co-borrower's self-employment.
   
Reviewer Comment (2019-08-07): The loan images contain the personal and business transcripts which are acceptable when there  is lack of signature on the returns.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self Employed - Implicit Adherence
Qualified Mortgage (Dodd-Frank 2014): Self Employed borrower's loan file contained tax returns that are not signed/dated, but the loan file contains the tax transcripts to evidence the tax returns were signed/dated at time of submission to the IRS.
The loan images contain the personal and business transcripts which are acceptable when there  is lack of signature on the returns.
   
Reviewer Comment (2019-08-26): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
The loan images contain the personal and business transcripts which are acceptable when there is lack of signature on the returns per lender
   
Reviewer Comment (2019-08-26): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-08-07): Received per client.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Second Home
Purchase
 
C
B
B
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-08-23): Desk review provided with no variance. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Second Home
Purchase
 
C
B
B
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
     
Buyer Comment (2019-08-20): Waived by XXXXX on Rate Lock: Ok to accept. No A/L or outside SOL
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Second Home
Purchase
 
C
B
B
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Provided Prior to Date Performed
ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.
Appraisal was provided XXXXX to borrower, however, appraisal  effective date was XXXXX.
   
Reviewer Comment (2019-06-12): Client Elects to Waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
The Closing Disclosure date was XXXXX.  The security instrument was signed and  notarized on XXXXX.
   
Reviewer Comment (2019-06-12): Client Elects to Waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Income / Employment
Income Documentation
Income Docs Missing:
-
     
Reviewer Comment (2019-06-11): Received XXXXX W-2's. Exception cleared.
 
 
Seller Comment (2019-06-11): Please see attached XXXXX W2 for XXXXX XXXXX. Page 1 of the attachment on the right side.  Please review and clear the conditions.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
A
C
A
A
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
Missing secondary valuation.
   
Reviewer Comment (2019-06-18): Provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
Missing evidence appraisal sent prior to closing.
   
Reviewer Comment (2019-06-12): Client Elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
This exception is due to open 0% or 10% tolerance exceptions and will be cured when all tolerance violations are resolved.
   
Reviewer Comment (2019-06-12): Client Elects to Waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Lender Credit Tolerance Violation
TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $XXXXX  is less than amount of binding Lender Credit previously disclosed in the amount of $XXXXX.
No evidence of a cure provided.
   
Reviewer Comment (2019-06-12): XXXXX received XXXXX COC. Exception Cleared.
 
 
Seller Comment (2019-06-11): See attached COC
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
Binding LE disclosed a Transfer Tax Fee of $XXXXX and Consumer's Final CD disclosed $XXXXX.  Consumer's Final CD disclosed a Lender Credit of $XXXXX for increase in Closing Costs above legal limit which is sufficient to cure the 0% tolerance violation.
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Final CD evidences Cure
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 0XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Final CD disclosed a Closing Date of XXXXX, however, the actual date of consummation is XXXXX.
   
Reviewer Comment (2019-06-12): Client Elects to Waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-06-18): Provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
RESPA -  Initial Escrow Account statement Inaccurate
RESPA: Initial escrow account statement does not match charges on HUD-1/Final Closing Disclosure.
Initial escrow account statement disclosed an initial deposit of $XXXXX, however, Final CD disclosed $XXXXX.
   
Reviewer Comment (2019-06-10): PCCD issued on XXXXX reflects the IED starting balance.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Provided Prior to Date Performed
ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.
Appraisal reflects an Effective Date of XXXXX and was signed on XXXXX.  Appraisal was provided to borrower on XXXXX which is after the Effective Date of the appraisal.
   
Reviewer Comment (2019-06-12): Client Elects to Waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Final CD disclosed a Closing Date of XXXXX, however, actual date of consummation is XXXXX per Security Instrument.
   
Reviewer Comment (2019-06-12): Client Elects to Waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - Wholesale Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
Final CD did not disclose the Lender Contact Name and NMLS ID.
   
Reviewer Comment (2019-06-12): Client Elects to Waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Closing date is XXXXX; CD closing date is XXXXX.
   
Reviewer Comment (2019-06-12): Client Elects to Waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Home Loan Toolkit Provided
Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.
Missing Home Loan Toolkit Disclosure.
   
Reviewer Comment (2019-06-12): Client elects to Waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
No Defined Cure
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-06-18): Provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
Proof of when appraisal was provided to borrowers was not provided.
   
Reviewer Comment (2019-06-14): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Summaries Of Transactions - Seller Credit
TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on XXXXX disclosed a Seller Credit that does not match the Seller Credit from the Calculating Cash to Close table.
Seller credit included item paid by seller on behalf of borrower.
   
Reviewer Comment (2019-06-14): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Income / Employment
Income Documentation
REO Documents are missing.
-
statement missing to verify taxes and ins are escrowed.
   
Reviewer Comment (2019-06-13): Received tax and insurance statement.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Escrowed Property Costs Year 1 -  October XXXXX
TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Escrowed Property Costs over Year 1 of XXXXX on Final Closing Disclosure provided on XXXXX not accurate.
The file is missing the tax mill rate used to qualify the borrower. California purchase estimate value would be XXXXX% est at $XXXXX unless the taxing authority mill rate is provided. The tax value used was lower then the estimate at $XXXXX
   
Reviewer Comment (2019-06-17): XXXXX received tax calculation. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Estimated Escrow Payment
TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXX disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan.
The file is missing the tax mill rate used to qualify the borrower. California purchase estimate value would be XXXXX% est at $XXXXX unless the taxing authority mill rate is provided. The tax value used was lower then the estimate at $XXXXX
   
Reviewer Comment (2019-06-17): XXXXX received tax calculation. Exception Cleared.
 
 
Seller Comment (2019-06-14): see attached. tax rate of XXXXX% was used
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Estimated Total Minimum Payment Fixed Rate
TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXX disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan.
The file is missing the tax mill rate used to qualify the borrower. California purchase estimate value would be XXXXX% est at $XXXXX unless the taxing authority mill rate is provided. The tax value used was lower then the estimate at $XXXXX
   
Reviewer Comment (2019-06-17): XXXXX received tax calculation. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
     
Reviewer Comment (2019-06-12): Client Elects to Waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Invalid Section B Combinations
TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on XXXXXreflects a fee Paid To lender or broker for fee within Services Borrower Did Not Shop For section.
Final CD reflects paid to lender. Missing invoices.
   
Reviewer Comment (2019-06-12): Client Elects to Waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Good Faith Redisclosure
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
The lender did not provide a cure amount to the borrower with regard to fees exceeding the legal limit.
   
Reviewer Comment (2019-06-12): Client Elects to Waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Home Loan Toolkit Provided
Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.
Disclosure not provided to borrower.
   
Reviewer Comment (2019-06-12): Client elects to Waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
No Defined Cure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Survey Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
The lender did not provide a cure amount to the borrower with regard to fees exceeding the legal limit.
   
Reviewer Comment (2019-06-19): XXXXX received PCCD indicating cure, LOE, and Refund Check. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
     
Reviewer Comment (2019-06-12): Client Elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Survey Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower.
XXXXXreceived PCCD indicating cure, LOE, and Refund Check, Exception Cured.
   
Reviewer Comment (2019-06-19): XXXXX received PCCD indicating cure, LOE, and Refund Check, Exception Cured.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Partnership Income Documentation Test
Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Partnership).
Third party verification was not provided at the time of review.
   
Reviewer Comment (2019-06-18): Income not needed to qualify. Exception cleared.
 
 
Seller Comment (2019-06-17): Third Party Verification
 
 
Reviewer Comment (2019-06-14): Need a Third party verification Carnelian Holdings LLC. Exception remains.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
General Ability To Repay Provision Employment - Partnership Test
Ability-to-Repay (Dodd-Frank 2014): Unable to verify current Partnership status using reasonably reliable third-party records.
     
Reviewer Comment (2019-06-18): Income not needed to qualify. Exception cleared.
 
 
Seller Comment (2019-06-17): Third Party Verification
 
 
Reviewer Comment (2019-06-16): Need TPV for XXXXX XXXXX.  XXXXX XXXXX XXXXX keeps being submitted.  Exception remains.
 
 
Seller Comment (2019-06-14): VOE
 
 
Reviewer Comment (2019-06-14): Need a Third party verification Carnelian Holdings LLC. Exception remains.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of ATR Fail.
Pending third party verification
   
Reviewer Comment (2019-06-18): Income not needed to qualify. Exception cleared.
 
 
Seller Comment (2019-06-17): Third Party Verification
 
 
Reviewer Comment (2019-06-14): Need a Third party verification Carnelian Holdings LLC. Exception remains.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
NonQM ATR
Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.
Third party verification for XXXXX XXXXX XXXXXwas not provided at the time of review.
   
Reviewer Comment (2019-06-18): Income not needed to qualify. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 05/17/2019 disclosed a Closing Date that did not match the actual date of consummation.
The Notary is dated XXXXX whereas the final CD states a closing date of XXXXX
   
Reviewer Comment (2019-06-12): Client Elects to Waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XX/XX/XXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
Cash to Close table did not indicate the dollar figure for exceeded legal limit amount; no cure was provided.
   
Reviewer Comment (2019-06-12): Client Elects to Waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Pest Inspection Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Pest Inspection Fee was not initially disclosed on XXXXX, change of circumstance was provided, however did not disclose fee;  no cure given to Consumer(s).
   
Reviewer Comment (2019-06-18): XXXXX received PCCD correcting pest inspection to section H and LOE. Exception Cured
 
 
Seller Comment (2019-06-17): CD and LOX
 
 
Reviewer Comment (2019-06-17): XXXXX reviewed exception. If the pest inspection was optional it would require the fee to be in Section H. Section C fees are required by lender or chosen provider. Please provide corrected CD and LOE to cure.
 
 
Seller Comment (2019-06-14): See attached COC.  Bwr elected to get XXXXX XXXXX, please refer to the purchase contract.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Total Property Costs Year 1 - October XXXXX
TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of XXXXX on Final Closing Disclosure provided on XXXXX not accurate.
The file is missing a tax cert or UW worksheet of the property taxes used. Per the 1008 the annual tax used was $XXXXX. The tax rate of  XXXXX1 would be $XXXXX. Currently the taxes used to verify was based on XXXXX% using the higher until evidence is provided.
   
Reviewer Comment (2019-06-14): Received tax cert. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
Binding LE disclosed an Appraisal Fee of $XXXXX and Consumer's Final CD disclosed $XXXXX.  Consumer's Final CD disclosed a Lender Credit of$XXXXX for increase in Closing Costs above legal limit which is sufficient to cure the X% tolerance violations.
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Final CD evidences Cure
A
A
A
A
A
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-07-10): Per client collateral received.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Guideline Requirement: PITIA reserves months discrepancy.
 
Reserves required for XXXXX months PITI, but only XXXXX months verified after required funds needed to close.
   
Reviewer Comment (2019-08-28): Exception cleared.
 
 
Reviewer Comment (2019-08-02): AUS in file reflects Approve/Ineligible. Loans are to be reviewed as a manual underwrite to lender guides per client. Exception remains.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-08-01): Received
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Flood Certificate not provided
 
Flood Certificate is missing from subject file; per Appraisal, flood zone area reflects X.
   
Reviewer Comment (2019-07-22): Provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-07-22): Provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-07-30): Received
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
B
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
Additional valuation product required.
   
Reviewer Comment (2019-07-24): Provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
B
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-07-10): Per client collateral received.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
A
C
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Guideline Requirement: PITIA reserves months discrepancy.
 
No assets were provided for reserves. Guidelines state XXXXX months reserves required if under XXXXX% LTV on a primary residence. Cash out is less than XXXXX months of reserves.
   
Reviewer Comment (2019-08-28): Exception cleared,
 
 
Reviewer Comment (2019-08-13): The transaction was not reviewed to AUS guidelines but to the provided guidelines revision XXXXX & XXXXX XXXXX XXXXX Fixed and ARM which requires a FICO of XXXXX to approve an LTV up to XXXXX% and the borrower score is only XXXXX. Also required is XXXXX months reserves. The guidelines do not state funds from the transaction are eligible to be used to support reserves.
 
 
Reviewer Comment (2019-07-24): The borrower score is XXXXX and not sufficient for the higher LTV of XXXXX%. No additional assets were provided. The exception remains.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
A
C
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Closing Disclosure Timing without Waiver
TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.
Initial CD provided on XXXXX was provided 3 days prior to closing.
   
Reviewer Comment (2019-07-16): Evidence of earlier receipt provided.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
No Defined Cure
C
A
C
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Revised Loan Estimate Timing Before Closing
TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on XXXXX not received by borrower at least four (4) business days prior to closing.
Revised LE was provided more than 4 days prior to closing.
   
Reviewer Comment (2019-07-16): Evidence of earlier receipt provided.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
No Defined Cure
C
A
C
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Borrower and Mortgage Eligibility
Mortgage / Program Eligibility
Guideline Requirement: Loan to value discrepancy.
 
With a minimum credit score of XXXXX the LTV limit is XXXXX%, with a XXXXX score the LTV limit is XXXXX%.
   
Reviewer Comment (2019-08-28): Exception cleared,
 
 
Reviewer Comment (2019-08-13): The transaction was not reviewed to AUS guidelines but to the provided guidelines revision XXXXX & XXXXX XXXXX XXXXX Fixed and ARM which requires a FICO of XXXXX to approve an LTV up to XXXXX% and the borrower score is only XXXXX.
 
 
Reviewer Comment (2019-07-24): The borrower score is XXXXX which is not sufficient for the increased LTV of XXXXX%
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
A
C
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-07-19): Per client received. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
A
C
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Borrower and Mortgage Eligibility
Mortgage / Program Eligibility
Guideline Requirement: Loan to value discrepancy.
 
LTV of XXXXX% exceeds guidelines of XXXXX% with a XXXXX credit score.
   
Reviewer Comment (2019-08-22): Additional guidelines were provided.
 
 
Reviewer Comment (2019-07-24): These transactions are reviewed under the Manual Jumbo guidelines and the max LTV is XXXXX% for a cash out refinance up to $XXXXXwith a score of XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
A
C
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Closing Disclosure Timing without Waiver
TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.
Initial Final CD provided to borrower XXXXX.
   
Reviewer Comment (2019-07-16): Evidence of earlier receipt provided.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
No Defined Cure
C
A
C
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Guideline Requirement: PITIA reserves months discrepancy.
 
Guideline require 9 months and verified assest totaling $XXXXX
   
Reviewer Comment (2019-08-22): Additional guidelines were provided. Lender guidelines indicate you should refer to the AUS for reserve requirements. AUS in file discloses there are no reserves required.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
A
C
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-08-05): received per client
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
B
A
B
A
A
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-07-10): Per client collateral received.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-07-24): Provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Credit Documentation
Aged document: Credit Report  is more than XXXXX days prior to the note date.
-
     
Reviewer Comment (2019-08-22): Per the XXXXX matrix and addendum the expiration of documentation is based on XXXXX
 
 
Reviewer Comment (2019-08-02): XXXXX reflects Approve/Ineligible. Per client loans are to be reviewed as a manual underwrite to lender guidelines. Exception remains.
 
 
Reviewer Comment (2019-07-24): Per lender guidelines under documentation type states all credit documents must be dated within XXXXX days of closing.  The credit report is dated XXXXX and the note is dated XXXXX. The exception remains.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
         
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Final CD evidences Cure
C
A
C
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Guideline Requirement: PITIA reserves months discrepancy.
 
Based on final verified reserves less than XXXXX months required assets according to manual guidelines. Initial XXXXX shows unverified XXXXX with sufficient assets.
   
Reviewer Comment (2019-08-22): Received additional guidelines. Lender guidelines indicate you should refer to the XXXXX for reserve requirements. XXXXX in file discloses there are no reserves required.
 
 
Reviewer Comment (2019-08-02): XXXXX reflects Approve/Ineligible. Per client loans are to be reviewed as a manual underwrite to lender guidelines. Exception remains.
 
 
Reviewer Comment (2019-07-24): Guidelines do not state XXXXX is used for reserves only the required months based on LTV, DTI and FICO. Please provide additional guidelines supporting statement reserves based on an Approve/Ineligible XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-08-05): received per client
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-08-16): Secondary valuation provided with 0% variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
FACTA Disclosure Missing
FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
     
Reviewer Comment (2019-08-01): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance (Circuit 2, 5, 7, 8, 9, 10 or DC)
Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 form should have been used.
     
Reviewer Comment (2019-08-01): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Guideline Requirement: PITIA reserves months discrepancy.
 
Guidelines state XXXXXmonths for subject property + XXXXX months for each financed retained property.
   
Reviewer Comment (2019-08-22): Additional guidelines provided. Lender guidelines indicate you should refer to the XXXXX to verify reserve requirements. XXXXX in file confirms there are no reserves required.
 
 
Reviewer Comment (2019-08-13): The transaction was not reviewed to XXXXX guidelines but to the provided guidelines revision XXXXX & XXXXX XXXXX which requires XXXXX months reserves. for the subject and an additional XXXXX months PITIA for retained properties for a total of XXXXXmonths.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-07-10): Per client collateral received.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
B
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
Only one appraisal was provided.
   
Reviewer Comment (2019-07-18): Desk Review provided with 0% variance.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
B
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XX/XX/XXXX disclosed a Closing Date that did not match the actual date of consummation.
Closing dated  XXXXX whereas the notary is dated  XXXXX
   
Reviewer Comment (2019-07-11): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
B
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-06-17): Received desk review
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
A
A
C
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
$ XXXXX
   
Reviewer Comment (2019-06-17): fee paid to borrower chosen provider - no tolerance
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
A
A
A
C
A
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Insurance Binder Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
$ XXXXX
   
Reviewer Comment (2019-06-17): fee paid to borrower chosen provider - no tolerance
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
A
A
A
C
A
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Miscellaneous Compliance
Rental Income Documentation - Schedule E Method
Qualified Mortgage (Dodd-Frank 2014): Rental income documentation requirement not met for XXXXX Place.  Lease Agreement and/or Tax Transcripts / Returns not provided.
     
Reviewer Comment (2019-06-17): Received lease extension
 
 
Reviewer Comment (2019-06-17): Need a copy of the lease
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Wages Documentation
Qualified Mortgage (Dodd-Frank 2014): Wages / W-2 income documentation not sufficient.
Missing XXXXX W-2
   
Reviewer Comment (2019-06-17): Received XXXXX
 
 
Buyer Comment (2019-06-17): no XXXXX had XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Provided Prior to Date Performed
ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.
     
Reviewer Comment (2019-10-09): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
General Ability To Repay Provision Income and Assets - Wages
Ability to Repay (Dodd-Frank 2014): Unable to verify Wages/W-2 income using reasonably reliable third-party records.
Borrower recently started his new job therefore has limited income docs on file, however has a signed offer letter and VOE on file.
   
Reviewer Comment (2019-06-17): updated input as letter includes income
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
NonQM ATR
Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.
Borrower recently started XXXXX new job therefore has limited income docs on file, however has a signed XXXXXand XXXXX on file.
   
Reviewer Comment (2019-06-17): updated input as letter includes income
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of ATR Fail.
Borrower recently started his new job therefore has limited income docs on file, however has a signed offer letter and VOE on file.
   
Reviewer Comment (2019-06-17): Updated dates of employments
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation
ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.
     
Reviewer Comment (2019-10-09): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Income / Employment
Income Documentation
Income Docs Missing:
-
Missing XXXXX prior to closing Confirming borrower has started in the new employment position.  All VVOEs were completed before XXXXX start date of XXXXX
   
Reviewer Comment (2019-06-17): VVOE completed  XXXXX provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM Employment History - Current and/or Previous Employment Documentation lacks Date Info
Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two years employment history for current and/or prior employment.
Hire date after Note date
   
Reviewer Comment (2019-06-17): 2 years provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure
RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
Please provide fully executed ABA.
   
Reviewer Comment (2019-07-11): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Esign Consent Agreement Status
ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.
Missing evidence of the borrower's electronic consent.
   
Reviewer Comment (2019-07-11): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
No Defined Cure
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Summaries Of Transactions - Closing Costs Paid At Closing
TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on XXXXX disclosed a Closing Costs Paid at Closing that does not match the Total Closing Costs (Borrower-Paid) from page 2. (Final/XXXXX)
Final Closing Disclosure reflects Closing Costs (J) of $ XXXXX but should reflect $ XXXXX.
   
Reviewer Comment (2019-07-11): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Will Not Have Escrow -  Reason
TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXX incorrectly disclosed whether the loan will have an escrow account. (Final/XXXXX)
No escrows - declined by borrower
   
Reviewer Comment (2019-06-17): Received PCCD and LOE to borrower.
 
 
Reviewer Comment (2019-06-17): XXXXX received PCCD indicating non escrowed property costs of $XXXXX. The allowable tolerance for the escrow account field on page four of the CD is $XXXXX per month of escrowed costs or $XXXXXfor 12 months. Total disclosed on page four of CD is $XXXXX and documentation in images indicates total should be $XXXXX. ($XXXXX for hazard insurance, $XXXXX for property taxes, and HOA Dues of $XXXXX).  Letter of Explanation and Corrected CD required to cure.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing. (Type:Primary/XXXXX)
Missing proof of appraisal being sent to borrower.
   
Reviewer Comment (2019-06-17): Prior compliance review; reran testing, and cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - Wholesale Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name). (Final/XXXXX)
Information was not provided
   
Reviewer Comment (2019-06-17): Prior compliance review; reran testing, and cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Missing Final 1003
 
(2) copies of initial 1003 provided, no final signed copy XXXXX in submission.
   
Reviewer Comment (2019-06-17): Final signed 1003 has been provided.
 
 
Buyer Comment (2019-06-17): Please see final 1003
 
 
Reviewer Comment (2019-06-17): reopened
 
 
Reviewer Comment (2019-06-17): no longer needed
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Asset
Asset Documentation
Missing Document: Asset Documentation not provided
 
XXXXX statement for account ending in XXXXX shows a large deposit on XXXXX for $XXXXX. Unable to determine source of large deposit.. Documentation to source the deposit has not  been provided.
XXXXX% DTI o < XXXXX% guideline max
AMC
Reviewer Comment (2019-06-17): rating remained a 3 instead of 2 with a WAIVE
 
 
Buyer Comment (2019-06-17): This condition "Missing Document: Asset Documentation not provided" Category 3 is waived however we need the category lowered to a 2  or 1 one.
 
 
Reviewer Comment (2019-06-17): Cancelled check in file from XXXXX Title Insurance Company, Inc.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
Loan is to go in a securitization and reflects only one valuation product when two are required
   
Reviewer Comment (2019-06-17): Received CDA
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Approval not provided
 
Please provide Final Approval.
   
Reviewer Comment (2019-06-17): Received Approval.
 
 
Buyer Comment (2019-06-17): See attached aapproval
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Total Property Costs Year 1
TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of $XXXXX on Final Closing Disclosure provided on XXXXX not accurate.
Disclosure reflects No Escrow Estimated Property Costs over Year 1 as ($ XXXXX), however the calculated Non-Escrowed Monthly Property Costs are ($ XXXXX)
   
Reviewer Comment (2019-06-17): Tax cert provided and updated taxes, reran testing, cleared
 
 
Buyer Comment (2019-06-17): Email Sent to XXXXX and XXXXX to clear condition with screenshots and the following message:  Can you review this file again for the 2 reasons noted below:
 
1)  The condition "Missing Document: Asset Documentation not provided" Category 3 is waived however we need the category lowered to a 2  or 1 one.
2) We disagree with the condition listed as "TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of $XXXXX on Final Closing Disclosure provided on XXXXX not accurate." " Disclosure reflects No Escrow Estimated Property Costs over Year 1 as ($XXXXX), however the calculated Non-Escrowed Monthly Property Costs are ($XXXXX)".
 
Based on the HOI: XXXXX = XXXXX, Annual Taxes XXXXX = XXXXX and HOA $XXXXX Monthly. TOTAL $XXXXX rounded is $XXXXX.   This matches the CD please review to clear conditions.
 
Please let us know if there is any issue this.  We are trying to clear this loan as quickly as possible.
 
Thank you
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
S-Corp Income Documentation Test
Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (S-Corp).
     
Reviewer Comment (2019-07-11): Client allows transcripts in lieu of actual signatures.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
Due to missing documentation for income
   
Reviewer Comment (2019-07-11): Client allows transcripts in lieu of actual signatures.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self Employed - Implicit Adherence
Qualified Mortgage (Dodd-Frank 2014): Self Employed borrower's loan file contained tax returns that are not signed/dated, but the loan file contains the tax transcripts to evidence the tax returns were signed/dated at time of submission to the IRS.
     
Reviewer Comment (2019-07-11): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Asset
Asset Calculation / Analysis
Available for Closing is insufficient to cover Cash From Borrower.
 
Verified assets for Closing of  $XXXXX is less than Cash From Borrower $XXXXX.
   
Reviewer Comment (2019-06-17): Rec'd copy of cashiers check for funds rec'd from XXXXX on additional investment property owned.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Abstract / Title Search.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
$ XXXXX Title - Abstract fee not disclosed Initial Loan Estimate but disclosed on Final Closing Disclosure.  Valid Change of Circumstance not provided.  Provider for this fee is not same as the provider for other title fees disclosed in Section C on the initial Loan Estimate. Final Closing Disclosure does not reflect a Lender credit for $ XXXXX tolerance.
   
Reviewer Comment (2019-06-17): XXXXX received required documents, exception is cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
B
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Miscellaneous Compliance
Other Compliance Exception (Manual Add)
 
Missing revised Closing Disclosure dated XXXXX indicated on Lender's Disclosure Tracking Summary (XXXXX). Loan file contains Closing Disclosure dated XXXXX e-signed XXXXX and Closing Disclosure dated XXXXX live signed XXXXX wit XXXXX and XXXXX.  TRID Testing is incomplete
   
Reviewer Comment (2019-06-17): n/a
 
 
Buyer Comment (2019-06-17): Final CD is the one that was pulled on XXXXX. The XXXXXmanual entry was XXXXX this is a conventional loan and had to pull the UCD report which created a XXXXX CD, which was not sent out to no one.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
C
B
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
Final Closing Disclosure does not disclose a Lender cure credit for $ XXXXX tolerance.
   
Reviewer Comment (2019-06-17): XXXXX received required documents, exception is cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
C
B
C
B
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Borrower and Mortgage Eligibility
Mortgage / Program Eligibility
Guideline Issue:  Subject loan is a non-arms length transaction  outside of credit guidelines
 
Non-Arm's Length Transaction.  Borrower is employee of the origination lender.  Non-Arm's Length Transactions approved on a case by case basis.  Missing XXXXX signed CRE acknowledging exception approval
Borrower on this Full documentation loan has a disposable income of $XXXXX
 
XXXXX%% DTI on this Full documentation loan < XXXXX% guideline max
Originator
 
Originator
Reviewer Comment (2019-06-17): Received Credit Risk Summary & Exception Approval. Non-arms length transaction. Borr is an employee of XXXXX (XXXXX). Compensating Factors: 1) Credit History. 2) DTI. 3) Housing Pymt Decrease. 4) Residual Income.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
C
B
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Securitization Review and the supporting secondary valuation was an AVM
       
Reviewer Comment (2019-06-17): Received desk review
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
B
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
AVM used as supporting valuation.
-
     
Reviewer Comment (2019-06-17): Received desk review
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
B
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Credit Exception:
 
Additonal information is needed for the property identifed as A on Sch XXXXX of the XXXXX tax returns.  The property was not reflected on the REO schedule of the XXXXXs.  Please provide information to support no longer owner of this property or PITIA information to add to the DTI review of this loan.
   
Reviewer Comment (2019-06-17): Retrieved property tax information from 1XXXXX
 
 
Reviewer Comment (2019-06-17): Please provide documentation to show that the business pays for the PITIA forXXXXX St (tax return showsXXXXX St).
 
 
Buyer Comment (2019-06-17): XXXXX is the borrowers business address. Most likely it was a typo. The borrower's business address is on his business license which is in file & also on the VOE.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
B
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Income / Employment
Income Documentation
Income Docs Missing:
- ___
Missing third party verification of business existence withinXXXXX days of closing.
Borrower has job stability for XXXXXyears as self employed
 
XXXXX representative FICO score > XXXXX guideline minimum
Originator
 
Originator
Reviewer Comment (2019-06-17): Received Credit Risk Summary & Exception Approval. Documentation missing - Third party verification of business existence within 10 days of closing. Compensating Factors: 1) Credit Score. 2) Credit History. 3) Stable Employment History.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
B
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Credit Exception:
 
Lender used XXXXX income from Schedule XXXXX to qualify the borrower.  This income shows a decline from the prior years tax returns.  Correspondence in the file shows a request was made to waive the LOE from the borrower per guidelines.  Please provide sufficient documentation that supports a lender exception removing the documentation needed per guidelines.
XXXXX months reserves > XXXXX months guideline minimum
 
Borrower has job stability for XXXXXyears as self employed
 
XXXXX representative FICO score > XXXXX guideline minimum
Originator
 
Originator
 
Originator
Reviewer Comment (2019-06-17): Rec'd Lender exception approval in trailing docs.
 
 
Reviewer Comment (2019-06-17): Rec'd explanation for use of declining income.  Written, signed exception still required.
 
 
Reviewer Comment (2019-06-17): Exception not found in file for use of declining income. (XXXXX shows a continued decline)
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
B
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation
ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.
Valuation received date XXXXX > XXXXX (XXXXX Note date less 3)
   
Reviewer Comment (2019-10-09): Client elects to waive.
 
 
Reviewer Comment (2019-06-17): Rec'd evidence the XXXXX was sent XXXXX.  The assumed date of receipt is XXXXX which is less than 3 business days prior to closing.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided onXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
Final Closing Disclosure does not disclose a Lender cure credit for $ XXXXX tolerance.
   
Reviewer Comment (2019-06-17): Upon further review, the exception is cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Missing valid change of circumstance for Initial Closing Disclosure dated  XXXXX disclosing  XXXXX% $ XXXXX Loan Discount fee added.  Final Closing Disclosure does not disclose a Lender cure credit for $ XXXXXtolerance.
   
Reviewer Comment (2019-06-17): Upon further review, the exception is cleared.
 
 
Buyer Comment (2019-06-17): Note: The change happened on the LE dated XXXXX COC uploaded
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Will Not Have Escrow -  Reason
TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXX incorrectly disclosed whether the loan will have an escrow account.
Reason loan will not have an escrow account is not disclosed
   
Reviewer Comment (2019-06-17): XXXXX received PCCD correcting escrow section and LOE. Exception Cured.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM Employment History
Qualified Mortgage (Dodd-Frank 2014): Employment history requirement not met.
Missing 2 year history
   
Reviewer Comment (2019-06-17): Received LOE
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
Due to employment history
   
Reviewer Comment (2019-06-17): Received LOE
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower. (XXXXX)
No cure check evident in the file.
   
Reviewer Comment (2019-06-17): XXXXX received XXXXX LE and COC. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower. (XXXXX)
Final disclosure reflects a total expense for the appraisal reinspection fee of $ XXXXX, initially disclosed as $ XXXXX, sufficient cure was not provided at closing.
   
Reviewer Comment (2019-06-17): Post CD, letter to borrower, refund check, and signed letter form borrowers they received and cashed $XXXXX check provided.
 
 
Buyer Comment (2019-06-17): LOX attached, showing borrower received refund check of $XXXXX.  Please review and clear, asap.  Thanks.
 
 
Reviewer Comment (2019-06-17): Please provide copy of cashed check as proof of delivery.
 
