EX-99.3 14 efc19-643_ex993s2.htm SCHEDULE 2 - EXCEPTION REPORT
Unique Loan ID Overall Event Final Credit Event Credit Exceptions Credit Comments Final Compliance Event Compliance Exceptions Compliance Comments Eligible For Predatory Testing - Unable to Test Compliance Comp Factors Purpose at origination Occupancy at origination LTV Original (Calculated) LTV Combined Orig (Calculated) Debt (Back) Ratio From 1008
25921962 3 1     3 [3] ROR Missing [2] Credit Score Disclosure Not Present [2] Initial TIL Missing [2] State - Missing Anti-Coercion Notice [2] State - Missing Choice of Attorney disclosure [2] HMDA-reportable rate spread (1/1/04-10/1/09)     ROR - 3yrs for rescindable transactions. The loan is outside the SOL. Cashout Refi Owner Occ 10.41 88.43 39.619
25369742 3 3 [3] Appraisal Missing [3] Final Application Missing [3] Missing Initial Application   2 [2] Initial GFE Date not within 3 days of Initial Application Date [2] HMDA-reportable rate spread (1/1/04-10/1/09)       Cashout Refi Owner Occ 70 70 37.86
25864855 3 3 [3] Appraisal Missing [3] Final Application Missing [3] Credit Report Missing [3] Missing Initial Application   3 [3] TIL Missing [3] ROR Missing [3] HUD-1 Missing [2] Credit Score Disclosure Not Present [2] State - Missing Application Addedum stating applicant, if married, may apply for a separate account [2] State - Missing Consumer Credit Score Disclosure [2] State - Missing Fair Lending Notice [2] State - Missing Acknowledgment of Receipt of Good Faith Estimate [2] State - Missing Impound Authorization Disclosure [2] State - Missing Interim Interest Disclosure [2] Initial GFE Missing [2] Initial TIL Missing   YES ROR - 3yrs for rescindable transactions. The loan is outside the SOL. Cashout Refi Owner Occ 85 85  
25264223 2 1     2 [2] State - Missing Insurance Disclosure       Cashout Refi Owner Occ 80 80 46.24
25106594 3 3 [3] Appraisal Missing [3] Final Application Missing [3] Credit Report Missing [3] Missing Initial Application   3 [3] Missing HELOC fee disclosures required under TILA. Unable to validate compliance with TILA HELOC Account-opening disclosure requirements. [2] Affiliated Business Doc Missing [2] Initial GFE Missing     TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. HELOC Owner Occ 25.64 25.64  
25652563 2 1     2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Affiliated Business Doc Missing [2] State - Missing Acknowledgment of Receipt of Home Mortgage Loan Informational Document / Attorney General Information Statement [2] State - Missing Attorney General Information Statement [2] State - Missing Insurance Disclosure [2] State - Missing Ohio Business Relationship Disclosure Notice / Conflict of Interest Disclosure [2] State - Missing Optional Credit Insurance Disclosure [2] State - Missing Statutory Authority Disclosure [2] State - Missing Notice of Escrow of Taxes and Regular Monthly Payment [2] State - Missing Closing Statement / Closing Disclosure [2] State - Missing Nature of Relationship and Notice to Borrower in the Mortgage Loan Originator Disclosure / Addendum to GFE [2] Initial TIL Missing       Cashout Refi Owner Occ 80 100 36.11
25547718 3 3 [3] Missing Initial Application   2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Missing Application Disclosure [2] State - Missing Rate Lock [2] State - Missing Licensee Name Number and NMLS Unique Identifier on the application [2] Initial TIL Missing       Cashout Refi Owner Occ 80.35 80.35  
25734120 2 1     2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Missing Acknowledgment of Receipt of Home Mortgage Loan Informational Document / Attorney General Information Statement [2] State - Missing Mortgage Loan Origination Dislcosure [2] State - Missing Anti-Discrimination Notice [2] State - Missing High Loan to Value Disclosure in the Mortgage Loan Disclosure Statement [2] Missing Notice of Change in Mortgage Terms / Revised Mortgage Loan Originator Disclosure [2] State - Missing Statutory Authority Disclosure [2] State - Missing Notice of Escrow of Taxes and Regular Monthly Payment [2] State - Missing Nature of Relationship and Notice to Borrower in the Mortgage Loan Originator Disclosure / Addendum to GFE       Cashout Refi Owner Occ 100 100  
