Exception Grades

Run Date - 5/12/2020 5:30:28 PM

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

Compensating Factor Information

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

207022223

[Redact]

[Redact]

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

05/24/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

207022223

[Redact]

[Redact]

Credit

Property - Appraisal

Appraisal Adjustments

Excessive site value noted on appraisal without appraiser comments to justify

-

Site value not addressed by appraiser

Reviewer Comment (2019-06-17): Site value addressed in addendum. Buyer Comment (2019-06-17): Appraiser did address on the addendum: Cost Approach: No weight was giving to this approach. Site value was based on recent similar land sales in the subject area.The estimated site value is $XXXXX. Site sales are within the appraiser work-file Income Approach Although the subject property will be owner occupied there is some

04/09/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

207022223

[Redact]

[Redact]

Compliance

Compliance

State Compliance

(TX50(a)(6)) Texas Cash-out Loan (Home Equity loan on homestead that exceeds the Acreage limits)

XXXXX: XXXXX Cash-out Loan. Home Equity loan on homestead that exceeds the Acreage limits.

The exception is noted by the lender.

Reviewer Comment (2019-06-17): Based on additional review of the appraisal on the subject property only one service is explicitly noted, even if storm sewer is provided, the loan would still not be considered urban. Buyer Comment (2019-06-17): Based on the XXXXX Property Code Definition of Homestead; A homestead is considered to be urban if, at the time the designation is made, the property is: (1) located within the limits of a municipality or its extraterritorial jurisdiction or a platted subdivision; and (2) served by police protection, paid or volunteer fire protection, AND AT LEAST THREE OF THE FOLLOWING SERVICES PROVIDED by a municipality or under contract to a municipality: (A) electric - YES (B) natural gas - NO, PROPANE GAS (C) sewer - SEPTIC (D) storm sewer - UNKNOWN (E) water - RAINWATER COLLECTION Based on the definition the property does not meet the definition of urban. Please review and advise. Reviewer Comment (2019-06-17): Document provided is not sufficient. Reviewer Comment (2019-06-17): Disclosure required. Buyer Comment (2019-06-17): Note: If we made an exception on this why is this an open 3?

05/02/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

Send the owner a written acknowledgement that the lien is valid only in the amount that the extension of credit does not exceed the CLTV of 80%, and notice that the lien is valid only in the amount that the extension of credit secured by the homestead and not to the extent it is secured by additional real or personal property other than the homestead.

C

B

C

B

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

207022223

[Redact]

[Redact]

Compliance

Compliance

State Compliance

(TX50(a)(6)) Texas Cash-out Loan (Acknowledgment of Fair Market Value Disclosure Not Signed by the Lender)

XXXXX: Acknowledgment of the Fair Market Value not properly executed by the Lender.

Disclosure not executed by the lender

Reviewer Comment (2019-06-17): Rec'd signed disclosure.

04/09/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

To Remediate: Lender must either sign the AFMV. Best practices would be to deliver to the borrower the required disclosure signed by the lender or refund or credit the borrower $1,000 and offer the borrower the right to refinance the extension of credit for the remaining term of the loan at no cost to the borrower on the same terms, including interest, as the original extension of credit with any modifications necessary to comply with this section or on terms on which the borrower and the lender or holder otherwise agree.

C

B

C

B

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

207022223

[Redact]

[Redact]

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.

No lender credit for tolerance cure

Reviewer Comment (2019-06-17): Title - Tax Certificate Fee subject to 10% fee testing same provider borrower sis not shop

04/10/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

207022223

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Tax Certificate Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

No tolerance cure provided. Provider is unique to this fee. Change of circumstance does not apply.

Reviewer Comment (2019-06-17): Title - Tax Certificate Fee subject to 10% fee testing same provider borrower sis not shop

04/10/2019

1

A

[Redact]

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

B

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

207022223

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Credit Exception:

Ineligible property subject acreage XXXXX > 10 acres allowable. (Guidelines: Acreages exceeding ten (10) acres is not allowed for XXXXX.)

Guideline variance approved by lender at time of origination

Originator Pre-Close

Reviewer Comment (2019-06-17): CRE D201

04/03/2019

2

B

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

207022223

[Redact]

[Redact]

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 ___.

Guideline variance approved by lender at time of origination

Originator Pre-Close

Reviewer Comment (2019-06-17): CRE D201

04/03/2019

2

B

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

207022223

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

S-Corp Income Documentation Test

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (S-Corp).

Reviewer Comment (2019-06-18): Signed returns provided. Exception cleared.

06/18/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

207022223

[Redact]

[Redact]

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 signed personal returns

Reviewer Comment (2019-06-18): Signed returns provided. Exception cleared.

06/18/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

Lender to provide updated ATR/QM status

C

B

C

B

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

207787657

[Redact]

[Redact]

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 (2019-09-10): Desk Review provided with no variance. Exception cleared.

09/10/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Home Improvement

C

B

C

A

B

B

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

207787657

[Redact]

[Redact]

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 Information was not provided

Reviewer Comment (2019-09-04): Client has elected to Waive

09/04/2019

2

B

[Redact]

Primary

Refinance - Cash-out - Home Improvement

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

207787657

[Redact]

[Redact]

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Per guidelines: A VVOE be completed no more than 10 business days prior to the Note date. One in file is dated XXXXX.

Reviewer Comment (2019-09-05): Per Lender Attestation and internal guidelines, VVOE requirements is 30 days from the Note Date vs. 10 on the AUS, exception cleared Seller Comment (2019-09-05): attached is our internal credit policy showing that we have the 30 variance with both DU and LP. The VVOE we have on file meets this requirement. Please rescind, thank you Reviewer Comment (2019-09-04): Per AUS approval item 14 a non self-employed borrower VVOE must be completed within 10 days of the note. Seller Comment (2019-09-04): XXXXX has a variance that allows for VVOE's to be dated within 30 days of the note date. Please rescind. Thank you

09/05/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Home Improvement

C

B

C

A

B

B

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

207898926

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-04): Received per client.

12/04/2019

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207898926

[Redact]

[Redact]

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 (2019-12-09): Client elects to Waive Reviewer Comment (2019-12-06): The Survey Fee was disclosed as $XXXXX as a Non Shopable Fee on the LE in Section B. Borrower was not permitted to shop thus fee subject to 0%

12/09/2019

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

207898926

[Redact]

[Redact]

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.

Survey Fee was disclosed on the initial LE in the amount of $XXXXX but on the final CD reads $XXXXX. It appears the borrower was not notified of this increased fee after initial 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 (2019-12-26): XXXXX received corrected closing disclosure, letter of explanation, copy of refund check and proof of mailing. Reviewer Comment (2019-12-06): The Survey Fee was disclosed as $XXXXX as a Non Shopable Fee on the LE in Section B. Borrower was not permitted to shop thus fee subject to 0%

12/26/2019

2

B

[Redact]

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

207898926

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2019-12-05): Desk review in file. Exception cleared.

12/05/2019

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207898926

[Redact]

[Redact]

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.

CD reflects payable to lender. PCCD reflects payable to 3rd party.

Reviewer Comment (2019-12-04): PCCD cured this exception

12/04/2019

2

B

[Redact]

Primary

Purchase

Good Faith Redisclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

207933789

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2019-11-04): Received per client.

11/04/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207933789

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Flood Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXX did not disclose number of months for Flood Insurance Premium under Prepaids.

On Final CD under Prepaid Flood Insurance Premium Months the amount is blank, however, the Post CD issued XXXXX reflects the correct months of Prepaid Flood Insurance Premium.

Reviewer Comment (2019-10-24): PCCD cured this exception and added 12 months fro flood insurance.

10/24/2019

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

207933789

[Redact]

[Redact]

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. The H-8 form was used, the H-9 form should have been used. (The property state is in the 1st, 4th, 6th, or 11th circuit.)

Right to Cancel is on Form H-8 however, subject loan is paying off an existing XXXXX loan via XXXXX. Right to Cancel should be on Form H-9.

Reviewer Comment (2019-11-20): The lender provided an LOE, CD, mailing label and correct ROR form Reviewer Comment (2019-11-19): ROR, LOE, CD and mailing was provided pending the three days to pass as of XXXXX Buyer Comment (2019-11-18): XXXXX to provide correct Right to Cancel form

11/20/2019

1

A

[Redact]

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

207933789

[Redact]

[Redact]

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

HOI Coverage of $XXXXX is insufficient to cover 80% of the Appraised value that is $XXXXX resulting in a Coverage Shortfall of $XXXXX. Replacement cost from the insurer to determine coverage amount is sufficient was not provided.

Reviewer Comment (2019-11-07): The insurer provided additional verbiage that the dwelling amount is the insurable value. Reviewer Comment (2019-10-28): Please provide the guidelines for the XXXXX as guidelines state the coverage must at least cover the lessor of the loan amount $XXXXX or the cost to replace (which was no evidence on the appraisal). The images are missing either evidence of guidelines, the cost to replace or a letter from the Insurer stating maximum coverage. Seller Comment (2019-10-25): (XXXXX) This is only a requirement on XXXXX loans. Since this loan is aXXXXX product, this would not be required. Thank you!

11/07/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207933789

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2019-10-30): Desk review provided. Exception cleared.

10/30/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207935755

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-21): The client has accepted the collateral package

01/21/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

C

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

No

207935755

[Redact]

[Redact]

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Reviewer Comment (2020-01-23): All items provided

01/23/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

C

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

No

207935755

[Redact]

[Redact]

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 Processing Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Sufficient or excess cure was provided to the borrower at Closing.

01/07/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Final CD evidences Cure

C

A

C

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

207935755

[Redact]

[Redact]

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 Collateral Desktop Analysis. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Sufficient or excess cure was provided to the borrower at Closing.

01/07/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Final CD evidences Cure

C

A

C

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

207942240

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-11): The client has accepted the final collateral package

02/11/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207942240

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-02-14): Secondary product provided to support origination value.

02/14/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207942240

[Redact]

[Redact]

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 (2020-02-20): Client Elects to waive

02/20/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207942240

[Redact]

[Redact]

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 was provided for 0% tolerance fee of $XXXXX. Letter in file reflects a check was sent to the borrower on XXXXX. (D0163)

Reviewer Comment (2020-02-10): The lender issued a PCCD, LOE and check to the borrower for the fee failure

02/10/2020

2

B

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

207942240

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-14): Secondary product provided to support origination value.

02/14/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207956981

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-24): Client has accepted the collateral package

02/24/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

207956981

[Redact]

[Redact]

Compliance

Compliance

State Compliance

(TX50(a)(6)) Texas Cash-out Loan (Acknowledgment of Fair Market Value Disclosure Not Signed by the Lender)

XXXXX: Acknowledgment of the Fair Market Value not properly executed by the Lender.

Documentation in file is missing Lender's signature.

Reviewer Comment (2020-02-10): Exception cleared

02/10/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

To Remediate: Lender must either sign the AFMV. Best practices would be to deliver to the borrower the required disclosure signed by the lender or refund or credit the borrower $1,000 and offer the borrower the right to refinance the extension of credit for the remaining term of the loan at no cost to the borrower on the same terms, including interest, as the original extension of credit with any modifications necessary to comply with this section or on terms on which the borrower and the lender or holder otherwise agree.

C

A

C

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

207956981

[Redact]

[Redact]

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 was disclosed on the Final Closing Disclosure, which is sufficient to cure the 0% tolerance violation of $XXXXX.

02/05/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

C

A

C

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

207956981

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-02-10): 0% variance.

02/10/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

207956981

[Redact]

[Redact]

Credit

Asset

Asset Documentation

Aged document: Asset Account date is more than 90 days prior to the note.

-

Borrower's 401-K retirement account statement is not within 90 days of transaction date of XXXXX.

Reviewer Comment (2020-02-14): Updated statement provided

02/14/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

207959262

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-09-25): Client has accepted the final collateral package.

09/25/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Other

B

A

B

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

No

207959377

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-11-25): The client has accepted the collateral package

11/25/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207959377

[Redact]

[Redact]

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 date that the appraisal was provided to the borrowers was not found in the file.

Reviewer Comment (2019-11-22): Client Elects to Waive

11/22/2019

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207959377

[Redact]

[Redact]

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 disclosed a closing date of XXXXX. The notary date was XXXXX.

Reviewer Comment (2019-11-22): Client Elects to Waive

11/22/2019

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

207959377

[Redact]

[Redact]

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).

RTC disbursement should be XXXXX. Expiration date on RTC is XXXXX.

Reviewer Comment (2019-12-03): The lender provided evidence of the actual disbursement date via closing statement along with a corrected PCCD

12/03/2019

2

B

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

207959377

[Redact]

[Redact]

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.