 
Buyer Comment (2019-06-17): Copy of LOX and check uploaded.  Also, this was uploaded on XXXXX.  Please review and clear, asap.  Thank you
 
 
Reviewer Comment (2019-06-17): XXXXX received attestation the check was sent via regular mail on XXXXX.  Please provide copy of cashed check as proof of delivery.
 
 
Buyer Comment (2019-06-17): Please review the attached proof of delivery
 
 
Reviewer Comment (2019-06-17): XXXXX received PCCD, LOE and Copy of refund check.  Need proof of delivery to cure.
 
 
Buyer Comment (2019-06-17): Attached is the PCCD, LOX, copy of refund check.
 
 
Reviewer Comment (2019-06-17): XXXXX received CD dated XXXXX and change of circumstance.  Appraisal Re-Inspection Fee was originally disclosed as $XXXXX.  Fee increased to $XXXXXcure required as change of circumstance provided does not explain why the fee increase.  Receiving the invoice that is greater than the amount disclosed to the borrower is not considered a valid change of circumstance.
 
 
Reviewer Comment (2019-06-17): XXXXX received XXXXX COC indicating the Appraisal Re Inspection Fee increased $XXXXX. Invoice supports COC however it states fee was redisclosed on XXXXX. Please provide XXXXX CD to determine if exception can be cleared.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/XXXXX)
The exceeds legal limits is blank on the disclosure.
   
Reviewer Comment (2019-06-17): Letter of Explanation & Corrected Closing Disclosure provided
 
 
Reviewer Comment (2019-06-17): XXXXX received CD dated 01/18/2019 and change of circumstance.  Appraisal Re-Inspection Fee was originally disclosed as $XXXXX.  Fee increased to $XXXXXcure required as change of circumstance provided does not explain why the fee increase.  Receiving the invoice that is greater than the amount disclosed to the borrower is not considered a valid change of circumstance.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Seller Closing Disclosure
TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/XXXXX)
The Seller's final disclosure is not provided.
   
Reviewer Comment (2019-10-09): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Approval not provided
 
The Loan Approval was not provided.
   
Reviewer Comment (2019-06-17): Received Loan Approval.
 
 
Buyer Comment (2019-06-17): Loan approval uploaded.  Thank you.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Asset
Asset Calculation / Analysis
Available for Closing is insufficient to cover Cash From Borrower.
Documented qualifying Assets for Closing of  ___ is less than Cash From Borrower ___.
Assets in the amount of $XXXXX were required to close. The loan file contained a statement indicating the borrower provided Earnest Money Deposit funds in the amount of $XXXXX. The loan file is missing verification of additional assets of $XXXXX.
   
Reviewer Comment (2019-06-17): Able to tie the online statement to full print out from XXXXX bank statement - cleared
 
 
Reviewer Comment (2019-06-17): Did not receive a full statement for XXXXX Savings acct XXXXX. unable to determine all account holders.
 
 
Buyer Comment (2019-06-17): The 2 accounts used for closing was XXXXX with the latest statement dated XXXXX and updated with a printout through XXXXXand XXXXX with the latest full statement dated XXXXXand updated with a printout through XXXXX.  There are no gaps in the account histories and we have always accepted a printout to supplement a full statement.
 
 
Reviewer Comment (2019-06-17): Traditional bank statement for acct  XXXXX was not provided. Please provide the statements to clear this exception.
 
 
Buyer Comment (2019-06-17): Please note the prints out dated XXXXX and XXXXX has the last four digits of XXXXX as listed on the traditional bank statements in the file.  Please review and clear.  Thank you.
 
 
Reviewer Comment (2019-06-17): Received bank statement for acct XXXXX with balance of $XXXXX however, XXXXX acct XXXXX with a balance of $XXXXX is an online print and does not reflect borrowers name. Unable to verify with documentation provided is borrowers are owners of the account. Please provide the bank statement to clear this exception.
 
 
Buyer Comment (2019-06-17): Bank statements uploaded .  For accounts XXXXX and XXXXX XXXXX accounts.
 
 
Reviewer Comment (2019-06-17): XXXXX initial loan documentation did not include any XXXXX Statements. XXXXX received XXXXX statements for account XXXXX for the months of XXXXX to XXXXX, and XXXXX to XXXXX on XXXXX. Reviewer has scrolled through every XXXXX documents uploaded. The file is still missing XXXXX month recent statements for XXXXX XXXXX and XXXXX XXXXX, evidencing liquid funds in the amount of $XXXXX and $XXXXX for those acct #'s.
 
 
Buyer Comment (2019-06-17): Their citing is incorrect.
 
We have sufficient funds in the file to cover both the reserves and the funds for closing.
 
EMD cleared already
 
Loan closed  XXXXX
 
 XXXXX as of  XXXXX $ XXXXX
 XXXXX as of  XXXXX $ XXXXX
Auditor needs to scroll through each page to find these latest balances.
 
These are all in the assets-bank statement folder and lender sent them again in the post closing file (easier to locate in the post closing folder from the lender).
 
Borrower only needs:
 
 XXXXX mos PITIA $ XXXXX
Funds to close $ XXXXX.
 
Borrower HAS TOTAL  of $ XXXXX liquid (see above breakdown) which would leave $ XXXXX left over to use towards reserves.
Borrower has investment funds in file totaling $ XXXXX.  $ XXXXX investment balance PLUS the liquid overage of $ XXXXX totals $ XXXXX which is more than sufficient to cover the reserves.
 
Their citing is incorrect.
 
We have sufficient funds in the file to cover both the reserves and the funds for closing.
 
EMD cleared already
 
Loan closed  XXXXX
 
 XXXXX as of  XXXXX $ XXXXX
 XXXXX as of  XXXXX $ XXXXX
Auditor needs to scroll through each page to find these latest balances.
 
These are all in the assets-bank statement folder and lender sent them again in the post closing file (easier to locate in the post closing folder from the lender).
 
Borrower only needs:
 
XXXXX mos PITIA $XXXXX
Funds to close $XXXXX
 
Borrower HAS TOTAL  of $XXXXXliquid (see above breakdown) which would leave $XXXXX left over to use towards reserves.
Borrower has investment funds in file totaling $XXXXX.  $XXXXX investment balance PLUS the liquid overage of XXXXX totals $XXXXX which is more than sufficient to cover the reserves.
 
You can forward this email as a response to XXXXX
 
 
 
 
 
Reviewer Comment (2019-06-17): Received verification of 3 earnest money deposits totaling $XXXXX that cleared the borrowersXXXXX account in XXXXX and XXXXX, XXXXX. Final 1003 dated XXXXX disclosed the following XXXXX accounts: XXXXX with a balance of $XXXXX and #XXXXX with a balance of $XXXXX. However, file is missing the most recent 2 months of statements to verify the current balances and the remaining liquid assets of $XXXXX are insufficient to cover the funds for closing of $XXXXX.
 
 
Buyer Comment (2019-06-17): Please review the EMD check for $XXXXX.  XXXXX XXXXX on XXXXX.  XXXXX on XXXXXon XXXXX account ending XXXXX.
 
 
Reviewer Comment (2019-06-17): File is missing evidence of EMD in the amount of $XXXXX, and there are no XXXXX Statements provided. Only retirement accounts with XXXXXand XXXXX
 
 
Buyer Comment (2019-06-17): Please review the XXXXX account ending XXXXX balance  on XXXXX was $XXXXX and  account ending XXXXX was $XXXXX those balance equals $XXXXX.  Please review  and clear.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
The Second Valuation Product was not provided.
   
Reviewer Comment (2019-06-17): Received desk review
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - ATR Risk
Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.
     
Reviewer Comment (2019-06-17): Loan Approval Provided.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM Loan Designation
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
General Ability To Repay Provision Investor Guidelines Not Provided
Ability to Repay (Dodd-Frank 2014): Unable to determine ability to repay due to missing guidelines. Loan characteristics are DTI: XXXXX%, LTV/CLTV: XXXXX%/V%, Credit Score: XXXXX Occupancy: Primary, Purpose: Purchase,
The Loan Approval is missing from the loan file.
   
Reviewer Comment (2019-06-17): Loan Approval Provided.
 
 
Buyer Comment (2019-06-17): Loan approval uploaded.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Unknown Loan Designation
Ability to Repay (Dodd-Frank 2014): Originator Loan Designation not provided. Due Diligence Loan Designation is Safe Harbor QM.
A Compliance Report is missing from the loan file. Deal Notes indicate Loan Designation is to obtained from a Compliance Report.
   
Reviewer Comment (2019-06-17): Exception not longer valid, Originator Loan Designation provided.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Provided Prior to Date Performed
ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements. (Type:Primary/XXXXX)
     
Reviewer Comment (2019-10-09): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing. (XXXXX)
         
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Final CD evidences Cure
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-07-10): Per client collateral received.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
B
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
Only one appraisal was provided.
   
Reviewer Comment (2019-07-24): Provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
B
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
No cure provided.
   
Reviewer Comment (2019-07-08): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
B
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Lender Credit Tolerance Violation
TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $XXXXX  is less than amount of binding Lender Credit previously disclosed in the amount of $XXXXX.
No cure provided.
   
Reviewer Comment (2019-07-24): The lender credit decreased when the borrower loan program changed per COC
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
B
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-08-07): Received per client.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
Loan is to go in a securitization and reflects only one valuation product when two are required.
   
Reviewer Comment (2019-08-16): Secondary valuation provided with 0% variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
   
Reviewer Comment (2019-08-20): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Guideline Requirement: PITIA reserves months discrepancy.
 
Guidelines call for XXXXX months reserves. No assets were provided.
   
Reviewer Comment (2019-08-22): Additional guidelines were provided. Lender guidelines indicate you should refer to the XXXXX for reserve requirements. XXXXX in file discloses there are no reserves required.
 
 
Reviewer Comment (2019-08-15): Per client all loans are to be reviewed to the XXXXX Jumbo Fixed and ARM Conventional Non-Conforming Program Summary which requireXXXXXmonths reserves. Exception remains.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-08-05): received per client
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
B
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
Loan is to go in a securitization and reflects only one valuation product when two are required.
   
Reviewer Comment (2019-08-16): Secondary valuation received with 0% variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
B
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-08-05): received per client
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Homeowner's Insurance Premium Months
TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.
Final Closing Disclosure, Section F disclosed insurance as XXXXX months instead of  XXXXX
   
Reviewer Comment (2019-08-07): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
On Final CD under Total Closing Costs Exceeds Limits the amount is blank.
   
Reviewer Comment (2019-08-07): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date
Truth in Lending Act:  Subject loan transaction disbursed on XXXXX, prior to three (3) business days from transaction date of XXXXX.
Loan closed and disbursed on  XXXXX.   Borrower was did sign RTC disclosure giving RTC date until  XXXXX
   
Reviewer Comment (2019-08-22): Evidence of a new ROR, CD, LOE and evidence of tracking shipped to the borrower
 
 
Reviewer Comment (2019-08-13): PCCD along with LOE and proof of delivery provided for tolerance violations, however this did not address the rescission exception. Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form. Exception remains.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $XXXXX exceeds tolerance of $XXXXX plus XXXXX% or $XXXXX.  Insufficient or no cure was provided to the borrower.
Cure for various  XXXXX% and  XXXXX% tolerance violations $ XXXXX was not provided, however, the Title fees are reflected in Section C and Borrowers did use Vendor on the  XXXXX,
   
Reviewer Comment (2019-08-09): Letter of Explanation, Copy of Refund Check, and Corrected CD provided.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Ten Percent Tolerance Violation With Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $XXXXX exceeds tolerance of $XXXXX plus XXXXX% or $XXXXX.  Sufficient or excess cure was provided to the borrower.
Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD needed.
   
Reviewer Comment (2019-08-09): Letter of Explanation, Copy of Refund Check, and Corrected CD provided.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-08-05): received per client
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
Additional appraisal product is not provided.
   
Reviewer Comment (2019-07-24): Provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
Failure due to points and fees exceeding allowable percentage.
   
Reviewer Comment (2019-08-02): Bona Fide worksheet provided. Exception cleared.
 
 
Reviewer Comment (2019-07-22): Please provide evidence of undiscounted rate/pricing sheet to exclude bona fide discount points as reflected per Mavent report provided.
 
 
Seller Comment (2019-07-17): Mavent compliance report
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM Points and Fees
Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of XXXXX% is in excess of the allowable maximum of  XXXXX% of the Federal Total Loan Amount. Points and Fees total $XXXXX on a Federal Total Loan Amount of $XXXXX vs. an allowable total of $XXXXX (an overage of $XXXXX or .XXXXX%).
Allowable percentage is exceeded when broker compensation is included.
   
Reviewer Comment (2019-08-02): Bona Fide worksheet provided. Exception cleared.
 
 
Reviewer Comment (2019-07-22): Please provide evidence of undiscounted rate/pricing sheet to exclude bona fide discount points as reflected per Mavent report provided.
 
 
Seller Comment (2019-07-17): per the XXXXX report fees were charged at XXXXX% which do not exceed the maximum XXXXX% limit of the Total loan amount
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
If a creditor or assignee determines after consummation that the total points and fees exceeds the QM Points and Fees limit, but the loan meets the other requirements to be a QM, the QM Points and Fees exception can be cured through a refund including interest at the contract rate from consummation to the date of cure, with the following conditions:
1)      Refund is made within 210 days of consummation;
2)      The consumer has not instituted any actions against the creditor or provided written notice that the loan's fees exceeded the legal limit;
3)      The loan is not 60 days delinquent;
4)      The creditor or assignee (depending who is curing) has policies in place to identify and cure excessive fees collected from the consumer (the creditor or assignee can only take advantage of this cure provision if they maintain policies and procedures for post-consummation review of points and fees and for providing the cure payments); and
5)      The loan was closed on or before January 10, 2021;
 
Documents Required to Cure
1)      Letter of Explanation
2)      Copy of Refund Check (in the amount of overage plus interest)
3)      Proof of Delivery
4)      Lender/Seller Attestation indicating:
        a)      The consumer has not instituted any actions against the creditor or provided written notice that the loan's fees exceeded the legal limit;
        b)      The loan is not 60 days delinquent; and
        c)      The creditor or assignee (depending who is curing) has policies in place to identify and cure excessive fees collected from the consumer
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Approval not provided
 
Approval not found in file
   
Reviewer Comment (2019-07-17): Received loan approval
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
No evidence of date when borrower received appraisal
   
Reviewer Comment (2019-07-19): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-07-10): Per client collateral received.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Purchase Agreement / Sales Contract not provided
 
Only the purchase contract from the sale of the borrower primary home was provided
   
Reviewer Comment (2019-07-24): Provided was the complete escrow instructions to purchase.XXXXX is an XXXXX state
 
 
Reviewer Comment (2019-07-24): No new image provided. The same purchase agreement from the sale of the borrower current home was provided. Exception remains.
 
 
Reviewer Comment (2019-07-17): The purchase agreement provided was for XXXXX Ave and not the subject property.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
Borrowers signed acknowledgement at closing but date appraisal was provided is not documented.
   
Reviewer Comment (2019-07-11): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
D
B
D
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.
Initial report date was XXXXX.  Date provided is not documented.
   
Reviewer Comment (2019-07-11): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
D
B
D
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Guideline Requirement: PITIA reserves months discrepancy.
 
Borrowers are shortXXXXX months reserves.   Total assets documented $XXXXX, required for closing $XXXXX including XXXXX money.
   
Reviewer Comment (2019-07-24): All assets have been verified.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
S-Corp Income Documentation Test
Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (S-Corp).
The borrower changed from a  XXXXX to an XXXXX from  XXXXX to  XXXXX. The  XXXXX personal returns are not executed in order to be considered QM.
   
Reviewer Comment (2019-08-14): The XXXXXpersonal returns evidenced as signed and dated based on the tax transcript.  The business converted from Schedule XXXXX to S Corp in XXXXX. Income can be considered from a business existing less than two years when the consumer has prior experience, which this one did as XXXXX.
 
 
Reviewer Comment (2019-08-14): The file is missing the XXXXXsigned personal returns for both self employed borrowers along with a third party verification to support the business in existence for a two year history.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
S-Corp Income Documentation Test
Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (S-Corp).
Third party verification for self-employment income is not found in file.
   
Reviewer Comment (2019-07-29): Business transitioned from Schedule XXXXX to XXXXX in XXXXX.  Consumer provided two years signed/dated personal returns and the one year of S Corp returns. (The schedule XXXXX income was reflected on the XXXXX Returns for the same business.)
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
The current loan designation is Non QM based on missing signatures on the XXXXX and evidence from a third party source confirming the begin date of both borrowers schedule XXXXX business as the XXXXX stated the income reporting changed in XXXXX to support a two year history as required per Appendix Q.
   
Reviewer Comment (2019-08-14): SHQM loan
 
 
Reviewer Comment (2019-08-13): The file is missing the XXXXXsigned personal returns for both self employed borrowers along with a third party verification to support the business in existence for a two year history.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Credit Exception:
 
Missing Mortgage Statement or XXXXX and XXXXX Verification for property located at XXXXX. Tax Statement in file is missing tax amount, it only includes the Assessed Value.
   
Reviewer Comment (2019-08-16): Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-08-05): received per client
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM Employment History
Qualified Mortgage (Dodd-Frank 2014): Employment history requirement not met.
The  XXXXX letter provided only discusses the change from schedule  XXXXX to  XXXXX. The file is missing a third party verification to document how long the borrower was self-employed to meet a two year history per appendix Q
   
Reviewer Comment (2019-08-16): Exception cleared.
 
 
Reviewer Comment (2019-08-14): Regraded to EV2-B as the XXXXXSchedule XXXXX reflects income to XXXXX and a XXXXX from XXXXX to backstop the dates referenced on the consumers application
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM Employment History
Qualified Mortgage (Dodd-Frank 2014): Employment history requirement not met.
The  XXXXX letter provided only discusses the change from schedule  XXXXX to  XXXXX. The file is missing a third party verification to document how long the borrower was self-employed to meet a two year history per appendix Q
   
Reviewer Comment (2019-08-16): Exception cleared.
 
 
Reviewer Comment (2019-08-14): Regraded to EV2-B as the XXXXX Schedule XXXXX reflects income to XXXXX to backstop the dates referenced on the consumers application
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self Employed - Implicit Adherence
Qualified Mortgage (Dodd-Frank 2014): Self Employed borrower's loan file contained tax returns that are not signed/dated, but the loan file contains the tax transcripts to evidence the tax returns were signed/dated at time of submission to the IRS.
     
Buyer Comment (2019-08-20): Waived by  XXXXX on Rate Lock: OK to accept. 2yrs personal/business tax returns in file each bwr  XXXXX and  XXXXX tax transcripts fully executed in file in place of signed tax returns
 
 
Buyer Comment (2019-08-20): (XXXXX) OK to accept. 2yrs personal/business tax returns in file each bwr XXXXX and XXXXX tax transcripts fully executed in file in place of signed tax returns
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-08-05): received per client
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
B
B
B
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation
ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.
Initial appraisal date is XXXXX, delivery is not documented.
   
Reviewer Comment (2019-08-01): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
B
B
B
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
Loan is to go in a securitization and reflects only one valuation product when two are required.
   
Reviewer Comment (2019-07-15): Desk review provided with no variance. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
   
Reviewer Comment (2019-07-02): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
Due to QM points an fees failure
   
Reviewer Comment (2019-07-22): Lender provided a Bona Fide Discount worksheet
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM Points and Fees
Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of XXXXX% is in excess of the allowable maximum of  XXXXX% of the Federal Total Loan Amount. Points and Fees total $XXXXXon a Federal Total Loan Amount of $XXXXX vs. an allowable total of $XXXXXX (an overage of $XXXXX or .XXXXX%).
Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of  XXXXX% is in excess of the allowable maximum of  XXXXX% of the Federal Total Loan Amount. Points and Fees total $ XXXXXon a Federal Total Loan Amount of $5 XXXXX vs. an allowable total of $ XXXXX (an overage of $ XXXXX or . XXXXX%).
   
Reviewer Comment (2019-07-22): Lender provided a Bona Fide Discount worksheet
 
 
Seller Comment (2019-07-19): bone fide worksheet
 
 
Reviewer Comment (2019-07-18): Compliance report reflects Bona Fide discount points were excluded. Provide Bona Fide worksheet for evidence of Bona Fide points to be excluded from testing. Exception remains.
 
 
Seller Comment (2019-07-17): please review our points & fees test
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
If a creditor or assignee determines after consummation that the total points and fees exceeds the QM Points and Fees limit, but the loan meets the other requirements to be a QM, the QM Points and Fees exception can be cured through a refund including interest at the contract rate from consummation to the date of cure, with the following conditions:
1)      Refund is made within 210 days of consummation;
2)      The consumer has not instituted any actions against the creditor or provided written notice that the loan's fees exceeded the legal limit;
3)      The loan is not 60 days delinquent;
4)      The creditor or assignee (depending who is curing) has policies in place to identify and cure excessive fees collected from the consumer (the creditor or assignee can only take advantage of this cure provision if they maintain policies and procedures for post-consummation review of points and fees and for providing the cure payments); and
5)      The loan was closed on or before January 10, 2021;
 
Documents Required to Cure
1)      Letter of Explanation
2)      Copy of Refund Check (in the amount of overage plus interest)
3)      Proof of Delivery
4)      Lender/Seller Attestation indicating:
        a)      The consumer has not instituted any actions against the creditor or provided written notice that the loan's fees exceeded the legal limit;
        b)      The loan is not 60 days delinquent; and
        c)      The creditor or assignee (depending who is curing) has policies in place to identify and cure excessive fees collected from the consumer
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - Wholesale Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on  XXXXXdid not disclose the required Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name). (Final/ XXXXX
   
Reviewer Comment (2019-07-02): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
     
Reviewer Comment (2019-07-02): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
Evidence that borrower received copy of appraisal at least 3 business days prior to closing was not provided.
   
Reviewer Comment (2019-07-02): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 05/31/2019 disclosed a Closing Date that did not match the actual date of consummation.
Final CD disclosed a Closing Date of  XXXXX, however, actual date of consummation is  XXXXX.
   
Reviewer Comment (2019-07-02): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-07-22): Desk Review provided with 0% variance.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
Subject to securitization, requiring two full appraisals.  File contains only one
   
Reviewer Comment (2019-07-23): Provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
Did not disclose the legal limit was exceeded
   
Reviewer Comment (2019-07-02): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Wire /Funding/ Disbursement Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Fee not initially disclosed for this fee paid to SSP
   
Reviewer Comment (2019-07-12): XXXXX reviewed exception. Fee would be placed in XXXXX% category and is under the XXXXX% threshold. Exception Cleared.
 
 
Seller Comment (2019-07-11): Fee was disclosed, see attached
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Title Update.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Fee not initially disclosed for this fee paid to SSP
   
Reviewer Comment (2019-07-12): XXXXX reviewed exception. Fee would be placed in XXXXX% category and is under the XXXXX% threshold. Exception Cleared.
 
 
Seller Comment (2019-07-11): Fee was disclosed, See attached
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Borrower and Mortgage Eligibility
Mortgage / Program Eligibility
Missing Document: Note - Subordinate Lien not provided
 
Not provided.
   
Reviewer Comment (2019-07-09): HELOC not was provided
 
 
Seller Comment (2019-07-01): Note - Subordinate Lien
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
California subject property. Closed in escrow.
   
Reviewer Comment (2019-07-01): PCCD issued with correct closing date.
 
 
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Provided Prior to Date Performed
ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.
Appraisal updated about zoning XXXXX after being provided to the borrower.
   
Reviewer Comment (2019-07-02): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Invalid XXXXX Combinations
TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on XXXXX reflects a fee Paid To lender or broker for fee within Services Borrower Did Not Shop For section.
Final CD reads fee payable to lender.
   
Reviewer Comment (2019-07-02): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Good Faith Redisclosure
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
 
Pending Internal Customer Final Collateral Package Review.
   
Reviewer Comment (2019-08-07): Received per client.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
There's no evidence of a secondary valuation as required.
   
Reviewer Comment (2019-08-16): Secondary valuation required with XXXXX variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
The appraisal fee increased from the initial LE to the Final CD without a cure in the loan file.
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Final CD evidences Cure
C
A
C
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Insurance
Insurance Analysis
Insufficient Coverage: Hazard insurance coverage amount is insufficient.
 
AMC tests hazard coverage in accordance with Fannie Mae, which requires coverage equal to or the lesser of the following: 1) XXXXXof the insurable value of the improvements, as established by the property insurer; or 2) the unpaid principal balance of the mortgage, as long as it at least equals the minimum amount-XXXXX of the insurable value of the improvements-required to compensate for damage or loss on a replacement cost basis. If it does not, then coverage that does provide the minimum required amount must be obtained. Coverage shortfall XXXXX. The binder does not include the specific amount for extended coverage.
   
Reviewer Comment (2019-08-14): Exception cleared
 
 
Seller Comment (2019-08-13): please advise if this has been cleared
 
 
Seller Comment (2019-08-09): XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-08-05): received per client
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Approval not provided
       
Reviewer Comment (2019-08-08): Received loan approval
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Notary Date and the signature date on the CD is XXXXX, however, the Date Issued, Closing Date, and Disbursement Date on the final CD is XXXXX.
   
Reviewer Comment (2019-08-01): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
This exception is due to open XXXXX tolerance exceptions and will be cured when all tolerance violations are resolved
   
Reviewer Comment (2019-08-01): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
Fee disclosed as XXXXX on LE dated XXXXX, but disclosed as XXXXX on Final Closing Disclosure.  The fee was re-disclosed on the LE dated XXXXX, however, a valid reason for the fee increase was not provided.
   
Reviewer Comment (2019-08-14): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided. Exception cured.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Sufficient or excess cure was provided to the borrower.
     
Buyer Comment (2019-08-20): Waived by XXXXX on Rate Lock: Ok to accept. No A/L or outside SOL
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Loan Package Documentation
Closing / Title
Missing Document: Note - Subject Lien not provided
       
Reviewer Comment (2019-07-03): Received subject lien note
 
 
Seller Comment (2019-07-02): Note added
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
D
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Closing / Title
Missing Document: Security Instrument not provided
       
Reviewer Comment (2019-07-03): Received recorded security instrument
 
 
Seller Comment (2019-07-02): Mortgage Added
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
D
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Approval not provided
       
Reviewer Comment (2019-07-03): Received loan approval
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
D
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation
ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.
Evidence of the date on which the Borrowers received the report not provided.
   
Reviewer Comment (2019-07-03): Received proof of delivery and receipt on XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
D
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
RESPA -  Initial Escrow Account Statement Missing
RESPA: Initial escrow account statement was not provided to the borrower.
     
Reviewer Comment (2019-07-02): XXXXX received required documents, exception is cleared.
 
 
Seller Comment (2019-07-02): Document uploaded
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
D
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Contact Information - Lender
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID).
The final CD did not disclose the lender's contact information.
   
Reviewer Comment (2019-07-02): Upon further review, the exception is cleared.
 
 
Seller Comment (2019-07-02): The final CD signed at closing did have all the required information for the lender, copy uploaded
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
D
B
D
A
D
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Closing Disclosure Timing without Waiver
TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.
Earlier CD not provided
   
Reviewer Comment (2019-07-02): XXXXX received required documents, exception is cleared.
 
 
Seller Comment (2019-07-02): Cd XXXXX is e-sgined by the borrower on XXXXX starting the 3 day clock to allow the borrower to sign on XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
No Defined Cure
D
B
D
A
D
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Seller Closing Disclosure
TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.
Seller CD missing.
   
Reviewer Comment (2019-07-02): Upon further review, the exception is cleared.
 
 
Seller Comment (2019-07-02): Seller side of the final CD is completed, do not need a separate seller CD
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
D
B
D
A
D
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
No amount disclosed
   
Reviewer Comment (2019-07-03): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
D
B
D
A
D
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Seller Closing Disclosure
TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.
Disclosure not evidenced in loan file.
   
Reviewer Comment (2019-07-03): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
D
B
D
A
D
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-07-05): Desk review provided
 
 
Reviewer Comment (2019-07-02): Please provide XXXXX  once complete
 
 
Seller Comment (2019-07-02): XXXXX to order XXXXX  on loan files
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM Employment History - Current and/or Previous Employment Documentation lacks Date Info
Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two years employment history for current and/or prior employment.
Missing required third party VOE for sole proprietorship.
   
Reviewer Comment (2019-07-03): Client elects to waive
 
 
Reviewer Comment (2019-07-02): Need third party verification for CB's sole proprietor business Freedom Analytics and not W2 job as provided.  Exception remains.
 
 
Seller Comment (2019-07-02): Co borrower current employer XXXXX, prior employer XXXXX. both work number are uploaded below
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Closing Disclosure Timing without Waiver
TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.
Evidence of earlier borrower receipt was not found.
   
Reviewer Comment (2019-07-03): Received proof of delivery on XXXXX.
 
 
Seller Comment (2019-07-03): initial cd XXXXX uploaded
 
 
Reviewer Comment (2019-07-03): Disclosure Summary reflects initial CD was provided on XXXXX however file does not evidence a CD dated XXXXX.  Please provide CD dated XXXXX.
 
 
Seller Comment (2019-07-02): Initial CD received by borrower XXXXX, disclosure tracking uploaded
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
No Defined Cure
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
         
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Final CD evidences Cure
C
A
A
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-07-05): Desk Review provided
 
 
Reviewer Comment (2019-07-03): Please provide XXXXX  once received
 
 
Seller Comment (2019-07-02): XXXXX will order the XXXXX  on the loan file
 
 
Seller Comment (2019-07-02): XXXXX to order XXXXX  for loan file
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
A
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Purchase Agreement / Sales Contract not provided
 
There is no evidence of the purchase agreement in the file.
   
Reviewer Comment (2019-07-02): Received purchase agreement
 
 
Seller Comment (2019-07-02): Purchase Contract uploaded
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Approval not provided
 
Missing QM approval
   
Reviewer Comment (2019-07-03): Received loan approval
 
 
Seller Comment (2019-07-03): XXXXX uploaded
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
General
Initial Rate Lock rate date is not documented in file.
 
There is no evidence of documentation confirming the initial rate lock date.
   
Reviewer Comment (2019-07-02): Received rate lock
 
 
Seller Comment (2019-07-02): Rate lock agreement uploaded
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Income / Employment
Income Documentation
Income Docs Missing:
-
Missing XXXXX (XXXXX), XXXXX (XXXXX), Paystubs (XXXXX), Transcripts (XXXXX), Transcripts (XXXXX), VVOE - Employment Only, W-2 (XXXXX), W-2 (XXXXX).
   
Reviewer Comment (2019-07-05): XXXXX & XXXXX 1040's were provided
 
 
Seller Comment (2019-07-03): Tax returns are now uploaded
 
 
Reviewer Comment (2019-07-03): Still missing last 2 years XXXXX
 
 
Reviewer Comment (2019-07-02): Still missing last 2 years XXXXX, last 2 years tax transcripts and VVOE for Co-Borrower.
 
 
Seller Comment (2019-07-02): Income docs uploaded
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Asset
Asset Eligibility
Asset Verification Level is less than XXXXX.
-
Missing all assets used
   
Reviewer Comment (2019-07-02): Received 2 months verified assets totaling XXXXX
 
 
Seller Comment (2019-07-02): Assets uploaded
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
There is no evidence that a second valuation was provided; however, guidelines direct that for purchases, two (2) Appraisals required for all loans > XXXXX. The subject loan is for XXXXX.
   
Reviewer Comment (2019-07-05): Desk Review provided.
 
 
Reviewer Comment (2019-07-02): Exception to be addressed once XXXXX  is received.
 
 
Seller Comment (2019-07-02): XXXXX to order XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Wages Documentation
Qualified Mortgage (Dodd-Frank 2014): Wages / W-2 income documentation not sufficient.
Missing XXXXX (XXXXX), XXXXX (XXXXX), Paystubs (XXXXX), Transcripts (XXXXX), Transcripts (XXXXX), VVOE - Employment Only, W-2 (XXXXX), W-2 (XXXXX).
   