25779358 3 3 [3] Missing Initial Application   2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Credit Score Disclosure Not Present [2] State - Missing Acknowledgment of Receipt of Home Mortgage Loan Informational Document / Attorney General Information Statement [2] State - Missing Attorney General Information Statement [2] State - Missing High Loan to Value Disclosure in the Mortgage Loan Disclosure Statement [2] State - Missing Insurance Disclosure [2] State - Missing Ohio Business Relationship Disclosure Notice / Conflict of Interest Disclosure [2] State - Missing Statutory Authority Disclosure [2] State - Missing Notice of Escrow of Taxes and Regular Monthly Payment [2] State - Missing Closing Statement / Closing Disclosure       Cashout Refi Owner Occ 100 100 44.75
25033576 3 3 [3] Missing Initial Application   1         PURCHASE Owner Occ 20 100  
25835953 1 1     1         HELOC Owner Occ 16.13 82.26 44.31
25307688 3 3 [3] Final Application Missing   2 [2] State - Missing Anti-Coercion Notice       HELOC Owner Occ 30.83 89.8 44.933
25805038 3 3 [3] Final Application Missing [3] Missing Initial Application   3 [3] HUD-1 Missing [2] Affiliated Business Doc Missing [2] State - Missing Oral Modifications of Credit Agreements / Confirmation of Statements on Note [2] State - Missing Broker Agreement [2] Initial GFE Missing [2] Initial TIL Missing [2] HMDA-reportable rate spread (1/1/04-10/1/09)   NO   Purchase Owner Occ 20 100  
25426024 3 3 [3] Missing Initial Application   2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Missing Right to Choose Insurance Provider [2] Initial GFE Missing [2] Initial TIL Missing       Purchase Owner Occ 20 100  
25883802 3 3 [3] Final Application Missing [3] Missing Initial Application   2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)       Purchase Owner Occ 20 100 46.4
25019322 3 3 [3] Appraisal Missing [3] Credit Report Missing   2 [2] Credit Score Disclosure Not Present [2] State - Missing Domestic Partnership Affidavit       Cashout Refi Owner Occ 25 100  
25365108 3 3 [3] Missing Initial Application   3 [3] TIL Incomplete [2] State - Missing Interest Rate Disclosre [2] State - Missing Mortgage Originator Disclosure [2] State - Missing Notice of Right to Discontinue Escrow [2] Initial GFE Missing [2] Initial TIL Missing [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Credit Score Disclosure Not Present Final TIL incomplete due to missing payment details and signature. TESTED   Purchase Owner Occ 19.96 99.96 54.83
25734517 3 3 [3] Final Application Missing [3] Missing Initial Application   2 [2] State - Missing Broker Agreement [2] State - Missing Rate and Points Lock/Float Agreement [2] State - Missing Commitment Letter [2] State - Missing Loan Brokerage Disclosure Statement       Purchase Owner Occ 20 100 49
25185317 3 2 [2] Only Preliminary Title in File   3 [3] HELOC Underdislosed Finance Charge [2] State - Missing Application Addedum stating applicant, if married, may apply for a separate account [2] State - Missing Comparison of Sample Mortgage Features: Typical Mortgage [2] State - Missing Impound Authorization Disclosure Finance charges under disclosed by $770.83. The Final HELOC agreement did not disclose a Interest fee of $770.83.   1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability.The loan is outside the SOL. HELOC Owner Occ 21.98 82.42 37.5
25118232 2 1     2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)       Purchase Owner Occ 20 100 49.44
25945493 2 1     2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Missing Notice to Purchaser-Mortgagor [2] State - Missing Broker Agreement       Purchase Owner Occ 20 100 48.7
25229259 3 3 [3] Final Application Missing [3] Missing Initial Application   3 [3] TIL Missing [2] State - Missing Interest Rate Disclosre [2] Initial GFE Missing [2] Initial TIL Missing [2] HMDA-reportable rate spread (1/1/04-10/1/09)   YES   Rate/Term Refi Owner Occ 14.85 94.85 39.063
25079194 3 3 [3] Appraisal Missing [3] Final Application Missing [3] Credit Report Missing [3] Missing Title Evidence [3] Missing Initial Application   3 [3] TIL Missing [3] HUD-1 Missing [2] Credit Score Disclosure Not Present [2] State - Missing Notice to Purchaser-Mortgagor [2] State - Missing Anti-Coercion Notice [2] State - Missing Pre-Application Dislcosure [2] Initial GFE Missing [2] Initial TIL Missing   NO   Purchase Owner Occ 11.11 100  