An explanation from the CPA was provided.

Reviewer Comment (2020-01-14): Exception cleared.

01/14/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207959377

[Redact]

[Redact]

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.

Failed QM due to missing income documentation.

Reviewer Comment (2020-01-16): Leases provided to support the rental income as required by Appendix Q

01/16/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

207959377

[Redact]

[Redact]

Compliance

Compliance

Miscellaneous Compliance

Rental Income Documentation - Schedule E Method

Qualified Mortgage (Dodd-Frank 2014): Rental income documentation requirement not met for XXXXX. Lease Agreement and/or Tax Transcripts / Returns not provided.

A current executed lease agreement was not provided.

Reviewer Comment (2020-01-16): Leases provided to support the rental income as required by Appendix Q Reviewer Comment (2020-01-16): Lease was not provided, please provide a copy of the lease for this property to support rental income. Reviewer Comment (2019-12-03): Per Appendix Q, rental income used to qualify requires, in addition to the tax returns, a current lease. The exception still remains pending a copy of the lease

01/16/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207959377

[Redact]

[Redact]

Compliance

Compliance

Miscellaneous Compliance

Rental Income Documentation - Schedule E Method

Qualified Mortgage (Dodd-Frank 2014): Rental income documentation requirement not met for XXXXX. Lease Agreement and/or Tax Transcripts / Returns not provided.

A current executed lease agreement was not provided.

Reviewer Comment (2020-01-16): Leases provided to support the rental income as required by Appendix Q Reviewer Comment (2020-01-16): Lease was not provided, please provide a copy of the lease for this property to support rental income. Reviewer Comment (2019-12-03): Per Appendix Q, rental income used to qualify requires, in addition to the tax returns, a current lease. The exception still remains pending a copy of the lease

01/16/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207959377

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2019-11-25): Secondary value provided

11/25/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207959377

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Disbursement Date

Closing Information section of CD dated XXXXX reflects inaccurate Disbursement Date.

PCCD was provided

Reviewer Comment (2019-12-03): The lender provided a closing statement showing the corrected disbursement date along with a PCCD

12/03/2019

2

B

[Redact]

Primary

Refinance - Rate/Term

Good Faith Redisclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

207974871

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-11-04): Received per client.

11/04/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207974871

[Redact]

[Redact]

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 not provided.

Reviewer Comment (2019-11-01): Provided

11/01/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207974871

[Redact]

[Redact]

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 (2019-10-28): Client elects to waive.

10/28/2019

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

207974871

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Provided to All Parties

TILA-RESPA Integrated Disclosure: Closing Disclosure was not provided to all parties whose ownership interest is or will be subject to the security interest.

The spouse's name was not on the Closing Disclosure.

Reviewer Comment (2020-01-23): XXXXX received exhibit A indicating subject property. Exception Cleared. Seller Comment (2020-01-16): (XXXXX) XXXXX Please see attached Exhibit A Reviewer Comment (2019-12-19): XXXXX received sole and separate property agreement that is missing exhibit A. Exhibit A is required to determine ownership. Document provided on XXXXX is the sane document previously provided on XXXXX and XXXXX. Document states "See Exhibit A" but Exhibit A has not been provided Seller Comment (2019-12-17): (XXXXX) Please see attached the quitclaim deed. Please clear. Reviewer Comment (2019-12-11): XXXXX received sole and separate property agreement that is missing exhibit A. Exhibit A is required to determine ownership. Document provided on XXXXX is the sane document previously provided on XXXXX. Document states "See Exhibit A" but Exhibit A has not been provided Reviewer Comment (2019-12-02): XXXXX received sole and separate property agreement that is missing exhibit A. Exhibit A is required to determine ownership. Seller Comment (2019-11-25): (XXXXX) XXXXX is a Non borrowing title holder Reviewer Comment (2019-11-25): Please provide final Title Policy to verify single ownership. Seller Comment (2019-11-21): (XXXXX) Please advise what additional information is needed to clear this condition ? Reviewer Comment (2019-11-19): XXXXX received copy of Sole and Separate Property Agreement and Conveyance, however the Final application indicates the property will be jointly held. Please provide final Title Policy with single ownership to clear. Reviewer Comment (2019-11-06): Letter of Explanation & Corrected Closing Disclosure, and proof of delivery and NORTC to re-open recession required to cure. Seller Comment (2019-11-05): (XXXXX) Please provide an update on the QCD and DT closing package to cure conditions per Compliance.

01/23/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure, and proof of delivery and NORTC if reopened rescission required

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

207974871

[Redact]

[Redact]

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 Closing Disclosure was dated XXXXX.

Reviewer Comment (2019-11-11): Initial CD provided Reviewer Comment (2019-11-06): The loan file only contains CD's issued on XXXXX which is the same day of closing. Please provide Initial CD and proof of receipt Seller Comment (2019-11-05): (XXXXX) Please provide an update on the QCD and DT closing package to cure conditions per Compliance.

11/11/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

No Defined Cure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207974871

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2019-11-01): Provided

11/01/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207974871

[Redact]

[Redact]

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.

Same lender refinance and the incorrect form was used.

Reviewer Comment (2019-10-25): The new lender is not the same as the prior lender per title

10/25/2019

1

A

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

207997962

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-06): The client has accepted the collateral package.

01/06/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207997962

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-09): Secondary product provided supporting original value

01/09/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207997962

[Redact]

[Redact]

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Approval was not provided with loan documents.

Reviewer Comment (2020-01-07): approval provided Seller Comment (2020-01-07): (XXXXX) please see attached which was included in original upload,please waive

01/07/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

207997962

[Redact]

[Redact]

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.

Final CD disclosed Amount of Non-Escrowed Property Costs over Year 1 of $XXXXX, however, the actual amount is $XXXXX.

Reviewer Comment (2020-01-10): XXXXX received PCCD correcting non escrowed property costs and LOE. Exception Cured. Seller Comment (2020-01-08): (XXXXX) please see attached, please clear

01/10/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

207997962

[Redact]

[Redact]

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's Contact Name and NMLS ID.

Reviewer Comment (2020-01-07): Client Elects to Waive

01/07/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

207997962

[Redact]

[Redact]

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.

Binding LE disclosed a Lender Credit of $XXXXX and Final CD disclosed $XXXXX Cure for 0% tolerance violation was not provided.

Reviewer Comment (2020-01-10): XXXXX reviewed XXXXX rate lock. Exception Cleared. Seller Comment (2020-01-08): (XXXXX) please see attached, please clear Seller Comment (2020-01-08): (XXXXX) Please see the lock action that extended the rate until XXXXX. This justifies the reduce lender credit

01/10/2020

1

A

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

207997962

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-01-09): Secondary product provided supporting original value

01/09/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208069765

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-02): Secondary product provided supporting origination value

01/02/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208069765

[Redact]

[Redact]

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Missing Document: Note - Subordinate Lien not provided

Missing copy of subordinate financing Note & terms

Reviewer Comment (2020-01-08): Provided

01/08/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208069765

[Redact]

[Redact]

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 proof of delivery/receipt of appraisal to borrower within 3 business days of closing

Reviewer Comment (2019-12-26): Client elects to Waive

12/26/2019

2

B

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208069765

[Redact]

[Redact]

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 (2020-01-09): XXXXX received XXXXX CD received the same day. Exception Cleared. Reviewer Comment (2020-01-03): XXXXX received disclosure tracking for XXXXX CD. Please provide XXXXX CD as it is not located in file.

01/09/2020

1

A

[Redact]

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208069765

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-30): Client has accepted the collateral package

12/30/2019

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208185227

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-17): Exception cleared

01/17/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208185227

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-22): Secondary product provided supporting the original value

01/22/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208185227

[Redact]

[Redact]

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 on CD's.

Reviewer Comment (2020-01-17): Client elects to waive

01/17/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208185227

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Reconveyance Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

Title - Reconveyance 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 initial 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 (2020-01-23): XXXXX the borrower chose the title services provider. Seller Comment (2020-01-22): (XXXXX) The eeConveyance Fee is not a zero tolerance fee. This fee was in section C which allows it to change. Please clear this condition. Please see the Cd disclosed on XXXXX that displays the compensation change

01/23/2020

1

A

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208185227

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Originator Compensation. Fee Amount of $5XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

Changed in circumstance is dated XXXXX.

Reviewer Comment (2020-02-07): XXXXX received Changed Circumstance. The compensation changed from lender paid to borrower paid. At the time of closing the borrower had less cost. Seller Comment (2020-02-05): Please see attached, These changes occurred on the XXXXX not the XXXXX. please clear Reviewer Comment (2020-01-29): XXXXX a Changed Circumstance for the XXXXX addition of a Loan Originator fee is needed. The loan was locked on XXXXX why did the pricing change on XXXXX to borrower paid. A valid Changed Circumstance or cure is required. Seller Comment (2020-01-27): Please see the change of circumstances changing the comp from lender paid to borrower paid and the LE that was re-disclosed and the Lock where the comp changed from lender paid to borrower paid proves no increase in comp occurred, please clear Reviewer Comment (2020-01-23): XXXXX the file did not contain a Changed Circumstance dated XXXXX with the reason that a Loan Originator Compensation would be added. A valid Changed Circumstance or cure is required. Seller Comment (2020-01-22): (XXXXX) The eeConveyance Fee is not a zero tolerance fee. This fee was in section C which allows it to change. Please clear this condition. Please see the Cd disclosed on XXXXX that displays the compensation change

02/07/2020

1

A

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208185262

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-23): The client has accepted the final collateral package

01/23/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208185262

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-15): Secondary product provided supporting original value

01/15/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208185262

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Wire / Funding / Disbursement Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

Wire fee paid to attorney was not previously disclosed.

Reviewer Comment (2020-01-28): Upon further review, the exception is cleared.

01/28/2020

1

A

[Redact]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208214581

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-21): The client has accepted the collateral package

01/21/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208214581

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-08): Secondary value provided

01/08/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208214581

[Redact]

[Redact]

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 (2020-01-23): The $XXXXX variance is the application fee which was given as a credit at closing

01/23/2020

1

A

[Redact]

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

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208340353

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-26): Client has accepted the collateral package

12/26/2019

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208340353

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-02): Secondary product provided supporting origination value

01/02/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208340353

[Redact]

[Redact]

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 Flood Certification (Life Of Loan). Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Sufficient or excess cure was provided to the borrower at Closing.

Cure provided at closing.

12/20/2019

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208340353

[Redact]

[Redact]

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 acknowledged appraisal receipt or waiver form on XXXXX however appraisal delivery date documented in file is XXXXX.

Reviewer Comment (2019-12-26): Client elects to Waive

12/26/2019

2

B

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208340353

[Redact]

[Redact]

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 closing disclosure is not signed and proof of delivery is missing.

Reviewer Comment (2020-01-09): XXXXX received disclosure tracking indicating the initial CD was received the same day issued. Exception Cleared.

01/09/2020

1

A

[Redact]

Primary

Purchase

No Defined Cure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208340353

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Additional appraisal document is required.

Reviewer Comment (2020-01-02): Secondary product provided supporting origination value

01/02/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208382951

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-05): Received per client. Exception cleared.

12/05/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208382951

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2019-12-03): Desk review provided. Exception cleared.

12/03/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208382951

[Redact]

[Redact]

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.

Homeownership Counseling Disclosure and List of Organizations was not provided in imaged file.

Reviewer Comment (2019-12-04): Client elects to Waive

12/04/2019

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208382951

[Redact]

[Redact]

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.

File is missing Lender's Credit Itemization.

Reviewer Comment (2019-12-04): Client elects to Waive

12/04/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208382951

[Redact]

[Redact]

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 Closing Disclosure, Section F. Prepaids disclosed (0) number of months for the prepaid Property Taxes.

Reviewer Comment (2019-12-04): Client elects to Waive

12/04/2019

2

B

[Redact]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208382951

[Redact]

[Redact]

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 10% 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 10% tolerance violation of $XXXXX.

11/25/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208382951

[Redact]

[Redact]

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

HOI Coverage of $XXXXX is insufficient to cover Original Loan Amount value that is $XXXXX resulting in a Coverage Shortfall of $XXXXX. Replacement cost from the insurer to determine coverage amount is sufficient was not provided.

Reviewer Comment (2020-01-15): Replacement cost provided

01/15/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208382951

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2019-12-03): Desk review provided. Exception cleared.

12/03/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208382951

[Redact]

[Redact]

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 (2019-12-04): Client elects to Waive

12/04/2019

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208452083

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-19): Client has accepted the collateral package

12/19/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208452083

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2019-12-23): Secondary product provided supporting origination value

12/23/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208452083

[Redact]

[Redact]

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.