Reviewer Comment (2019-07-02): Received income documentation including paystubs, previous 2 years W2's, VVOE & WVOE
 
 
Seller Comment (2019-07-02): W2 uploaded
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Wages Documentation
Qualified Mortgage (Dodd-Frank 2014): Wages / W-2 income documentation not sufficient.
Missing XXXXX (XXXXX), XXXXX (XXXXX), Paystubs (XXXXX), Transcripts (XXXXX), Transcripts (XXXXX), VVOE - Employment Only, W-2 (XXXXX), W-2 (XXXXX).
   
Reviewer Comment (2019-07-02): Received income documentation including paystubs, previous 2 years W2's, VVOE & WVOE
 
 
Seller Comment (2019-07-02): W2 uploaded
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation
ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.
There is no evidence that a copy of each valuation was provided to the applicant three (3) business days prior to consummation.
   
Reviewer Comment (2019-07-02): Received proof of delivery on XXXXX
 
 
Seller Comment (2019-07-02): App acknowledgement uploaded
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Appraisal Disclosure - ECOA Status
ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.
There is no evidence that the right to receive a copy of the Appraisal Disclosure was provided to the applicant.
   
Reviewer Comment (2019-07-03): Client elects to waive.
 
 
Reviewer Comment (2019-07-02): Disclosure or LE not evidenced in loan file
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Good faith redisclosure
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
(Missing Data) Last Rate Set Date
Last Date Rate Set and Initial Rate Lock Date not provided.  Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing.
There is no evidence that the Last Date Rate Set and Initial Rate Lock Date was provided. Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing.
   
Reviewer Comment (2019-07-02): Received rate lock
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Notice of Special Flood Hazard Disclosure Not Provided Timely
FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.
There is no evidence that the Notice of Special Flood Hazard Disclosure was provided to the applicant.
   
Reviewer Comment (2019-07-03): Client elects to waive.
 
 
Reviewer Comment (2019-07-02): Flood cert is dated XXXXX and disclosure was provided to borrower on XXXXX, which is 5 days prior to closing.  XXXXX
 
 
Seller Comment (2019-07-02): uploaded
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
There is no evidence that the Loan Originator Compensation disclosure was provided to the applicant.
   
Reviewer Comment (2019-07-03): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
General Ability To Repay Provision Employment - W-2
Ability to Repay (Dodd-Frank 2014): Unable to verify current Wages/W-2 employment status using reasonably reliable third-party records.
Missing XXXXX (XXXXX), XXXXX (XXXXX), Paystubs (XXXXX), Transcripts (XXXXX), Transcripts (XXXXX), VVOE - Employment Only, W-2 (XXXXX), W-2 (XXXXX).
   
Reviewer Comment (2019-07-02): Received income documentation including paystubs, previous 2 years W2's, VVOE & WVOE
 
 
Seller Comment (2019-07-02): W2 uploaded to prior conditions
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
General Ability To Repay Provision Employment - W-2
Ability to Repay (Dodd-Frank 2014): Unable to verify current Wages/W-2 employment status using reasonably reliable third-party records.
Missing XXXXX (XXXXX), XXXXX (XXXXX), Paystubs (XXXXX), Transcripts (XXXXX), Transcripts (XXXXX), VVOE - Employment Only, W-2 (XXXXX), W-2 (XXXXX).
   
Reviewer Comment (2019-07-02): Received income documentation including paystubs, previous 2 years W2's, VVOE & WVOE
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
General Ability To Repay Provision Income and Assets - Wages
Ability to Repay (Dodd-Frank 2014): Unable to verify Wages/W-2 income using reasonably reliable third-party records.
Missing XXXXX (XXXXX), XXXXX (XXXXX), Paystubs (XXXXX), Transcripts (XXXXX), Transcripts (XXXXX), VVOE - Employment Only, W-2 (XXXXX), W-2 (XXXXX).
   
Reviewer Comment (2019-07-02): Received income documentation including paystubs, previous 2 years W2's, VVOE & WVOE
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
General Ability To Repay Provision Income and Assets - Wages
Ability to Repay (Dodd-Frank 2014): Unable to verify Wages/W-2 income using reasonably reliable third-party records.
Missing XXXXX (XXXXX), XXXXX (XXXXX), Paystubs (XXXXX), Transcripts (XXXXX), Transcripts (XXXXX), VVOE - Employment Only, W-2 (XXXXX), W-2 (XXXXX).
   
Reviewer Comment (2019-07-02): Received income documentation including paystubs, previous 2 years W2's, VVOE & WVOE
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of ATR Fail.
Missing XXXXX (XXXXX), XXXXX (XXXXX), Paystubs (XXXXX), Transcripts (XXXXX), Transcripts (XXXXX), VVOE - Employment Only, W-2 (XXXXX), W-2 (XXXXX).
   
Reviewer Comment (2019-07-05): The lender provided evidence of a three year history of bonus income
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Servicing Disclosure Status
File does not evidence the consumer was provided with the Servicing Disclosure.
There is no evidence that the Servicing Disclosure was provided to the applicant.
   
Reviewer Comment (2019-07-03): Client elects to waive.
 
 
Reviewer Comment (2019-07-02): Please provide copy of LE or disclosure as no LE's evidenced in loan file.
 
 
Seller Comment (2019-07-02): XXXXX of the LE states that we intend to transfer the servicing of the loan file
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Good faith redisclosure
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
RESPA Disclosure - List of Homeownership Counseling Organizations Missing
RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower.
There is no evidence that the List of Homeownership Counseling Organizations was provided to the applicant.
   
Reviewer Comment (2019-07-03): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Home Loan Toolkit Provided
Truth in Lending Act XXXX: Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.
There is no evidence that the XXXXX was provided to the applicant.
   
Reviewer Comment (2019-07-03): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
No Defined Cure
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Closing Disclosure Timing without Waiver
TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.
Only final CD is provided in the file. There is no evidence that the initial Closing Disclosure was provided to the Borrower(s) at least three (3) business days prior to closing.
   
Reviewer Comment (2019-07-03): Received proof of receipt
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
No Defined Cure
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File
TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to XXXXX may be required.
Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).
   
Reviewer Comment (2019-07-03): Received loan estimate
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
No Defined Cure
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Seller Closing Disclosure
TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.
Missing
   
Reviewer Comment (2019-07-03): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
XXXXX 2Yr Calc
Qualified Mortgage (Dodd-Frank 2014): Use of Overtime/Bonus income for less than two (2) years not justified or documented in writing.
File is missing breakdown of bonus income for the last 2 years from employer for Borrower as required per Appendix Q.  WVOE in file only contains ytd bonus amount.
   
Reviewer Comment (2019-07-05): Provided
 
 
Seller Comment (2019-07-05): WVOE with last two years bonus uploaded
 
 
Reviewer Comment (2019-07-03): File is missing breakdown of bonus income for the last 2 years from employer for Borrower as required per Appendix Q.  WVOE in file only contains ytd bonus amount.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
XXXXX Declining
Qualified Mortgage (Dodd-Frank 2014): Use of continual decline in income for Overtime/Bonus not justified or documented.
File is missing breakdown of bonus income for the last 2 years from employer for Borrower as required per Appendix Q.  WVOE in file only contains ytd bonus amount.
   
Reviewer Comment (2019-07-05): The lender provided evidence of a three year history of bonus income
 
 
Reviewer Comment (2019-07-03): File is missing breakdown of bonus income for the last 2 years from employer for Borrower as required per Appendix Q.  WVOE in file only contains ytd bonus amount.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
XXXXX Method of Calculation
Qualified Mortgage (Dodd-Frank 2014): Significant income variation requires a period of more than two (2) years when calculating the average Overtime/Bonus income.
File is missing breakdown of bonus income for the last 2 years from employer for Borrower as required per Appendix Q.  WVOE in file only contains ytd bonus amount.
   
Reviewer Comment (2019-07-05): The lender provided evidence of a three year history of bonus income
 
 
Reviewer Comment (2019-07-03): File is missing breakdown of bonus income for the last 2 years from employer for Borrower as required per Appendix Q.  WVOE in file only contains ytd bonus amount.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM Employment History - Current Employment Documentation lacks Date Info
Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two years current employment.
The file is missing documentation to verify the start and end dates for the borrower's prior employment to verify a 2 year employment history, as required by Appendix Q.
   
Reviewer Comment (2019-07-02): Received income documentation including paystubs, previous 2 years W2's, VVOE & WVOE
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM Employment History - Current Employment Documentation lacks Date Info
Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two years current employment.
The file is missing documentation to verify the start and end dates for the co-borrower's prior employment to verify a 2 year employment history, as required by Appendix Q.
   
Reviewer Comment (2019-07-02): Received income documentation including paystubs, previous 2 years W2's, VVOE & WVOE
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Asset
Asset Documentation
Guideline Issue:Insufficient asset documentation.
-
Missing bank statements. Documentation for a VOD consists of account statements for the most recent two (2) months.
   
Reviewer Comment (2019-07-02): Received 2 months verified assets totaling XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Provided Prior to Date Performed
ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.
Appraisal was provided on XXXXX, prior to report date of XXXXX
   
Reviewer Comment (2019-07-03): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
Cure provided at closing
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Final CD evidences Cure
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Verification Of Employment Fee.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
         
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Final CD evidences Cure
C
A
C
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-07-05): Desk review provided.
 
 
Reviewer Comment (2019-07-03): Please provide XXXXX  once received
 
 
Seller Comment (2019-07-03): XXXXX to provide XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
A
C
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
A copy of Income Verification Report is not on file.
 
Per the borrower pay stub there is base, bonus, profit sharing and commissions earned. The file is missing a written VVOE showing the income sources as the lender placed all income under Bonus.
   
Reviewer Comment (2019-07-03): Per Appendix Q the borrower income sources of commission and bonus were both met and used a 2 year average regardless of source listed on the pay stub. The pay stub does not reflect any RSU income source to cause alert.
 
 
Seller Comment (2019-07-03): Income calculation uploaded
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
A
C
A
A
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Insurance
Insurance Analysis
Insufficient Coverage: Hazard insurance coverage amount is insufficient.
 
HOI coverage is insufficient by XXXXX.  Provide updated policy reflecting minimum coverage of XXXXX or evidence of the replacement cost estimator or a letter from the Insurer stating the maximum allowable coverage.
   
Reviewer Comment (2019-07-03): Received insurer's replacement cost estimate.  Coverage is sufficient.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM Employment History - Current and/or Previous Employment Documentation lacks Date Info
Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two years employment history for current and/or prior employment.
Documentation supporting Borrowers prior employment history was not supported with a third party verification supporting start and end date.
   
Reviewer Comment (2019-07-03): Client elects to waive.
 
 
Reviewer Comment (2019-07-03): Still missing VOE from XXXXX.  In addition, borrower has XXXXX that is not addressed.
 
 
Seller Comment (2019-07-02): WVOE uploaded for 2 years employment
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Guideline Requirement: Investor qualifying total debt ratio discrepancy.
Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.
Per guidelines, max DTI for a loan with LTV XXXXX.  The lender's calculation of rental income from XXXXX excluded the Total Expenses reflected on the returns resulting in a higher amount of rental income than calculated in Clarity.
FICO, Reserves
Aggregator
Reviewer Comment (2019-07-03): Client elects to waive
 
 
Seller Comment (2019-07-02): Requested a DTI exception from XXXXX
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
Per guidelines, two (2) Appraisals required for all loans > XXXXX. The subject loan is for XXXXX.
   
Reviewer Comment (2019-07-05): Desk Review provided.
 
 
Reviewer Comment (2019-07-03): Please provide XXXXX  once received.
 
 
Seller Comment (2019-07-02): XXXXX to order XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Esign Consent Agreement Status
ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to XXXXX and disclosure timing violations.
No consent for electronic delivery found in the loan images.
   
Reviewer Comment (2019-07-03): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
No Defined Cure
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
Lender credit violation
   
Reviewer Comment (2019-07-03): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Lender Credit Tolerance Violation
TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of XXXXX  is less than amount of binding Lender Credit previously disclosed in the amount of XXXXX.
Fee was disclosed on initial LE, however initial CD disclosure was sent electronically and no evidence of consent was located in file rendering disclosure invalid for baseline testing.  No valid COC was provided for addition of fee after, and no evidence of cure was located in file.
   
Reviewer Comment (2019-07-05): .
 
 
Reviewer Comment (2019-07-05): XXXXX received COC indicating loan amount change. Exception Cleared.
 
 
Seller Comment (2019-07-03): COC uploaded
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
Fee disclosed as XXXXX on LE dated XXXXX, but disclosed as XXXXX on Final Closing Disclosure.The cure provided at closing was sufficient to address this fee increase, however, not all of the tolerance violations are addressed.
   
Reviewer Comment (2019-07-03): Exception has already been cured.
 
 
Seller Comment (2019-07-02): CD has a cure for legal limit of XXXXX which is the increase of the appraisal fee
 
 
Reviewer Comment (2019-07-01): The lender provided a cure at closing for XXXXX
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
Fee disclosed as XXXXX on LE dated XXXXX, but disclosed as XXXXX on Final Closing Disclosure.The cure provided at closing was sufficient to address this fee increase, however, not all of the tolerance violations are addressed.
   
Reviewer Comment (2019-07-01): The lender provided a cure to the borrower at closing for XXXXX
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Seller Closing Disclosure
TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.
The Seller Closing Disclosure related to the purchase transaction was not provided for review.
   
Reviewer Comment (2019-07-03): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-08-05): received per client
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Sole Proprietorship Income Documentation Test
Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Sole Proprietorship).
Missing XXXXX YTD P&L for co-borrower's XXXXX.
   
Reviewer Comment (2019-08-29): The XXXXX and cost sheet were provided for this business and the lower income was used to qualify.
 
 
Reviewer Comment (2019-08-14): Loan reviewed as a manual underwrite to lender guidelines and to QM requirements per client direction. Exception remains.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
Firing due to missing income documentation for co borrower.
   
Reviewer Comment (2019-08-29): The XXXXX and cost sheet were provided for this business and the lower income was used to qualify.
 
 
Reviewer Comment (2019-08-14): Loan reviewed as a manual underwrite to lender guidelines and to QM requirements per client direction. Exception remains.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Summaries Of Transactions - Cash From To Borrower
TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on XXXXX disclosed an Amount of Cash to Close that does not match the Final value of Cash to Close in the Calculating Cash to Close table.
Cash to Close on XXXXX, is inaccurate and does not match cash to close on XXXXX.  Corrected on post closing document.
   
Reviewer Comment (2019-08-01): PCCD provided with correct cash to close on XXXXX
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
This exception is due to open XXXXX tolerance exceptions and will be cured when all tolerance violations are resolved
   
Reviewer Comment (2019-08-06): Letter of Explanation & Corrected Closing Disclosur provided.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Approval not provided
 
XXXXX is not signed by an underwriter.
   
Reviewer Comment (2019-08-22): signed XXXXX provided to support approval
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
A cure provided on PCCD on XXXXX for XXXXX
   
Reviewer Comment (2019-08-01): PCCD, LOE and a copy of the check provided.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Asset
Asset Documentation
Guideline Issue: Insufficient asset documentation.
-
Guidelines require: Full Asset Documentation is required for both funds to close and reserves. For most asset types, this would include all pages of the most
recent two months statements or the most recent quarterly statement. Borrower only provided 1 month  XXXXX
   
Reviewer Comment (2019-08-22): Per AUS the total funds required to be verified are XXXXX and no reserves required. The removal of this asset does not affect the loan approval.
 
 
Reviewer Comment (2019-08-14): Loan reviewed as a manual underwrite to lender guidelines and to QM requirements per client direction. Exception remains.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self Employed Financial Strength
Qualified Mortgage (Dodd-Frank 2014): Financial strength of self-employed business reflects annual earnings that significantly decline over the analysis period.
Co-borrowers XXXXX from XXXXX to XXXXX in XXXXX, a XXXXX.
   
Reviewer Comment (2019-08-29): The XXXXX and cost sheet were provided for this business and the lower income was used to qualify.
 
 
Reviewer Comment (2019-08-14): Loan reviewed as a manual underwrite to lender guidelines and to QM requirements per client direction. Exception remains.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - SubEscrow Fee.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
Title-Sub Escrow Fee was not disclosed on the initial LE but on the final CD reads XXXXX. It appears the borrower was not notified of this additional fee after LE was disclosed. Missing valid change in circumstance. To cure, provided corrected PC CD along with LOE to borrower and evidence of deliver.
   
Reviewer Comment (2019-08-06): XXXXX received an attestation for Title - SubEscrow fee was a required fee by Borrower's chosen provider.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-08-16): A secondary valuation was provided with 0% variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Sufficient or excess cure was provided to the borrower.
Cured after closing
   
Reviewer Comment (2019-08-06): Cured on PCCD dated XXXXX with LOE and copy of check.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-08-26): Received
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
B
A
C
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Closing Disclosure Timing without Waiver
TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.
Missing evidence of receipt of appraisal
   
Reviewer Comment (2019-08-05): Disclosure tracking details provided confirms receipt of the Initial CD
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
No Defined Cure
C
A
B
A
C
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-08-29): Secondary valuation provided with XXXXX variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
B
A
C
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Missing Secondary Valuation.
       
Reviewer Comment (2019-08-30): Desk review received. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
B
A
C
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Closing date disclosed as XXXXX.  Documents were signed XXXXX.
   
Reviewer Comment (2019-07-09): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date
Truth in Lending Act:  Subject loan transaction disbursed on XXXXX, prior to three (3) business days from transaction date of XXXXX.
Subject loan Transaction disbursed on XXXXX with in the three business days of XXXXX. The earliest disbursement date should have been XXXXX
   
Reviewer Comment (2019-07-22): The lender provided from title a final closing statement with the correct disbursement date along with an LOE and evidence of receipt to the borrower
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of XXXXX exceeds tolerance of XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
Cure provided at closing.
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Final CD evidences Cure
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Insurance
Insurance Analysis
Insufficient Coverage: Hazard insurance coverage amount is insufficient.
 
Replacement Cost Estimator was not provided at the time of audit review.
   
Reviewer Comment (2019-07-24): verified replacement cost
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
B
C
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-07-17): Desk Review provided with 0% variance.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
B
C
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Homeowner's Insurance Premium Months
TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXX did not disclose number of months for homeowner's insurance under Prepaids.
Consumer(s) Final CD disclosed Zero for the number of months collected at the time of consummation.
   
Reviewer Comment (2019-07-09): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Prepaid Property Tax Months
TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXX did not disclose number of months for Property Tax under Prepaids.
Consumer(s) Final CD disclosed Zero for the number of months collected at the time of consummation.
   
Reviewer Comment (2019-07-09): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.
       
Reviewer Comment (2019-07-25): Exterior inspection shows no damage
 
 
Reviewer Comment (2019-07-22): AUS provided a PIW which did not require any inspection of the property. Once the secondary product is available this will be reviewed.
 
 
Seller Comment (2019-07-19): can you tell me the disaster  you need it for,  I haven't found anything in Orange county since XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
C
C
A
B
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date
TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXX received on or after the date the Closing Disclosure XXXXX was received.
Supporting documentation was not provided to verify delivery/receipt of disclosure at the time of audit review.
   
Reviewer Comment (2019-07-09): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
No Defined Cure
C
C
C
A
B
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Consumer(s) Final CD disclosed Closing Date of XXXXX, however consummation took place on XXXXX.
   
Reviewer Comment (2019-07-09): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Homeowner's Insurance Premium Months
TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXX did not disclose number of months for homeowner's insurance under Prepaids.
Consumer(s) Final CD did not disclose the number of months collected at the time of consummation.
   
Reviewer Comment (2019-07-09): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date
Truth in Lending Act:  Subject loan transaction disbursed on XXXXX, prior to three (3) business days from transaction date of XXXXX.
Expiration date on ROR was XXXXX.  Eligible funding date is XXXXX
   
Reviewer Comment (2019-07-22): The lender provided a signed closing statement with the correct disbursement date along with an LOE and evidence sent to the borrower
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
CU score is XXXXX
   
Reviewer Comment (2019-07-17): Desk Review provided with 0% variance.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
 
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation
ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.
Missing evidence when appraisal provided to borrowers.
   
Reviewer Comment (2019-07-09): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
 
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-07-17): Desk Review provided with 0% variance.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
A
A
A
A
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-07-17): Desk Review provided with 0% variance.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
A
A
A
A
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-07-17): Desk Review provided with 0% variance.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided onXXXXX disclosed a Closing Date that did not match the actual date of consummation.
Final CD issued XXXXX, closing date of XXXXX and signed XXXXX, Security instrument notarized XXXXX.
   
Reviewer Comment (2019-07-09): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-07-17): Desk Review provided with 0% variance.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
The acknowledgement of receipt of appraisal is dated XXXXX
   
Reviewer Comment (2019-07-09): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
The Security Instrument/Deed of Trust disclosed a Notary Date of XXXXX;
   
Reviewer Comment (2019-07-09): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Insurance
Insurance Analysis
Insufficient Coverage: Hazard insurance coverage amount is insufficient.
 
Replacement Cost Estimate was not provided;
   
Reviewer Comment (2019-07-25): Provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Closing Disclosure Timing without Waiver
TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.
Initial CD provided on XXXXX and signature date on final CD XXXXX
   
Reviewer Comment (2019-07-24): The PCCD corrected the closing date to XXXXX which is more than 3 days from the Initial CD
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
No Defined Cure
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Post Close Closing Disclosure Finance Charge
TILA-RESPA Integrated Disclosure - Post Closing Disclosure:  Finance Charge of XXXXX disclosed on the Final Closing Disclosure dated XXXXX is under-disclosed by more than XXXXX compared to the Financed Charge calculated based on fees disclosed on the Post Closing Disclosure of XXXXX provided on XXXXX, a difference of XXXXX
XXXXX increased on the Post Closing Disclosure causing finance charges on Final CD dated XXXXX to be under disclosed.
Remediation includes Letter of Explanation, Refund check for under disclosed equivalent amount, Reopened Rescission, updated CD and proof of delivery.
   
Reviewer Comment (2019-07-24): The lender provided an updated CD correcting the TOP and Finance charges
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected CD, and Re-open Rescission if Applicable
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Post Close Closing Disclosure Total Of Payments Test Non-Rescindable Transactions
TILA-RESPA Integrated Disclosure - Post Closing Disclosure:  Total of Payments of XXXXX disclosed on the Final Closing Disclosure dated XXXXX is inaccurate by more than XXXXX compared to the Total of Payments calculated based on fees disclosed on the Post Closing Disclosure of XXXXX  provided on XXXXX, a difference of XXXXX.
Borrower paid charges in XXXXX increased on the Post Closing Disclosure causing the Total of Payments on the Final CD dated XXXXX to be under disclosed. Remediation includes Letter of Explanation, Refund check for under disclosed equivalent amount, Reopened Rescission, updated CD and proof of delivery.
   
Reviewer Comment (2019-07-24): The lender provided an updated CD correcting the TOP and Finance charges
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected CD, and Re-open Rescission if Applicable
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Final CD disclosed a Closing Date of XXXXX, however, the actual date of consummation is XXXXX per Security Instrument.
   
Reviewer Comment (2019-07-09): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien
TRID Final Closing Disclosure XXXXX on a first lien purchase transaction did not disclose any Seller paid fees/charges on XXXXX. (Points and Fees testing limited to Borrower paid fees.)
Final CD did not disclose any seller paid fees, however, this was cured with the Post Close CD provided.
   
Reviewer Comment (2019-07-24): PCCD dated XXXXX lists all seller paid fees
 
 
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Miscellaneous Compliance
Other Compliance Exception (Manual Add)
 
The PCCD to the borrower listed a total funds to close as XXXXX however the CD dated XXXXX used to close listed funds required of XXXXX. There was no evidence of either a principle reduction or refund to the borrower for the overage paid in the amount of XXXXX
   
Reviewer Comment (2019-07-25): Master final settlement statement figures match the PCCD.
 
 
Seller Comment (2019-07-25): The funds to close on the PCCD match with the final settlement statement at disbursement.  Washington is a dry funding state so the closing costs can change after the borrower has signed.  The cash to close on the PCCD matches with the settlement agent's disbursement so that is evidence of what the borrower was actually charged (cash to closeXXXXX due to borrower, so no cure is required
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
The file only contains one appraisal report when two are required for securitization.
   
Reviewer Comment (2019-07-15): Desk review provided with no variance. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
     
Reviewer Comment (2019-07-09): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX9 disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
The seller's CD reflects total closing costs of XXXXX whereas the Borrowers' CD reflects total closing costs of XXXXX
   
Reviewer Comment (2019-07-09): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Closing Disclosure Timing without Waiver
TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.
The initial CD was provided to the Borrowers' on XXXXX.
   
Reviewer Comment (2019-07-17): XXXXX received disclosure tracking indicating the CD was received 06/17. Exception Cleared.
 
 
Seller Comment (2019-07-16): DocuSign shows viewed XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
No Defined Cure
C
B
A
A
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
The appraisal fee exceeds the zero percent tolerance and no cure was provided.
   
Reviewer Comment (2019-07-08): lender provided a cure credit at closing
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
 
Pending Internal Customer Final Collateral Package Review.
   
Reviewer Comment (2019-08-15): Received
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
B
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
There's no evidence of a secondary valuation as required for securitization.
   
Reviewer Comment (2019-09-03): Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
B
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Partnership Income Documentation Test
Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Partnership).
There's no evidence of most recent YTD quarterly P&L Statement for borrower's self-employment XXXXX. Only cover page in the file.
   
Reviewer Comment (2019-08-21): Signed YTD P&L provided, exception cleared.
 
 
Seller Comment (2019-08-20): Please advise if doc submitted has been reviewed and provide update
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
B
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Partnership Income Documentation Test
Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Partnership).
There's no evidence of most recent YTD quarterly P&L Statement for borrower's self-employment XXXXX. Only cover page in the file.
   
Reviewer Comment (2019-08-21): Signed P&L provided in trailing docs, exception cleared.
 
 
Seller Comment (2019-08-20): Please advise if doc submitted has been reviewed and provide update
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
B
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
Updated Appraisal was provided on XXXXX less than 3 days prior to closing of XXXXX
   
Reviewer Comment (2019-08-20): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
B
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Closing Disclosure Lump Sum Allocation
Lump sum lender/seller credit disclosed on Closing Disclosure applied to offset non-finance charge closing costs in XXXXX, then finance charges pursuant to client's election.
Lump sum lender/seller credit disclosed on Closing Disclosure applied to offset non-finance charge closing costs in XXXXX first, then finance charges pursuant to client's election.
   
Reviewer Comment (2019-08-20): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
B
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
Designation is not a match due to missing income documents for the borrower's self-employment business. XXXXX.
   
Reviewer Comment (2019-08-21): Trailing docs provided YTD financials, exception cleared.
 
 
Seller Comment (2019-08-20): Please advise if doc submitted has been reviewed and provide update
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
C
B
B
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
Appraisal fee increase no valid CC on file, there's no cure in the file for change in closing costs.
   
Reviewer Comment (2019-08-20): Clients elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
B
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
There's a XXXXX for the appraisal costs that changed from the initial LE to Final CD without a cure in the loan file.
   
Reviewer Comment (2019-08-29): PCCD, LOE, Principal reduction completed.  See new exception for cure.
 
 
Reviewer Comment (2019-08-16): Initial LE dated XXXXX disclosed appraisal fee at XXXXX, this is the baseline document.
 
 
Seller Comment (2019-08-15): please advise document used for violation, initial LE discloses XXXXX for appraisal
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
B
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Sufficient or excess cure was provided to the borrower.
PCCD, LOE, Principal reduction completed.
   
Reviewer Comment (2019-08-29): PCCD, LOE, Principal reduction completed.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
 
C
B
B
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
The borrowers signed the final CD on XXXXX
   
Reviewer Comment (2019-07-15): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Seller Closing Disclosure
TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.
Not provided.
   
Reviewer Comment (2019-07-15): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
State Compliance
Colorado Home Loan (Ability to Repay not Verified)
XXXXX:  File does not contain evidence that broker performed an analysis of borrower's ability to repay based on verified income, obligations, assets, and/or employment.
     
Reviewer Comment (2019-07-15): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Property - Appraisal
Appraisal Documentation
Missing Document: Appraisal was made "subject to" and Form 1004D/442 was not provided.
-
     
Reviewer Comment (2019-07-17): Provided
 
 
Seller Comment (2019-07-15): XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
Safe Harbor QM is the expected result.
   
Reviewer Comment (2019-07-17): Lender provided the discount rate sheet
 
 
Seller Comment (2019-07-15): Bona Fide
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM Points and Fees
Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of XXXXX is in excess of the allowable maximum of  XXXXX of the Federal Total Loan Amount. Points and Fees total XXXXX on a Federal Total Loan Amount of XXXXX vs. an allowable total of XXXXX (an overage of XXXXX.
Total of points and XXXXX exceeds the threshold to pass the QM Points & Fees test XXXXX
   
Reviewer Comment (2019-07-17): Lender provided the discount rate sheet
 
 
Seller Comment (2019-07-15): Bona Fide
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
If a creditor or assignee determines after consummation that the total points and fees exceeds the QM Points and Fees limit, but the loan meets the other requirements to be a QM, the QM Points and Fees exception can be cured through a refund including interest at the contract rate from consummation to the date of cure, with the following conditions:
1)      Refund is made within 210 days of consummation;
2)      The consumer has not instituted any actions against the creditor or provided written notice that the loan's fees exceeded the legal limit;
3)      The loan is not 60 days delinquent;
4)      The creditor or assignee (depending who is curing) has policies in place to identify and cure excessive fees collected from the consumer (the creditor or assignee can only take advantage of this cure provision if they maintain policies and procedures for post-consummation review of points and fees and for providing the cure payments); and
5)      The loan was closed on or before January 10, 2021;
 
Documents Required to Cure
1)      Letter of Explanation
2)      Copy of Refund Check (in the amount of overage plus interest)
3)      Proof of Delivery
4)      Lender/Seller Attestation indicating:
        a)      The consumer has not instituted any actions against the creditor or provided written notice that the loan's fees exceeded the legal limit;
        b)      The loan is not 60 days delinquent; and
        c)      The creditor or assignee (depending who is curing) has policies in place to identify and cure excessive fees collected from the consumer
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
The final Closing Disclosure reflects a Closing Date of XXXXX, but the transaction consummation mortgage notary date was XXXXX.  Provide a post-close CD and a copy of the letter of explanation to the borrower disclosing the changes made.
   
Reviewer Comment (2019-07-15): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Loan Estimate Timing Electronically Provided
TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.
     
Reviewer Comment (2019-07-15): Initial LE issued on XXXXX, mailbox rule applied.
 
 
Seller Comment (2019-07-13): disclosure tracking
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Loan Estimate Esign Consent Agreement Timing
ESIGN Act - Loan Estimate provided on XXXXX was electronically provided prior to borrower's consent to receive electronic disclosures.  Disclosure will not be used to rebaseline for tolerance purposes and may result in disclosure timing violations.
Borrower did not provide consent until XXXXX.  The initial disclosures were sent electronically on XXXXX.
   
Reviewer Comment (2019-07-15): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
No Defined Cure
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-07-18): Desk Review provided with 0% variance.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
Due to failing QM points and fees
   
Reviewer Comment (2019-07-22): Bona Fide worksheet provided. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM Points and Fees
Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of XXXXX is in excess of the allowable maximum of  XXXXX of the Federal Total Loan Amount. Points and Fees total XXXXX on a Federal Total Loan Amount of XXXXX vs. an allowable total of XXXXX.
Per Final CD reflects XXXXX Broker compensation and XXXXX loan points.  Compliance report passed the points and fees testing.
   