25677961 3 3 [3] Appraisal Missing [3] Final Application Missing [3] Credit Report Missing [3] Missing Title Evidence [3] Missing Initial Application   3 [3] TIL Missing [3] ROR Missing [3] HUD-1 Missing [3] State Late Charge Not Standard [2] State - Missing Borrower's Bill of Rights [2] State - Missing Consumer Caution and Counseling Disclosure [2] Initial GFE Missing [2] Initial TIL Missing [2] Credit Score Disclosure Not Present Late charge fee of 10% or $40 exceeds the max allowed of the Greater of 5% or $15 for the state of Michigan. YES ROR - 3yrs for rescindable transactions. The loan is outside the SOL. Cashout Refi Owner Occ 20 100  
25004211 3 3 [3] Missing Initial Application   3 [3] HUD-1 Missing [2] Credit Score Disclosure Not Present [2] State - Missing Cover Page / Social Security Disclosure [2] Initial GFE Missing [2] Initial TIL Missing   NO   Purchase Second Home 10 90 37.07
25595885 3 3 [3] Final Application Missing [3] Missing Title Evidence [3] Missing Initial Application   2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Missing Appraisal Notice [2] Initial TIL Missing       Cashout Refi Owner Occ 28.17 96.78  
25682684 3 3 [3] Missing Title Evidence [3] Missing Initial Application   2 [2] Affiliated Business Doc Missing       HELOC Owner Occ 9.77 80.31 33.87
25917576 3 3 [3] Final Application Missing [3] Missing Title Evidence [3] Missing Initial Application   3 [3] ROR Missing [3] HUD-1 Missing [3] Missing HELOC fee disclosures required under TILA. Unable to validate compliance with TILA HELOC Account-opening disclosure requirements. [2] State - Missing Notice to Purchaser-Mortgagor [2] State - Missing Anti-Coercion Notice [2] State - Missing Broker Agreement [2] State - Missing Pre-Application Dislcosure [2] State - Missing Notice of Material Change of Mortgage Loan Terms [2] Initial GFE Missing   NO ROR - 3yrs for rescindable transactions. The loan is outside the SOL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. HELOC Owner Occ 13.47 96.25  
25052057 3 3 [3] Final Application Missing [3] Missing Initial Application   2 [2] State - Missing Mortgage Broker Agreement [2] State - Missing Commitment Letter [2] State - Missing Notice of Choice of Agent or Insurer [2] Initial GFE Missing       HELOC Owner Occ 16.28 96.28 47
25087354 2 1     2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)       Purchase Owner Occ 14.99 94.98  
25708229 3 1     3 [3] Missing HELOC fee disclosures required under TILA. Unable to validate compliance with TILA HELOC Account-opening disclosure requirements. [2] HMDA-reportable rate spread (1/1/04-10/1/09)     TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. Cashout Refi Owner Occ 20 100 40.4
25800613 3 3 [3] Final Application Missing [3] Credit Report Missing [3] Missing Initial Application   2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)       Purchase Owner Occ 20 100  
25672080 3 3 [3] Final Application Missing [3] Credit Report Missing [3] Missing Initial Application   2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)       Purchase Owner Occ 20 100 30.18
25446420 3 3 [3] Appraisal Missing [3] Final Application Missing [3] Credit Report Missing [3] Missing Title Evidence [3] Missing Initial Application   3 [3] ROR Missing [3] HUD-1 Missing [2] State - Missing Borrower's Bill of Rights [2] State - Missing Consumer Caution and Counseling Disclosure [2] Initial GFE Missing [2] Initial TIL Missing   YES ROR - 3yrs for rescindable transactions. The loan is outside the SOL. Cashout Refi Owner Occ 100 0  
25551490 3 3 [3] Missing Title Evidence   2 [2] Affiliated Business Doc Missing       Purchase Investment Property 10 90 31.45
25835284 3 3 [3] Missing Title Evidence   2 [2] Initial TIL Missing       Cashout Refi Owner Occ 20 100 48.03
25135026 3 3 [3] Missing Title Evidence   1         Purchase Owner Occ 19.98 99.96 44.45
25064284 2 1     2 [2] State - Missing Anti-Coercion Notice       Purchase Owner Occ 20.01 100 44.644
25446172 3 3 [3] Final Application Missing [3] Credit Report Missing [3] Missing Initial Application   3 [3] Missing HELOC fee disclosures required under TILA. Unable to validate compliance with TILA HELOC Account-opening disclosure requirements. [2] Affiliated Business Doc Missing [2] State - Missing Attorney Disclosure [2] State - Missing Domestic Partnership Affidavit [2] State - Missing Commitment Letter     TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. HELOC Owner Occ 19.93 99.64 49.73