Provide borrower's consent to receive electronic disclosures XXXXX

Reviewer Comment (2020-02-14): XXXXX received required document reviewed document and upon further review find issue resolved at close no violation exists. Seller Comment (2020-02-14): Uploaded Doc U Sign Reviewer Comment (2019-12-19): There was a LE issued on XXXXX (appears to be Brokers LE) that was electronically signed by the borrower on XXXXX. In order to address the exception E-consent needs to be provided that is on or before XXXXX. Seller Comment (2019-12-17): (XXXXX) All 6 pieces of information were not available to generate an application. They did not become available until XXXXX Reviewer Comment (2019-12-16): Initial LE is E-signed XXXXX. File does not contain E-consent that is dated on or prior to XXXXX. Seller Comment (2019-12-13): (XXXXX) All information is provided that is needed. Please rescind

02/14/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208452083

[Redact]

[Redact]

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.

Initial LE issue on XXXXX reflects -$XXXXX and final CD reads -$XXXXX.

Reviewer Comment (2019-12-19): COC - re-lock Seller Comment (2019-12-17): (XXXXX) on XXXXX the borrower requested to relock their loan (NO COC required for a relock) which affected the pricing. Please see the lock confrimation from XXXXX in the file (XXXXX) and the redisclosed CD to the borrower on XXXXX in the file (XXXXX).

12/19/2019

1

A

[Redact]

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

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208452083

[Redact]

[Redact]

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.

Broker application was taken on XXXXX. Missing broker initial List of Homeownership Counseling Organizations.

Reviewer Comment (2019-12-13): Client elects to waive

12/13/2019

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208452083

[Redact]

[Redact]

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).

Exception replacing EV3 exception as loan is not a table-funded loan.

Reviewer Comment (2019-12-26): Client elects to Waive

12/26/2019

2

B

[Redact]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208469440

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-11-26): Client has accepted the collateral package

11/26/2019

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

208469440

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

The Settlement Service Provider list was not provided.

Reviewer Comment (2019-11-22): Client Elects to Waive

11/22/2019

2

B

[Redact]

Primary

Purchase

No Defined Cure

C

B

B

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

208469440

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller Value - Total Closing Costs

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed the Final value of Total Closing Costs that does not match the Total Closing Costs (Borrower-Paid) from page 2.

Section J total closing cost is listed as $XXXXX which matches the funds to close at and prior to closing by the borrower however page 3 section calculating the cash to close is $XXXXX which does not match and the variance is the Appraisal re inspection fee of $XXXXX paid prior to closing making the total closing cost paid before closing as $XXXXX but listed as $XXXXX on page 3

Reviewer Comment (2019-11-22): Client Elects to Waive

11/22/2019

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

208469440

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Borrower Closing Costs

TILA-RESPA Integrated Disclosure - Costs at Closing: Final Closing Disclosure provided on XXXXX disclosed Total Closing Costs that does not match Total Closing Costs (Borrower-Paid) on page 2.

Section J total closing cost is listed as $XXXXX which matches the funds to close at and prior to closing by the borrower however page 3 section calculating the cash to close is $XXXXX which does not match and the variance is the Appraisal re inspection fee of $XXXXX paid prior to closing making the total closing cost paid before closing as $XXXXX but listed as $XXXXX on page 3

Reviewer Comment (2019-11-22): Client Elects to Waive

11/22/2019

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

208469440

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Borrower Paid Loan Costs

TILA-RESPA Integrated Disclosure - Costs at Closing: Final Closing Disclosure provided on XXXXX disclosed Loan Costs that does not match Total Loan Costs (Borrower-Paid) on page 2.

Section J total closing cost is listed as $XXXXX which matches the funds to close at and prior to closing by the borrower however page 3 section calculating the cash to close is $XXXXX which does not match and the variance is the Appraisal re inspection fee of $XXXXX paid prior to closing making the total closing cost paid before closing as $XXXXX but listed as $XXXXX on page 3

Reviewer Comment (2019-11-22): Client Elects to Waive

11/22/2019

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

208469440

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Of Payments

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXX disclosed a Total of Payments that does not match the actual total of payments for the loan.

Per the final CD the TOP was disclosed as $XXXXX however the final calculation of the TOP is $XXXXX for a variance of $XXXXX

Reviewer Comment (2019-12-10): Letter of Explanation, Proof of Delivery, Refund check for under disclosed equivalent amount, Corrected CD provided Reviewer Comment (2019-12-02): Corrected CD and Letter of Explanation provided, Proof of Delivery and Refund check for underdisclosed equivalent amount, are needed to cure.

12/10/2019

2

B

[Redact]

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

B

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

208469440

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller Value - Closing Costs Paid Before Closing

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXX disclosed a Final value of Closing Costs Paid Before Closing that does not match the Subtotal of fees paid before closing.

Section J total closing cost is listed as $XXXXX which matches the funds to close at and prior to closing by the borrower however page 3 section calculating the cash to close is $XXXXX which does not match and the variance is the Appraisal re inspection fee of $XXXXX paid prior to closing making the total closing cost paid before closing as $XXXXX but listed as $XXXXX on page 3

Reviewer Comment (2019-11-22): Client Elects to Waive

11/22/2019

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

208469440

[Redact]

[Redact]

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.

Documentation was not provided to verify the date the appraisal was provided to the borrower.

Reviewer Comment (2019-11-22): Client Elects to Waive

11/22/2019

2

B

[Redact]

Primary

Purchase

C

B

B

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

208513691

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-16): The client has accepted the collateral package

12/16/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208513691

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2019-12-16): Secondary product provided supporting the origination value

12/16/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208513691

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

RESPA - Initial Escrow Account Statement Missing

RESPA: Initial escrow account statement was not provided to the borrower.

This disclosure was not found in the file.

Reviewer Comment (2019-12-11): IEAS was provided

12/11/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208513691

[Redact]

[Redact]

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.

The number of months was 0.

Reviewer Comment (2019-12-11): The lender provided a PCCD correcting the prepaids

12/11/2019

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208513691

[Redact]

[Redact]

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 reads "0".

Reviewer Comment (2019-12-11): The lender provided a PCCD correcting the months collected

12/11/2019

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208513691

[Redact]

[Redact]

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 cure of $XXXXX was provided at closing.

12/09/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

Final CD evidences Cure

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208513691

[Redact]

[Redact]

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. The H-8 form was used, the H-9 form should have been used. (The property state is in the 1st, 4th, 6th, or 11th circuit.)

Incorrect Notice of Right to Cancel form was used.

12/10/2019

2

A

[Redact]

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

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208513691

[Redact]

[Redact]

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying housing ratio discrepancy.

Calculated investor qualifying housing ratio of ___ exceeds Guideline housing ratio of ___.

The housing ratio of XXXXX% exceeds the lender guideline housing ratio of XXXXX%. No lender exceptions found in file.

Guideline variance approved by lender at time of origination. Borrower has XXXXX months reserves at closing Borrower has job stability for XXXXX years.

Originator Originator

Reviewer Comment (2019-12-20): ok to accept; Fail due to > XXXXX% front ratio. XXXXX reserves, $XXXXX% reduction in housing payment, $XXXXX mthly residual. BWR has owned home XXXXX yrs - all payments on time Reviewer Comment (2019-12-11): Client to review. The lender has made an exception to the housing DTI exceeding XXXXX% with compensating factors of reserves of XXXXX months reserves and an XXXXX year employment history

12/20/2019

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208515816

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-16): The client has accepted the collateral package

12/16/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208515816

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2019-12-13): Secondary product provided supporting origination value Buyer Comment (2019-12-13): XXXXX

12/13/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208515816

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Received one appraisal for review with loan documents.

Reviewer Comment (2019-12-13): Secondary product provided supporting origination value

12/13/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208515816

[Redact]

[Redact]

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.

Proof appraisal provided to borrower not in file.

Reviewer Comment (2019-12-09): Client elects to Waive

12/09/2019

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208529934

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-11-27): The client has accepted the collateral package

11/27/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208529934

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2019-11-25): Provided supporting the origination value

11/25/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208529934

[Redact]

[Redact]

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's Contact Name and NMLS ID.

Reviewer Comment (2019-11-22): Client Elects to Waive

11/22/2019

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208529934

[Redact]

[Redact]

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 CD disclosed the dollar amount by which the Total Closing Costs exceeded the legal limit of $XXXXX, however, the actual amount is $XXXXX.

Reviewer Comment (2019-11-22): Client Elects to Waive

11/22/2019

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208529934

[Redact]

[Redact]

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.

Binding LE disclosed a Credit Report Fee of $XXXXXand Final CD disclosed $XXXXX. Final CD disclosed a Lender Credit of $XXXXX, however, it is insufficient to cure the 0% tolerance violation. There is no valid COC to support the increase. The invoice dated XXXXX and again XXXXX disclosed the higher cost but this was not reported to the borrower

Reviewer Comment (2019-12-02): XXXXX received a Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD to cure this exception. Seller Comment (2019-11-29): (XXXXX) Please see attached

12/02/2019

2

B

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208529934

[Redact]

[Redact]

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.

XXXXX received a Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD to cure this exception.

Reviewer Comment (2019-12-03): XXXXX received a Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD to cure this exception.

12/03/2019

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208530353

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-16): The client has accepted the collateral package

12/16/2019

1

A

[Redact]

Primary

Purchase

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208530353

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2019-12-13): Secondary product provided supporting origination value

12/13/2019

1

A

[Redact]

Primary

Purchase

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208530353

[Redact]

[Redact]

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.

Documentation indicates appraisal was received XXXXX.

Reviewer Comment (2019-12-13): Client Elects to Waive Reviewer Comment (2019-12-13): A copy of the appraisal was mailed to the borrower on XXXXX. The effective date is XXXXX & the date of the appraisal reports is XXXXX. Exception remains. Seller Comment (2019-12-13): effective date of appraisal was XXXXX. plz see upld

12/13/2019

2

B

[Redact]

Primary

Purchase

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208530353

[Redact]

[Redact]

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.

Number of months for Property Tax paid by seller was not disclosed

Reviewer Comment (2019-12-13): Client Elects to Waive

12/13/2019

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208530353

[Redact]

[Redact]

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.

Fee amount for appraisal exceed, $XXXXX credit given by lender

12/10/2019

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208530353

[Redact]

[Redact]

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying housing ratio discrepancy.

Calculated investor qualifying housing ratio of ___ exceeds Guideline housing ratio of ___.

Lender granted the exception.

XXXXX representative FICO score > XXXX guideline minimum - 110 points above guideline minimum Guideline variance approved by lender at time of origination Lender exception in file.

Originator Originator

Reviewer Comment (2019-12-20): Ok to accept; Fail due to > XXXXX% front ratio. XXXXX reserves, $ XXXXX residual, XXXXX FICO no lates Reviewer Comment (2019-12-20): Ok to accept; Fail due to > XXXXX% front ratio. XXXXX reserves, $ XXXXX residual, XXXXX FICO no lates Buyer Comment (2019-12-13): Client to review Seller Comment (2019-12-13): if we granted the exception can we change the grade?

12/20/2019

2

B

[Redact]

Primary

Purchase

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208531512

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-17): Exception cleared

01/17/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208531512

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-14): Exception cleared 0% variance.

01/14/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208531512

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-01-14): Exception cleared. 0% variance.

01/14/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208531644

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-30): Client has accepted the collateral package

12/30/2019

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208531644

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-02): Secondary product provided supporting origination value

01/02/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208531644

[Redact]

[Redact]

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 provided on XXXXX did not disclose the required lender contact information.

Reviewer Comment (2019-12-26): Client elects to Waive

12/26/2019

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208531644

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Credit Exception:

the XXXXX 1120S for the borrower loss used to qualify is incomplete. Only page 1 was provided.

Reviewer Comment (2020-01-06): Provided

01/06/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208531645

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-19): Client has accepted the collateral package

12/19/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208531645

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Missing Secondary Valuation.

Reviewer Comment (2019-12-23): Secondary product provided supporting origination value

12/23/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208531645

[Redact]

[Redact]

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 (2019-12-23): Secondary product provided supporting origination value

12/23/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208531645

[Redact]

[Redact]

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 provided on XXXXX did not disclose the required lender contact information on page 4 of the Final CD.

Reviewer Comment (2019-12-13): Client elects to waive

12/13/2019

2

B

[Redact]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208531645

[Redact]

[Redact]

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.

Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-12-13): Client elects to waive

12/13/2019

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208531645

[Redact]

[Redact]

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 $1,125.00 exceeds tolerance of $1,015.00 plus 10% or $1,116.50. Sufficient or excess cure was provided to the borrower at Closing.