Reviewer Comment (2019-07-22): Bona Fide worksheet provided. Exception cleared.
 
 
Seller Comment (2019-07-18): escalating to XXXXX as no response on this from XXXXX upload, almost a week ago.
 
 
Seller Comment (2019-07-17): Please advise why this condition has not been reviewed or cleared.  The QM worksheet for bona fide points shows XXXXX in EXCLUDABLE point which XXXXX the loan into tolerance level for points and fees.  Please advise today
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
If a creditor or assignee determines after consummation that the total points and fees exceeds the QM Points and Fees limit, but the loan meets the other requirements to be a QM, the QM Points and Fees exception can be cured through a refund including interest at the contract rate from consummation to the date of cure, with the following conditions:
1)      Refund is made within 210 days of consummation;
2)      The consumer has not instituted any actions against the creditor or provided written notice that the loan's fees exceeded the legal limit;
3)      The loan is not 60 days delinquent;
4)      The creditor or assignee (depending who is curing) has policies in place to identify and cure excessive fees collected from the consumer (the creditor or assignee can only take advantage of this cure provision if they maintain policies and procedures for post-consummation review of points and fees and for providing the cure payments); and
5)      The loan was closed on or before January 10, 2021;
 
Documents Required to Cure
1)      Letter of Explanation
2)      Copy of Refund Check (in the amount of overage plus interest)
3)      Proof of Delivery
4)      Lender/Seller Attestation indicating:
        a)      The consumer has not instituted any actions against the creditor or provided written notice that the loan's fees exceeded the legal limit;
        b)      The loan is not 60 days delinquent; and
        c)      The creditor or assignee (depending who is curing) has policies in place to identify and cure excessive fees collected from the consumer
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Per Final CD reflects closing date XXXXX, signing date XXXXX
   
Reviewer Comment (2019-07-15): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-07-23): Provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Provided Prior to Date Performed
ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.
     
Reviewer Comment (2019-07-17): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID XXXXX Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: XXXXX Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
Per Final CD reflects Appraisal fee XXXXX in file.
   
Reviewer Comment (2019-07-09): Cure provided at closing
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID XXXXX Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: XXXXX Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
         
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Final CD evidences Cure
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
Loan Originator Compensation (XXXXX) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
Disclosure not found in the file.
   
Reviewer Comment (2019-07-15): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Notary date is XXXXX.
   
Reviewer Comment (2019-07-15): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
Did not disclose the legal limit was exceeded
   
Reviewer Comment (2019-07-12): XXXXX received required documents, exception is cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID XXXXX Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: XXXXX Fee Tolerance exceeded for Appraisal Desk Review Fee.  Fee Amount of XXXXX.  Insufficient or no cure was provided to the borrower.
A valid COC not found.  A cure was not provided
   
Reviewer Comment (2019-07-12): XXXXX received required documents, exception is cleared.
 
 
Seller Comment (2019-07-11): Please see attached COC.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
No amount was disclosed on the Final CD;
   
Reviewer Comment (2019-07-15): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID XXXXX Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: XXXXX Fee Tolerance exceeded for Transfer Tax.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
Proof that a sufficient cure was provided to the Borrower not found in file. Transfer taxes were apportioned between the buyer, seller, and the lender;
   
Reviewer Comment (2019-07-17): The transfer tax is a fee typically split by borrower and lender. The overage is the lender paid XXXXX and the seller paid of XXXXX
 
 
Reviewer Comment (2019-07-15): Our client has elected to include fees paid by the consumer, seller and third parties in tolerance testing.  XXXXX is unable to address the exception at this time. A PCCD, LOE, copy of any refund check and proof of delivery is required in order to address the exception.
 
 
Seller Comment (2019-07-12): where are you getting these figures and where are you seeing the fees split 3 ways?  Final CD shows exactly how fees were completed and the combined fee isn't XXXXX.  Where does this figure come from? what are you including specifically?  please provide specific figures and where they are found to calculate out to XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-08-26): Received
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
B
A
B
A
A
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID XXXXX Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: XXXXX Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
XXXXX Fee Tolerance exceeded for Collateral Desktop Analysis. Fee Amount of XXXXX exceeds tolerance of XXXXX.
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Final CD evidences Cure
B
A
B
A
A
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-08-26): Received
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Closing Disclosure Timing without Waiver
TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.
Evidence of Borrowers' earlier receipt is missing from subject file.
   
Reviewer Comment (2019-08-16): Disclosure summary provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
No Defined Cure
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Closing Disclosure Lump Sum Allocation
Lump sum lender/seller credit disclosed on Closing Disclosure applied to offset non-finance charge closing costs in XXXXX first, then finance charges pursuant to client's election.
The Lender Credit was not itemized in subject file; specific client instructions did not address lump sum Lender credits.
   
Reviewer Comment (2019-08-20): Clients elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Guideline Requirement: PITIA reserves months discrepancy.
 
Guidelines require XXXXX plus additional XXXXX.
   
Reviewer Comment (2019-08-28): Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
The final CD disclosed an issue date and closing date of XXXXX and a disbursement date of XXXXX.  The information disclosed on the closing disclosure matches the note date of XXXXX.
   
Reviewer Comment (2019-07-08): XXXXX received PCCD however the close date still reflects XXXXX.  The security instrument indicates the consummation date if XXXXX. Please provide corrected CD and LOE to cure.
 
 
Buyer Comment (2019-07-08): Please review PCCD
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
B
B
B
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Payment Shock exceeds credit guidelines.
Payment Shock: ___
Payment shock maximum is XXXXX. UW exception was not provided.
XXXXX rating reported to bureaus
 
XXXXX months reserves XXXXX months guideline minimum
 
XXXXX representative FICO score XXXXX guideline minimum
Originator
 
Originator
 
Originator
Reviewer Comment (2019-07-08): CRE provided for XXXXX payment shock > XXXXX maximum
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
B
B
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is missing secondary valuation product required for securitization.
       
Reviewer Comment (2019-07-08): XXXXX provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
B
B
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Credit Exception:
 
Second appraisal was not provided.. XXXXX a borrower paid second appraisal must be obtained.
XXXXX rating reported to bureaus
 
XXXXX months reserves XXXXX months guideline minimum
 
XXXXX representative FICO score XXXXX guideline minimum
Originator
 
Originator
 
Originator
Reviewer Comment (2019-07-08): Exception approval for use of XXXXX in lieu of full appraisal
 
 
Reviewer Comment (2019-07-08): Approved XXXXX loan amount, XXXXX LTV, under EG Portfolio (Jumbo Prime Guidelines and Matrix), loan amounts XXXXX: a borrower paid second appraisal must be obtained.  Issue remains XXXXX for second full appraisal report or a signed CRE with verified compensating factors for missing full second appraisal report required at approved XXXXX loan amount.  XXXXX provided XXXXX in lieu of full appraisal
 
 
Reviewer Comment (2019-07-08): Approved XXXXX loan amount, XXXXX LTV, under EG Portfolio (Jumbo Prime Guidelines and Matrix), loan amounts XXXXX with LTV XXXXX: a borrower paid second appraisal must be obtained.  Issue remains XXXXX for second full appraisal report or a signed CRE with verified compensating factors for missing full second appraisal report required at approved XXXXX loan amount.  XXXXX provided XXXXX in lieu of full appraisal
 
 
Buyer Comment (2019-07-08): Please waive
 
 
Buyer Comment (2019-07-08): A second appraisal is not required…that is for platinum/port select.  Our loan amount is less than XXXXX.  Here are the jumbo guidelines regarding 2nd appraisals:
 
-XXXXX Appraisal Review
- The Appraisal Review Process requires a secondary appraisal product to support the appraisal value for the transaction.
- Acceptable review products include AVM's, enhanced desk reviews, field reviews, and second full appraisals.
- Existing policies should continue to be followed for guidance on ordering discretionary appraisal review products if there are concerns with the original appraisal report.
- The following transactions must adhere to the Appraisal Review Process:
XXXXX
XXXXX
 
 
Reviewer Comment (2019-07-08): XXXXX, received a signed CRE with verified compensating factors on XXXXX.  CRE did not indicate that exception was approved for "missing full second appraisal report required at approved XXXXX loan amount.  XXXXX provided in lieu of full appraisal".
 
 
Buyer Comment (2019-07-08): CRE with signature line complete.
Is this sufficient to downgrade condition to a XXXXX
 
 
Reviewer Comment (2019-07-08): Received a duplicate copy of XXXXX dated XXXXX in lieu of full second appraisal report required at approved XXXXX loan amount. A  CRE with verified compensating factors waiving requirement for second full appraisal report was not provided.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
B
B
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation
ECOA Valuations Rule (XXXXX): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.
Proof of delivery date of primary and secondary valuations was not provided
   
Reviewer Comment (2019-07-08): Updated input
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
B
B
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (XXXXX): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
XXXXX Business tax returns and or extension for business returns is not evident in the file.
   
Reviewer Comment (2019-07-08): XXXXX tax returns not received
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Securitization Review and the supporting secondary valuation was an AVM
       
Reviewer Comment (2019-07-08): XXXXX provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
B
A
B
A
A
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-07-08): XXXXX provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Second Home
Purchase
 
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
XXXXX
   
Reviewer Comment (2019-07-08): Letter of Explanation & Corrected Closing Disclosure provided.
 
 
Reviewer Comment (2019-07-08): Courier and XXXXX were not disclosed properly and are listed in section C, although the vendor was listed on the SSPL. A PCCD, LOE, copy of any refund check and proof of delivery required in order to address the exception.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Second Home
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID XXXXX Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of XXXXX exceeds tolerance of XXXXX plus XXXXX.  Insufficient or no cure was provided to the borrower.
Closing agent on Service Provider list.
   
Reviewer Comment (2019-07-08): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided
 
 
Reviewer Comment (2019-07-08): XXXXX received PCCD, LOE and Copy of Refund check.  XXXXX per the website - label has been created, but not yet shipped.  Proof of delivery is needed to cure.
 
 
Reviewer Comment (2019-07-08): The cure amount is XXXXX tolerance violation.
 
 
Buyer Comment (2019-07-08): please recalculate your XXXXX. you are only using the recording fees into calculations. the XXXXX threshold for title fees and recording fees are XXXXX.  anything that exceeds that threshold for title fee and recording fee is what requires the cure. We show we only owe a cure of XXXXX
 
 
Reviewer Comment (2019-07-08): Courier and POA fee were not disclosed properly and are listed in section C, although the vendor was listed on the XXXXX.  A PCCD, LOE, copy of any refund check and proof of delivery required in order to address the exception.
 
 
Buyer Comment (2019-07-08): can you please explain? I am not seeing a fee on the final cd for XXXXX.
 
thanks
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Second Home
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Borrower and Mortgage Eligibility
Mortgage / Program Eligibility
Guideline Requirement: Loan to value discrepancy.
Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___.
Second Home Purchase maximum LTV isXXXXX
XXXXX on this Full documentation loan XXXXX guideline max XXXXX below program guideline maximum
 
XXXXX representative FICO score XXXXX guideline minimum
Originator
 
Originator
Reviewer Comment (2019-07-08): CRE with compensating factors provided forXXXXX
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Second Home
Purchase
 
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID XXXXX Violation With Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of XXXXX exceeds tolerance of XXXXX plus XXXXX or XXXXX.  Sufficient or excess cure was provided to the borrower.
Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided
   
Reviewer Comment (2019-07-08): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Second Home
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
B
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (XXXXX): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
Self-employed income was not documented with the most recent tax return and the creditor application date > tax filing date
   
Reviewer Comment (2019-07-08): XXXXX tax returns not received
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
B
B
B
B
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Guideline
Guideline Issue
Borrower does not have the minimum active tradelines per guidelines.
 
Credit Risk Summary & Exception Approval in file. Tradeline requirements not met. Compensating Factors:XXXXX
XXXXX Residual Income
 
XXXXX months guideline minimum - borrowers have verified reserves of XXXXX
 
XXXXX LTV XXXXX guideline max
 
XXXXX DTI on this Full documentation loan XXXXX guideline max
Originator
 
Originator
 
Originator
 
Originator
Reviewer Comment (2019-07-08): Compensating Factors: 1) Credit History. 2) DTI. 3) LTV. 4) Reserves. 5) Residual Income.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
B
B
B
B
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Guideline Requirement: Investor qualifying total debt ratio discrepancy.
 
Lender used undocumented income from XXXXX
Guideline variance approved by lender at time of origination.XXXXX
 
Borrower has job XXXXX
Originator Pre-Close
 
Originator
Reviewer Comment (2019-07-08): updated income based on the XXXXX months of bank statements
 
 
Reviewer Comment (2019-07-08): To update
 
 
Reviewer Comment (2019-07-08): Exception approval
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Guideline Requirement: Investor qualifying housing ratio discrepancy.
 
Lender used undocumented income from XXXXX
Guideline variance approved by lender at time of origination.XXXXX
 
Borrower has job XXXXX
Originator Pre-Close
 
Originator
Reviewer Comment (2019-07-08): updated income based on the XXXXX months of bank statements
 
 
Reviewer Comment (2019-07-08): To update
 
 
Reviewer Comment (2019-07-08): Received exception approval for DTI
 
 
Reviewer Comment (2019-07-08): Borrower is refinancing solely in XXXXX name. New mortgage is now Borrower's XXXXX financial obligation by execution of Note.  XXXXX is not required to pay.
 
 
Reviewer Comment (2019-07-08): XXXXX it will remain in both parties names and since the borrower is refinancing solely in XXXXX name XXXXX is not required to pay.
 
 
Buyer Comment (2019-07-08): it is stated in XXXXX is to pay half of mortgage
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Insurance
Insurance Analysis
Insufficient Coverage: Hazard insurance coverage amount is insufficient.
 
Coverage Shortfall XXXXX
   
Reviewer Comment (2019-07-08): Replacement Cost Estimator documents XXXXX estimated reconstruction cost.  XXXXX dwelling coverage XXXXX estimated reconstruction cost
 
 
Buyer Comment (2019-07-08): the insurance agent's cost to rebuild calc.  We can't make them get more insurance than what the agent is saying it would cost to rebuild the property.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Insurance
Insurance Analysis
Hazard Insurance Policy expires within XXXXX of the Note Date.
Hazard Insurance Policy Expiration Date ___, Note Date ___
Closing Disclosure indicates renewal due XXXXX was already paid by Borrower, but no receipt from insurance agent indicating renewal paid.
   
Reviewer Comment (2019-07-08): received invoice showing payment made, monthly payments
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
S-Corp Income Documentation XXXXX
Qualified Mortgage (XXXXX): Self-employed income documentation not sufficient (S-Corp).
Business and Personal tax returns are not signed
   
Reviewer Comment (2019-07-08): Updated input returns are signed
 
 
Reviewer Comment (2019-07-08): XXXXX signed by Borrower were not provided under Prime Jumbo, subject to Appendix Q for loan/Note dated after XXXXX
 
 
Reviewer Comment (2019-07-08): Must be signed
 
 
Buyer Comment (2019-07-08): these were self-prepared and transcripts are in file
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
General Ability To Repay Provision Income and Assets - S-Corp
Ability to Repay (XXXXX): Unable to verify XXXXX income using reasonably reliable third-party records.
Business and Personal tax returns are not signed
   
Reviewer Comment (2019-07-08): XXXXX signed by Borrower were provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
General Ability To Repay Provision Investor Guidelines
Ability to Repay (XXXXX): Based on the loan failing one or more guideline components, the loan is at ATR risk.
DTI
   
Reviewer Comment (2019-07-08): Updated with exception approval for DTI
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines
Ability to Repay (XXXXX): The DTI calculated in accordance with the Lenders Guidelines and XXXXX moderately exceeds the guideline maximum of XXXXX. (DTI Exception is eligible to be regraded with compensating factors.)
DTI
Guideline variance approved by lender at time of origination.XXXXX
 
Borrower has job XXXXX
Originator Pre-Close
 
Originator
Reviewer Comment (2019-07-08): updated income based on the XXXXX months of bank statements
 
 
Reviewer Comment (2019-07-08): To update
 
 
Reviewer Comment (2019-07-08): Exception approval for DTI based on employment history, payment shock, and reserves
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
NonQM ATR
Ability-to-Repay (XXXXX): General Ability-to-Repay requirements not satisfied.
DTI
   
Reviewer Comment (2019-07-08): XXXXX signed by Borrower were provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (XXXXX): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
DTI
   
Reviewer Comment (2019-07-08): updated income based on the XXXXX months of bank statements
 
 
Reviewer Comment (2019-07-08): Updated from: Qualified Mortgage XXXXX: Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of ATR Risk.
 
 
Reviewer Comment (2019-07-08): Updated from: Qualified Mortgage XXXXX: Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of ATR Fail.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Lender to provide updated ATR/QM status
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID XXXXX Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of XXXXX exceeds tolerance of XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
         
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Final CD evidences Cure
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM DTI
Qualified Mortgage (XXXXX): Total Debt to Income Ratio exceeds XXXXX and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.
DTI
   
Reviewer Comment (2019-07-08): updated income based on the XXXXX months of bank statements
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Homeowner's Insurance Premium Months
TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.
CD XXXXX
   
Reviewer Comment (2019-07-08): Letter of Explanation & Corrected Closing Disclosure provided.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Approval not provided
 
Missing.  XXXXX in file.
   
Reviewer Comment (2019-07-08): XXXXX is sufficient.
 
 
Buyer Comment (2019-07-08): Please see attached XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
C
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
Only appraisal in file.
   
Reviewer Comment (2019-07-08): Received XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
C
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Legal / Regulatory / Compliance
Title / Lien Defect
Final Title Policy is missing. No evidence of title in file.
 
Missing final title.
   
Reviewer Comment (2019-07-08): Received Final Title.
 
 
Buyer Comment (2019-07-08): Please see attached Final Title Policy
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
C
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM Employment History
Qualified Mortgage (XXXXX): Employment history requirement not met.
Missing XXXXX from XXXXX
   
Reviewer Comment (2019-07-08): Received XXXXX
 
 
Buyer Comment (2019-07-08): LOX for Employment gap
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
C
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (XXXXX): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
Missing XXXXX from XXXXX
   
Reviewer Comment (2019-07-08): Received XXXXX
 
 
Buyer Comment (2019-07-08): Please see LOE for employment
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
C
A
C
A
C
A
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Escrowed Property Costs Year 1 -  XXXXX
TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Escrowed Property Costs over Year XXXXX on Final Closing Disclosure provided on XXXXX not accurate.
Tax cert shows XXXXX
   
Reviewer Comment (2019-07-08): Confirmed Tqx cert taxes of XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
A
C
A
C
A
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Estimated Escrow Payment
TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXX disclosed an escrow payment for XXXXX that does not match the actual payment for the loan.
Verified final CD Year 1 of escrow.
   
Reviewer Comment (2019-07-08): Confirmed Tqx cert taxes of XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable
C
A
C
A
C
A
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Estimated Total Minimum Payment Fixed Rate
TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXX disclosed an Estimated Total Monthly Payment for XXXXX that does not match the actual total payment for the loan.
Verified final CD Year 1 of escrow.
   
Reviewer Comment (2019-07-08): Confirmed Tqx cert taxes of XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable
C
A
C
A
C
A
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Closing Disclosure Timing without Waiver
TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.
Verified initial CD XXXXX.
   
Reviewer Comment (2019-07-08): disclosure tracking details provided
 
 
Buyer Comment (2019-07-08): This XXXXX is 3 days prior to closing
 
 
Buyer Comment (2019-07-08): Please see attache disc tracking showing borrowers recieved initial CD on XXXXX and esigned.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
No Defined Cure
C
A
C
A
C
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation
ECOA Valuations Rule (XXXXX): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.
Received date of closing
   
Reviewer Comment (2019-07-08): Received Disclosure Tracking. Appraisal was sent to borrower within required timing.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
C
A
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM Employment History - Current and/or Previous Employment Documentation lacks Date Info
Qualified Mortgage (XXXXX): Missing Employment Dates to verify two years employment history for current and/or prior employment.
No evidence of XXXXX documenting employment history.
   
Reviewer Comment (2019-08-20): Client elects to waive
 
 
Reviewer Comment (2019-08-06): Missing a CPA letter to verify dates on employment  fro S-Corp. Exception remains.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Closing Disclosure Lump Sum Allocation
Lump sum lender/seller credit disclosed on Closing Disclosure applied to offset non-finance charge closing costs in XXXXX first, then finance charges pursuant to client's election.
     
Reviewer Comment (2019-08-07): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Miscellaneous Compliance
Family Owned Business Ownership Verification
Qualified Mortgage (XXXXX): Borrower employed by Family Owned Business did not provide satisfactory evidence that he/she is not owner of the business.
Per Third Party Employer Verification XXXXX, the XXXXX as reflected on the XXXXX and bank statements.  XXXXX.
   
Reviewer Comment (2019-08-06): Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (XXXXX): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
Borrower's employer is his spouse.  Evidence that borrower is not an owner of the business is not provided.
   
Reviewer Comment (2019-08-06): Exception cleared.
 
 
Seller Comment (2019-07-30): plz note internet search shows owner and it is not XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-08-22): The lender has accepted the collateral package
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-08-28): The lender has accepted the final collateral package
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID XXXXX Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: XXXXX Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
Cure of XXXXX was disclosed on the Final Closing Disclosure, which is sufficient to cure the XXXXX tolerance violation of XXXXX.
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Final CD evidences Cure
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
This exception is due to open XXXXX exceptions and will be cured when all tolerance violations are resolved
   
Reviewer Comment (2019-08-22): SitusXXXXX received required documents, exception is cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Lender Credit Tolerance Violation
TILA-RESPA Integrated Disclosure: XXXXX Tolerance exceeded for Lender Credits. Final Lender Credit of XXXXX  is less than amount of binding Lender Credit previously disclosed in the amount of XXXXX
LE issued on XXXXX listed a lender credit of XXXXX. Final CD does not reflect a lender credit.
   
Reviewer Comment (2019-08-22): SitusXXXXX received required documents, exception is cleared.
 
 
Seller Comment (2019-08-21): The rate changed on XXXXX and the Lender Credit no longer applied therefore it was removed.
 
thanks
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID XXXXX Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: XXXXX Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
A cure provided at closing of XXXXX
   
Reviewer Comment (2019-08-21): A cure provided at closing of XXXXX
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
 
Pending XXXXX.
   
Reviewer Comment (2019-08-26): Received
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
D
B
C
A
D
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Loan Package Documentation
Closing / Title
Missing Document: Note - Subject Lien not provided
 
There's no evidence of a Note in the loan file.
   
Reviewer Comment (2019-08-28): Note provided in trailing docs, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
D
B
C
A
D
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Missing Document
General
Missing Document: Desk Review not provided
 
Per XXXXX guidelines effective XXXXX, a Collateral Desktop Analysis (XXXXX) is required for XXXXX properties and is missing from subject file.
   
Reviewer Comment (2019-08-22): Received additional guidelines and confirmed a XXXXX is not required.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
D
B
C
A
D
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Borrower signed the Closing Package two days prior to the date on documents.  The date on documents was XXXXX and Borrower signed on XXXXX, then also signed the documents on XXXXX by crossing out and initialing the date from XXXXX.
   
Reviewer Comment (2019-08-20): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
D
B
C
A
D
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Homeowner's Insurance Premium Months
TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.
Final Closing Disclosure, Section F. Prepaids  disclosed XXXXX for the Hazard insurance premium. Input should have been 12 months. PCCD corrected CD required.
   
Reviewer Comment (2019-08-20): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
D
B
C
A
D
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller Change - Total Payoffs
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX incorrectly disclosed whether there was a change in the Total Payoffs and Payments.
Closing Disclosure reflects XXXXX for Total Payoffs and the LE reflects XXXXX which is properly rounded, however, Did this Change is answered Yes. PCCD required to evidence "No Change"
   
Reviewer Comment (2019-08-20): Client elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
D
B
C
A
D
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Insurance
Insurance Analysis
Insufficient Coverage: Hazard insurance coverage amount is insufficient.
 
XXXXX XXXXXs hazard coverage in accordance with XXXXX, which requires coverage equal to or the lesser of the following: 1) XXXXXof the insurable value of the improvements, as established by the property insurer; or 2) the unpaid principal balance of the mortgage, as long as it at least equals the minimum amount-XXXXX of the insurable value of the improvements-required to compensate for damage or loss on a replacement cost basis. If it does not, then coverage that does provide the minimum required amount must be obtained. Coverage shortfall XXXXX
   
Reviewer Comment (2019-07-30): Updated Insurance Policy for subject indicating full value replacement cost on dwelling, exception cleared.
 
 
Seller Comment (2019-07-30): Updated HOI coverage
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
 
C
C
C
A
A
A
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller - Closing Costs Financed
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed Closing Costs Financed that does not match actual amount of closing costs financed.
Disclosure reflects Closing Costs Finances as XXXXX; calculated is XXXXX.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
B
B
A
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID XXXXX Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of XXXXX exceeds tolerance of XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
Final CD reflects an increase in fees subject to XXXXX: Binding LE dated XXXXX discloses the following fee subject to XXXXX Recording fee. Final Closing Disclosure includes the following fee subject to XXXXX Recording Fee. This is a XXXXX increase from binding amounts (XXXXX). Cure was provided.
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Final CD evidences Cure
B
B
A
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Non Escrowed Property Costs Year 1
TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year XXXXX on Final Closing Disclosure provided on XXXXX not accurate.
     
Reviewer Comment (2019-08-01): XXXXX received evidence of actual HOA dues at XXXXX monthly.
 
 
Seller Comment (2019-07-31): Hello - The correct HOA dues is XXXXX.  If we provide an appraisal updated to show this, will this be acceptable.  Thank you.
 
 
Reviewer Comment (2019-07-30): Appraisal indicates HOA fees are XXXXX. PCCD, and LOE required in order to address the exception.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID XXXXX Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: XXXXX Fee Tolerance exceeded for Transfer Tax.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
Insufficient cure provided.
   
Reviewer Comment (2019-07-26): The lender cured the overage at closing with a credit of XXXXX
 
 
Reviewer Comment (2019-07-26): Transaction is a refinance and paid by the borrower with no cure
 
 
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Final CD evidences Cure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Provided Prior to Date Performed
ECOA Valuations Rule (XXXXX): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.
Appraisal email receipt dated XXXXX however the report was not completed until XXXXX
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Credit Exception:
 
Final 1003 reflects borrower is US Citizen; file has a XXXXX.
   
Reviewer Comment (2019-08-12): The corrected 1003 was provided
 
 
Seller Comment (2019-08-07): Please see attached, it was marked incorrectly and has been corrected
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Second Home
Purchase
 
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Disclosure reflects closing date as XXXXX; mortgage notary date is XXXXX.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Second Home
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
The notary date was XX/XX/XXXX.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Closing date listed as XXXXX documents signed XXXXX.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Total Property Costs Year 1 - XXXXX XXXXX
TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of XXXXX on Final Closing Disclosure provided on XXXXX not accurate.
Estimated cost based on amount used for qualifying is XXXXX (based on XXXXX hazard & XXXXX tax).  Amount listed on CD is XXXXX ( based on XXXXX).
   
Reviewer Comment (2019-07-31): Letter of Explanation & Corrected Closing Disclosure provided.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Seller Closing Disclosure
TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.
Seller CD not provided.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Closing / Title
Missing Document: XXXXX not provided
 
The copy of Co-Borrower's POA is not fully executed in subject file.
   
Reviewer Comment (2019-07-30): Executed XXXXX included in Trialing documents, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Provided Prior to Date Performed
ECOA Valuations Rule (XXXXX): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.
No evidence in file that borrower received a copy of the updated appraisal report dated XX/XX/XXXX.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Appraisal Disclosure - ECOA Timing
ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.
Initial LE is dated XXXXX; application date is XXXXX. Additional disclosure not provided in file.
   
Reviewer Comment (2019-07-31): XXXXX received required documents, exception is cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
C
A
A
C
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Federal FACTA Disclosure Timing XXXXX
FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score.
Disclosure in file was provided at closing.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
C
A
A
C
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Servicing Disclosure Timing
File does not evidence the consumer was provided with the Servicing Disclosure within 3 days of the loan application date.
Initial LE is dated XXXXX; application date is XXXXX. Additional disclosure not provided in file.
   
Reviewer Comment (2019-07-31): XXXXX received required documents, exception is cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
C
A
A
C
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
RESPA Disclosure - List of Homeownership Counseling Organizations Missing
RESPA Disclosure Rule (XXXXX): Creditor did not provide List of Homeownership Counseling Organizations to borrower.
Copy of disclosure with list of agencies not provided in file.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
C
A
A
C
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Loan Estimate Timing
TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application.
Initial LE is dated XXXXX; application date is XXXXX.
   
Reviewer Comment (2019-07-31): XXXXX received required documents, exception is cleared.
 
 
Seller Comment (2019-07-30): tracking with all LE/CD's uploaded
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
No Defined Cure
C
C
A
A
C
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Closing Disclosure Timing without Waiver
TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.
Initial CD dated XXXXX was signed dated at closing.
   
Reviewer Comment (2019-07-31): XXXXX received required documents, exception is cleared.
 
 
Seller Comment (2019-07-30): tracking with all LE/CD's uploaded
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
No Defined Cure
C
C
A
A
C
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Settlement Service Provider Status
TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.
Copy of disclosure not provided in file.
   
Reviewer Comment (2019-07-31): XXXXX received required documents, exception is cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
No Defined Cure
C
C
A
A
C
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application
RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
Application date XXXXX and disclosure is dated XXXXX.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
C
A
A
C
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self Employed - Implicit Adherence
Qualified Mortgage (Dodd-Frank 2014): Self Employed borrower's loan file contained tax returns that are not signed/dated, but the loan file contains the tax transcripts to evidence the tax returns were signed/dated at time of submission to the IRS.
Tax returns were not signed by borrowers.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Home Improvement
 
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Final closing date was XXXXX documents were signed XXXXX.
   
Reviewer Comment (2019-07-30): PCCD XXXXX
 
 
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Home Improvement
Letter of Explanation & Corrected Closing Disclosure
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - Wholesale Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
Contact information was not provided for Lender.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Home Improvement
Letter of Explanation & Corrected Closing Disclosure
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller - Closing Costs Financed
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed Closing Costs Financed that does not match actual amount of closing costs financed.
Closing Disclosure Closing Costs Financed Without Seller $XXXXX and Closing Disclosure Calculated Closing Costs Financed is $XXXXX.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Home Improvement
Letter of Explanation & Corrected Closing Disclosure
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation
ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.
Appraisal was provided less than 3 days prior to closing and a signed waiver is not in the file.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Home Improvement
 
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Property - Appraisal
Appraisal Reconciliation
Appraisal is required to be in name of Lender
-
Appraisal transferred.
   
Buyer Comment (2019-08-08): Ok to accept. Appraisal transfer letter in file.  Comp factors: XXXXX
 
 
Reviewer Comment (2019-08-05): Appraisal transfer letter provided, however per guides Transferred appraisals are not allowed.
 
 
Seller Comment (2019-08-05): Please see attached appraisal transfer letter.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
C
B
C
B
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided Within 3 Business Days of Application
RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Organizations not provided to applicant within three (3) business days of application.
List provided XXXXX.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
C
B
C
B
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - Wholesale Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
Missing lender contact info on Final CD.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
C
B
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
COC provided XXXXX.
   
Reviewer Comment (2019-08-07): Letter of Explanation & Corrected Closing Disclosure provided.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
C
B
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Verification Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
COC provided XXXXX.
   
Reviewer Comment (2019-08-07): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided.
 