Ten Percent Fee Tolerance exceeded. Total amount of $XXXXX exceeds tolerance of $XXXXX plus 10% or $XXXXX. Sufficient or excess cure was provided to the borrower at Closing.

12/12/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208531695

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-21): The client has accepted the collateral package

01/21/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

A

C

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208531695

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Missing Secondary Valuation.

Reviewer Comment (2020-01-06): Secondary valuation provided supporting origination value.

01/06/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

A

C

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208531695

[Redact]

[Redact]

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Reviewer Comment (2020-01-15): evidence of extended coverage was provided Reviewer Comment (2020-01-06): The cost to replace per the appraiser is $XXXXX the coverage is insufficient to cover the replacement cost. The file is missing an estimated cost to replace from the insurer or an LOE from the Insurer regarding the maximum coverage allowed.

01/15/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

A

C

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208531695

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Partnership Income Documentation Test

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Partnership).

Missing additional year of tax returns, profit and loss and balance sheet.

Reviewer Comment (2020-01-15): The required documentation was provided to support appendix Q requirements. Reviewer Comment (2020-01-08): XXXXX K1 and 1065 were provided however the images are still missing a P&L and balance sheet for Commonwealth

01/15/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

A

C

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208531695

[Redact]

[Redact]

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 missing income documentation.

Reviewer Comment (2020-01-15): The required documentation was provided to support appendix Q requirements. Reviewer Comment (2020-01-08): XXXXX K1 and 1065 were provided however the images are still missing a P&L and balance sheet for Commonwealth

01/15/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208531948

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-26): Client has accepted the collateral package

12/26/2019

1

A

[Redact]

Second Home

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208531948

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2019-12-27): Secondary product provided supporting original value

12/27/2019

1

A

[Redact]

Second Home

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208531948

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2019-12-27): Secondary product provided supporting original value

12/27/2019

1

A

[Redact]

Second Home

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208531948

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 Test

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of 7,106.99 on Final Closing Disclosure provided on XXXXX not accurate.

The annual taxes $XXXXX, HOI $XXXXX and HOA $XXXXX for a total of $XXXXX

Reviewer Comment (2020-01-15): XXXXX received a corrected CD and LOE. Exception Cured.

01/15/2020

2

B

[Redact]

Second Home

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208531948

[Redact]

[Redact]

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 $45.95 exceeds tolerance of $45.72. Sufficient or excess cure was provided to the borrower at Closing.

12/20/2019

1

A

[Redact]

Second Home

Refinance - Rate/Term

Final CD evidences Cure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208534178

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-09): The client has accepted the collateral package

01/09/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

B

A

B

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

No

208534846

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-02): Secondary product provided but does not support value

01/02/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208534846

[Redact]

[Redact]

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 proof of delivery/receipt of appraisal to borrower within 3 business days of closing

Reviewer Comment (2019-12-26): Client elects to Waive

12/26/2019

2

B

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208534846

[Redact]

[Redact]

Credit

Loan Package Documentation

Application / Processing

Missing Document: Tax Certificate not provided

Missing tax certificate to support tax amount of $XXXXX/mo

Reviewer Comment (2020-01-04): Provided

01/04/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208534846

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-09): 2055 Drive provided supporting the value within 2% Reviewer Comment (2020-01-02): The XXXXX provided valuation variance is more then 10% at a variance of 12.09% and a another product is required

01/09/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208534846

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-30): Client has accepted the collateral package

12/30/2019

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208540464

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-16): The client has accepted the collateral package

12/16/2019

1

A

[Redact]

Second Home

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208540464

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2019-12-05): Desk review in file. Exception cleared.

12/05/2019

1

A

[Redact]

Second Home

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208561485

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-13): The client has accepted the collateral package

12/13/2019

1

A

[Redact]

Primary

Purchase

C

A

C

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208561485

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-13): Secondary product provided supporting original value

01/13/2020

1

A

[Redact]

Primary

Purchase

C

A

C

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208561485

[Redact]

[Redact]

Credit

Loan Package Documentation

Loan File

Missing Document: Hazard Insurance Policy not provided

Reviewer Comment (2020-01-04): Provided

01/04/2020

1

A

[Redact]

Primary

Purchase

C

A

C

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208561485

[Redact]

[Redact]

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Final Title Policy is missing. No evidence of title in file.

Missing copy of the Final Title Policy.

Reviewer Comment (2020-01-13): Provided

01/13/2020

1

A

[Redact]

Primary

Purchase

C

A

C

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208561485

[Redact]

[Redact]

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 sent electronically and e-sign consent was not provided resulting in a fee tolerance violation.

Reviewer Comment (2020-01-04): Provided Reviewer Comment (2019-12-30): Lender to provide regulatory citation that states Verbal Consent is valid. LE is E-signed by the borrower and E-consent has not been provided.

01/04/2020

1

A

[Redact]

Primary

Purchase

C

A

C

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208561485

[Redact]

[Redact]

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 $1,306.00 exceeds tolerance of $0.00. Insufficient or no cure was provided to the borrower.

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 initial 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 (2019-12-19): XXXXX received XXXXX CD. Exception Cleared.

12/19/2019

1

A

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208561485

[Redact]

[Redact]

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 per Security Instrument.

Reviewer Comment (2019-12-12): Removed from scope based on SFA Grid 3.0. Exception regraded to EV1-A

12/12/2019

1

A

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208561485

[Redact]

[Redact]

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.

CD issued on XXXXX was not provided at least 3 business days prior to closing date of XXXXX.

Reviewer Comment (2019-12-19): XXXXX received XXXXX CD. Exception Cleared.

12/19/2019

1

A

[Redact]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208561485

[Redact]

[Redact]

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 $7,682.60 and disclosure timing violations.

Missing e-sign consent agreement.

Reviewer Comment (2020-01-04): Provided

01/04/2020

1

A

[Redact]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208561485

[Redact]

[Redact]

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 disclosed homeowner's insurance under Prepaids of $XXXXX or $XXXXX per month and per month calculation disclosed is $XXXXX.

Reviewer Comment (2019-12-12): Removed from scope based on SFA Grid 3.0. Exception regraded to EV1-A

12/12/2019

1

A

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208561485

[Redact]

[Redact]

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 (2019-12-12): Removed from scope based on SFA Grid 3.0. Exception regraded to EV1-A

12/12/2019

1

A

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208561963

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-09): The client has accepted the collateral package

01/09/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208561963

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Missing Secondary Valuation.

Reviewer Comment (2020-01-03): Provided at initial review

01/03/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208561963

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00 is less than amount of binding Lender Credit previously disclosed in the amount of $-770.00.

No cure, lenders credit changed from $-XXXXX to $-XXXXX. Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD.

Reviewer Comment (2020-01-10): XXXXX received required documents, exception is cleared. Seller Comment (2020-01-10): can you please tell me what page in your file you are seeing a coc dated XXXXX? I just went thru it twice and cannot locate. tks Reviewer Comment (2020-01-06): There is a COC in the loan file that is dated XXXXX saying the loan was re-locked to XXXXX% but the CD is issued XXXXX (not within 3 business days). Please provide CD issued within 3 business days of COC. Reviewer Comment (2020-01-06): Updated from: 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. (9300) Seller Comment (2020-01-03): on XXXXX the apr rate dropped to XXXXX therefore making the lender credit drop to $770 and then on XXXXX the APR dropped again to XXXXX therefore the lender credit no longer applied.

01/10/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208561963

[Redact]

[Redact]

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 $600.00 exceeds tolerance of $500.00. Insufficient or no cure was provided to the borrower.

No cure, appraisal fee increased by $XXXXX. Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD.

Reviewer Comment (2020-01-06): COC - appraisal complexity

01/06/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208562397

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-19): Client has accepted the collateral package

12/19/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208562397

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2019-12-23): Secondary product provided to support origination value

12/23/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208562397

[Redact]

[Redact]

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 provided on XXXXX did not disclose the required Lender Contact Information

Reviewer Comment (2019-12-23): Client elects to Waive

12/23/2019

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208583932

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-30): Client has accepted the collateral package

12/30/2019

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208583932

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-03): Secondary product provided supporting origination value

01/03/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208583932

[Redact]

[Redact]

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.

Reviewer Comment (2020-01-03): Secondary product provided supporting origination value

01/03/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208583932

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Partnership Income Documentation Test

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Partnership).

Signed Business Tax Returns for XXXXX are not in the file for XXXXX.

Reviewer Comment (2020-02-12): CPA letter bridged the name change with the loan file containing XXXXX K-1s and tax returns for the prior named entitiy with the same ID Seller Comment (2020-02-10): Please see attached letter Reviewer Comment (2020-02-03): Provided was only the XXXXX for XXXXX, this business reported in XXXXX on the borrower 1040 under XXXXX. It appears an indication that XXXXX became XXXXX during a name change or visa versa. The 1065 just showing name change is insufficient. Please provide a CPA letter to verify the changes and did XXXXX EIN XXXXX issue a final K1. The losses were used and must meet SHQM Seller Comment (2020-01-31): please see attached Reviewer Comment (2020-01-21): Trailing doc was provided for XXXXX, need signed XXXXX 1065 for XXXXX; different entity

02/12/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208583932

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Partnership Income Documentation Test

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Partnership).

Signed Business Tax Returns for XXXXX are not in the file for XXXXX.

Reviewer Comment (2020-02-12): CPA letter bridged the name change with the loan file containing XXXXX K-1s and tax returns for the prior named entitiy with the same ID Seller Comment (2020-02-10): Please see attached letter Reviewer Comment (2020-02-03): Provided was only the XXXXX for XXXXX, this business reported in XXXXX on the borrower 1040 under XXXXX. It appears an indication that XXXXX became XXXXX during a name change or visa versa. The 1065 just showing name change is insufficient. Please provide a CPA letter to verify the changes and did XXXXX EIN XXXXX issue a final K1. The losses were used and must meet SHQM Seller Comment (2020-01-31): please see attached Reviewer Comment (2020-01-21): Trailing doc was provided for XXXXX, need signed XXXXX 1065 for XXXXX; different entity

02/12/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208583932

[Redact]

[Redact]

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.

Missing 3rd party verification.

Reviewer Comment (2020-02-12): CPA letter uploaded as trailing doc Seller Comment (2020-02-10): Please see attached Reviewer Comment (2020-02-03): Once the status of the business is verified via CPA letter a review to rescind the third party for income losses used to qualify will be submitted. Seller Comment (2020-01-31): please see attached Reviewer Comment (2020-01-21): VVOE provided by Lender is not considered a 3rd party verification

02/12/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208583932

[Redact]

[Redact]

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.

Third party verification not provided in file.

Reviewer Comment (2020-02-12): CPA letter uploaded as a trailing doc and confirming status of XXXXX; renamed XXXXX Seller Comment (2020-02-10): please see attached Reviewer Comment (2020-01-21): VVOE provided by Lender is not considered a 3rd party verification

02/12/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208583932

[Redact]

[Redact]

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 missing income documentation.

Reviewer Comment (2020-02-12): SHQM Loan Reviewer Comment (2020-02-03): Loan designation review pending additional information. Seller Comment (2020-01-31): please see attached

02/12/2020

1

A

[Redact]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208583932

[Redact]

[Redact]

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).

Disclosure does not reflect Lender Contact and Contact NMLS ID.

Reviewer Comment (2019-12-26): Client elects to Waive

12/26/2019

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208583932

[Redact]

[Redact]

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 $9,508.80 exceeds tolerance of $8,629.00. Insufficient or no cure was provided to the borrower.

Loan Discount Points was disclosed on the initial LE in the amount of $XXXXX but on the final CD reads $XXXXX. It appears the borrower was not notified of this increased fee after initial 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 (2020-01-21): XXXXX received Changed Circumstance. Seller Comment (2020-01-20): please attached explanation and supporting documents Reviewer Comment (2020-01-14): Provide a Valid Change of Circumstance for this exception. COC is vague and unable to determine if fee increase is justifiable. Additional details surrounding the change of circumstance required. COC XXXXX notes sales price change only. Provide a Valid Change of Circumstance outlining the fee change applicable to this exception or a cure including A Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD to cure this exception.

01/21/2020

1

A

[Redact]

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

208583932

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

NonQM ATR

Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.

Due to missing income documentation.

Reviewer Comment (2020-02-12): CPA letter provided

02/12/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208583947

[Redact]

[Redact]

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 $775.00 exceeds tolerance of $460.00. Sufficient or excess cure was provided to the borrower at Closing.

10/01/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

A

A

A

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

208583947

[Redact]

[Redact]

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 Title - Lender's Title Insurance. Fee Amount of $1,611.25 exceeds tolerance of $1,499.00. Sufficient or excess cure was provided to the borrower at Closing.

10/01/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

A

A

A

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

208691870

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-06): The client has accepted the collateral package.

01/06/2020

2

B

[Redact]

Primary

Purchase

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208691870

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-06): Secondary valuation provided supporting origination value.

01/06/2020

1

A

[Redact]

Primary

Purchase

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208691870

[Redact]

[Redact]

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

No replacement cost indicator in file.

Reviewer Comment (2020-01-16): Replacement cost provided Seller Comment (2020-01-15): (XXXXX) XXXXX XXXXX Please see attached

01/16/2020

1

A

[Redact]

Primary

Purchase

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208691870

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-01-06): Secondary valuation provided supporting origination value.

01/06/2020

1

A

[Redact]

Primary

Purchase

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208691870

[Redact]

[Redact]

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 name and information missing from Cd.

Reviewer Comment (2020-01-07): Client Elects to Waive

01/07/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208693142

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Pending Internal Customer Final Collateral Package Review.

Reviewer Comment (2019-12-23): The client has accepted the collateral package

12/23/2019

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208693142

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Missing Secondary Valuation.

Reviewer Comment (2019-12-23): Secondary product provided supporting the original value

12/23/2019

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208693142

[Redact]

[Redact]

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

XXXXXtests hazard coverage in accordance with XXXXX, which requires coverage equal to or the lesser of the following: 1) 100% 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-80% 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 $13,000.

Reviewer Comment (2020-01-06): updated value policy provided Reviewer Comment (2019-12-23): The HOI declaration page does not state any additional coverage or the percentage. Please provide a source document to verify. Seller Comment (2019-12-19): It has 25% extended replacement coverage is fine

01/06/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208693142

[Redact]

[Redact]

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 $3,475.72 exceeds tolerance of $2,770.00 plus 10% or $3,047.00. Insufficient or no cure was provided to the borrower.

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.

Reviewer Comment (2020-01-17): LOE, Proof of Delivery, corrected PCCD, and refund check provided. Exception cleared. Reviewer Comment (2019-12-23): XXXXX reviewed exception. The rate locked is not a valid changed circumstance to add title fees. Please provide a valid COC if available or please provide a corrected CD, LOE, refund check, and proof of mailing to cure. Seller Comment (2019-12-19): these fees were added on XXXXX when the rate locked as we did not get the title until XXXXX.there is no tolerance violation

01/17/2020

1

A

[Redact]

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

208693142

[Redact]

[Redact]

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 $3,475.72 exceeds tolerance of $2,770.00 plus 10% or $3,047.00. Sufficient or excess cure was provided to the borrower.

Reviewer Comment (2020-01-17): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided.

01/17/2020

2

B

[Redact]

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

208696371

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is missing secondary valuation product required for securitization.

Reviewer Comment (2019-12-06): Desk review provided. Exception cleared.

12/06/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208696371

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Purpose Test

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXX disclosed a Purpose that does not match the actual purpose for the loan.

Limited Cash-Out refinance and the final CD reflects Home Equity Loan

Reviewer Comment (2019-12-11): Client elects to waive.

12/11/2019

2

B

[Redact]

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

208696371

[Redact]

[Redact]

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.

Closing costs exceed legal limit and a cure for the 0% and/or 10% tolerance violation was not provided

Reviewer Comment (2019-12-11): Client elects to waive.

12/11/2019

2

B

[Redact]

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

208696371

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-19.64 is less than amount of binding Lender Credit previously disclosed in the amount of $-700.00.

The lender credit in the amount of -$XXXXX was disclosed on the loan estimate dated XXXXX and decreased to -$XXXXX on the final closing disclosure. No valid changed circumstance of evidence of cure provided

Reviewer Comment (2020-01-14): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided Seller Comment (2020-01-10): CD with verbiage on pgs 2 and 3 Reviewer Comment (2019-12-23): Corrected CD and LOE to cure., Lender provided a cure in the amount of $XXXXX. Page 2 in Section J needs to reflect a $XXXXX cure with a total cure and lender credit reflected as -$XXXXX. Page 3 of the CD in the calculating cash to close section needs to reflect "exceeds legal limit by $XXXXX". Cure check and proof of delivery previously provided. Seller Comment (2019-12-19): from Compliance: it's already in section J and lender credits does not show on page 3. Page 3 will only show total closing costs, which is already taken into account the lender credit. " Are you saying it should be with the "Payoffs and Payments" section of pg. 3 and not in Lender credits? Reviewer Comment (2019-12-18): The exception itself is a tolerance violation. As such, the $XXXXX should be listed in the tolerance section on section J, and on page 3. A PCCD is still required in order to cure. Seller Comment (2019-12-17): $XXXXXwas added back to lender credits, which in section J now lists $XXXXX please note that the previous CD listed only $XXXXX. Lender Credits are not reflected on pg 3. Reviewer Comment (2019-12-17): PCCD provided does not show the cure in section J, or on page 3. Please provide PCCD and LOE with cure in requires areas. Seller Comment (2019-12-16): CD for refund check Seller Comment (2019-12-16): refund check for lender credit

01/14/2020

2

B

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208696382

[Redact]

[Redact]

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Final Title Policy is missing. No evidence of title in file.

The file was missing a copy of the final title policy.

Reviewer Comment (2019-12-09): Exception cleared

12/09/2019

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

208696382

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

C-Corp Income Documentation Test

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (C-Corp).

Missing XXXXX 1120 Tax Return. Tax Extension was provided.

Reviewer Comment (2019-12-17): Exception cleared Reviewer Comment (2019-12-11): Once trailing docs are uploaded, they will be reviewed. Seller Comment (2019-12-10): Nowhere are any of the conditions asking for signed/dated XXXXX returns. I understand they are needed, but this condition could have been addressed days ago if the correct item had been requested. I will work on getting the Personal XXXXX signed returns. Reviewer Comment (2019-12-09): From our compliance dept. The personal tax returns for XXXXX are in the loan file, but they are not signed/dated as required under Appendix Q and the transcripts are not available to provide implicit adherence to document the returns were filed. Understanding the business returns were on extension, thereby not available, the personal returns were provided, but unsigned. Exception remains. Reviewer Comment (2019-12-09): Submitted to our compliance dept fro review. Seller Comment (2019-12-07): PLEASE ADVISE: WHY ISN'T THE EXTENSION BEING ACCEPTED? XXXXX HAS BEEN EXTENDED, THEY ARE NOT AVAILABLE. VALID EXTENSION WAS PROVIDED AND CONFIRMED BY YOUR SUSPENSE ABOVE. WHAT IS THE ISSUE AND WHAT DO YOU NEED TO CLEAR IF XXXXX ARE NOT COMPLETED?

12/17/2019

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

208696382

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Partnership Income Documentation Test

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Partnership).

Borrower provided a signed XXXXX and Unsigned XXXXX personal returns. XXXXX Transcripts search found no record for XXXXX personal returns.

Reviewer Comment (2019-12-17): Exception cleared

12/17/2019

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

208696382

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Partnership Income Documentation Test

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Partnership).

Business started on XXXXX. Borrower provided XXXXX business returns and signed XXXXX and Unsigned XXXXX personal returns. No results found for XXXXX personal Transcripts.

Reviewer Comment (2020-01-13): XXXXX Business returns not filed per CPA letter. Reviewer Comment (2019-12-18): This exception only pertains to tax returns. Only need signed XXXXX Business returns for XXXXX then will submit for our compliance dept to review. Seller Comment (2019-12-18): None of this was originally conditioned for -- you reference Personal Returns being unsinged. Specifics were never provided. If this had been addressed earlier, this could have been provided. Before I go back again, is there anything else I will need other than the XXXXX signed business returns to get this cleared? Provided in original upload is the P&L for XXXXX. it is signed and dated. Is this not being considered? Reviewer Comment (2019-12-18): Borrower provided unsigned XXXXX business tax returns. File does not contain XXXXX business transcripts. Appendix require 2 years business returns. Business started in XXXXX. Please provided a signed XXXXX and once received will submit to our compliance dept to review since we do not have 2 years business returns. Exception remains. Seller Comment (2019-12-17): there will be no transcripts....both personal and business are extended and i provided all of that evidence. Please advise asap why this isn't cleared. Seller Comment (2019-12-17): i am very confused. You said XXXXX signed personal returns that I provided and you signed off. Now you want transcripts too?

01/13/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

208696382

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure: Seller Closing Disclosure not located in the file.

missing Seller CD

Reviewer Comment (2019-12-11): Client elects to waive.

12/11/2019

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

208696382

[Redact]

[Redact]

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 $775.00 exceeds tolerance of $750.00. Insufficient or no cure was provided to the borrower.

Cure of $XXXXX was provided on Final Closing Disclosure.

Reviewer Comment (2019-12-03): A cure of $XXXXX provided at closing.

12/03/2019

1

A

[Redact]

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

208696382

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for MERS Fee. Fee Amount of $12.00 exceeds tolerance of $0.00. Insufficient or no cure was provided to the borrower.

MERS 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 initial 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 (2019-12-17): COC provided. Exception cleared.

12/17/2019

1

A

[Redact]

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

208696382

[Redact]

[Redact]

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 income documentation.

Reviewer Comment (2020-01-13): SHQM Loan Reviewer Comment (2019-12-18): Due to missing income documentation.

01/13/2020

1

A

[Redact]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

208696382

[Redact]

[Redact]

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 reflects a closing date of XXXXX however borrower signed on XXXXX.

Reviewer Comment (2019-12-11): Client elects to waive.

12/11/2019

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

208696382

[Redact]

[Redact]

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.

Number of months was not provided.

Reviewer Comment (2019-12-11): Client elects to waive.

12/11/2019

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

208696382

[Redact]

[Redact]

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 (2019-12-11): Client elects to waive.

12/11/2019

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

208696382

[Redact]

[Redact]

Credit

Loan Package Documentation

Loan File

Missing Document: Hazard Insurance Policy not provided

The file was missing a copy of the Homeowner's Insurance declaration page.

Reviewer Comment (2019-12-17): Exception cleared

12/17/2019

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

208696382

[Redact]

[Redact]

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.

Borrower provided XXXXX Tax Extension

Reviewer Comment (2019-12-11): Client elects to waive.

12/11/2019

2

B

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

208696382

[Redact]

[Redact]

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.

Borrower provided XXXXX Tax Extension

Reviewer Comment (2019-12-11): Client elects to waive.

12/11/2019

2

B

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

208696382

[Redact]

[Redact]

Credit

Asset

Asset Documentation

Guideline Issue: Insufficient asset documentation.

-

Guidelines require: Personal assets require the two most recent, consecutive months' statements for each account. Only have a print out from XXXXX - XXXXX.

Reviewer Comment (2019-12-09): Exception cleared Seller Comment (2019-12-07): THIS WAS PROVIDED AT ORIGINAL UPLOAD - UPLOADING AGAIN

12/09/2019

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

208696382

[Redact]

[Redact]

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 $775.00 exceeds tolerance of $750.00. Sufficient or excess cure was provided to the borrower at Closing.

12/17/2019

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

208696385

[Redact]

[Redact]

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 (2019-12-12): XXXXX received required documents, exception is cured.

12/12/2019

2

B

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208696385

[Redact]

[Redact]

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 difference of $XXXXX the cash back to the borrower.

Reviewer Comment (2019-12-11): Client elects to waive.

12/11/2019

2

B

[Redact]

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

208696385

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Partial Payments

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXX incorrectly disclosed whether the loan allows for Partial Payments.

Closing disclosure page 4 indicates both the lender may accept partial payments and does not accept partial payments.

Reviewer Comment (2019-12-31): XXXXX received a corrected CD and LOE. Exception Cured. Reviewer Comment (2019-12-18): ROR for provided. Pending CD correction for Partial Payments. Exception remains. Reviewer Comment (2019-12-12): Page 4 of PCCD dated XXXXX has two check marks under partial payment heading when there should be only one. PCCD and LOE required to cure.

12/31/2019

2

B

[Redact]

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

208696385

[Redact]

[Redact]

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.

1. Current payoff balance $XXXXX. 2. New loan amount w/same lender $XXXXX. 3. Borrower is getting cash back at closing in the amount $XXXXX. Loan is subject recession.

Reviewer Comment (2019-12-20): ROR expired. Exception cured. Reviewer Comment (2019-12-18): LOE and correct form provided. Borrower signed form as Proof of Delivery. Rescission expires after XXXXX. Exception will be cured on XXXXX. Exception remains.

12/20/2019

2

B

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208696385

[Redact]

[Redact]

Property

Property - Appraisal

General Appraisal Requirements

Valuation Exception:

Per guidelines: One full appraisal AND XXXXX Appraisal Department desk review required with loan amounts > $1XXXXX. File is missing internal desk review.