 
Seller Comment (2019-08-06): Please see attachment.
 
 
Reviewer Comment (2019-08-02): An increase in price may not be passed to the consumer unless there is a reason, not known at the time of the original disclosure, that causes the fee increase.  An error on the part of the lender or vendor is an an acceptable reason for the increase.  A PCCD, LOE and refund check is required to address the exception.
 
 
Seller Comment (2019-08-01): This is a broker's loan.  We updated the invoice that we rec'd from the broker and sent out a new CD.
 
 
Reviewer Comment (2019-08-01): XXXXX received COC and invoice. Receiving an invoice is not a valid change of circumstance. Please provide additional details on what occurred for the fee to be required or please provide corrected CD, LOE, and refund check to cure.
 
 
Seller Comment (2019-07-31): Please see attached COC and receipt.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
C
B
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
Desk review provided.
   
Reviewer Comment (2019-08-08): A secondary valuation was received with XXXXX variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
C
B
C
B
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower.
Letter of Explanation, copy of check, POD & Corrected Closing Disclosure provided.
   
Reviewer Comment (2019-08-07): Letter of Explanation, copy of check, POD & Corrected Closing Disclosure provided.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
C
B
C
B
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Partnership Income Documentation Test
Qualified Mortgage (Dodd-Frank 2014): XXXXX income documentation not sufficient (XXXXX).
XXXXX years business tax returns not provided; business started in XXXXX; XXXXX filed extension; copy provided in file.
   
Reviewer Comment (2019-08-07): The file contains XXXXX years personal returns and the business return for the one year that has been filed.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
XXXXX personal and business tax returns filed extension; copy provided in file.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
XXXXX personal and business tax returns filed extension; copy provided in file.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
XXXXX personal and business tax returns filed extension; copy provided in file.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency - ATR
Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
XXXXX personal and business tax returns filed extension; copy provided in file.
   
Reviewer Comment (2019-08-07): SHQM Loan
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency - ATR
Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
XXXXX personal and business tax returns filed extension; copy provided in file.
   
Reviewer Comment (2019-08-07): SHQM Loan
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency - ATR
Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
XXXXX personal and business tax returns filed extension; copy provided in file.
   
Reviewer Comment (2019-08-07): SHQM Loan
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of ATR Risk.
Due to missing most recent personal and business tax returns.
   
Reviewer Comment (2019-08-07): Based on Business start date, only one XXXXX XXXXX returns available.
 
 
Seller Comment (2019-08-01): None of the conditions show missing personal returns. What personal returns are you missing.  Please provide specifics
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Lender to provide updated ATR/QM status
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Total Property Costs Year 1 - October XXXXX Test
TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of XXXXX on Final Closing Disclosure provided on XXXXX not accurate.
Disclosure reflects $XXXXX; calculated is $XXXXX (based on $XXXXX hazard & $XXXXX tax). This is due to calculated taxes being higher.
   
Reviewer Comment (2019-08-09): Letter of Explanation & Corrected Closing Disclosure provided.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Guideline Requirement: Total cash-out discrepancy.
HUD-1 total cash-out of ___ is greater than Guideline total cash-out of ___.
Copy of exception request provided in file; copy of approval not in file.
Reserves, FICO, self-employment tenure
Aggregator
Reviewer Comment (2019-08-13): Client elects to waive.
 
 
Reviewer Comment (2019-08-12): Client to review.
 
 
Seller Comment (2019-08-09): i have uploaded exception approval again.  the full document sent on XXXXX does not show in your system and i don't know why so i have reuploaded the approval email
 
 
Seller Comment (2019-08-08): this was already in the original upload.  uploading again.  Approved exception
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Income / Employment
Income Documentation
Income Docs Missing:
-
Copy of  XXXXX XXXXX for XXXXX XXXXX not provided in file.
   
Reviewer Comment (2019-08-06): Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines
Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of XXXXX% significantly exceeds the guideline maximum of XXXXX%. (DTI Exception requires compelling compensating factors to consider regrading to XXXXX-XXXXX.)
Income used in audit review XXXXX (XXXXX XXXXX, XXXXX XXXXX, XXXXX (XXXXX) & XXXXX XXXXX) and lender total income XXXXX.
   
Reviewer Comment (2019-08-06): Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM DTI
Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds XXXXX% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.
Income used in audit review XXXXX (XXXXX XXXXX, XXXXX XXXXX, XXXXX (XXXXX) & XXXXX XXXXX) and lender total income XXXXX.
   
Reviewer Comment (2019-08-06): Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Invalid Section B Combinations
TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on XXXXX reflects a fee Paid To lender or broker for fee within Services Borrower Did Not Shop For section.
Income used in audit review XXXXX (XXXXX XXXXX, XXXXX XXXXX, XXXXX (XXXXX) & XXXXX XXXXX) and lender total income XXXXX.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Good Faith Redisclosure
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Guideline Requirement: Investor qualifying total debt ratio discrepancy.
 
Income used in audit review XXXXX (XXXXX XXXXX, XXXXX XXXXX, XXXXX (XXXXX) & XXXXX XXXXX) and lender total income XXXXX.
   
Reviewer Comment (2019-08-06): Exception cleared.
 
 
Seller Comment (2019-08-06): Please provide detailed specifics on how income was calculated for each entity in the suspense(s).  Per our underwriter:  I have worked our income every which way I can think of and I cannot come up with their figures.      Please email directly to me at XXXXX for faster communication to the underwriter.
Please provide right away as this loan is significantly aged and needs to move forward. Thank you.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
General Ability To Repay Provision Investor Guidelines
Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.
Income used in audit review XXXXX (XXXXX XXXXX, XXXXX XXXXX, XXXXX (XXXXX) & XXXXX XXXXX) and lender total income XXXXX.
   
Reviewer Comment (2019-08-07): SHQM Loan
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
C
B
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
Missing secondary appraisal. Collateral score was over XXXXX.
   
Reviewer Comment (2019-08-08): A Secondary valuation was provided with XXXXX% variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX XXXXX XXXXX XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
Fee disclosed was  last disclosed as XXXXX on LE but disclosed as XXXXX on Final Closing Disclosure.XXXXX lenders credit was provided on final CD statement.
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Final CD evidences Cure
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
The final CD statement closing date reflects XXXXX however borrower signed on XXXXX.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Provided Prior to Date Performed
ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.
Evidence in file reflects the appraisal was emailed to the borrower on XXXXX however the appraisal in loan file is dated XXXXX
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
Cure for XXXXX tolerance violation $XXXXX was not provided.
   
Reviewer Comment (2019-08-02): Tolerance exceptions are addressed. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
B
B
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $XXXXX exceeds tolerance of $XXXXX plus XXXXX% or $XXXXX.  Insufficient or no cure was provided to the borrower.
Final CD reflects an increase in fees subject to XXXXX variance: Binding LE dated XXXXX discloses the following fee subject to XXXXX variance: $XXXXX Recording fee. Final Closing Disclosure includes the following fee subject to XXXXX variance: $XXXXX Recording Fee. This is a $XXXXX increase from binding amounts ($XXXXX above XXXXX threshold).
   
Reviewer Comment (2019-08-02): XXXXX reviewed exception. Final settlement statement indicates recording fees charged are XXXXX. Exception Cleared.
 
 
Seller Comment (2019-08-01): Recording Fees is lesser on the final Charges.  See final Settlement Statement. XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
B
B
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
Most recent tax returns provided is XXXXX; extension for XXXXX provided in file.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
C
B
B
B
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
Most recent tax returns provided is XXXXX; extension for XXXXX provided in file.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
C
B
B
B
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
Most recent tax returns provided is XXXXX; extension for XXXXX provided in file.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
C
B
B
B
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Property - Appraisal
Appraisal Reconciliation
Appraisal is required to be in name of Lender
-
Appraisal reflects lender as Broker; transfer letter provided in file; per guidelines and update transfer appraisals are not eligible.
   
Buyer Comment (2019-08-08): Ok to accept. Comp factors: XXXXX
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
C
B
B
B
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self Employed - Implicit Adherence
Qualified Mortgage (Dodd-Frank 2014): Self Employed borrower's loan file contained tax returns that are not signed/dated, but the loan file contains the tax transcripts to evidence the tax returns were signed/dated at time of submission to the IRS.
XXXXX returns are not signed.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
This exception is due to open XXXXX or XXXXX tolerance exceptions and will be cured when all tolerance violations are resolved
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Lender Credit Tolerance Violation
TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $XXXXX  is less than amount of binding Lender Credit previously disclosed in the amount of $XXXXX.
Final Lender Credit of XXXXX  is less than amount of binding Lender Credit previously disclosed in the amount of XXXXX. Loan Program changed on XXXXX.
   
Reviewer Comment (2019-08-12): The loan amount increased and the fees were lowered changing the lender credit
 
 
Seller Comment (2019-08-12): The loan amount increase changed the pricing on the loan. What other explanation do you want?
 
 
Reviewer Comment (2019-08-09): XXXXX received updated COC however additional details are requested as it is not borrower's interest to request to decrease lender credit. Please provide additional details regarding the change or please provide corrected CD, LOE, and refund check to cure.
 
 
Seller Comment (2019-08-07): Updated COC
 
 
Reviewer Comment (2019-07-31): XXXXX received COC dated XXXXX for Loan Amount change, however the reason for the decreased Lender Credit was not provided.  Please provide more details on the reason for the repricing or fee changes for redetermination.
 
 
Seller Comment (2019-07-30): COC
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-08-08): A secondary valuation was provided with XXXXX variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Loan Estimate Timing Electronically Provided
TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.
Initial LE dated XXXXX was electronically sent; borrower E Signed on XXXXX; E Consent form signed on XXXXX.
   
Reviewer Comment (2019-08-13): Confirmed Paper copy of Initial LE was sent via US Mail to the borrower
 
 
Reviewer Comment (2019-08-13): Compliance department review comments: The rule requires the creditor to deliver or mail the Loan Estimate no later than the third business day after the creditor receives the consumer's written application. If the LE is e-delivered, the creditor must first comply with the ESign Act by obtaining consent from the borrower to receive the disclosure electronically. The EConsent for the loan in question was signed on XXXXX, therefore, XXXXX will not consider the LE to have been delivered or mailed to the borrower until XXXXX.
If the client can provide evidence they mailed the disclosure to the borrower on the XXXXX, we can review further; however, with the current documentation, the timing exceptions remain
 
 
Reviewer Comment (2019-07-31): Application date was XXXXX, and initial LE was not received by borrower within 3 days of application, but was received on XXXXX.  Unable to address the exception.
 
 
Seller Comment (2019-07-30): Please condition. The Initial LE dated XXXXX was issued within 3 days of application date of XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Loan Estimate Esign Consent Agreement Timing
ESIGN Act - Loan Estimate provided on XXXXX was electronically provided prior to borrower's consent to receive electronic disclosures.  Disclosure will not be used to rebaseline for tolerance purposes and may result in disclosure timing violations.
The Electronic consent was agreed upon on XXXXX but the LE was sent on XXXXX
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
No Defined Cure
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Loan Estimate Esign Consent Agreement Timing
ESIGN Act - Loan Estimate provided on XXXXX was electronically provided prior to borrower's consent to receive electronic disclosures.  Disclosure will not be used to rebaseline for tolerance purposes and may result in disclosure timing violations.
The Electronic consent was agreed upon on XXXXX but the LE was sent on XXXXX
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
No Defined Cure
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-08-08): A secondary valuation was received with XXXXX variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
A
A
D
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided Within 3 Business Days of Application
RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Organizations not provided to applicant within three (3) business days of application.
Application date was XXXXX documents provided XXXXX,
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
D
B
A
A
D
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Home Loan Toolkit Timing
Truth in Lending Act (2015): Creditor or broker did not provide the Home Loan Toolkit Disclosure to applicant within 3 business days of application.
Application date was XXXXX documents were provided XXXXX.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
No Defined Cure
D
B
A
A
D
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM Points and Fees
Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of XXXXX% is in excess of the allowable maximum of  XXXXX% of the Federal Total Loan Amount. Points and Fees total $XXXXX on a Federal Total Loan Amount of $XXXXX8 vs. an allowable total of $XXXXX (an overage of $XXXXX or .XXXXX%).
Fees exceed maximum allowed.
   
Reviewer Comment (2019-08-06): Exception cleared.
 
 
Seller Comment (2019-08-02): Please see attached Bona Fide.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
If a creditor or assignee determines after consummation that the total points and fees exceeds the QM Points and Fees limit, but the loan meets the other requirements to be a QM, the QM Points and Fees exception can be cured through a refund including interest at the contract rate from consummation to the date of cure, with the following conditions:
1)      Refund is made within 210 days of consummation;
2)      The consumer has not instituted any actions against the creditor or provided written notice that the loan's fees exceeded the legal limit;
3)      The loan is not 60 days delinquent;
4)      The creditor or assignee (depending who is curing) has policies in place to identify and cure excessive fees collected from the consumer (the creditor or assignee can only take advantage of this cure provision if they maintain policies and procedures for post-consummation review of points and fees and for providing the cure payments); and
5)      The loan was closed on or before January 10, 2021;
 
Documents Required to Cure
1)      Letter of Explanation
2)      Copy of Refund Check (in the amount of overage plus interest)
3)      Proof of Delivery
4)      Lender/Seller Attestation indicating:
        a)      The consumer has not instituted any actions against the creditor or provided written notice that the loan's fees exceeded the legal limit;
        b)      The loan is not 60 days delinquent; and
        c)      The creditor or assignee (depending who is curing) has policies in place to identify and cure excessive fees collected from the consumer
D
B
A
A
D
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Total Property Costs Year 1 - October XXXXX Test
TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year XXXXX of XXXXX on Final Closing Disclosure provided on XXXXX not accurate.
Hoa dues based on appraisal are $XXXXX per month. Lender qualified with $XXXXX and estimated costs over one year are based on higher amount.
   
Reviewer Comment (2019-08-02): XXXXX received PCCD correcting total property costs and LOE. Exception Cured.
 
 
Seller Comment (2019-08-01): Please see attached updated CD.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
D
B
A
A
D
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Temporary SHQM (GSE/Agency Eligible) does not match Due Diligence Loan Designation of Non QM.
Failure due to missing or dated documents.
   
Reviewer Comment (2019-08-06): Exception cleared.
 
 
Seller Comment (2019-08-02): Please see attached Bona Fide.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
D
B
A
A
D
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Loan Package Documentation
Loan File
(Missing Doc) Incomplete loan images/file
 
Some tax returns are corrupted and illegible.
   
Reviewer Comment (2019-08-06): Exception cleared.
 
 
Seller Comment (2019-08-01): Please see attached tax returns
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
A
A
D
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Federal FACTA Disclosure Timing Test
FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score.
Disclosure was provided at/or prior closing.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
 
C
C
A
A
C
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
RESPA Disclosure - List of Homeownership Counseling Organizations Missing
RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower.
Disclosure with list of agencies not provided in file.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
 
C
C
A
A
C
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing
RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to borrower.
Disclosure provided from Title Company reflects business relationship; disclosure from Lender not provided.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
 
C
C
A
A
C
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
Cure for various XXXXX tolerance violations $XXXXX was not provided.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
Letter of Explanation & Corrected Closing Disclosure
C
C
A
A
C
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Closing Disclosure Timing without Waiver
TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.
Initial/Final CD dated XXXXX is signed XXXXX. It appears that the file is missing the Initial CD sent on XXXXX per the Disclosure Tracking document.
   
Reviewer Comment (2019-07-31): Initial CD provided
 
 
Seller Comment (2019-07-30): tracking with all le/cd's uploaded
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
No Defined Cure
C
C
A
A
C
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Lender Credit Tolerance Violation
TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $XXXXX  is less than amount of binding Lender Credit previously disclosed in the amount of $XXXXX.
Lender Credit disclosed as XXXXX on the LE dated XXXXX; but disclosed as XXXXX on the Final Closing Disclosure with a cure in the loan file.
   
Reviewer Comment (2019-08-09): Borrower received credit in amount equal or greater to binding lender credit.
 
 
Seller Comment (2019-08-08): COC UPLOADED
 
 
Seller Comment (2019-08-06): COC UPLOADED
 
 
Reviewer Comment (2019-07-31): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD required to cure.  The LE disclosed lender credit of XXXXX.  The Initial and Final CD reflect lender credit of XXXXX.  File does not contain change of circumstance for decrease in the lender credit.
 
 
Seller Comment (2019-07-30): tracking with all le/cd's uploaded. please advise if more is needed
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
C
A
A
C
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Settlement Service Provider Status
TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.
Copy of disclosure not provided in the loan file.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
No Defined Cure
C
C
A
A
C
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
S-Corp Income Documentation Test
Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (XXXXX-XXXXX).
CPA letter indicates in XXXXX XXXXX XXXXX XXXXX files a single member XXXXX on XXXXX XXXXX. IN XXXXX XXXXX XXXXX elected to file XXXXX-XXXXX. Have XXXXX XXXXX SE and XXXXX XXXXX
   
Reviewer Comment (2019-08-07): The personal returns for XXXXX contained the business tax information with XXXXX being reflected on the filed business returns being provided for the XXXXX..
 
 
Seller Comment (2019-08-07): PLEASE respond...it's been 3 working days since I requested clarification.
 
 
Seller Comment (2019-08-06): it has been XXXXX days since this was originally requested for clarification and full details without any comment. I need detailed specifics to provide to the underwriter to get this addressed.  please advise why no response has been provided and please provide asap.  this loan is significantly aged.
 
 
Seller Comment (2019-08-01): this condition is vague. What exactly is required to cure this suspense....nothing is indicated.  why is income documentation insufficient?
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date v,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
Two years signed federal tax returns, current year tax extension, and prior YTD and current YTD signed P&L and Balance sheets have been provided, as Loan Application is prior to XXXXX.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
Documentation is missing from subject file.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency - ATR
Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
Two years signed federal tax returns, current year tax extension, and prior YTD and current YTD signed P&L and Balance sheets have been provided, as Loan Application is prior to XXXXX.
   
Reviewer Comment (2019-08-07): SHQM loan, the recency exception present under QM considerations.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
CPA letter indicates in XXXXX XXXXX XXXXX XXXXX files a single member XXXXX on XXXXX XXXXX. IN XXXXX XXXXX XXXXX elected to file XXXXX-XXXXX. Have XXXXX XXXXX and XXXXXXXXXX.
   
Reviewer Comment (2019-08-07): SHQM loan based on all filed business returns being provided.
 
 
Seller Comment (2019-08-01): YOUR COMMENTS IN ANOTHER SUSPENSE:  No tolerance violation of Lender Credit Fee due to Change of Circumstance letter issued on XXXXX reflects Borrower requested change to loan amount, discount points ( or lender credit), and the credit report fee.---  Please clear this as XXXXX clearly states there is no violation
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Lender to provide updated ATR/QM status
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
This exception is due to open XXXXX or XXXXX tolerance exceptions and will be cured when all tolerance violations are resolved
   
Reviewer Comment (2019-08-07): Valid COC provided.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Lender Credit Tolerance Violation
TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $XXXXX  is less than amount of binding Lender Credit previously disclosed in the amount of $XXXXX.
No tolerance violation of Lender Credit Fee due to Change of Circumstance letter issued on XXXXX reflects Borrower requested change to loan amount, discount points ( or lender credit), and the credit report fee.
   
Reviewer Comment (2019-08-07): Valid COC provided.
 
 
Reviewer Comment (2019-08-05): XXXXX agrees that a loan amount change is a valid COC, however, the lender credit percentage of change is not the same as the loan amount percentage change.  Pricing changes could determine if the loan amount change was valid.  Please provide additional details on why the lender credit decreased, i.e. more points charged?, rate extension?, additional details are needed for a redetermination.
 
 
Seller Comment (2019-08-02): I am still confused.  The condition still states NO TOLERANCE VIOLATION OF LENDER CREDIT FEE DUE TO COC ISSUED XXXXX.  Why do you suggest there is additional pricing changes??  what are you seeing??  It is CRITICAL all information is provided by you when addressing TRID issues..  How can this violation be cleared as you indicate if you see additional issues?  what additional issues are you seeing that results in you asking about additional pricing changes?  lender credit reducing due to loan amount reducing is a valid change...
 
 
Reviewer Comment (2019-08-02): COC on XXXXX for Borrower requested loan amount change from XXXXX to XXXXX is a XXXXX change and the decreased Lender credit from XXXXX to XXXXX is a XXXXX change.  If there was additional pricing changes please provide evidence for redetermination.
 
 
Seller Comment (2019-08-01): why is this a suspense.  The EXCEPTION INFORMATION clearly states no tolerance violation.  why is this a '3' condition?  if no tolerance violation, why is this not cleared?  what exactly is needed?  Per above comments:  No tolerance violation of Lender Credit Fee due to Change of Circumstance letter issued on XXXXX reflects Borrower requested change to loan amount, discount points ( or lender credit), and the credit report fee.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Provided Prior to Date Performed
ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.
Appraisal effective date is XXXXX, and report date is XXXXX. Sent date on disclosure is XXXXX.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided Within 3 Business Days of Application
RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Organizations not provided to applicant within three (3) business days of application.
Application date is XXXXX, and date on disclosure is XXXXX.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Invalid Section B Combinations
TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on XXXXX reflects a fee Paid To lender or broker for fee within Services Borrower Did Not Shop For section.
Fee paid to lender on final CD
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Good Faith Redisclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Income / Employment
Income Documentation
Income Docs Missing:
-
VVOE provided was not completed for the borrower's XXXXX XXXXX in the loan file.
   
Reviewer Comment (2019-07-31): Provided
 
 
Reviewer Comment (2019-07-30): VVOE in trailing documents do not illustrate start date and/or borrower as active at company. The document is only signed/dated.
 
 
Seller Comment (2019-07-30): VOE
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
 
C
B
C
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Property - Appraisal
General Appraisal Requirements
The owner on the appraisal is incorrect.
-
XXXXX on appraisal indicates XXXXX XXXXX XXXXX XXXXX XXXXX. Should be borrower. Loan is refinance transaction.
   
Reviewer Comment (2019-08-12): Appraisal updated
 
 
Seller Comment (2019-08-07): updated appraisal report
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
 
C
B
C
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Income / Employment
Income Documentation
REO Documents are missing.
-
The file did not contain verification or evidence of Tax verification or a Mortgage Statement for the borrower's REO property.
   
Reviewer Comment (2019-07-31): Provided
 
 
Seller Comment (2019-07-31): XXXXX, XXXXX, XXXXX
 
 
Reviewer Comment (2019-07-30): No evidence of a Mortgage Statement and Tax Verification for property located at XXXXX XXXXX in trailing documents.
 
 
Seller Comment (2019-07-30): XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
 
C
B
C
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
State Compliance
Colorado Home Loan (Ability to Repay not Verified)
Colorado Home Loan (HB1322):  Borrower's ability to repay not verified with reliable documentation.
There was no evidence of a VOE prior to or at the time of the loan application in the lona file.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
 
C
B
C
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Closing Disclosure Timing without Waiver
TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.
Initial CD was provided XXXXX, and non-signed date is XXXXX. Note date is XXXXX. There's no evidence of a Disclosure of when this document was received.
   
Reviewer Comment (2019-07-31): Esigned provided showing all dates the LE and CD were issued and viewed by the borrower.
 
 
Seller Comment (2019-07-31): Disclosure Tracking
 
 
Reviewer Comment (2019-07-30): Trailing documents for tracking of LE's/CD's blank, please resubmit evidence of document with dates sent/received.
 
 
Seller Comment (2019-07-30): Closing Disclosure tracking
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
No Defined Cure
C
B
C
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Interim Closing Disclosure Timing
TILA-RESPA Integrated Disclosure - Corrected Closing Disclosure provided on XXXXX contains a change in APR, loan product or addition of prepayment penalty and was not received by borrower at least three (3) business days prior to consummation
Initial CD was provided XXXXX, and non-signed date is XXXXX. Note date is XXXXX. There's no evidence of a Disclosure of when this document was received.
   
Reviewer Comment (2019-07-31): Esigned provided showing all dates the LE and CD were issued and viewed by the borrower.
 
 
Seller Comment (2019-07-31): Disclosure Tracking
 
 
Reviewer Comment (2019-07-30): Trailing documents for tracking of LE's/CD's blank, please resubmit evidence of document with dates sent/received.
 
 
Seller Comment (2019-07-30): Closing Disclosure tracking
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
No Defined Cure
C
B
C
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Revised Loan Estimate Timing Before Closing
TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on XXXXX not received by borrower at least four (4) business days prior to closing.
Non-signed date is XXXXX, and closing date is XXXXX. There's no evidence of a Disclosure of when this document was received.
   
Reviewer Comment (2019-07-31): Esigned provided showing all dates the LE and CD were issued and viewed by the borrower.
 
 
Seller Comment (2019-07-31): Disclosure Tracking
 
 
Reviewer Comment (2019-07-30): Trailing documents for tracking of LE's/CD's blank, please resubmit evidence of document with dates sent/received.
 
 
Seller Comment (2019-07-30): Closing Disclosure tracking
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
No Defined Cure
C
B
C
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
Loan Application Date is prior to XXXXX and Borrower signed an XXXXX federal tax extension. There's no evidence of XXXXX Tax Returns in the loan file.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Guideline Requirement: PITIA reserves months discrepancy.
 
Lender stated $XXXXX in verified assets, but missing updated or additional statements to accurately provide the amount verified in the loan file.
   
Reviewer Comment (2019-07-31): updated guidelines state no reserves for retained properties the max reserves are only XXXXX
 
 
Seller Comment (2019-07-29): updated 1008
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
There's no evidence of a secondary valuation as required for securitization.
   
Reviewer Comment (2019-08-08): A secondary valuation was provided with XXXXX variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
Documentation is missing from subject file.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Loan Estimate Timing Electronically Provided
TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.
Evidence of Borrowers' earlier receipt of E-consent authorization is not found in file.
   
Reviewer Comment (2019-08-01): Initial LE electronically signed on XXXXX and XXXXX which is after Broker's Intent to Proceed was received.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Loan Estimate Esign Consent Agreement Timing
ESIGN Act - Loan Estimate provided on XXXXX was electronically provided prior to borrower's consent to receive electronic disclosures.  Disclosure will not be used to rebaseline for tolerance purposes and may result in disclosure timing violations.
Borrower agreed to receive electronic disclosures on XXXXX, however LE is dated (XXXXX) prior to E-Consent date. Unable to determine when the initial LE was sent to the borrower.
   
Reviewer Comment (2019-08-01): Initial LE electronically signed on XXXXX and XXXXX which is after Broker's Intent to Proceed was received.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
No Defined Cure
C
B
A
A
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided Within 3 Business Days of Application
RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Organizations not provided to applicant within three (3) business days of application.
Evidence of Borrowers' earlier receipt is not found in file.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
Only one appraisal was provided. Two are required for securitization.
   
Reviewer Comment (2019-08-08): A secondary valuation was provided with XXXXX variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-09-03): The client has accepted the collateral package
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Homeowner's Insurance Premium Months
TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.
The Hazard Insurance Premium number of months disclosed is correct. The monthly amount collected for hazard insurance is rounded up which is causing a difference in total for annual calculation. $XXXXX*XXXXX = $XXXXX as opposed to the actual annual premium of $XXXXX.
   
Reviewer Comment (2019-08-23): XXXXXXXXXX received required documents, exception is cured.
 
 
Seller Comment (2019-08-22): insurance is actually XXXXX not XXXXX so XXXXX x XXXXX = XXXXX
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Prepaid Tax Prepaid Other XXXXX Months
TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXX did not disclose number of months for Tax Prepaid - Other under Prepaids.
The number of months collected was not provided on the final CD. The amount disclosed does equate to XXXXX months of Solid Waste Tax.
   
Reviewer Comment (2019-08-23): XXXXXXXXXX received required documents, exception is cured.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Cure of XXXXX was disclosed on the Final Closing Disclosure.
   
Reviewer Comment (2019-08-22): A cure of XXXXX provided at closing.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date
TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXX received on or after the date the Closing Disclosure XXXXX 12:00:00 AM was received.
ESigned on XXXXX and Initial CD was Esigned on XXXXX.
   
Reviewer Comment (2019-08-26): Client elects to waive.
 
 
Reviewer Comment (2019-08-23): Disclosure Summary provided clearly shows the message viewed was XXXXX for the eDisclosures sent on XXXXX. Exception stands.
 
 
Reviewer Comment (2019-08-23): Unable to address the exception.  Provided data does not confirm date XXXXX LE (signed XXXXX) was received.  Mailbox rule not in effect as there is no confirmation in loan file that documents were sent by mail.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
No Defined Cure
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Prepaid Other XXXXX Months
TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXX did not disclose number of months for Solid Waste under Prepaids.
Number of months missing on the prepaids for Solid Waste
   
Reviewer Comment (2019-08-23): Letter of Explanation & Corrected Closing Disclosure provided.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Provided Prior to Date Performed
ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.
     
Buyer Comment (2019-09-03): Waived by rkeplinger on Rate Lock: No A/L or outside SOL
 
 
Buyer Comment (2019-09-03): (Rate Lock) No A/L or outside SOL - per compliance ok to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
B
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-08-26): Received
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Homeowner's Insurance Premium Months
TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXX did not disclose number of months for homeowner's insurance under Prepaids.
CD  provided on XXXXX disclosed (XXXXX) number of months.
   
Reviewer Comment (2019-08-26): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Prepaid Interest
TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXX disclosed prepaid interest under Prepaids that does not match calculated figures.
Should be $XXXXX( XXXXX X XXXXX days = $XXXXX). CD used a figure $2XXXXX.
   
Reviewer Comment (2019-08-26): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Asset
Asset Calculation / Analysis
Available for Closing is insufficient to cover Cash From Borrower.
Documented qualifying Assets for Closing of  ___ is less than Cash From Borrower ___.
The final CD shows XXXXX to borrower. No funds to close.
   
Reviewer Comment (2019-08-28): Borrower paid upfront before closing $XXXXX towards insurance and XXXXX for appraisal. Borrower received XXXXX cash out at lose minus these amounts equal XXXXX cash out. Funds not required to close. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
The tax returns used were not current based on the closing date. the filing of the extension does not make the stale returns current, it just means the consumer is deferring their filing with the IRS. Specifically the income being used to qualify is not based on recent returns
   
Reviewer Comment (2019-08-26): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
 
Pending Internal Customer Collateral Package Review.
   
Reviewer Comment (2019-08-26): Received
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
A
C
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Loan Estimate Timing Electronically Provided
TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.
Application date on initial XXXXX is XXXXX. LE provided XXXXX. The XXXXX is the XXXXX business day after application.
   
Reviewer Comment (2019-08-14): XXXXX received E consent dated XXXXX. Exception Cleared.
 
 
Seller Comment (2019-08-13): Econsent sent XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
A
C
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Guideline Requirement: Combined loan to value discrepancy.
 
Per 1008, lender granted exception to go outside guidelines for LTV based on cash-out requirements of a max LTV of XXXXX% vs. XXXXX.
   
Reviewer Comment (2019-08-22): Additional guidelines were provided.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
A
C
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Borrower and Mortgage Eligibility
Mortgage / Program Eligibility
Guideline Requirement: Loan to value discrepancy.
 
Per 1008, lender granted exception to go outside guidelines for LTV based on cash-out requirements of a max LTV of XXXXX% vs. XXXXX LTV.
   
Reviewer Comment (2019-08-22): Additional guidelines were provided.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
A
C
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Pending Internal Customer Final Collateral Package Review
       
Reviewer Comment (2019-09-03): The client has accepted the collateral package
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
B
B
B
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Closing Disclosure Lump Sum Allocation
Lump sum lender/seller credit disclosed on Closing Disclosure applied to offset non-finance charge closing costs in Sections A, B, C, or E first, then finance charges pursuant to client's election.
Lump sum lender/seller credit disclosed on Closing Disclosure applied to offset non-finance charge closing costs in Sections A, B, C, or E first, then finance charges pursuant to client's election.
   