Reviewer Comment (2019-12-12): Secondary product provided supporting the origination value

12/12/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208696397

[Redact]

[Redact]

Compliance

Loan Package Documentation

Application / Processing

Missing Document: Missing Lender's Initial 1003

Missing Document: Missing Lender's Initial 1003

Reviewer Comment (2019-12-17): Client elects to waive

12/17/2019

2

B

[Redact]

Primary

Purchase

D

B

D

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208696397

[Redact]

[Redact]

Credit

Property - Appraisal

Appraisal Documentation

Missing Document: Appraisal not provided

Missing Document: Appraisal not provided

Reviewer Comment (2020-01-08): Exception cleared.

01/08/2020

1

A

[Redact]

Primary

Purchase

D

B

D

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208696397

[Redact]

[Redact]

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 (2020-01-08): Exception cleared

01/08/2020

1

A

[Redact]

Primary

Purchase

D

B

D

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208696397

[Redact]

[Redact]

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) 100% 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-80% 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 $87,500.

Reviewer Comment (2020-01-08): Exception cleared

01/08/2020

1

A

[Redact]

Primary

Purchase

D

B

D

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208696397

[Redact]

[Redact]

Property

Missing Document

Appraisal Documentation

Loan is to go into a securitization, and full appraisal was not provided.

There's no evidence of a secondary valuation as required for securitization.

Reviewer Comment (2020-01-08): Exception cleared

01/08/2020

1

A

[Redact]

Primary

Purchase

D

B

D

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208696397

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Missing Initial Loan Application Test

No evidence of application date located in file. Compliance tests were run using an application date of XXXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.

Reviewer Comment (2019-12-17): Client elects to waive

12/17/2019

2

B

[Redact]

Primary

Purchase

D

B

D

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208696397

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

NMLS - Missing Evidence of Initial Loan Application Date

Truth in Lending Act (NMLSR Dodd- Frank 2014): Unable to determine compliance with NMLSR timing requirements due to missing evidence of initial loan application date.

Reviewer Comment (2020-01-08): Exception cleared

01/08/2020

1

A

[Redact]

Primary

Purchase

D

B

D

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208696397

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision REO Principal and Interest Amount Considered

Ability to Repay (Dodd-Frank 2014): REO has no P&I amount but is not indicated as a free & clear owned property.

REO at XXXXX has no P&I amount but is not indicated as a free & clear owned property. Per Final 1003 subject is Pending Sale, however, Closing Statement of Closing Disclosure were not provided.

Reviewer Comment (2020-01-08): Exception cleared

01/08/2020

1

A

[Redact]

Primary

Purchase

D

B

D

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208696397

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

NonQM ATR

Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.

General Ability-to-Repay requirement not satisfied due to P&I from Pending Sale not considered.

Reviewer Comment (2020-01-08): Exception cleared

01/08/2020

1

A

[Redact]

Primary

Purchase

D

B

D

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208696397

[Redact]

[Redact]

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.

Originator Loan Designation discrepancy is due to P&I from Pending Sale not considered.

Reviewer Comment (2020-01-08): Exception cleared

01/08/2020

1

A

[Redact]

Primary

Purchase

Lender to provide updated ATR/QM status

D

B

D

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208696397

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

QM REO Principal and Interest Amount Considered

Qualified Mortgage (Dodd-Frank 2014): REO has no P&I amount but is not indicated as a free & clear owned property.

REO at XXXXX has no P&I amount but is not indicated as a free & clear owned property. Per Final 1003 subject is Pending Sale, however, Settlement Statement or Closing Disclosure were not provided.

Reviewer Comment (2020-01-08): Exception cleared

01/08/2020

1

A

[Redact]

Primary

Purchase

D

B

D

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208696397

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided Within 3 Business Days of Application

Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.

Unable to verify timing requirements due to missing Initial Loan Application.

Reviewer Comment (2019-12-17): Client elects to waive

12/17/2019

2

B

[Redact]

Primary

Purchase

D

B

D

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208696397

[Redact]

[Redact]

Property

Missing Document

Appraisal Documentation

Loan is to go into a securitization, and full appraisal was not provided.

Reviewer Comment (2020-01-29): exception cleared

01/29/2020

1

A

[Redact]

Primary

Purchase

D

B

D

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208696402

[Redact]

[Redact]

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 listed on the Final Closing Disclosure is 1 day before the actual closing date.

Reviewer Comment (2019-12-11): Client elects to waive.

12/11/2019

2

B

[Redact]

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

208696402

[Redact]

[Redact]

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 was left blank on the initial Closing Disclosure.

Reviewer Comment (2019-12-11): Client elects to waive.

12/11/2019

2

B

[Redact]

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

208696402

[Redact]

[Redact]

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.

The Initial Loan Estimate was not provided until almost a week after origination.

Reviewer Comment (2019-12-12): Exception cleared.

12/12/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208696402

[Redact]

[Redact]

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 (2019-12-11): Client elects to waive.

12/11/2019

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208696402

[Redact]

[Redact]

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's Contact information was not provided on the Final Closing Disclosure.

Reviewer Comment (2019-12-11): Client elects to waive.

12/11/2019

2

B

[Redact]

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

208696402

[Redact]

[Redact]

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 $3,617.72 exceeds tolerance of $3,320.00. Insufficient or no cure was provided to the borrower.

The amount increased without a valid change of circumstance.

Reviewer Comment (2019-12-12): Exception cleared.

12/12/2019

1

A

[Redact]

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

208696402

[Redact]

[Redact]

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 (2019-12-12): Exception cleared. Seller Comment (2019-12-12): XXXXX property - finalized PCCD attached for review.

12/12/2019

1

A

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208696402

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2019-12-12): 0% variance

12/12/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208696402

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application.

Missing broker initial LE, broker application date is XXXXX, have lender LE issued on XXXXX.

Reviewer Comment (2019-12-17): Cleared new exception set.

12/17/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208696402

[Redact]

[Redact]

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 received and is e-signed XXXXX. File missing E-consent signed and dated by the borrower on or before XXXXX. Lender consent obtained on XXXXX. Missing Broker E-consent

Reviewer Comment (2019-12-30): E-consent provided

12/30/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208704767

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-13): Client has accepted the collateral package.

01/13/2020

2

B

[Redact]

Primary

Purchase

C

B

B

B

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208704767

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-03): Provided at initial review

01/03/2020

1

A

[Redact]

Primary

Purchase

C

B

B

B

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208704767

[Redact]

[Redact]

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.

There's no evidence of an earlier CD in the file provided prior to 3-business days of the closing date.

Reviewer Comment (2020-01-09): XXXXX received edisclosure tracking and attestation indicating XXXXX CD that was printed on XXXXX was issued on XXXXX. Reviewer Comment (2020-01-08): XXXXX received XXXXX CD however bottom is dated XXXXX. Please provide attestation if this CD has the issue date incorrect or please provide the XXXXX CD referenced for review. Reviewer Comment (2020-01-04): The disclosure summary indicates a CD was created with a XXXXX date however this CD was not provided.

01/09/2020

1

A

[Redact]

Primary

Purchase

No Defined Cure

C

B

B

B

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208706628

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-30): Client has accepted the collateral package

12/30/2019

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208706628

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-06): Secondary valuation provided supporting origination value.

01/06/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208728885

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-30): Client has accepted the collateral package

12/30/2019

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208728885

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-02): Secondary product provided supporting origination value

01/02/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208728885

[Redact]

[Redact]

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.

Sufficient documentation for the Borrowers previous employment is not provided.

Reviewer Comment (2020-01-13): Client has elected to Waive Reviewer Comment (2020-01-04): Per SHQM a two year history verified is required. The borrower current employer is less than two year and the application is not a sufficient document to support prior. Please provide a verbal for the borrower prior employer with begin and end dates. Seller Comment (2020-01-03): previous employment is on final 1003 and attached is the current dates.

01/13/2020

2

B

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208728885

[Redact]

[Redact]

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 $815.00 exceeds tolerance of $665.00. Sufficient or excess cure was provided to the borrower at Closing.

Tolerance Exceeded. No cure provided.

12/20/2019

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208728892

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-22): Client has accepted the collateral package

01/22/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208728892

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-23): Secondary product provided supporting original value

01/23/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208728892

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-01-23): Secondary product provided supporting original value

01/23/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208728892

[Redact]

[Redact]

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 information is not indicated on the Borrower's Final Closing Disclosure.

Reviewer Comment (2020-01-23): Client Elects to Waive

01/23/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208735600

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-13): The client has accepted the collateral package

03/13/2020

1

A

[Redact]

Second Home

Refinance - Rate/Term

B

B

B

A

B

B

A

A

Safe Harbor QM

Safe Harbor QM

No

208735600

[Redact]

[Redact]

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 Borrower's receipt of the Appraisal is not included in the file.

Reviewer Comment (2020-03-10): Client has elected to waive

03/10/2020

2

B

[Redact]

Second Home

Refinance - Rate/Term

B

B

B

A

B

B

A

A

Safe Harbor QM

Safe Harbor QM

No

208735600

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

RESPA - Initial Escrow Account Statement Missing

RESPA: Initial escrow account statement was not provided to the borrower.

Reviewer Comment (2020-03-10): Client has elected to waive

03/10/2020

2

B

[Redact]

Second Home

Refinance - Rate/Term

B

B

B

A

B

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

208737683

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-03): Secondary product provided supporting origination value

01/03/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208737683

[Redact]

[Redact]

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 closed and disbursed on XXXXX - New Construction, first permanent financing loan.

Reviewer Comment (2020-01-28): Exception cleared.

01/28/2020

1

A

[Redact]

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

A

A

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208737683

[Redact]

[Redact]

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).

Subject closed and disbursed on XXXXX - New Construction, first permanent financing loan.

Reviewer Comment (2020-01-21): No need for cure, ledger shows New construction funded on XXXXX. Seller Comment (2020-01-20): Please see attached, payoff proves we paying off a construction loan. The ledger shows the funds were wired XXXXX. Please clear condition.

01/21/2020

1

A

[Redact]

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

A

A

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208737683

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-03): Secondary product provided supporting origination value

01/03/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208737683

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-30): Client has accepted the collateral package

12/30/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208744198

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-06): The client has accepted the collateral package.

01/06/2020

2

B

[Redact]

Primary

Purchase

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208744198

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Missing Secondary Valuation.

Reviewer Comment (2020-01-06): Secondary valuation provided supporting origination value.

01/06/2020

1

A

[Redact]

Primary

Purchase

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208744198

[Redact]

[Redact]

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Approval was not provided with loan documents.

Reviewer Comment (2020-01-04): Provided Seller Comment (2020-01-02): XXXXX XXXXX Please see attached

01/04/2020

1

A

[Redact]

Primary

Purchase

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208744198

[Redact]

[Redact]

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 information was not provided for Lender on page 5 of the Final CD.

Reviewer Comment (2020-01-07): Client Elects to Waive

01/07/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208744562

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-30): Client has accepted the collateral package

12/30/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208744562

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-02): Secondary product provided supporting origination value

01/02/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208744562

[Redact]

[Redact]

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.

Letter of explanation in file reflects decline in self-employed income is due to deferred compensation billed in XXXXX and received in XXXXX. YTD P&L reflects income to be in line and exceeding XXXXX income.

Reviewer Comment (2020-01-17): Agree with findings, exception cleared. Seller Comment (2020-01-10): (XXXXX) The LOX does not state that the compensation was billed in XXXXX and paid in XXXXX. It is stating that the compensation was billed in XXXXX and paid out in XXXXX hence the decline in the income for XXXXX and increase in income for XXXXX. The stability of the business would not be in question in this case.

01/17/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208744562

[Redact]

[Redact]

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 the Lender's Contact Name and NMLS ID number on Page 5 of the Final CD.

Reviewer Comment (2019-12-26): Client elects to Waive

12/26/2019

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208744562

[Redact]

[Redact]

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.

File is missing signatures on XXXXX 1040's and Letter of explanation in file reflects decline in self-employed income is due to deferred compensation billed in XXXXX but received in XXXXX. YTD P&L reflects income to be in line and exceeding XXXXX income. Lender to provide updated ATR/QM status

Reviewer Comment (2020-01-17): Agree with findings, exception cleared. Seller Comment (2020-01-10): (XXXXX) The LOX does not state that the compensation was billed in XXXXX and paid in XXXXX. It is stating that the compensation was billed in XXXXX and paid out in XXXXX hence the decline in the income for XXXXX and increase in income for XXXXX. The stability of the business would not be in question in this case.

01/17/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208744562

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-02): Secondary product provided supporting origination value

01/02/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208756300

[Redact]

[Redact]

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 the amount is blank, however, on Post CD the cure of $XXXXX was reflected, which is insufficient to cure violations of $XXXXX.

Reviewer Comment (2019-12-12): Removed from scope based on SFA Grid 3.0. Exception regraded to EV1-A

12/12/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208756300

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Document Preparation Fee. Fee Amount of $100.00 exceeds tolerance of $0.00. Insufficient or no cure was provided to the borrower.

Cure of $XXXXX was disclosed on the Post Closing Disclosure, which is insufficient to cure the various 0% tolerance violations of $XXXXX.

Reviewer Comment (2019-12-18): XXXXX received a Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD to cure this exception. Seller Comment (2019-12-18): (XXXXX) please see attached revised cd, lox, check, tracking, please clear thank you

12/18/2019

2

B

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208756300

[Redact]

[Redact]

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 $250.00 exceeds tolerance of $0.00. Insufficient or no cure was provided to the borrower.

Cure of $XXXXX was disclosed on the Post Closing Disclosure, which is insufficient to cure the various 0% tolerance violations of $XXXXX.

Reviewer Comment (2019-12-18): XXXXX received a Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD to cure this exception. Seller Comment (2019-12-18): (XXXXX) please see attached revised cd, check, lox tracking, please clear

12/18/2019

2

B

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208756300

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 Test

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of 10,192.92 on Final Closing Disclosure provided on XXXXX not accurate.

Final Closing Disclosure disclosed Total Property Costs Year 1 of $1XXXXX; calculated Total Property Costs Year 1 is $XXXXX. Difference is due to property taxes used by the Lender reflects an annual premium of $XXXXX or $XXXXX per month, however, Final Closing Disclosure disclosed the annual premium as $XXXXX or $XXXXX per month.

Reviewer Comment (2020-01-23): PCCD provided correcting the cost year 1 Seller Comment (2020-01-22): Please see revised cd/lox/tracking, please clear thank you Reviewer Comment (2020-01-14): XXXXX reviewed exception. The allowable tolerance for the escrow account fields on page four of the CD is $0.02 per month of property costs or $0.24 for 12 months. Total disclosed on page four of CD is $2XXXXX and documentation in images indicates total should be $ XXXXX or $ XXXXX ($ XXXXX HOI, $XXXXX Taxes) Please provide verification if using an updated amount. Letter of Explanation and Corrected CD required to cure. Seller Comment (2020-01-10): (XXXXX) Attached is the tax information that the Correspondent used to calculate the taxes on the CD. The first page shows the total as $XXXXX, which matches their CD. Reviewer Comment (2020-01-08): XXXXX reviewed exception. Please provide calculation used to determine taxes for review. Seller Comment (2020-01-06): (XXXXX) As per the correspondent, The property is a XXXXX property. The tax cert for XXXXX has an assessed value of $XXXXX. The value for XXXXX and moving forward is far more likely to match the higher figure. Listing an unimproved amount would be an underdisclose that does not match the good faith effort required by the CFPB. Reviewer Comment (2020-01-03): There seems to be no evidence to support the larger figure for taxes, and as such, the borrower is currently being overcharged. PCCD and LOE required to cure. Seller Comment (2020-01-02): (XXXXX) As per the Correspondent, The tax cert is without improvements. The last CD provided on XXXXX had estimated taxes at $XXXXX which is far more accurate than $XXXXX from an unimproved XXXXX tax cert please clear thank you Reviewer Comment (2019-12-17): Letter of explanation and Corrected CD required to cure. Lender using $ XXXXX / month for taxes and insurance. Insurance confirmed $ XXXXX / month and XXXXX taxes $ XXXXX (based on tax cert) for a total of $ XXXXX Seller Comment (2019-12-13): (XXXXX) As per the Correspondent, . In addition, XXXXX paid his XXXXX property taxes at closing and he is not escrowing. There should be no further conditions required.Please clear thank you

01/23/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208756300

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-19): Client has accepted the collateral package

12/19/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208756300

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2019-12-23): Secondary product provided to support origination value

12/23/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208756300

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Document Preparation Fee. Fee Amount of $100.00 exceeds tolerance of $0.00. Sufficient or excess cure was provided to the borrower.

XXXXX received a Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD to cure this exception.

Reviewer Comment (2019-12-23): Client elects to Waive

12/23/2019

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208756300

[Redact]

[Redact]

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 $250.00 exceeds tolerance of $0.00. Sufficient or excess cure was provided to the borrower.

XXXXX received a Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD to cure this exception.

Reviewer Comment (2019-12-23): Client elects to Waive

12/23/2019

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208756301

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-19): Client has accepted the collateral package

12/19/2019

1

A

[Redact]

Primary

Refinance - Limited Cash-out GSE

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208756301

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2019-12-23): Secondary product provided to support origination value

12/23/2019

1

A

[Redact]

Primary

Refinance - Limited Cash-out GSE

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208756301

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

S-Corp Income Documentation Test

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (S-Corp).

Self-employed income documentation not sufficient due to Personal and Business Tax Returns provided are not signed/dated.

Reviewer Comment (2020-01-15): Signed returns provided

01/15/2020

1

A

[Redact]

Primary

Refinance - Limited Cash-out GSE

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208756301

[Redact]

[Redact]

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 borrower personal and business returns along with the P&L and Balance sheet were not signed.

Reviewer Comment (2020-01-15): Signed returns provided Seller Comment (2020-01-10): The profit and loss statements and balance sheets are not required to be signed. Please rescind.

01/15/2020

1

A

[Redact]

Primary

Refinance - Limited Cash-out GSE

Lender to provide updated ATR/QM status

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208756301

[Redact]

[Redact]

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 (2019-12-13): Client elects to waive

12/13/2019

2

B

[Redact]

Primary

Refinance - Limited Cash-out GSE

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208756301

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-4,611.75 is less than amount of binding Lender Credit previously disclosed in the amount of $-6,674.00.

Binding LE disclosed a Lender Credit of $XXXXX and Final CD disclosed $XXXXX. Cure for 0% tolerance violation was not provided.

Reviewer Comment (2019-12-23): COC - loan pricing changed as appraised values went from $XXXXX to $XXXXX Seller Comment (2019-12-19): (XXXXX) On XXXXX a COC was submitted to change the appraised value significantly (COC XXXXX in the file pages 328 - 330). Please see the re-disclosed LE deliver to the borrower on XXXXX (LE does not show cents, will always round up or down lender credit shows $XXXXX on LE) see pages 292 - 294.

12/23/2019

1

A

[Redact]

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

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208756301

[Redact]

[Redact]

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 (2020-01-13): Client has elected to Waive

01/13/2020

2

B

[Redact]

Primary

Refinance - Limited Cash-out GSE

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208790120

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-26): The client has accepted the collateral package

12/26/2019

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208790120

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-02): Secondary product provided supporting origination value

01/02/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208790120

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

S-Corp Income Documentation Test

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (S-Corp).

Failed QM due to missing P&L and Balance sheet.

Reviewer Comment (2020-01-17): uploaded as trailing doc Seller Comment (2020-01-13): (XXXXX) XXXXX XXXXX Please see attached.

01/17/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208790120

[Redact]

[Redact]

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.

Failed QM due to missing P&L and Balance sheet.

Reviewer Comment (2020-01-17): uploaded as trailing doc Seller Comment (2020-01-13): (XXXXX) XXXXX XXXXX Please see attached.

01/17/2020

1

A

[Redact]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208790120

[Redact]

[Redact]

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).

A Lender Contact was not provided.

Reviewer Comment (2019-12-26): Client elects to Waive

12/26/2019

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208790120

[Redact]

[Redact]

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 $1,090.00 exceeds tolerance of $470.00. Sufficient or excess cure was provided to the borrower at Closing.

Tolerance exceeded for Appraisal Fee, Final CD contains lender credit of $XXXXX to cure tolerance.

12/18/2019

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208790120

[Redact]

[Redact]

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 $60.25 exceeds tolerance of $50.00. Sufficient or excess cure was provided to the borrower at Closing.

Tolerance exceeded for Credit Report Fee, Final CD contains lender credit of $XXXXX to cure tolerance.

12/18/2019

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208790120

[Redact]

[Redact]

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.

Missing a signed document at closing acknowledging their receipt of the valuation 3 days prior to closing.

Reviewer Comment (2019-12-26): Client elects to Waive

12/26/2019

2

B

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208794865

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-13): Client has accepted the collateral package

01/13/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208794865

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization

Reviewer Comment (2020-01-14): Exception cleared. 0% variance.

01/14/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208794865

[Redact]

[Redact]

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 for Lender was not provided.

Reviewer Comment (2020-01-13): Client has elected to Waive

01/13/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208796789

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-18): Client has accepted the collateral package

12/18/2019

1

A

[Redact]

Second Home

Purchase

C

B

B

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

208796789

[Redact]

[Redact]

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 was provided

Reviewer Comment (2019-12-13): Client Elects to Waive

12/13/2019

2

B

[Redact]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

208796789

[Redact]

[Redact]

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 $525.00 exceeds tolerance of $375.00. Insufficient or no cure was provided to the borrower.

The images are missing either a valid change of circumstance for the increase fee or a cure to the borrower.

Reviewer Comment (2020-01-14): XXXXX received required documents, exception is cured. Reviewer Comment (2019-12-23): Survey Fee disclosed on the LE's in Section B $XXXXX. Section B fees considered Non Shop-able subject to 0% tolerance

01/14/2020

2

B

[Redact]

Second Home

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

A

A

Safe Harbor QM

Safe Harbor QM

Yes

208796789

[Redact]

[Redact]

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 $525.00 exceeds tolerance of $375.00. Sufficient or excess cure was provided to the borrower.

XXXXX received required documents, exception is cured.

Reviewer Comment (2020-01-14): XXXXX received required documents, exception is cured.

01/14/2020

2

B

[Redact]

Second Home

Purchase

C

B

B

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

208797400

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-06): The client has accepted the collateral package.

01/06/2020

2

B

[Redact]

Primary

Purchase

C

B

B

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208797400

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-06): Secondary valuation provided supporting origination value.

01/06/2020

1

A

[Redact]

Primary

Purchase

C

B

B

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208797400

[Redact]

[Redact]

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).

Information not included on CD.

Reviewer Comment (2020-01-07): Client Elects to Waive

01/07/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208797412

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-26): Client has accepted the collateral package

12/26/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208797412

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-02): Secondary product provided to support origination value

01/02/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208797412

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-01-02): Secondary product provided to support origination value

01/02/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208797413

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-26): Client has accepted the collateral package

12/26/2019

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208797413

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-03): Secondary product provided supporting origination value

01/03/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208797413

[Redact]

[Redact]

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 declining income source.

Reviewer Comment (2020-01-04): Income evaluated and data inputs corrected the borrower total income meets DTI guidelines and all sources confirmed. Reviewer Comment (2019-12-31): The failure is due to income causing a DTI issue. The cash flow provided lists income for the CCorp as $XXXXX however the values of $XXXXX for XXXXX and $XXXXX for XXXXX is not supported. The 1120 profits reported are not income reporting to the borrower. The income used is the W2 and depreciation only for the CCorp which is $XXXXX

01/04/2020

1

A

[Redact]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208797413

[Redact]

[Redact]

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 $1,622.50 on Final Closing Disclosure provided on XXXXX not accurate.

HOA dues over one year are $XXXXX.

Reviewer Comment (2020-01-07): XXXXX received PCCD correcting non escrowed property costs and LOE. Exception Cured. Reviewer Comment (2019-12-30): XXXXX reviewed the exception. The appraisal indicates HOA dues of $ XXXXX/mo or $ XXXXX/year or $ XXXXX for 11 months. The allowable tolerance for the escrow account fields on page four of the CD is $0.02 per month of property costs or $0.24 for 12 months. Please provide verification if using an updated amount. Letter of Explanation and Corrected CD required to cure. Seller Comment (2019-12-30): (XXXXX) Hello, we are not seeing the discrepancy here. We uploaded the final CD, please advise.

01/07/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208797413

[Redact]

[Redact]

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 required.

Reviewer Comment (2020-01-03): Secondary product provided supporting origination value

01/03/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208797413

[Redact]

[Redact]

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 43.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

The borrower verified income is $XXXXX from primary and $XXXXX from C Corp. The income used by lender of $XXXXX is not supported and there is no income worksheet or year to date W2 earnings that would show a higher income source.

Reviewer Comment (2020-01-04): Income evaluated and data inputs corrected the borrower total income meets DTI guidelines and all sources confirmed. Reviewer Comment (2019-12-31): The failure is due to income causing a DTI issue. The cash flow provided lists income for the CCorp as $XXXXX however the values of $XXXXX for XXXXX and $XXXXX for XXXXX is not supported. The 1120 profits reported are not income reporting to the borrower. The income used is the W2 and depreciation only for the CCorp which is $XXXXX

01/04/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208797413

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

QM DTI

Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.