Reviewer Comment (2019-08-26): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
B
B
B
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
Cure provided for second appraisal fee.
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Final CD evidences Cure
B
B
B
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Insurance
Insurance Analysis
Hazard Insurance Policy expires within XXXXX days of the Note Date.
Hazard Insurance Policy Expiration Date ___, Note Date ___
Hazard Insurance Policy expires within 90 days of the Note Date.
   
Reviewer Comment (2019-08-09): The XXXXX covers walls in the other policy from the borrower is just for personal property.
 
 
Seller Comment (2019-08-08): The Master Policy has XXXXX coverage so an XXXXX policy should not be needed, please refer to page 2 of the attached.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
C
C
B
A
A
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Credit Eligibility
There are red flags on the fraud report that have not been addressed
-
Red flags on the fraud report that have not been addressed.
   
Reviewer Comment (2019-08-21): Per Fraud Report in loan file, OFAC, HUD-LDP and GSA-EPLS have all passed, exception cleared.
 
 
Seller Comment (2019-08-14): If possible, please provide additional information/color regarding this condition so HP can address correctly. Thank you
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
C
C
B
A
A
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Income / Employment
Income Documentation
Employment Error: Employment job title not provided.
-
Employment job Title is blank for prior jobs.
   
Buyer Comment (2019-08-05): OK to accept. W2s and transcripts are in file and no concerns with history.  Comp factors: XXXXX
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
C
C
B
A
A
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.
       
Reviewer Comment (2019-08-16): XXXXX XXXXX-XXXXX provided reflecting no damage. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
C
C
B
A
A
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
No amount is disclosed as exceeding limit.
   
Reviewer Comment (2019-08-01): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of XXXXX exceeds tolerance of XXXXX plus XXXXX% or XXXXX.  Insufficient or no cure was provided to the borrower.
The abstract title search fee was not disclosed on the initial LE and no VCOC was provided
   
Reviewer Comment (2019-08-20): XXXXX received copy of refund check and LOE to go along with PCCD.  Fedex shipping label also provided.
 
 
Reviewer Comment (2019-08-06): XXXXX received PCCD indicating cure. Please provide LOE and refund check to cure.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Ten Percent Tolerance Violation With Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of XXXXX exceeds tolerance of XXXXX plus XXXXX% or XXXXX.  Sufficient or excess cure was provided to the borrower.
XXXXX received PCCD indicating cure. Please provide LOE and refund check to cure.
   
Buyer Comment (2019-08-14): No A/L or outside SOL
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Total Property Costs Year 1 - October XXXXX Test
TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year XXXXX of XXXXX on Final Closing Disclosure provided on XXXXX not accurate.
Final CD lists the cost estimate year one as XXXXXwhereas the taxes used to qualify was XXXXX using a XXXXX% estimate as no tax cert was provided and the HOI annual fee as $XXXXX. The total should be $XXXXX or evidence of the Mill rate used for property taxes.
   
Reviewer Comment (2019-08-14): Letter of Explanation & Corrected Closing Disclosure provided. Exception cured.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
PCCD corrected the closing date to match the notary date
   
Reviewer Comment (2019-07-30): PCCD corrected the closing date to match the notary date
 
 
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Provided Prior to Date Performed
ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.
Borrower signed document on XXXXX stating receipt of appraisal, after effective date of XXXXX; however, prior to signature/completion date of XXXXX.
   
Reviewer Comment (2019-08-01): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
     
Reviewer Comment (2019-08-01): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
 
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Total Property Costs Year 1 - October XXXXX Test
TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year XXXXX of 1XXXXX on Final Closing Disclosure provided on XXXXX not accurate.
Amount of Estimated Property Costs over Year XXXXX on Final Closing Disclosure is $X.  Missing proof of additional taxes in the amount of $XXXXX/year.
   
Reviewer Comment (2019-08-16): Evidence of XXXXX payment in the amount of XXXXX provided and reason for difference.Exception cleared.
 
 
Reviewer Comment (2019-08-05): XXXXX received lender correspondence. Using the calculated taxes of XXXXX+XXXXX XXXXX+XXXXX XXXXX XXXXX=XXXXX or XXXXX for XXXXX months. Please provide corrected CD and LOE to cure.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date
Truth in Lending Act:  Subject loan transaction disbursed on XXXXX, prior to three (3) business days from transaction date of XXXXX.
     
Reviewer Comment (2019-08-20): Funding date was on XXXXX.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
The Final Closing Disclosure reflected a closing date of XXXXX and the loan signed XXXXX
   
Reviewer Comment (2019-08-01): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Waiver Less than 3 Days From Consummation
ECOA Valuations Rule (Dodd-Frank 2014): Borrower provided appraisal waiver less than three (3) business days prior to consummation.
     
Reviewer Comment (2019-08-01): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
 
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Disbursement Date
Closing Information section of CD dated 0XXXXX reflects inaccurate Disbursement Date.
Disbursement date on Final CD is XXXXX, however per documentation provided funds were disbursed on XXXXX.
   
Buyer Comment (2019-08-22): ok to accept
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
Good Faith Redisclosure
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Borrowers signed final documents XXXXX.
   
Reviewer Comment (2019-07-30): PCCD XXXXX
 
 
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Finance Charge
TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.
Final Closing Disclosure provided on XXXXX disclosed a finance charge of $XXXXX, calculated finance charge are $XXXXX, resulting in a variance of XXXXX. To cure, provided corrected PC CD along with LOE to borrower and evidence of deliver.
   
Reviewer Comment (2019-08-13): XXXXXXXXXX received required documents, exception is cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission if Applicable
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
Final disclosure did not disclose a value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
   
Reviewer Comment (2019-08-01): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - SubEscrow Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Title - SubEscrow Fee was not disclosed on the initial LE but on the final CD reads XXXXX. It appears the borrower was not notified of this additional fee after LE was disclosed. Missing valid change in circumstance. To cure, provided corrected PC CD along with LOE to borrower and evidence of deliver
   
Reviewer Comment (2019-08-15): XXXXX reviewed exception. Fee should be included in XXXXX tolerance and XXXXX fees are within threshold. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Will Not Have Escrow -  Reason
TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXX incorrectly disclosed whether the loan will have an escrow account.
Final CD does not reflect the reason for no escrows.  Updated Post-Close CD reflects the borrower declined escrows.
   
Reviewer Comment (2019-07-30): XXXXX PCCD
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided Within 3 Business Days of Application
RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Organizations not provided to applicant within three (3) business days of application.
Application dated XXXXX list dated XXXXX
   
Reviewer Comment (2019-08-01): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
Missing evidence in file of appraisal being sent to borrower.
   
Reviewer Comment (2019-08-01): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
B
B
A
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Waiver Less than 3 Days From Consummation
ECOA Valuations Rule (Dodd-Frank 2014): Borrower provided appraisal waiver less than three (3) business days prior to consummation.
     
Reviewer Comment (2019-08-01): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
B
B
A
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
FACTA Disclosure Missing
FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
     
Reviewer Comment (2019-08-01): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Assumption
TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXX incorrectly disclosed whether the loan allows for Assumption.
Final CD disclosed loan does allow for Assumption, however, Note does not contain Assumption language.
   
Reviewer Comment (2019-08-01): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-08-15): Exceptions cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
General
Initial Rate Lock rate date is not documented in file.
 
There is no evidence in the file of exactly when the loan was locked
   
Reviewer Comment (2019-08-15): Exception cleared
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Insurance
Insurance Analysis
The Hazard Insurance Policy effective date is after the Transaction Date.
 
The loan closed XXXXX and the HOI is not in effect until XXXXX.
   
Reviewer Comment (2019-08-15): Exception cleared
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
FACTA Disclosure Missing
FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
Creditor did not provide FACTA Credit Score Disclosure/Notice to the Applicant.
   
Reviewer Comment (2019-08-01): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
B
B
A
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
The file was missing a secondary appraisal report.
   
Reviewer Comment (2019-08-09): Provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Esign Consent Agreement Status
ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $XXXXX and disclosure timing violations.
The file was missing a esign disclosure.
   
Reviewer Comment (2019-08-12): XXXXX received XXXXX E Consent. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
No Defined Cure
C
B
A
A
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Loan Estimate Timing Electronically Provided
TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.
The file was missing a esign disclosure.
   
Reviewer Comment (2019-08-12): XXXXX received XXXXX E Consent. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
FACTA Disclosure Missing
FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
     
Reviewer Comment (2019-08-01): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Finance Charge
TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.
Final Closing Disclosure provided on XXXXX disclosed a finance charge of XXXXX, calculated finance charge are XXXXX, resulting in a variance of XXXXX (Title Services on LE's and CD's). To cure, provided corrected PC CD along with LOE to borrower and evidence of deliver.
   
Reviewer Comment (2019-08-22): Corrected PCCD provided to correct fees to match final ALTA Settlement Statement and what borrower actually incurred at closing.  Exception cleared.
 
 
Reviewer Comment (2019-08-20): No cure provided in trailing docs. Exception remains.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission if Applicable
C
B
C
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Will Have Escrow -  Monthly Escrow Payment
TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXX disclosed the Monthly Escrow Payment that does not match the actual escrow payment for the loan.
Escrow on page 1 XXXXX does not match escrow on page 4 XXXXX.  XXXXX XXXXX XXXXX/month is missing.
   
Reviewer Comment (2019-08-20): PCCD is corrected on page 4 to read XXXXX.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Insurance
Insurance Documentation
Missing Document: Mortgage Insurance Certificate (MIC) not provided
 
The file was missing a copy of the Mortgage Insurance Certificate
   
Reviewer Comment (2019-08-05): File does not contain MI. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Wages Documentation
Qualified Mortgage (Dodd-Frank 2014): Wages / W-2 income documentation not sufficient.
Pay stub provided is dated XXXXX; WVOE is dated XXXXX; both are dated over 90 days.
   
Reviewer Comment (2019-08-12): Although the paystubn was from XXXXX, the work number evidenced employment through XXXXX
 
 
Seller Comment (2019-08-08): loanDepot XXXXX guidelilnes all for all credit documentation (which included income docs) to be max 120 days.   Loan to be reviewed per LD guides.  Docs were not 120 days old.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
General Ability To Repay Provision Income and Assets - Wages
Ability to Repay (Dodd-Frank 2014): Unable to verify Wages/W-2 income using reasonably reliable third-party records.
Due to borrower income docs being over 90 days old.
   
Reviewer Comment (2019-08-12): Although the paystubn was from XXXXX, the work number evidenced employment through XXXXX
 
 
Seller Comment (2019-08-08): loanDepot XXXXX guidelilnes all for all credit documentation (which included income docs) to be max 120 days.   Loan to be reviewed per LD guides.  Docs were not 120 days old.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of ATR Fail.
Due to borrower income docs being over 90 days old.
   
Reviewer Comment (2019-08-12): SHQM Loan,
 
 
Seller Comment (2019-08-08): loanDepot XXXXX guidelilnes all for all credit documentation (which included income docs) to be max 120 days.   Loan to be reviewed per LD guides.  Docs were not 120 days old.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Lender to provide updated ATR/QM status
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
NonQM ATR
Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.
Due to borrower income docs being over 90 days old.
   
Reviewer Comment (2019-08-12): SHQM loan
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Property - Appraisal
Appraisal Documentation
Missing Document: Appraisal was made "subject to" and Form XXXXX/XXXXX was not provided.
-
The file was missing a copy of the final re-inspection completion report with color photos.
   
Reviewer Comment (2019-08-06): Final Inspection XXXXX in trailing documents, exception cleared.
 
 
Seller Comment (2019-08-05): Attached
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - Wholesale Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
The lenders contact information was missing from the Final CD.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
A lenders credit of XXXXX was provided to cure appraisal increase fee.
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Final CD evidences Cure
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
The final CD closing date reflects XXXXX however the borrowers signed on  XXXXX.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Borrower and Mortgage Eligibility
Mortgage / Program Eligibility
Missing Document: Note - Subordinate Lien not provided
 
There's no evidence of the Note for the Subordinated Lien.
   
Reviewer Comment (2019-08-06): HELOC Agreement and Disclosure Statement provided in trailing documents, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
There's no evidence of a secondary valuation as required for securitization.
   
Reviewer Comment (2019-08-13): Secondary valuation was provided with XXXXX variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure
RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
     
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
CU risk score is XXXXX; secondary appraisal product is required.
   
Reviewer Comment (2019-08-13): A secondary valuation was provided with XXXXX variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Final disclosure reflects closing date of XXXXX; however, notary date reflects XXXXX.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM Employment History - Current Employment Documentation lacks Date Info
Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two years current employment.
Borrower has not been employed by current employer for XXXXXyears; however missing Third Party VOE for Partnership,
   
Buyer Comment (2019-08-13): Ok to accept. Last XXXXX years XXXXX are in file.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Final CD was signed XXXXX by borrowers in line with the notary date, but different than the Note date of XXXXX on the Final CD.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Seller Closing Disclosure
TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.
There's no evidence of a Final CD in the loan file.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
There's no evidence of a secondary valuation as required for securitization.
   
Reviewer Comment (2019-08-13): A secondary valuation was provided with XXXXX variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Compliance Audit / Quality Control Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Compliance Fee was not disclosed on the initial LE but on the final CD reads XXXXX. It appears the borrower was not notified of this additional fee after LE was disclosed. Missing valid change in circumstance. To cure, provided corrected PC CD along with LOE to borrower and evidence of deliver.
   
Reviewer Comment (2019-08-08): Upon further review, the exception is cleared.
 
 
Seller Comment (2019-08-07): Fees in question are not subject to tolerance as borrower did not utilize the provider we chose.  Fees are in Section C for this reason.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Wire /Funding/ Disbursement Fee.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
Wire Fee was not disclosed on the initial LE but on the final CD reads XXXXX. It appears the borrower was not notified of this additional fee after LE was disclosed. Missing valid change in circumstance. To cure, provided corrected PC CD along with LOE to borrower and evidence of deliver.
   
Reviewer Comment (2019-08-08): Upon further review, the exception is cleared.
 
 
Seller Comment (2019-08-07): Fees in question are not subject to tolerance as borrower did not utilize the provider we chose.  Fees are in Section C for this reason.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Policy Guarantee Fee.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
Policy Fee was not disclosed on the initial LE but on the final CD reads XXXXX. It appears the borrower was not notified of this additional fee after LE was disclosed. Missing valid change in circumstance. To cure, provided corrected PC CD along with LOE to borrower and evidence of deliver.
   
Reviewer Comment (2019-08-08): Upon further review, the exception is cleared.
 
 
Seller Comment (2019-08-07): Fees in question are not subject to tolerance as borrower did not utilize the provider we chose.  Fees are in Section C for this reason.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
This exception is due to open XXXXX or XXXXX tolerance exceptions and will be cured when all tolerance violations are resolved.
   
Reviewer Comment (2019-08-08): Upon further review, the exception is cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $XXXXX exceeds tolerance of $XXXXX plus XXXXX or $XXXXX.  Insufficient or no cure was provided to the borrower.
Total amount of $XXXXX (Title-Endorsement, Title - Abstract,  Title-Settlement/Closing, Title-Courier, Title-Electronic Delivery and Title-Recording fees all increased after initial LE without a valid change in circumstance) exceeds tolerance of $XXXXX plus XXXXX or $XXXXX.  Insufficient or no cure was provided to the borrower
   
Reviewer Comment (2019-08-08): Upon further review, the exception is cleared.
 
 
Seller Comment (2019-08-07): Fees in question are not subject to tolerance as borrower did not utilize the provider we chose.  Fees are in Section C for this reason.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Homeowner's Insurance Premium Months
TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.
Final CD reads an annual premium collected of XXXXX. Declaration page reflects annual premium under prepaid as XXXXX (XXXXX/month); monthly amount collected under escrows is XXXXX. To cure, provided corrected PC CD along with LOE to borrower and evidence of deliver.
   
Reviewer Comment (2019-08-08): Upon further review, the exception is cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Title Update.  Fee Amount of $XXXXX exceeds tolerance of XXXXX.  Insufficient or no cure was provided to the borrower.
Title Update fee was not disclosed on the initial LE but on the final CD reads $XXXXX. It appears the borrower was not notified of this additional fee after LE was disclosed. Missing valid change in circumstance. To cure, provided corrected PC CD along with LOE to borrower and evidence of deliver.
   
Reviewer Comment (2019-08-08): Upon further review, the exception is cleared.
 
 
Seller Comment (2019-08-07): Fees in question are not subject to tolerance as borrower did not utilize the provider we chose.  Fees are in Section C for this reason.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-08-13): A secondary valuation has been provided with XXXXX variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
The notary date was XXXXX.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - Wholesale Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
The lender contact name and contact NMLS ID were not provided.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Seller Closing Disclosure
TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.
There's no evidence of a Seller CD found in the loan file.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
Title Recording Fee was not disclosed on Loan Estimate.  File does not contain a valid COC for this fee, nor evidence of cure. It was not the same vendor as others.
   
Reviewer Comment (2019-08-09): Tolerance exceptions are addressed. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Recording Service Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Title Recording Fee was not disclosed on Loan Estimate.  File does not contain a valid COC for this fee, nor evidence of cure. It was not the same vendor as others.
   
Reviewer Comment (2019-08-09): XXXXX received PCCD correcting fee placement and LOE. Exception Cured.
 
 
Seller Comment (2019-08-08): CD and LOX
 
 
Reviewer Comment (2019-08-07): Title - Recording Service Charge fee is a zero tolerance fee as it was disclosed in Section B as a non-shoppable fee, not paid a party on the SSPL and a valid COC was not provided for the fee addition.  If Borrower was able to shop for this service the fee should be disclosed in Section C, or if the Borrower chosen provider required the fee, it should be disclosed in Section C.  A Corrected CD, copy of refund check, if applicable, letter of explanation and proof of delivery is required to cure.
 
 
Seller Comment (2019-08-06): Hello,
this is a XXXXX% fee, Please Re review.
Thank you
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
CD statement reflects a closing date of XXXXX however borrower signed on XXXXX.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
There's no evidence of a secondary valuation as required for securitization.
   
Reviewer Comment (2019-08-13): A secondary valuation was provided with XXXXX variance.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
Secondary valuation product is missing from subject file; file reflects Lender's Desk Review only.
   
Reviewer Comment (2019-08-13): A secondary valuation was provided with XXXXX variance.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Disclosure reflects Closing Date of XXXXX, but transaction consummation (mortgage notary) date was XXXXX.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien
TRID Final Closing Disclosure XXXXX on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.)
No seller-paid fees were listed and a seller CD was not provided.
   
Reviewer Comment (2019-08-09): XXXXX received seller's CD. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Seller Closing Disclosure Contains Fees not reflected on Consumer's Final Closing Disclosure
TILA-RESPA Integrated Disclosure: the Seller's final CD contained fees not reflected on the consumer's CD.
XXXXX received seller's CD. TRID requires any fee that is charged to the Seller to be reflected on the Consumer's CD as a Seller paid fee as well.  A Corrected CD and LOE is required to cure.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.
       
Reviewer Comment (2019-08-08): Appraisal provided. Exception cleared.
 
 
Seller Comment (2019-08-07): Appraisal date is XXXXX months after disaster ended.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Insurance
Insurance Documentation
Missing Document: Flood Insurance Policy not provided
 
The file was missing a copy of the flood policy.
   
Reviewer Comment (2019-08-08): Received flood insurance policy
 
 
Seller Comment (2019-08-07): Flood ins
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Property - Appraisal
Appraisal Documentation
Missing Document: Appraisal not provided
 
The file was missing a copy of the 1004 appraisal report. .
   
Reviewer Comment (2019-08-08): Appraisal provided. Exception cleared.
 
 
Seller Comment (2019-08-07): Appraisal
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Asset
Asset Calculation / Analysis
Available for Closing is insufficient to cover Cash From Borrower.
 
The file was missing all XXXXX bank statements supporting reserves and funds to close.
   
Reviewer Comment (2019-08-12): Additional Bank Statements provided and input from the loan file, exception cleared.
 
 
Seller Comment (2019-08-07): XXXXX Assets
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
The file was missing secondary appraisal report. Collateral score was a 4.
   
Reviewer Comment (2019-08-12): Desk review provided with no variance. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Legal / Regulatory / Compliance
Title / Lien Defect
Final Title Policy is missing. No evidence of title in file.
 
The title commitment report was missing from the loan file.
   
Reviewer Comment (2019-08-12): Title Commitment provided, exception cleared.
 
 
Seller Comment (2019-08-07): Title
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Closing Disclosure Timing without Waiver
TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.
Only Final CD provided in file.
   
Reviewer Comment (2019-08-08): XXXXX received required documents, exception is cleared.
 
 
Seller Comment (2019-08-07): Initial CD
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
No Defined Cure
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File
TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $XXXXX may be required.
The file was missing all LE's.
   
Reviewer Comment (2019-08-08): XXXXX received required documents, exception is cleared.
 
 
Seller Comment (2019-08-07): LEs
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
No Defined Cure
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Seller Closing Disclosure
TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.
The file was missing the sellers disclosure statement.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Servicing Disclosure Status
File does not evidence the consumer was provided with the Servicing Disclosure.
The file was missing servicing disclosure and Initial LE.
   
Reviewer Comment (2019-08-08): XXXXX received required documents, exception is cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Good faith redisclosure
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
RESPA Disclosure - List of Homeownership Counseling Organizations Missing
RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower.
The file was missing list of home ownership counseling statement.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
The file was missing LO compensation disclosure.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Appraisal Disclosure - ECOA Status
ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.
The file was missing right to receive appraisal disclosure and Initial LE.
   
Reviewer Comment (2019-08-08): XXXXX received required documents, exception is cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Good faith redisclosure
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Invalid Section B Combinations
TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on 07/11/2019 reflects a fee Paid To lender or broker for fee within Services Borrower Did Not Shop For section.
The appraisal desk review is paid by the lender to the lender.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Good Faith Redisclosure
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Approval not provided
 
Copy of approval not provided in file; XXXXX with explanations was provided.
   
Reviewer Comment (2019-08-08): Received loan approval
 
 
Seller Comment (2019-08-07): UW Approvals
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor
Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.
Copy of disclosure not provided in file.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Home Loan Toolkit Timing
Truth in Lending Act (2015): Creditor or broker did not provide the Home Loan Toolkit Disclosure to applicant within 3 business days of application.
Evidence of being provided is dated at closing.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
No Defined Cure
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Income / Employment
Income Documentation
Income Docs Missing:
-
VVOE for Borrower dated 10 days prior to note is not provided in file.
   
Reviewer Comment (2019-08-08): Received VVOE dated XXXXX.
 
 
Seller Comment (2019-08-07): VOE - please read ALL of the pages
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Income / Employment
Income Documentation
REO Documents are missing.
-
Copy of statement to verify escrows included in payment not provided in file.
   
Reviewer Comment (2019-08-08): Received statement verifying payment includes escrows.
 
 
Seller Comment (2019-08-07): Mortgage statement
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation
ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.
     
Buyer Comment (2019-08-13): No A/L or outside SOL
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
D
B
D
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Non-Employment Income - Implicit Adherence
Qualified Mortgage (Dodd-Frank 2014): Borrower's loan file contained tax returns that are not signed/dated, but the loan file contains the tax transcripts to evidence the tax returns were signed/dated at time of submission to the IRS.
Per guidelines, a tax transcript obtained directly from the IRS may be used in lieu of signed tax returns. Personal tax returns provided in file are not signed.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self Employed - Implicit Adherence
Qualified Mortgage (Dodd-Frank 2014): Self Employed borrower's loan file contained tax returns that are not signed/dated, but the loan file contains the tax transcripts to evidence the tax returns were signed/dated at time of submission to the IRS.
Per guidelines, a tax transcript obtained directly from the IRS may be used in lieu of signed tax returns. Personal tax returns provided in file are not signed.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Provided Prior to Date Performed
ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.
Per documentation in file, the borrower received a copy of the appraisal on XXXXX, which is prior to the appraisal report date of XXXXX. Only one copy of appraisal provided.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
Appraisal fee disclosed as $XXXXX on the LE dated XXXXX; but disclosed as $XXXXX on the Final Closing Disclosure. Cure was provided.
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Final CD evidences Cure
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Guideline Requirement: PITIA reserves months discrepancy.
 
Lender used XXXXX account in assets.  This account is missing from documents and creating shortage of reserves.
   
Reviewer Comment (2019-08-12): Additional statements provided from XXXXX to support reserves
 
 
Seller Comment (2019-08-07): Please see attached XXXXX Statements.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Alternate Table Usage
TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.
PCCD issued on XXXXX did not have Costs at Closing/ Calculating Cash to Close.
   
Reviewer Comment (2019-08-06): PCCD is corrected
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Good Faith Redisclosure
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on 07/01/2019 disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
This exception is due to open XXXXX or XXXXX tolerance exceptions and will be cured when all tolerance violations are resolved.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Change in Circumstance in file does not indicate Loan discount Points at all.  Loan Discount Points was not disclosed on the initial LE but on the final CD reads $XXXXX. It appears the borrower was not notified of this additional fee after LE was disclosed. Missing valid change in circumstance. To cure, provided corrected PC CD along with LOE to borrower and evidence of deliver.
   
Reviewer Comment (2019-08-14): A cure is indicated on the final CD .Exception Cleared.
 
 
Seller Comment (2019-08-13): COC
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
XXXXX Report Fee was disclosed on the initial LE of $XXXXXbut on the final CD reads $XXXXX. It appears the borrower was not notified of this increased fee after LE was disclosed. Missing valid change in circumstance. To cure, provided corrected PC CD along with LOE to borrower and evidence of deliver.
   
Reviewer Comment (2019-08-14): A cure is indicated on the final CD .Exception Cleared.
 
 
Seller Comment (2019-08-13): Proof of tolerance cure
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-08-13): A secondary valuation was provided with XXXXX variance.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Provided Prior to Date Performed
ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.
The appraisal effective date is listed as XXXXX indicating it was updated prior to the final signature date on the report. Only one copy was provided.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower.
     
Reviewer Comment (2019-08-14): A cure is indicated on the final CD .Exception Cured.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower.
     
Reviewer Comment (2019-08-14): A cure is indicated on the final CD .Exception Cured.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
C
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
Cure for various XXXXX%  tolerance violations $XXXXX was provided on Post Close CD dated XXXXX. Need LOE or proof sent to the borrower.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower.
Appraisal fee disclosed as $XXXXX on the LE dated XXXXX; but disclosed as $XXXXXon the Final Closing Disclosure. Cure was provided on Post Close CD dated XXXXX, need evidence LOE sent to the borrower.
   
Buyer Comment (2019-08-13): No A/L or outside SOL
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
There's no evidence of a secondary valuation as require for securitization.
   
Reviewer Comment (2019-08-13): A secondary valuation was provided with XXXXX variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self Employed - Implicit Adherence
Qualified Mortgage (Dodd-Frank 2014): Self Employed borrower's loan file contained tax returns that are not signed/dated, but the loan file contains the tax transcripts to evidence the tax returns were signed/dated at time of submission to the IRS.
Personal Tax Returns were provided, but not signed, however transcripts were provided for the same years in loan file.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Fee Terminology
TILA-RESPA Integrated Disclosure: Final Closing Disclosure provided on XXXXX did not use the same fee terminology as the Loan Estimate.
LE dated XXXXX disclosed a Title - Examination Fee of $XXXXX, then CD dated XXXXX (including the final CD dated XXXXX) disclosed/revised the fee as a Title - Chain of Title Fee for $XXXXX.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Insurance
Insurance Analysis
Insufficient Coverage: Hazard insurance coverage amount is insufficient.
 
XXXXX tests hazard coverage in accordance with Fannie Mae, which requires coverage equal to or the lesser of the following: 1) XXXXX of the insurable value of the improvements, as established by the property insurer; or 2) the unpaid principal balance of the mortgage, as long as it at least equals the minimum amount-XXXXX of the insurable value of the improvements-required to compensate for damage or loss on a replacement cost basis. If it does not, then coverage that does provide the minimum required amount must be obtained. Coverage shortfall $XXXXX
   
Reviewer Comment (2019-08-12): Replacement Cost Estimator provided and input from the lender, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
There's no evidence of a secondary valuation as required for securitization.
   
Reviewer Comment (2019-08-13): A secondary valuation was provided with XXXXX variance.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Income / Employment
Income Documentation
REO Documents are missing.
-
Final 1003 provided conflicting evidence of $XXXXX per month for the borrower's previous primary. To request evidence $XXXXX per month is not included and/or provided corrected Final 1003. The result is a DTI variance >XXXXX%. Property Inspection Report in file does not verify taxes and not known if Mortgage Statement includes P&I + Insurance or PITI.
   
Reviewer Comment (2019-08-12): PITI and HOA is confirmed within the Mortgage and HOA Payment.
 
 
Seller Comment (2019-08-12): revised XXXXX removing the XXXXX - should not have been there. The mortgage payment on this property  (condo) includes escrows, per the mortgage statement in the file. The DTI includes the full PITIA verified on her departure residence.
 
 
Seller Comment (2019-08-12): Mortgage coupon and HOA dues.  Property is a condo.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation
ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.
A desk review was completed but not provided to the borrower. No value provided on the desk review.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
CD closing date of XXXXX signed XXXXX.
   
Reviewer Comment (2019-08-07): PCCD corrected issue.
 
 
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - Wholesale Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
Lender contact was not provided.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Invalid Section B Combinations
TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on XXXXX reflects a fee Paid To lender or broker for fee within Services Borrower Did Not Shop For section.
Tax Service and Flood Cert payed to Lender in section B.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Good Faith Redisclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
This exception is due to open XXXXX% or XXXXX% tolerance exceptions and will be cured when all tolerance violations are resolved
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Lender Credit Tolerance Violation
TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $XXXXX is less than amount of binding Lender Credit previously disclosed in the amount of $XXXXX
Decrease due to rate lock.
   
Reviewer Comment (2019-08-13): The COC was the rate lock
 
 
Seller Comment (2019-08-12): COC
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation
ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.
     
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - Wholesale Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
The lender contact name and contact NMLS ID were not provided.
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
This exception is due to open XXXXX or XXXXX tolerance exceptions and will be cured when all tolerance violations are resolved
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Lender Credit Tolerance Violation
TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $XXXXX  is less than amount of binding Lender Credit previously disclosed in the amount of $XXXXX.
The lender credit changed onXXXXX.
   
Reviewer Comment (2019-08-13): The COC was a rate change from the borrower
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Invalid Section B Combinations
TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on XXXXX reflects a fee Paid To lender or broker for fee within Services Borrower Did Not Shop For section.
Final Cd reads payable to "Lender"
   
Reviewer Comment (2019-08-12): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Good Faith Redisclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Provided Prior to Date Performed
ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.
     
Buyer Comment (2019-08-14): ok to accept
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
     
Reviewer Comment (2019-08-13): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
B
B
A
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.
     
Reviewer Comment (2019-08-13): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
B
B
A
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Final CD shows Closing date as XXXXX compared to a notary of XXXXX on the Security Instrument, please provided updated CD or PCCD.
   
Reviewer Comment (2019-08-13): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
B
B
A
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
XXXXX State - Final CD reflects closing date of XXXXX.  Loan was consummated on XXXXX.
   
Reviewer Comment (2019-08-13): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
B
B
A
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $XXXXX exceeds tolerance of $XXXXX plus XXXXX% or $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
         
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Final CD evidences Cure
B
B
A
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Insurance
Insurance Analysis
Hazard Insurance Policy expires within 90 days of the Note Date.
Hazard Insurance Policy Expiration Date ___, Note Date ___
     
Buyer Comment (2019-08-13): Ok to accept. Comp factors: DTI, LTV/CLTV
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
B
B
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
       
Reviewer Comment (2019-08-16): A secondary valuation was provided with XXXXX variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
B
B
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Final CD disclosed a Closing Date of XXXXX, however, the actual date of consummation is XXXXX per Security Instrument.
   
Reviewer Comment (2019-08-13): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
B
B
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Total Property Costs Year 1 - XXXXX Test
TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of XXXXX on Final Closing Disclosure provided on XXXXX not accurate.
Final CD disclosed Amount of Estimated Property Costs over Year 1 of XXXXX, however, the actual amount is $XXXXX.
   
Reviewer Comment (2019-08-14): Letter of Explanation & Corrected Closing Disclosure provided.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
B
B
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
     
Reviewer Comment (2019-08-13): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
B
B
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Missing Final XXXXX
       
Reviewer Comment (2019-08-16): Final 1003 provided. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
RESPA -  Initial Escrow Account Statement Missing
RESPA: Initial escrow account statement was not provided to the borrower.
Disclosure is not present in documents.
   
Reviewer Comment (2019-08-13): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
Due to tolerance violation.
   
Reviewer Comment (2019-08-13): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Re-Issue Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
No cure for tolerance fee overage of the credit debt report
   
Reviewer Comment (2019-08-14): Credit Report Reissue Fee disclosed as Undisclosed Debt Report on LE and CD.
 
 
Seller Comment (2019-08-12): undislosed debt report is on the final loan estimate in file, please clear
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Seller Closing Disclosure
TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.
TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.
   
Reviewer Comment (2019-08-13): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Prepaid Property Tax Months
TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXX did not disclose number of months for Property Tax under Prepaids.
Final CD is missing the number of months.
   
Reviewer Comment (2019-08-13): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
XXXXX risk score is XXXXX; secondary appraisal product is required.
   
Reviewer Comment (2019-08-16): Secondary valuation provided with XXXXX variance.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $XXXXX exceeds tolerance of $XXXXX plus XXXXX% or $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
         
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Final CD evidences Cure
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Legal / Regulatory / Compliance
Title / Lien Defect
Final Title Policy is missing. No evidence of title in file.
       
Reviewer Comment (2019-08-15): Exception cleared.
 
 
Seller Comment (2019-08-12): XXXXX always forwards final title policies when they are received from title companies. Please clear
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
Desk Review / AVM not provided.
   
Reviewer Comment (2019-08-16): Secondary valuation provided with XXXXX variance.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Loan Package Documentation
Application / Processing
Missing Document: Missing Lender's Initial 1003
       
Reviewer Comment (2019-08-13): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
 
C
C
A
A
B
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
Sufficient or excess cure was provided to the borrower at Closing
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
Final CD evidences Cure
C
C
A
A
B
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Legal / Regulatory / Compliance
Title / Lien Defect
Final Title Policy is missing. No evidence of title in file.
 
There's no evidence of a Final Title Policy in the loan file.
   
Reviewer Comment (2019-08-16): Preliminary title provided. Exception cleared.
 
 
Seller Comment (2019-08-15): Please clear the Title Commitment. The Final Title Policy will not yet be available since this is XXXXX. Pre-lim is acceptable.
 
 
Reviewer Comment (2019-08-12): File is missing commitment also. Please provide Title Commitment.
 
 
Seller Comment (2019-08-12): Title commitment is in file. XXXXX will forward title policy upon receipt; this has always been our policy, please clear
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
FEMA Disaster Issue: The most recent valuation inspection is dated prior to the most recent FEMA disaster.
 
Missing copy of the inspection dated after the disaster date of XXXXX
   
Reviewer Comment (2019-08-26): 2055 Drive-by provided. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
C
C
A
B
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided onXXXXX disclosed a Closing Date that did not match the actual date of consummation.
Final CD on XX/XX/XXXX disclosed a Closing Date of XXXXX that did not match the actual date of consummation per the notary on the Security Instrument of XXXXX. PCCD
   
Reviewer Comment (2019-08-20): Cleared exception with Post Closing CD Dated XXXXX.
 
 
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
C
C
A
B
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller Change - Total Payoffs
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX incorrectly disclosed whether there was a change in the Total Payoffs and Payments.
Final Closing Disclosure provided on XXXXX incorrectly disclosed whether there was a change in the Total Payoffs and Payments.
   
Reviewer Comment (2019-08-20): Cleared exception with Post Closing CD Dated XXXXX.
 
 
Reviewer Comment (2019-08-20): Cleared exception with Post Closing CD.
 
 
Reviewer Comment (2019-08-20): PCCD provided corrected whether there was a change in mortgage payoff amount.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
C
C
A
B
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Property - Appraisal
Appraisal Documentation
Missing Document: Appraisal not provided
       
Reviewer Comment (2019-08-20): Property Inspection Waiver provided in loan file.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
D
C
D
A
C
A
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.
 
FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.
   
Reviewer Comment (2019-08-26): 2055 Drive-bay provided. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
D
C
D
A
C
A
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Closing Disclosure Timing without Waiver
TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.
Disclosure not provided in time frame allowed.
   
Reviewer Comment (2019-08-22): Earlier receipt provided.
 
 
Seller Comment (2019-08-22): initial CD issued and acknowledged by borrower on XXXXX. note date XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
No Defined Cure
D
C
D
A
C
A
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Revised Loan Estimate Timing Before Closing
TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on XXXXX not received by borrower at least four (4) business days prior to closing.
There's no evidence of tracking for the LE dated XXXXXin the loan file.
   
Reviewer Comment (2019-08-21): XXXXX reviewed disclosure tracking. The XXXXX LE was received the same day. Exception Cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
No Defined Cure
D
C
D
A
C
A
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Total Property Costs Year 1 - XXXXX Test
TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of XXXXX on Final Closing Disclosure provided on XXXXX not accurate.
Amount provided on the final CD does not appear to be correct based on the amount of property taxes and homeowners insurance verified. Annual property taxes of $XXXXX listed on title and annual Homeowners insurance of $XXXXX total.
   
Reviewer Comment (2019-08-26): Property profile utilized for CD tax amount which did not include the supplemental tax. Tax disclosed in good faith. Exception cleared.
 
 
Reviewer Comment (2019-08-21): XXXXX reviewed exception. The allowable tolerance for the escrow account fields on page four of the CD is $XXXXX per month of property costs or $XXXXX for 12 months. Total disclosed on page four of CD is $XXXXX and documentation in images indicates total should be $XXXXX ($XXXXX HOI, $XXXXX Taxes, and $XXXXX Supplemental Taxes).  Please provide verification if using an updated amount.  Letter of Explanation and Corrected CD required to cure.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
D
C
D
A
C
A
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.
 
Disaster date is XXXXX. XXXXX years prior to closing. An appraisal confirming the subject was not affected would have been completed prior to the purchase of the subject which was well after the disaster date.
   
Reviewer Comment (2019-08-26): 2055 Drive-by appraisal provided. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
C
C
A
C
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Payoff Statement Missing
Missing Payoff Statement: Unable to determine if a prepayment penalty was included in the pay-off which may impact high cost findings.
     
Reviewer Comment (2019-08-27): Payoff provided. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
C
C
A
C
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date
Truth in Lending Act:  Subject loan transaction disbursed on XXXXX, prior to three (3) business days from transaction date of XXXXX.
RTC expiration date is XXXXX.
   
Reviewer Comment (2019-08-28): PCCD provided verifying transaction date and disbursement date. Rescission requirements met. Exception cleared.
 
 
Reviewer Comment (2019-08-27): Final CD reflects transaction date of XXXXX with a disbursement date of XXXXX. Final CD was signed on XXXXX. ROR reflects rescission ends on XXXXX. Appears Final CD needs corrected to reflect both the actual Close Date and actual disbursement date.
 
 
Reviewer Comment (2019-08-22): To cure the following is needed: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form
C
C
C
A
C
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Total Property Costs Year 1 - XXXXX Test
TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of XXXXX on Final Closing Disclosure provided on XXXXX not accurate.
Amount of Estimated Property Costs over Year 1 on final CD reads XXXXX. Per documentation in file taxes are $XXXXX and HOA $XXXXX = XXXXX=XXXXX  Provided corrected PC CD along with LOE to borrower and evidence of deliver.
   
Reviewer Comment (2019-08-22): HO-6 premium included in property costs.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Letter of Explanation & Corrected Closing Disclosure
C
C
C
A
C
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Final closing disclosure was signed and dated by the borrower on XXXXX but was dated XXXXX with a disbursement date of XXXXX.
   
Buyer Comment (2019-08-26): No A/L or outside SOL
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Letter of Explanation & Corrected Closing Disclosure
C
C
C
A
C
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Income / Employment
Income Documentation
Income Docs Missing:
-
Missing XXXXX W2 for XXXXX income and most recent paystub from XXXXX per underwriting worksheet.
   
Reviewer Comment (2019-08-28): WVOE provided for breakout of XXXXX income. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
C
C
A
C
B
C
C
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - Wholesale Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
Final Closing Disclosure is missing Complete Lender's Contact Name and NMLS ID number on Page 5 of the Final CD.
   
Reviewer Comment (2019-08-26): Client elects to waive.
 
 
Reviewer Comment (2019-08-22): After further review.  Exception must be reopened base on current deal settings selected by Client.   Client has elected to include lender individual contact name in testing on wholesale loans."
 
 
Reviewer Comment (2019-08-22): Sufficient lender contact was disclosed as a general email address and/or phone number on a brokered loan is acceptable.
 
 
Seller Comment (2019-08-21): Per TILA Commentary 1026.37(k)-3 the primary contact for the borrower should be listed which is generally the loan officer of the broker on broker loans.  The loan officer of the broker's contact information is listed on the CD on this loan (i.e. NMLS ID, name and email address).  Additionally, per TILA Commentary 1026.37(k)-4 disclosure of a general number for the lender satisfies this requirement.
Please rescind. Thank you
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $XXXXX exceeds tolerance of $XXXXX plus XXXXX% or $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
There was a Ten Percent Tolerance Exception without a cure in the loan file.
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Final CD evidences Cure
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
There's no evidence of a secondary valuation as required for securitization..
   
Reviewer Comment (2019-08-29): Secondary valuation provided with XXXXX variance.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - Wholesale Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
The Final CD does not list complete lender contact information on page 5.
   
Reviewer Comment (2019-08-26): Client elects to waive.
 
 
Reviewer Comment (2019-08-22): XXXXX reviewed exception. If primary contact for borrowers was broker please provide attestation. The client has chosen to include individual name for lender in testing. A corrected CD and LOE is required to cure if primary contact with borrowers was not with broker.
 
 
Seller Comment (2019-08-21): Per TILA Commentary 1026.37(k)-3 the primary contact for the borrower should be listed which is generally the loan officer of the broker on broker loans.  The loan officer of the broker's contact information is listed on the CD on this loan (i.e. NMLS ID, name and email address).  Additionally, per TILA Commentary 1026.37(k)-4 disclosure of a general number for the lender satisfies this requirement.
Please rescind. Thank you
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
CD has closing date of XXXXX. Borrowers signed XXXXX per notary on Security Instrument. To provide updated PCCD.
   
Reviewer Comment (2019-08-22): XXXXX received PCCD correcting close date and LOE. Exception Cured.
 
 
Seller Comment (2019-08-21): Please see attached revised CD, LOX, tracking, please clear.  Thank you.
 
 
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
There's no evidence of a secondary valuation as required for securitization in the loan file.
   
Reviewer Comment (2019-08-29): Secondary valuation provided with XXXXX variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $XXXXX exceeds tolerance of $XXXXX plus XXXXX% or $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
There's a Ten Percent Tolerance violation without a cure in the loan file that was provide at or post closing with LOE to borrowers.
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Final CD evidences Cure
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - Wholesale Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
Final CD provided on XXXXX did not disclose the required Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name.
   
Reviewer Comment (2019-08-26): Client elects to waive.
 
 
Reviewer Comment (2019-08-22): Client has elected to include lender individual contact name in testing on wholesale loans.
 
 
Seller Comment (2019-08-21): Per TILA Commentary 1026.37(k)-3 the primary contact for the borrower should be listed which is generally the loan officer of the broker on broker loans.  The loan officer of the broker's contact information is listed on the CD on this loan (i.e. NMLS ID, name and email address).  Additionally, per TILA Commentary 1026.37(k)-4 disclosure of a general number for the lender satisfies this requirement.
Please rescind. Thank you.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
B
B
A
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
There's no evidence of a secondary valuation as required for securitization.
   
Reviewer Comment (2019-08-29): Secondary valuation provided with XXXXX variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - Wholesale Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
Complete Contact info was not provided on page 5 of the Final CD in loan file.
   
Reviewer Comment (2019-08-26): Client elects to waive.
 
 
Reviewer Comment (2019-08-22): Client has elected to include lender individual contact name in testing on wholesale loans.
 
 
Seller Comment (2019-08-21): Please rescind condition-Per TILA Commentary 1026.37(k)-3 the primary contact for the borrower should be listed which is generally the loan officer of the broker on broker loans.  The loan officer of the broker's contact information is listed on the CD on this loan (i.e. NMLS ID, name and email address).  Additionally, per TILA Commentary 1026.37(k)-4 disclosure of a general number for the lender satisfies this requirement.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - XXXXX Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX9 did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
Final Closing Disclosure does not include complete  Lender's Contact Name and NMLS ID number on page 5 of the Final CD.
   
Reviewer Comment (2019-08-26): Client elects to waive.
 
 
Reviewer Comment (2019-08-22): Client has elected to include lender individual contact name in testing on XXXXX loans.
 
 
Seller Comment (2019-08-21): Please rescind condition- Per TILA Commentary 1026.37(k)-3 the primary contact for the borrower should be listed which is generally the loan officer of the broker on broker loans.  The loan officer of the broker's contact information is listed on the CD on this loan (i.e. NMLS ID, name and email address).  Additionally, per TILA Commentary 1026.37(k)-4 disclosure of a general number for the lender satisfies this requirement.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
There's no evidence of a secondary valuation as required for securitization in the loan file.
   
Reviewer Comment (2019-08-29): Secondary valuation provided with XXXXX variance.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - XXXXX Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
Complete Lender contact information was not provided on page 5 of the Final CD.
   
Reviewer Comment (2019-08-26): Client elects to waive.
 
 
Reviewer Comment (2019-08-22): Client has elected to include lender individual contact name in testing on XXXXX loans.
 
 
Seller Comment (2019-08-21): Please rescind - Per TILA Commentary 1026.37(k)-3 the primary contact for the borrower should be listed which is generally the loan officer of the broker on broker loans.  The loan officer of the broker's contact information is listed on the CD on this loan (i.e. NMLS ID, name and email address).  Additionally, per TILA Commentary 1026.37(k)-4 disclosure of a general number for the lender satisfies this requirement.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Insurance
Insurance Analysis
Insufficient Coverage: Hazard insurance coverage amount is insufficient.
 
XXXXX tests hazard coverage in accordance with XXXXX, which requires coverage equal to or the lesser of the following: 1) XXXXX of the insurable value of the improvements, as established by the property insurer; or 2) the unpaid principal balance of the mortgage, as long as it at least equals the minimum amount-XXXXX% of the insurable value of the improvements-required to compensate for damage or loss on a replacement cost basis. If it does not, then coverage that does provide the minimum required amount must be obtained. Coverage shortfall $XXXXX
   
Reviewer Comment (2019-09-06): Exception cleared.
 
 
Reviewer Comment (2019-09-04): The hazard policy does not indicate "XXXXX". Need a similar like construction dwelling replacement cost or replacement cost estimator. Exception remains.
 
 
Seller Comment (2019-09-03): Please see attached
 
 
Reviewer Comment (2019-08-29): Policy read a dwelling coverage of $XXXXX and includes replacement cost coverage on the dwelling. Estimated cost new $XXXXX. Loan amount $XXXXX - $XXXXXdwelling coverage = $XXXXX short coverage. Exception remains.
 
 
Seller Comment (2019-08-26): Per XXXXX guidelines we would only need to go off of what the insurance company deems the replacement cost of the property. We currently have an endorsement that shows we have replacement cost on the policy so we are okay with this one. Please rescind condition.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
B
C
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - XXXXX Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
Final Closing Disclosure is missing Complete Lender's Contact Name and NMLS ID number on page 5 of the Final CD.
   
Reviewer Comment (2019-08-26): Client elects to waive.
 
 
Reviewer Comment (2019-08-22): Client has elected to include lender individual contact name in testing on XXXXX loans.
 
 
Seller Comment (2019-08-21): Please rescind - Per TILA Commentary 1026.37(k)-3 the primary contact for the borrower should be listed which is generally the loan officer of the broker on broker loans.  The loan officer of the broker's contact information is listed on the CD on this loan (i.e. NMLS ID, name and email address).  Additionally, per TILA Commentary 1026.37(k)-4 disclosure of a general number for the lender satisfies this requirement.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
There's no evidence of a secondary valuation as required for securitization.
   
Reviewer Comment (2019-08-29): Secondary valuation provided with XXXXX variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - XXXXX Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX9 did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
The lenders contact information was missing from the final CD statement (page 5).
   
Reviewer Comment (2019-08-26): Client elects to waive.
 
 
Reviewer Comment (2019-08-24): Client has elected to include lender individual contact name in testing on XXXXX loans.
 
 
Seller Comment (2019-08-23): Per TILA Commentary 1026.37(k)-3 the primary contact for the borrower should be listed which is generally the loan officer of the broker on broker loans.  The loan officer of the broker's contact information is listed on the CD on this loan (i.e. NMLS ID, name and email address).  Additionally, per TILA Commentary 1026.37(k)-4 disclosure of a general number for the lender satisfies this requirement.
 
 
Reviewer Comment (2019-08-22): Client has elected to include lender individual contact name in testing on XXXXX loans.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
B
B
A
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller Change - Total Payoffs
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX incorrectly disclosed whether there was a change in the Total Payoffs and Payments.
The payoff reflects a variance of XXXXX cents from LE to the final CD statement. Normally lender would include No, this did not change.
   
Reviewer Comment (2019-08-22): Letter of Explanation & Corrected Closing Disclosure provided.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
B
B
A
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - XXXXX Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required Lender Contact Information on page 5 of the Final CD.
   
Reviewer Comment (2019-08-26): Client elects to waive.
 
 
Reviewer Comment (2019-08-24): Client has elected to include lender individual contact name in testing on XXXXX loans.
 
 
Seller Comment (2019-08-23): Per TILA Commentary 1026.37(k)-3 the primary contact for the borrower should be listed which is generally the loan officer of the broker on broker loans.  The loan officer of the broker's contact information is listed on the CD on this loan (i.e. NMLS ID, name and email address).  Additionally, per TILA Commentary 1026.37(k)-4 disclosure of a general number for the lender satisfies this requirement.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance (Circuit 2, 5, 7, 8, 9, 10 or DC)
Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 form should have been used.
Notice of Right to Cancel was not executed on the proper Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 form should have been used as per evidenced on the Preliminary Title.
   
Reviewer Comment (2019-09-06): LOE, correct RTC model form and proof of delivery provided.
 
 
Reviewer Comment (2019-09-06): cleared by mistake
 
 
Reviewer Comment (2019-08-26): Updated H-9 Form provided, exception cleared.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form
C
B
C
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Income / Employment
Income Documentation
REO Documents are missing.
-
Per mortgage statement in file, PITI is included in statement in the amount of $XXXXX per month. However, lender includes the same amount rounded plus an additional $XXXXX per month in expenses which is causing a large variance with DTI. Please provide evidence of discrepancy.
   
Reviewer Comment (2019-08-28): Lender double counted T&I for REO located at  XXXXX Street whereas T&I was already included in the Mortgage Statement.
 
 
Seller Comment (2019-08-27): Please let them know that we did not mark this property as being escrowed resulting in the taxes and insurance to be double counted. The rest of the expenses are expenses reporting on the tax returns that are not able to be added back into our rental income calculation.   In this case this would not matter as we were being more conservative and the loan still qualifies.
 
 
Reviewer Comment (2019-08-26): There's no explanation of the missing $XXXXX in Final XXXXX for Insurance, Maintenance, Taxes and Misc for XXXXX. Without expense, DTI is significantly lower than updated XXXXX in file. The expenses doesn't appear in XXXXX, yet DTI would be lower without it. T&I is escrowed in statement provided. Perhaps it's for HOA, which hasn't been provided.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
C
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TILA Notice of Right to Cancel Expiration Date greater than Deal Start Date.
Rescission expiration date provided by lender on Notice of Right to Cancel has not expired as of time of review.
     
Reviewer Comment (2019-09-06): Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
C
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - XXXXX Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
Lender Contact Information not provided on page 5 of Final CD.
   
Reviewer Comment (2019-08-26): Client elects to waive.
 
 
Reviewer Comment (2019-08-24): Client has elected to include lender individual contact name in testing on XXXXX loans.
 
 
Seller Comment (2019-08-23): Per TILA Commentary 1026.37(k)-3 the primary contact for the borrower should be listed which is generally the loan officer of the broker on broker loans.  The loan officer of the broker's contact information is listed on the CD on this loan (i.e. NMLS ID, name and email address).  Additionally, per TILA Commentary 1026.37(k)-4 disclosure of a general number for the lender satisfies this requirement.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
B
B
A
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
There's no evidence of a secondary valuation as required for securitization.
   
Reviewer Comment (2019-08-29): Secondary valuation provided with XXXXX variance, exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
B
A
A
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Lender Contact Information - XXXXX Loans
TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXX did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name).
The lenders complete contact information was missing from the Final CD, page 5.
   
Reviewer Comment (2019-08-26): Client elects to waive.
 
 
Reviewer Comment (2019-08-24): Client has elected to include lender individual contact name in testing on XXXXX loans.  Under theXXXXX Scope, if lender attests that the primary contact point with the consumer was through the broker, and not the lender, we can clear the exception.
 
 
Seller Comment (2019-08-23): Per TILA Commentary 1026.37(k)-3 the primary contact for the borrower should be listed which is generally the loan officer of the broker on broker loans.  The loan officer of the broker's contact information is listed on the CD on this loan (i.e. NMLS ID, name and email address).  Additionally, per TILA Commentary 1026.37(k)-4 disclosure of a general number for the lender satisfies this requirement.
 
 
Reviewer Comment (2019-08-22): Client has elected to include lender individual contact name in testing on XXXXX loans.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Temporary SHQM (GSE/Agency Eligible) does not match Due Diligence Loan Designation of Non QM.
Loan designation failure due to DTI ratio greater than AUS, but lender rounded, we are within 3%.
   
Reviewer Comment (2019-08-23): Exception cleared
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Lender to provide updated ATR/QM status
C
B
A
A
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM DTI
Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds XXXXX and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.
Ratios is higher due to amount used for hazard insurance by lender is less than documented.
   
Reviewer Comment (2019-08-23): Exception cleared
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
B
A
A
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
The closing date reflects XXXXX however borrowers signed on XXXXX per Notary on Security Instrument. PCCD evident in file that updates closing date, but requesting evidence LOE was sent to borrowers.
   
Reviewer Comment (2019-08-22): Error correction in date cured.
 
 
Reviewer Comment (2019-08-22): Letter of Explanation & Corrected Closing Disclosure provided.
 
 
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
General Ability To Repay - Missing Investor Guideline Qualifying Total Debt Ratio
Unable to complete ATR testing due to missing investor guideline qualifying total debt ratio.
DTI is slightly higher than threshold ofXXXXX% per guidelines. HOA for REO property located at XXXXX was $XXXXX per month vs. $XXXXX in Final XXXXX and lender rounded final DTI.
   
Reviewer Comment (2019-08-23): Exception cleared
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
B
A
A
C
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
Only one appraisal was provided. Two are required for securitization.
   
Reviewer Comment (2019-08-26): Desk review provided with no variance. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
     
Reviewer Comment (2019-08-26): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
C
B
A
A
B
B
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
One valuation product is provided.
   
Reviewer Comment (2019-09-04): Provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Guideline Requirement: Occupancy discrepancy.
Property occupancy of ___ does not match Guideline property occupancy of ___.
Discrepancy between initial and final XXXXX for Co borrower XXXXX.  Initial disclosed as occupying, final declarations do not.
   
Reviewer Comment (2019-09-09): The initial XXXXX is correct and the lender provided an updated XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
System
General
Valuation address does not match Note address.
-
The Note unit number reflects XXXXX and Appraisal unit number reflects XXXXX
   
Reviewer Comment (2019-09-06): Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
System
General
Closing Disclosure Subject Address does not match Note address.
-
The Note unit number reflects XXXXX and CD issued XXXXX and XXXXX unit number reflects XXXXX however, Final CD reflects the correct unit number XXXXX.
   
Reviewer Comment (2019-09-04): The legal for the deed and title match
 
 
Seller Comment (2019-09-03): The final CD shows the unit number that matches the Note so this is a non-issue.  Thank you,
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Provided Prior to Date Performed
ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.
Per documentation in file, appraisal provided to borrower XXXXX, appraisal was updated XXXXX.
   
Reviewer Comment (2019-09-04): Client Elects to Waive
 
 
Reviewer Comment (2019-09-04): Please indicate the appraisal was provided prior to the report date.
 
 
Seller Comment (2019-09-03): Effective date on Appraisal was XXXXX and sent to borrowerXXXXX
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Escrowed Property Costs Year 1 -  XXXXX Test
TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Escrowed Property Costs over Year 1 of XXXXX on Final Closing Disclosure provided on XXXXX not accurate.
Final CD Escrowed Property Costs Year 1 reflects $XXXXX which is based on XXXXX months and calculated Escrowed Property Costs Year 1 should be at least $XXXXX
   
Reviewer Comment (2019-09-06): Confirmed figures on page 4 of the Final CD
 
 
Seller Comment (2019-09-04): Please Clear - XXXXX uses XXXXX months to calculate Escrow Property Costs Over Year 1.
 
 
Reviewer Comment (2019-09-04): No PCCD was provided.
 
 
Seller Comment (2019-09-03): CD is correct. XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
C
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
Evidence that appraisal was provided to borrower at or before closing is missing from file.
   
Reviewer Comment (2019-09-04): Client Elects to Waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
B
B
A
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $XXXXX exceeds tolerance of $XXXXX plus XXXXX or $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
Cure of $XXXXX was disclosed on the Final Closing Disclosure, which is sufficient to cure the XXXXX tolerance violation of $XXXXX.
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Final CD evidences Cure
C
A
A
A
A
A
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
One valuation provided.
   
Reviewer Comment (2019-09-04): Provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
A
A
A
A
C
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Total Property Costs Year 1 - XXXXX Test
TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of XXXXX on Final Closing Disclosure provided on XXXXX not accurate.
Documented property costs are $XXXXX (documentation based on hazard $XXXXX and taxes $XXXXX = XXXXX)
   
Reviewer Comment (2019-09-06): See newly added exception for cure.
 
 
Seller Comment (2019-09-04): This needs to be waived. All XXXXX loan's Escrow Property Costs Over Year 1 are calculated over XXXXX months.
 
 
Reviewer Comment (2019-09-04): The total HOI is $XXXXX, the total taxes are $XXXXX. The cost year 1 is $XXXXX
 
 
Seller Comment (2019-09-03): Please note that this calculation is XXXXX months not XXXXX. Please escalate to get this condition cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Second Home
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
C
A
A
A
C
A
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Final Closing Disclosure closing date of  XXXXX does not match notary date of XXXXX
   
Reviewer Comment (2019-09-04): A PCCD was provided correcting the closing date
 
 
XX/XX/XXXX
 
1
A
 
[Redacted]
Second Home
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
C
A
A
A
C
A
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Total Property Costs Year 1 - XXXXX Test
TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of XXXXX on Final Closing Disclosure provided on XXXXX not accurate.
The issue is not the number of months used on page 4, but rather the monthly total on page 1.  The calculated monthly is $XXXXX (with the inclusion of the supplemental taxes shown on title report) and CD shows $XXXXX per month.
   
Reviewer Comment (2019-09-10): A PCCD was provided correcting the cost year 1 to $XXXXX which is XXXXX months of the total monthly payment of $XXXXX
 
 
Reviewer Comment (2019-09-09): Updated comments: the discrepancy is the monthly HOI. Hazard dec page reads annual of $XXXXX= $XXXXX monthly, Final XXXXX reads $XXXXX ($XXXXX annually). Need updated policy to read $XXXXX. Exception only pertains to HOI discrepancy.
 
 
Seller Comment (2019-09-09): XXXXX is multiplying the monthly hazard and tax amounts by XXXXX months; XXXXX's multiplier is XXXXX. Please clear.
 
 
Reviewer Comment (2019-09-06): Using monthly taxes of $XXXXX+ HOI ($XXXXX)= XXXXX. Total monthly for both $XXXXX. Final CD page 1 read $XXXXX. Final CD page 4 read $XXXXX is based on $XXXXX monthly. Need a PCCD to read a monthly taxes and HOI $XXXXX on the first page and $XXXXX on page four, Exceptions remains.
 
 
Seller Comment (2019-09-06): Please see attached tax bill. The taxes are correct as calculated per month.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Second Home
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
C
A
A
A
C
A
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
The waiver was provided and signed on XXXXX.  Document was mailed XXXXX which is insufficient time for borrower to receive prior to closing.
   
Reviewer Comment (2019-09-04): Client Elects to Waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
B
B
A
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
     
Reviewer Comment (2019-09-07): Client Elects to Waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
B
B
A
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Waiver Less than 3 Days From Consummation
ECOA Valuations Rule (Dodd-Frank 2014): Borrower provided appraisal waiver less than three (3) business days prior to consummation.
     
Reviewer Comment (2019-09-07): Client Elects to waive
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
B
B
A
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance (Circuit 1, 4, 6, or 11)
Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinancing by the same creditor. XXXXX form was used, the XXXXX form should have been used. (The property state is in the XXXXX circuit.)
     
Reviewer Comment (2019-09-06): No new money associated with new transaction. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form
A
A
A
A
A
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
The inital LE disclosed a appraisal fee amount of $XXXXX while the final CD reflects $XXXXX. This exceeds the zero percent tolerance.  The borrower appears to have been provided the $XXXXX cure.
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Limited Cash-out GSE
Final CD evidences Cure
A
A
A
A
A
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Home Loan Toolkit Provided
Unable to test disclosure of Home Loan Toolkit due to missing information.
This document was in file but there was no proof of when it was sent to the borrower.
   
Reviewer Comment (2019-08-27): Disclosure summary confirms toolkit sent on 0XXXXX
 
 
Buyer Comment (2019-08-26): See attached Audit Log evidencing delivery & customer review of Home Loan Took Kit XXXXX XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
No Defined Cure
C
A
C
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Home Loan Toolkit Timing
Truth in Lending Act (2015): Creditor or broker did not provide the Home Loan Toolkit Disclosure to applicant within 3 business days of application.
This document was in file but there was no proof of when it was sent to the borrower.
   
Reviewer Comment (2019-08-27): Disclosure summary confirms toolkit sent on 0XXXXX
 
 
Buyer Comment (2019-08-26): Uploaded Audit Log evidencing delivery & customer review of Home Loan Took Kit XXXXX XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
No Defined Cure
C
A
C
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Borrower and Mortgage Eligibility
Mortgage / Program Eligibility
Guideline Requirement: Loan to value discrepancy.
 
Max LTV for this transaction should have been XXXXX% per guides - actual LTV was XXXXX% and no exception was in file from lender.
   
Reviewer Comment (2019-08-29): This was reevaluated using most recent guides per Embrace policy, this cleared the exception.
 
 
Buyer Comment (2019-08-27): Updated XXXXX guide allows for XXXXX max LTV Purchase money, with FICO greater than XXXXX FICO.
 
 
Buyer Comment (2019-08-26): Please see XXXXX Matrix allowing for XXXXX LTV Purchase money
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Guideline Requirement: Combined loan to value discrepancy.
 
Max LTV for this transaction should have been XXXXX% per guides - actual LTV was XXXXX% and no exception was in file from lender.
   
Reviewer Comment (2019-08-29): This was reevaluated using most recent guides per Embrace policy, this cleared the exception.
 
 
Buyer Comment (2019-08-27): Updated XXXXX guide allows for XXXXX max LTV Purchase money, with FICO greater than XXXXX FICO.
 
 
Buyer Comment (2019-08-26): Please see XXXXX Matrix allowing for XXXXX LTV Purchase money
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
Exception is an ATR informative XXXXX (non-material) exception and is set because, although extensions have been filed, the loan is being qualified on income that is not considered most recent. Exception can be left open or waived as it cannot be cured or cleared. XXXXX can acknowledge the findings and waive.XXXXX
   
Buyer Comment (2019-08-12): Agree with due diligence. Please Waive finding. Business is on XXXXX Tax Extension
 
 
Reviewer Comment (2019-08-12): Exception is an ATR informative XXXXX (non-material) exception and is set because, although extensions have been filed, the loan is being qualified on income that is not considered most recent.  Exception can be left open or waived as it cannot be cured or cleared. Lender/Client can acknowledge the findings and waive. XXXXX rating.
 
 
Buyer Comment (2019-08-08): Attached you'll find XXXXX Extension filing, confirmation of no ownership change ofXXXXX% in HLP Integration, and 'XXXXX's for XXXXX.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Initial Loan Estimate Timing Electronically Provided
TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.
     
Reviewer Comment (2019-09-11): Received E-Consent documentation.
 
 
Buyer Comment (2019-09-11): See attached E-Consent delivery confirmation
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Esign Consent Agreement Status
ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $XXXXX and disclosure timing violations.
No evidence of consent to receive electronic disclosures is found in the loan images.
   
Reviewer Comment (2019-09-11): Received E-Consent documentation.
 
 
Buyer Comment (2019-09-11): E-consent has been uploaded.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
No Defined Cure
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Esign Consent Agreement Status
ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $XXXXX and disclosure timing violations.
No evidence of consent to receive electronic disclosures is found in the loan images.
   
Reviewer Comment (2019-09-10): Received E-Sign Consent Agreement.  Condition is cleared.
 
 
Buyer Comment (2019-09-10): Please see the attached e-consent
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
No Defined Cure
B
A
A
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
         
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Final CD evidences Cure
B
A
A
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
         
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Final CD evidences Cure
B
A
A
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Final Closing Disclosure reflects a closing date of XXXXX and the loan signed XXXXX.
   
Reviewer Comment (2019-09-09): Agree, cleared
 
 
Buyer Comment (2019-09-09): Post Consummated CD dated XXXXX reflects corrected Closing Date of XXXXX.  Corrected CD is not required.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
B
A
A
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)
ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.
Missing evidence of the appraisal being sent to the borrower prior to closing.
   
Reviewer Comment (2019-09-09): Received
 
 
Buyer Comment (2019-09-09): Disagree - Receipt of Appraisal was in the file and signed by the borrowers at closing. Documentation has been provided.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
 
B
A
A
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien
TRID Final Closing Disclosure XXXXX on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.)
No seller fees were disclosed on the consumer's CD.  Seller CD was not provided.
   
Reviewer Comment (2019-09-10): Seller's CD was provided.  Condition is cleared.
 
 
Buyer Comment (2019-09-10): Seller CD has been uploaded
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Invalid Section B Combinations
TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on XXXXX reflects a fee Paid To lender or broker for fee within Services Borrower Did Not Shop For section.
The Appraisal Fee is disclosed as paid to the Lender on the consumer's CD.  No appraisal invoice is provided to determine the payee.
   
Reviewer Comment (2019-09-13): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Good Faith Redisclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Homeowner's Insurance Premium Months
TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.
The premium disclosed on the consumer's final CD does not match the total premium reflected on the hazard insurance dec page.
   
Reviewer Comment (2019-09-13): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Costs Subtotals Seller Paid - At Closing
TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXX disclosed Total Closing Costs (Paid by Seller at Closing) that does not match sum of fees.
Final Closing Disclosure provided on XXXXX disclosed Total Closing Costs (Paid by Seller at Closing) that does not match sum of fees. (Final/XXXXX)
   
Reviewer Comment (2019-09-13): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Total Property Costs Year 1 - XXXXX Test
TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of XXXXX on Final Closing Disclosure provided on XXXXX not accurate.
Final CD shows XXXXX but calculation is $XXXXX
   
Reviewer Comment (2019-09-12): Letter of Explanation & Corrected Closing Disclosure provided
 
 
Buyer Comment (2019-09-11): Corrected CD and LOX has been provided.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Other
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
Cure of $XXXXX provided on the final CD
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Final CD evidences Cure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date
Truth in Lending Act:  Subject loan transaction disbursed on XXXXX, prior to three (3) business days from transaction date of XXXXX.
The RTC was signed on XXXXX, however, the final CD was signed on XXXXX.   The rescission period should begin on XXXXX, thus, the dates on the document are incorrect.
   
Reviewer Comment (2019-09-11): The Letter of Explanation, Proof of Delivery, and RTC has been provided.  Condition is cured
 
 
Buyer Comment (2019-09-11): The proof of delivery is located on page 2 and has been uploaded again.
 
 
Reviewer Comment (2019-09-10): Received proof of delivery and new RTC documentation.  Please provide missing letter of explanation.
 
 
Buyer Comment (2019-09-09): Agree, however the borrower was provided with a new rescission period on XXXXX at which time they did not choose to cancel the transaction.  New RTC documentation has been provided.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Date
Truth in Lending Act:  Actual Date(s) on Notice of Right to Cancel occurs prior to expected date(s).
The RTC was signed on XXXXX, however the final CD was signed on XXXXX.  The rescission period should begin on XXXXX, thus, the dates on the document are incorrect.
   
Reviewer Comment (2019-09-11): Received Letter of Explanation, Proof of Delivery, and RTC documentation.  Condition is cured.
 
 
Buyer Comment (2019-09-11): Letter of explanation was submitted and is located on page 2.
 
 
Reviewer Comment (2019-09-10): Received proof of delivery and new RTC documentation.  Please provide missing letter of explanation.
 
 
Buyer Comment (2019-09-09): Agree, however the borrower was provided with a new rescission period on XXXXX at which time they did not choose to cancel the transaction.  New RTC documentation has been provided.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
RESPA Disclosure - List of Homeownership Counseling Organizations Missing
Unable to determine Homeownership Counseling List was provided due to missing information.
The disclosure is undated.  Unable to determine date on which the document was provided.
   
Reviewer Comment (2019-09-13): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation
ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.
No evidence of appraisal delivery is provided.
   
Reviewer Comment (2019-09-09): Received
 
 
Buyer Comment (2019-09-09): Disagree - The borrower signed the Appraisal Notification and Acknowledgment form acknowledging the Appraisal was received 3 days prior to closing.  Documentation has been provided.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX Fee.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
         
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Final CD evidences Cure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Prepaid Property Tax Months
TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXX did not disclose number of months for Property Tax under Prepaids.
The field is blank on the final CD.
   
Reviewer Comment (2019-09-12): Cured with PCCD
 
 
Buyer Comment (2019-09-11): Please see the attached PCCD and LOE
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
         
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Final CD evidences Cure
C
B
C
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
AUS Discrepancy / Guidelines Discrepancy
Guideline Requirement: Maximum Loan Amount discrepancy.
Note loan amount of ___ is greater than Guideline maximum loan amount of ___.
Based upon the guidelines (XXXXX) in place at time of application, the loan amount of $XXXXX is greater than the guideline maximum of $XXXXX.
   
Reviewer Comment (2019-09-09): Based upon clarification of guidelines used provided by the lender, this condition is cleared.
 
 
Buyer Comment (2019-09-05): Disagree:  The XXXXX loan limits would apply.  XXXXX was submitted XXXXX.   Please see XXXXX Finding #VM with the limit of $XXXXX along with XXXXX Guidelines.   (Please see the attached.)
Loan Quality Advisor was updated on XXXXX8 so Sellers may begin evaluating Mortgages with these new original loan amounts immediately. Loan Product Advisor was updated on XXXXX so Sellers may begin originating Mortgages with these new loan amounts immediately. However, Mortgages meeting the XXXXX limits are not eligible for sale to XXXXX until on or after XXXXX. Loan Selling Advisor was updated on XXXXX. Mortgages originated with loan amounts that meet the XXXXX loan limits, but are not eligible under the XXXXXloan limits, must not have aXXXXX Funding Date or Settlement Date earlier than XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
B
B
A
A
Temporary SHQM (GSE/Agency Eligible)
Temporary SHQM (GSE/Agency Eligible)
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Credit Documentation
Aged document: Credit Report  is more than 90 days prior to the note date.
-
 
XXXXX FICO
AMC
Reviewer Comment (2019-08-19): Exception waived by client.
 
 
Reviewer Comment (2019-08-13): Loan was not marked for sale to XXXXX
 
 
Buyer Comment (2019-08-13): Attached is the approved exception for the expired credit report from XXXXX
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
A
B
A
B
A
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
     
Reviewer Comment (2019-08-26): LO Disclosure provided, exception cleared.
 
 
Buyer Comment (2019-08-23): MLO
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
B
A
A
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
There's no evidence in the file of a Federal LO Compensation Disclosure.
   
Reviewer Comment (2019-08-22): LO Comp disclosure provided. Exception cleared.
 
 
Buyer Comment (2019-08-21): LO COMP
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller - Closing Costs Financed
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed Closing Costs Financed that does not match actual amount of closing costs financed.
The Closing costs financed found on XXXXX of the CD are listed as XXXXX, but should be XXXXX. Please provided a corrected copy with LOE to borrower.
   
Reviewer Comment (2019-09-03): Letter of Explanation & Corrected Closing Disclosure provided
 
 
Buyer Comment (2019-09-03): LOE and corrected CD.
 
 
Buyer Comment (2019-09-03): Corrected CD
 
 
Reviewer Comment (2019-09-03): Seller did not elect to waive. Waived an error. Exception remains.
 
 
Buyer Comment (2019-08-29): I'm not sure how waived was selected but we have this exception open. Please reopen.
 
 
Reviewer Comment (2019-08-26): Client elects to waive.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Closing / Title
Security Instrument Error: Invalid MERS Min Number
 
Evidence this is a valid XXXXX per Security Instrument.
   
Reviewer Comment (2019-08-30): Updated recorded/signed Security Instrument in trailing docs, exception cleared.
 
 
Buyer Comment (2019-08-29): Corrected MIN
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (XXXXX): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
Total allowable fees exceed limits per Federal allowance of XXXXX
   
Reviewer Comment (2019-08-27): Rate sheet provided for Bona Fide calculations. Exception cleared.
 
 
Buyer Comment (2019-08-26): Uploaded evidence of bona fide points.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM Points and Fees
Qualified Mortgage XXXXX Points and Fees on subject loan of XXXXX is in excess of the allowable maximum of  XXXXX of the Federal Total Loan Amount. Points and Fees total XXXXX on a Federal Total Loan Amount of XXXXX vs. an allowable total of XXXXX (an overage of XXXXX).
Total allowable fees exceed limits per Federal allowance of XXXXX
   
Reviewer Comment (2019-08-27): Rate sheet provided for Bona Fide calculations. Exception cleared.
 
 
Buyer Comment (2019-08-26): Lock sheet, LLPA, evidence of bona fide points.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
If a creditor or assignee determines after consummation that the total points and fees exceeds the QM Points and Fees limit, but the loan meets the other requirements to be a QM, the QM Points and Fees exception can be cured through a refund including interest at the contract rate from consummation to the date of cure, with the following conditions:
1)      Refund is made within 210 days of consummation;
2)      The consumer has not instituted any actions against the creditor or provided written notice that the loan's fees exceeded the legal limit;
3)      The loan is not 60 days delinquent;
4)      The creditor or assignee (depending who is curing) has policies in place to identify and cure excessive fees collected from the consumer (the creditor or assignee can only take advantage of this cure provision if they maintain policies and procedures for post-consummation review of points and fees and for providing the cure payments); and
5)      The loan was closed on or before January 10, 2021;
 
Documents Required to Cure
1)      Letter of Explanation
2)      Copy of Refund Check (in the amount of overage plus interest)
3)      Proof of Delivery
4)      Lender/Seller Attestation indicating:
        a)      The consumer has not instituted any actions against the creditor or provided written notice that the loan's fees exceeded the legal limit;
        b)      The loan is not 60 days delinquent; and
        c)      The creditor or assignee (depending who is curing) has policies in place to identify and cure excessive fees collected from the consumer
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of XXXXX exceeds tolerance of XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
         
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Final CD evidences Cure
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Review Fee.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
         
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Final CD evidences Cure
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Lender Credit Tolerance Violation
TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of XXXXX  is less than amount of binding Lender Credit previously disclosed in the amount of XXXXX.
A cure in the amount of XXXXX was provided at closing.
   
Reviewer Comment (2019-08-13): The detailed disclosure summary of changes supports the change in fees, debt paid and shows the borrower did not require the additional lender credit
 
 
Buyer Comment (2019-08-13): attached COC showing the lender credit removed and cost the lock price increase due to AV and LTV
 
 
Buyer Comment (2019-08-12): Please clarify this condition a cure was provided at closing; why would a corrected CD, refund, LOE and proof of delivery still required to clear?
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Other
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
XXXXX tax returns not provided.
   
Reviewer Comment (2019-08-26): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
     
Reviewer Comment (2019-08-15): Exception cleared.
 
 
Buyer Comment (2019-08-14): XXXXX did not provide compensation to the Broker. See attached Cert
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Non Escrowed Property Costs Year 1
TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of XXXXX on Final Closing Disclosure provided on XXXXX not accurate.
The non escrowed cost of the HOI for year 1 should be XXXXX however XXXXX was input. The file is missing any evidence of this additional cost or a corrected CD
   
Reviewer Comment (2019-08-07): Letter of Explanation & Corrected Closing Disclosure provided. Exception cured.
 
 
Buyer Comment (2019-08-06): Correction
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Demand Feature
TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXX incorrectly disclosed whether the loan contains a Demand Feature.
XXXXX of the final CD under Demand Features was not completed.
   
Reviewer Comment (2019-08-07): Letter of Explanation & Corrected Closing Disclosure provided. Exception cured.
 
 
Buyer Comment (2019-08-06): correction
 
 
Buyer Comment (2019-08-06): Cure docs uploaded.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Invalid XXXXX Combinations
TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on XXXXX reflects a Paid To party other than to lender or broker for fee within Origination Charges.
Final CD reflects a fee paid to a third party in XXXXX.
   
Reviewer Comment (2019-08-07): Letter of Explanation and Correct Closing Disclosure provided. Exception cured.
 
 
Buyer Comment (2019-08-06): correction
 
 
Buyer Comment (2019-08-06): Cure docs uploaded.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Good Faith Redisclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Invalid XXXXX Combinations
TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on XXXXX reflects a fee Paid To lender or broker for fee within Services Borrower Did Not Shop For section.
Final CD reflects fees paid to the lender in XXXXX.
   
Reviewer Comment (2019-08-07): Letter of Explanation & Corrected Closing Disclosure provided. Exception cured.
 
 
Buyer Comment (2019-08-06): correction
 
 
Buyer Comment (2019-08-06): Cure docs uploaded.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Good Faith Redisclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
S-Corp Income Documentation Test
Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (S-Corp).
XXXXX and XXXXX XXXXX returns are not signed.
   
Reviewer Comment (2019-08-07): Signed XXXXX returns provided. Exception cleared.
 
 
Buyer Comment (2019-08-06): Uploaded
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency - ATR
Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
Missing XXXXX XXXXX returns.
   
Reviewer Comment (2019-08-07): Signed XXXXX returns provided. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
XXXXX and XXXXX XXXXX returns are not signed.
   
Reviewer Comment (2019-08-07): Signed XXXXX returns provided. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Lender to provide updated ATR/QM status
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Credit Exception:
 
Title report reflects a modification on XXXXX. Loan file does not contain documentation of modification to determine if guidelines are met.
   
Reviewer Comment (2019-08-13): All modification documents were provided and support the process
 
 
Buyer Comment (2019-08-13): Uploaded Modification
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Approval not provided
 
The file does not contain the Lender's Approval
   
Reviewer Comment (2019-08-15): Approval provided. Exception cleared.
 
 
Buyer Comment (2019-08-14): Uploaded loan approval
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
File contains  XXXXX and  XXXXX  XXXXX and  XXXXX and Balance Sheets.   XXXXX year average of  XXXXX income documents used to qualify.  Tax Return Extension in file for personal returns only.
   
Reviewer Comment (2019-08-24): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 07/26/2019 disclosed a Closing Date that did not match the actual date of consummation.
The Final CD disclosed a closing date of  XXXXX, and the loan closed on  XXXXX.
   
Reviewer Comment (2019-08-15): XXXXX received PCCD correcting close date and LOE. Exception Cured.
 
 
Buyer Comment (2019-08-14): Corrected Closing date with LOE
 
 
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Fraud Report not provided
       
Reviewer Comment (2019-08-15): Fraud report provided. Exception cleared.
 
 
Buyer Comment (2019-08-14): Uploaded FG
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
C
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Total Property Costs Year 1 - XXXXX XXXXX
TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of XXXXX on Final Closing Disclosure provided on XXXXX not accurate.
The Property Costs over Year 1 Should have been XXXXX. Corrected on the post-close CD.
   
Reviewer Comment (2019-08-01): PCCD corrected annual amount.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
ECOA Appraisal - Appraisal Provided Prior to Date Performed
ECOA Valuations Rule (XXXXX): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.
The Appraisal was provided on XXXXX, and the appraisal did not sign the appraisal until XXXXX.
   
Reviewer Comment (2019-08-09): Evidence borrower received revised appraisal provided. Exception cleared.
 
 
Buyer Comment (2019-08-08): Acknowledgment of received of XXXXX appraisal.
 
 
Reviewer Comment (2019-08-07): Appraisal provided dated XXXXX, however appraisal was revised on XXXXX. Please provide evidence that borrower received the revised appraisal dated XXXXX. Exception remains.
 
 
Buyer Comment (2019-08-05): Initial appraisal was revised on XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Sole Proprietorship Income Documentation Test
Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Sole Proprietorship).
Missing Year-to-date Profit and Loss
   
Reviewer Comment (2019-07-26): P&L provided. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
Fails shqm due to missing income documentation
   
Reviewer Comment (2019-07-26): P&L provided. Exception cleared.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
C
A
A
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Approval not provided
       
Reviewer Comment (2019-07-22): Approval provided
 
 
Buyer Comment (2019-07-22): Uploaded approval
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 06/19/2019 disclosed a Closing Date that did not match the actual date of consummation.
Closing date on the final CD is listed as XXXXX, and the loan closed on XXXXX.
   
Reviewer Comment (2019-07-10): Lender cured the closing date to match the notary date
 
 
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
A
C
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Self-Employed Tax Return Recency
Qualified Mortgage (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXX,  Most Recent Tax Return End Date XXXXX, Tax Return Due Date XXXXX.
Missing XXXXX business and personal tax returns were not received in the loan file.
   
Reviewer Comment (2019-08-07): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of XXXXX exceeds tolerance of XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
The credit report fee changed from the initial LE to Final CD without a cure in the loan file.
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Final CD evidences Cure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Total Property Costs Year 1 - XXXXX XXXXX
TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXX did not disclose Estimated Property Costs over Year 1.
XXXXX of the Final CD did not disclose the property costs over 1 year.
   
Reviewer Comment (2019-07-26): Letter of Explanation & Corrected Closing Disclosure provided. Exception cured.
 
 
Buyer Comment (2019-07-25): Correction uploaded.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Will Not Have Escrow -  Property Costs Year 1
TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXX did not disclose Estimated Property Costs over Year 1 for loan with no escrow account established.
Field is blank on final CD on XXXXX per the loan documents.
   
Reviewer Comment (2019-07-26): Letter of Explanation & Corrected Closing Disclosure provided. Exception cured.
 
 
Buyer Comment (2019-07-25): Correction
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Will Not Have Escrow -  Reason
TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXX incorrectly disclosed whether the loan will have an escrow account.
Field is blank on final CD on XXXXX of where the loan has an escrow account. Per XXXXX, it says now.
   
Reviewer Comment (2019-07-26): Letter of Explanation & Corrected Closing Disclosure provided. Exception cured.
 
 
Buyer Comment (2019-07-25): Correction uploaded.
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Miscellaneous
Credit Exception:
 
Missing the XXXXX on the departing residence as required per guidelines.
   
Reviewer Comment (2019-07-26): Property value report provided. Exception cleared.
 
 
Buyer Comment (2019-07-26): Uploaded Property Value report; XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
A
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XX/XX/XXXX disclosed a Closing Date that did not match the actual date of consummation.
Final CD disclosed a closing date of  XXXXX. Consummation date is  XXXXX.
   
Reviewer Comment (2019-08-02): Letter of Explanation & Corrected Closing Disclosure provided
 
 
Buyer Comment (2019-08-01): Correction
 
 
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
B
A
A
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
Tolerance cure in the amount of $ XXXXX was provided to the borrower at closing.
       
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Final CD evidences Cure
B
A
A
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Sufficient or excess cure was provided to the borrower at Closing.
         
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
Final CD evidences Cure
B
B
B
B
A
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Insurance
Insurance Analysis
Hazard Insurance Policy expires within 90 days of the Note Date.
Hazard Insurance Policy Expiration Date ___, Note Date ___
Hazard polic expires in XX days, no escrows.  Provided updated hazard declaration
   
Reviewer Comment (2019-06-21): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
 
B
B
B
B
A
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.
     
Reviewer Comment (2019-07-18): Document provided. Exception cleared.
 
 
Buyer Comment (2019-07-17): Disclosure
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
B
A
A
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Esign Consent Agreement Status
ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $XXXXX and disclosure timing violations.
E sign document is missing.
   
Reviewer Comment (2019-07-15): eConsent received
 
 
Buyer Comment (2019-07-15): Please advised on clearing this exception.
 
 
Buyer Comment (2019-07-12): econsent
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
No Defined Cure
B
A
A
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Documents were signed XXXXX.
   
Reviewer Comment (2019-07-22): The lender provided a PCCD dated XXXXX correcting the closing date to XXXXX matching the security notary date
 
 
Buyer Comment (2019-07-19): Correction
 
 
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
B
A
A
A
B
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Will Not Have Escrow -  Reason
TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXX incorrectly disclosed whether the loan will have an escrow account.
Final CD misses either box being checked on Page 4 concerning reason for decline.
   
Reviewer Comment (2019-07-26): Letter of Explanation & Corrected Closing Disclosure provided. Exception cured.
 
 
Buyer Comment (2019-07-25): Correction
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
$0 tolerance cure provided at closing.
   
Reviewer Comment (2019-07-24): The VCOC was for a rate re-lock change and valid for the lender credit change
 
 
Buyer Comment (2019-07-23): COC
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Letter of Explanation & Corrected Closing Disclosure
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Lender Credit Tolerance Violation
TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $XXXXX  is less than amount of binding Lender Credit previously disclosed in the amount of $XXXXX.
$0 tolerance cure provided at closing, loan was relocked at lower rate and lender credit removed.
   
Reviewer Comment (2019-07-24): The VCOC was for a rate re-lock change and valid for the lender credit change
 
 
Buyer Comment (2019-07-23): COC
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Settlement Service Provider Status
TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.
Missing Settlement closing provider list, File copy is blank and undated.
   
Reviewer Comment (2019-07-25): SSPL provided.
 
 
Buyer Comment (2019-07-24): Disclosure
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
No Defined Cure
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Insurance
Insurance Documentation
Hazard Insurance Error: Subject hazard insurance policy coverage amount is missing from evidence of insurance.
 
The policy provided appears to be the XXXXX for both XXXXX, the file is missing either evidence of a XXXXX policy or evidence the master building policy covers interior improvements. Also missing is the annual policy value used to qualify.
   
Reviewer Comment (2019-07-25): XXXXX was provided
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Cash-out - Debt Consolidation
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Purchase Agreement / Sales Contract not provided
       
Reviewer Comment (2019-07-09): Purchase contract provided. Exception cleared.
 
 
Buyer Comment (2019-07-08): Uploaded contract
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
D
A
D
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Home Loan Toolkit Provided
Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.
The file was missing evidence that the Home Loan Toolkit  was provided to the Borrowers within 3 business days of the initial application date.
   
Reviewer Comment (2019-07-09): Home Loan Tool Kit provided.
 
 
Buyer Comment (2019-07-08): home tool kit with docu signature receipt
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
No Defined Cure
D
A
D
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Seller Closing Disclosure
TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.
Missing Seller's Closing Disclosure
   
Reviewer Comment (2019-07-09): Seller's CD provided.
 
 
Buyer Comment (2019-07-08): seller CD
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
D
A
D
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $XXXXX exceeds tolerance of $XXXXX plus 10% or $XXXXX.  Insufficient or no cure was provided to the borrower.
No cure provided
   
Reviewer Comment (2019-07-10): Seller paid portion of recording fees were required per purchase contract.
 
 
Buyer Comment (2019-07-09): The purchase contract stated all necessary tax, mortgage, conveyance, release certificates or cancellations and seller closing fees if any shall be paid by the seller. This would also include recording fees.
 
 
Buyer Comment (2019-07-09): The final CD does in fact list $XXXXX in seller paid column on page 2 of the CD.
 
 
Reviewer Comment (2019-07-09): XXXXX reviewed the highlighted section of PC.  The XXXXX fee as disclosed is not listing as a Seller paid fee.  However, per the Seller's CD, the "XXXXX" fees were not disclosed properly as XXXXX of $XXXXX and XXXXX for $XXXXX, which totals the $XXXXXdisclosed as XXXXX fees on the final CD.  A Corrected CD and LOE are required to cure the discrepancy.
 
 
Buyer Comment (2019-07-09): Seller paid $XXXXX of this fee per the CD per the attached sales contract
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
D
A
D
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Fee disclosed on Seller's CD.  Per Deal Settings Seller fees not excluded.
   
Reviewer Comment (2019-07-09): Purchase Contract states Seller to pay for any releases fees required to cure liens.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
D
A
D
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Fee disclosed on Seller's CD.  Per Deal Settings Seller fees not excluded.
   
Reviewer Comment (2019-07-09): Purchase Contract states Seller to pay transfer tax.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
D
A
D
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Credit Documentation
Insufficient Verification of Rental History.
 
Missing VOR: per guidelines showing 24 months or 24 months of bank statements or cancel checks are required. The credit report only lists a 20 month history last reported XXXXX
   
Reviewer Comment (2019-06-13): Received bank statements showing withdrawal to landlord. Exception cleared.
 
 
Buyer Comment (2019-06-12): Please see Lease verifying rental pmt of $XXXXX, see bank-statements attached verifying 24 month history
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
A
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Credit Documentation
Aged document: Credit Report  is more than XXXXX days prior to the note date.
-
Credit report is dated XXXXX.
   
Reviewer Comment (2019-07-01): Received copy of the credit report dated XXXXX.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM Employment History
Qualified Mortgage (Dodd-Frank 2014): Employment history requirement not met.
The Former employment dates were not verified.
   
Reviewer Comment (2019-07-10): VVOE provided supporting both start and end date
 
 
Buyer Comment (2019-07-10): VVOE
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits
TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.
Legal limit on final CD dated XXXXX was not provided.
   
Reviewer Comment (2019-07-05): Tolerance exception is addressed. Exception Cleared.
 
 
Buyer Comment (2019-07-03): coc
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
C
A
C
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
Check Loan Designation Match - QM
Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation of Non QM.
Missing prior employment history to meet a two year history.
   
Reviewer Comment (2019-07-10): VVOE provided supporting both start and end date
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Lender to provide updated ATR/QM status
C
A
C
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Lender Credit Tolerance Violation
TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $XXXXX  is less than amount of binding Lender Credit previously disclosed in the amount of $XXXXX.
The file does not contain a valid COC for the decrease.
   
Reviewer Comment (2019-07-05): XXXXX received COC indicating loan amount change. Credit directly corresponds with loan amount decrease. Exception Cleared.
 
 
Buyer Comment (2019-07-03): coc
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
A
C
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Credit
Income / Employment
Income Documentation
Income Docs Missing:
-
Missing XXXXX & XXXXX Tax transcripts.
   
Reviewer Comment (2019-07-05): Transcripts provided. Exception cleared.
 
 
Buyer Comment (2019-07-03): Uploaded transcripts
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Credit
Credit Eligibility
There are red flags on the fraud report that have not been addressed
-
Co-borrower had a identity fraud alert; borrower did not document how the co-borrower's identity was verified.
   
Reviewer Comment (2019-07-10): Identity was provided with an adjusted fraud report
 
 
Buyer Comment (2019-07-10): Uploaded verification of ID.
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
A
C
A
C
A
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Credit
Loan Package Documentation
Application / Processing
Missing Document: Approval not provided
       
Reviewer Comment (2019-07-02): Approval provided. Exception cleared.
 
 
Buyer Comment (2019-07-01): Uploaded Loan Approval
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Purchase
 
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided
TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for XXXXX.  Fee Amount of $XXXXX exceeds tolerance of $XXXXX.  Insufficient or no cure was provided to the borrower.
Closing Disclosures provided cure of $XXXXX
   
Reviewer Comment (2019-06-27): The lender cured the failure of XXXXX at closing
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Purchase
Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD
C
B
C
A
C
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Property
Appraisal Reconciliation
Value Discrepancy
Loan is to go in a securitization and reflects only one valuation product when two are required.
 
The file does not contain the required desk review.
   
Reviewer Comment (2019-08-12): Desk review provided.Exception cleared.
 
 
Buyer Comment (2019-08-09): Uploaded XXXXX
 
XX/XX/XXXX
   
1
A
 
[Redacted]
Primary
Refinance - Rate/Term
 
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
No
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Negative Fees
TRID-RESPA Integrated Disclosure - Final Closing Disclosure provided on XXXXX disclosed a negative fee amount.
An appraisal credit was listed in section H.
   
Reviewer Comment (2019-08-12): Letter of Explanation & Corrected Closing Disclosure provided. Exception cured.
 
 
Buyer Comment (2019-08-12): correction
 
 
XX/XX/XXXX
 
2
B
 
[Redacted]
Primary
Refinance - Rate/Term
Letter of Explanation & Corrected Closing Disclosure
C
B
A
A
B
B
C
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
TRID Final Closing Disclosure Closing Date
TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
Final Closing Disclosure provided on XXXXX disclosed a Closing Date that did not match the actual date of consummation.
   
Reviewer Comment (2019-06-14): A PCCD lender corrected the closing date to XXXXX
 
 
XX/XX/XXXX
 
1
A
 
[Redacted]
Primary
Purchase
Letter of Explanation & Corrected Closing Disclosure
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
Yes
[Redacted]
[Redacted]
[Redacted]
     
Compliance
Compliance
Federal Compliance
QM Employment History - Current and/or Previous Employment Documentation lacks Date Info
Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two years employment history for current and/or prior employment.
Missing explicit dates of employment for co-borrower's prior self employment.
   
Reviewer Comment (2019-06-21): Client elects to waive.
 
   
XX/XX/XXXX
2
B
 
[Redacted]
Primary
Purchase
 
B
B
A
A
B
B
A
A
Safe Harbor QM
Safe Harbor QM
No