The borrower verified income is $XXXXX from primary and $XXXXX from C Corp. The income used by lender of $XXXXX is not supported and there is no income worksheet or year to date W2 earnings that would show a higher income source.

Reviewer Comment (2020-01-04): Income evaluated and data inputs corrected the borrower total income meets DTI guidelines and all sources confirmed. Reviewer Comment (2019-12-31): The failure is due to income causing a DTI issue. The cash flow provided lists income for the CCorp as $XXXXX however the values of $XXXXX for XXXXX and $XXXXX for XXXXX is not supported. The 1120 profits reported are not income reporting to the borrower. The income used is the W2 and depreciation only for the CCorp which is $XXXXX

01/04/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208797413

[Redact]

[Redact]

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

The borrower verified income is $XXXXX from primary and $XXXXX from C Corp. The income used by lender of $XXXXX is not supported and there is no income worksheet or year to date W2 earnings that would show a higher income source.

Reviewer Comment (2020-01-04): Income evaluated and data inputs corrected the borrower total income meets DTI guidelines and all sources confirmed. Reviewer Comment (2019-12-31): The failure is due to income causing a DTI issue. The cash flow provided lists income for the CCorp as $XXXXX however the values of $XXXXX for XXXXX and $XXXXX for XXXXX is not supported. The 1120 profits reported are not income reporting to the borrower. The income used is the W2 and depreciation only for the CCorp which is $XXXXX

01/04/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208797413

[Redact]

[Redact]

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.

ATR failure due to DTI issues

Reviewer Comment (2020-01-04): Income evaluated and data inputs corrected the borrower total income meets DTI guidelines and all sources confirmed. Reviewer Comment (2019-12-31): The failure is due to income causing a DTI issue. The cash flow provided lists income for the CCorp as $XXXXX however the values of $XXXXX for XXXXX and $XXXXX for XXXXX is not supported. The 1120 profits reported are not income reporting to the borrower. The income used is the W2 and depreciation only for the CCorp which is $XXXXX Seller Comment (2019-12-30): (XXXXX) Hello, we are not seeing the discrepancy here. We uploaded the final CD, please advise.

01/04/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208797415

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-26): Client has accepted the collateral package

12/26/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208797415

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-02): Secondary product provided to support origination value

01/02/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208797416

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-26): Client has accepted the collateral package

12/26/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

C

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208797416

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-04): Secondary product provided supporting origination value

01/04/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

C

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208797416

[Redact]

[Redact]

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Approval was not provided with loan documents.

Reviewer Comment (2019-12-31): provided Seller Comment (2019-12-31): (XXXXX) Hello, can you please advise if this has been cleared. Approval uploaded. Thank you

12/31/2019

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

C

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208797416

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Loan does not require two appraisals. Received and reviewed one appraisal.

Reviewer Comment (2020-01-04): Secondary product provided supporting origination value

01/04/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

C

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208797417

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-30): Client has accepted the collateral package

12/30/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208797417

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2019-12-27): Secondary product provided supporting original value

12/27/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208797417

[Redact]

[Redact]

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 $535.00 exceeds tolerance of $500.00. Sufficient or excess cure was provided to the borrower at Closing.

LE fee less cure listed on change circumstance

12/20/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

Final CD evidences Cure

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208797417

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2019-12-27): Secondary product provided supporting original value

12/27/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208797499

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-30): Client has accepted the collateral package

12/30/2019

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208797499

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-08): Secondary product provided supporting original value

01/08/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208797499

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Overtime Bonus 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.

Per Lender, averaging over XXXXX & XXXXX. LOX for borrower explains work history with XXXXX. Full two years being used to calculate. Borrower is only paid bonus and commissions once per month.

Reviewer Comment (2020-01-23): The borrower worked part time for current employer and was not full time receiving benefits of income until full time in XXXXX. The borrower has a two year history of earnings with current employer.

01/23/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208797499

[Redact]

[Redact]

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 appraisal being sent to borrower prior to closing.

Reviewer Comment (2019-12-26): Client elects to Waive

12/26/2019

2

B

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208797499

[Redact]

[Redact]

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 Lender, averaging over XXXXX & XXXXX. LOX for borrower explains work history with XXXXX. Full two years being used to calculate. Borrower is only paid bonus and commissions once per month. XXXXX has no history of earning this source of income.

Reviewer Comment (2020-01-23): The borrower worked part time for current employer and was not full time receiving benefits of income until full time in XXXXX. The borrower has a two year history of earnings with current employer.

01/23/2020

1

A

[Redact]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208797499

[Redact]

[Redact]

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 Closing Disclosure does not reflect the contact info for the Lender.

Reviewer Comment (2019-12-26): Client elects to Waive

12/26/2019

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208797499

[Redact]

[Redact]

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 $12,205.60 exceeds tolerance of $10,305.60. Insufficient or no cure was provided to the borrower.

The COC dated XXXXX states a property classification change that would not affect the loan discount points to change. The file is missing a valid COC or cure to the borrower.

Reviewer Comment (2020-01-16): XXXXX received Changed Circumstance. Seller Comment (2020-01-15): Please see the lock where the borrower requested an escrow waiver which increased their discount points. Please see e-signed CD where it was disclosed within 3 days of lock actions.

01/16/2020

1

A

[Redact]

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

208797499

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-08): Secondary product provided supporting original value

01/08/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208799507

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-13): Client has accepted the collateral package

01/13/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208799507

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-06): Secondary valuation provided supporting origination value.

01/06/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208799507

[Redact]

[Redact]

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 the Lender's Contact Name and NMLS ID number.

Reviewer Comment (2020-01-07): Client Elects to Waive

01/07/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208799507

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-06): Secondary valuation provided supporting origination value.

01/06/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208802494

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-29): The client has accepted the final collateral package

01/29/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208802494

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-27): Secondary product provided supporting original value

01/27/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208802494

[Redact]

[Redact]

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

HOI Coverage of $XXXXX is insufficient to cover Original Loan Amount value that is $XXXXX resulting in a Coverage Shortfall of $XXXXX. Replacement cost from the insurer to determine coverage amount is sufficient was not provided.

Reviewer Comment (2020-02-06): Replacement Cost Estimator provided as a trailing doc Reviewer Comment (2020-02-03): The HOI policy reviewed initially was provided. The images are missing either evidence of an extended coverage percentage or evidence of the cost to replace since not provided by the appraiser.

02/06/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208802494

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-01-27): Secondary product provided supporting original value

01/27/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208802494

[Redact]

[Redact]

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 (2020-01-27): Client elects to waive

01/27/2020

2

B

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208802494

[Redact]

[Redact]

Compliance

Compliance

State Compliance

Ohio Consumer Sales Practices Act (Acknowledgement of Receipt of Home Mortgage Loan Information Document Not Retained by Lender)

XXXXX: Acknowledgement of Receipt of XXXXX Document not retained by lender.

Evidence that borrower received copy of XXXXX Document was not provided.

Reviewer Comment (2020-01-27): Client elects to waive

01/27/2020

2

B

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208803353

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-13): Client has accepted the collateral package

01/13/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208803353

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-10): 0% variance, exception cleared.

01/10/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208803353

[Redact]

[Redact]

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).

Provide required Lender Contact Name & NMLS ID.

Reviewer Comment (2020-01-13): Client has elected to Waive

01/13/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208803407

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-21): The client has accepted the collateral package

01/21/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208803407

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-22): Secondary product provided to support original value

01/22/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208803724

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-13): Client has accepted the collateral package

01/13/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208803724

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-08): Secondary product provided supporting original value

01/08/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208803724

[Redact]

[Redact]

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).

Wholesale lender contact information is not provided.

Reviewer Comment (2020-01-13): Client has elected to Waive

01/13/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208803724

[Redact]

[Redact]

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 $600.00 on Final Closing Disclosure provided on XXXXX not accurate.

Non escrowed property costs are not documented.

Reviewer Comment (2020-02-06): XXXXX received PCCD correcting non escrowed property costs and LOE.

02/06/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208803724

[Redact]

[Redact]

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 $41.95 exceeds tolerance of $0.00. Sufficient or excess cure was provided to the borrower at Closing.

Cure provided at closing for VOE fee.

01/03/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208803724

[Redact]

[Redact]

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 required.

Reviewer Comment (2020-01-08): Secondary product provided supporting original value

01/08/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208803791

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-29): The client has accepted the final collateral package

01/29/2020

1

A

[Redact]

Primary

Refinance - Limited Cash-out GSE

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208803791

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-30): Desk review uploaded as trailing doc; -0- variance

01/30/2020

1

A

[Redact]

Primary

Refinance - Limited Cash-out GSE

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208805771

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-13): Client has accepted the collateral package

01/13/2020

1

A

[Redact]

Primary

Purchase

C

B

C

B

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208805771

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-10): 0% variance, exception cleared

01/10/2020

1

A

[Redact]

Primary

Purchase

C

B

C

B

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208805771

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Missing copy of the second valuation.

Reviewer Comment (2020-01-10): 0% variance, exception cleared

01/10/2020

1

A

[Redact]

Primary

Purchase

C

B

C

B

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208805771

[Redact]

[Redact]

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 provided on XXXXX did not disclose the required Lender Contact Information

Reviewer Comment (2020-01-13): Client has elected to Waive

01/13/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208805771

[Redact]

[Redact]

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.)

Post closing CD is dated incorrectly, not accounting for the year rollover.

Reviewer Comment (2020-01-29): XXXXX received required documents, exception is cleared. Seller Comment (2020-01-27): (XXXXX) XXXXX XXXXX Please see attached. Reviewer Comment (2020-01-17): Attestation Letter required indicating the XXXXX CD was dated and sent in error, and should be removed from testing is required to cure. Seller Comment (2020-01-15): (XXXXX) XXXXX XXXXX Please see attached

01/29/2020

1

A

[Redact]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208805771

[Redact]

[Redact]

Credit

Asset

Asset Documentation

Earnest Money Deposit is unsourced. Per guidelines EMD source is required.

Missing earnest deposit sourced in the amount of $XXXXXX. The only asset provided was an IRA account and there is no evidence of the funds being cashed.

Borrower has been employed in the same industry for more thanXXXXX years. Guideline variance approved by lender at time of origination Guideline variance approved by lender at time of origination

The borrower has been self employed for 4.5 years Guideline variance approved by lender at time of origination borrower fico is 767 Guideline variance approved by lender at time of origination. The borrower residual income is $17,000

Aggregator Aggregator Aggregator

Reviewer Comment (2020-02-04): Client has accepted and waives this condition with compensating factors. Reviewer Comment (2020-02-03): Per XXXXX assets for closing and EMD are to follow the XXXXX. Per the AUS item 20 it clearly states the EMD must be verified and per item 19 if the funds to close is less than 20% of the total assets no further verification is required however the funds to closer were $XXXXX and the assets available after 40% hair cut due to type (401K) is $XXXXX. The LOE provided by the lender is in conflict with guidelines and AUS. Client to review. Seller Comment (2020-02-03): (XXXXX) XXXXX XXXXX Please see attached. Reviewer Comment (2020-01-29): Please provide the policy as it conflicts with the guidelines so the client can review. Seller Comment (2020-01-27): (XXXXX) XXXXX XXXXX This is acceptable XXXXX policy to back the EMD out of available assets (retirement accounts included). Please rescind. Reviewer Comment (2020-01-15): Per AUS item 19 funds from an IRA being used to support closing and reserves receipt of funds realized from the sale must be verified. The only asset provided to close was an IRA account with no evidence of receipt of funds. Seller Comment (2020-01-13): (XXXXX) XXXXX XXXXX Please rescind because the EMD was backed out of available assets. Guidelines allow for this.

02/04/2020

2

B

[Redact]

Primary

Purchase

C

B

C

B

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208805771

[Redact]

[Redact]

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.

Proof appraisal given to borrower not in file.

Reviewer Comment (2020-01-13): Client has elected to Waive

01/13/2020

2

B

[Redact]

Primary

Purchase

C

B

C

B

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208817654

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-27): Client has accepted the collateral package

02/27/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208817654

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-03): The lender received an indeterminate value from XXXXX and obtained a field review to confirm and support value Reviewer Comment (2020-02-25): Per the CD the borrower was charged $150.00 for a XXXXX report. The images are missing a copy of the XXXXX.

03/03/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208817654

[Redact]

[Redact]

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.

The Final Closing Disclosure reflects XXXXX% or $XXXXX Loan Discount Points, the Initial Loan Estimate disclosed $6016.00. Evidence of a cure is not provided.

Reviewer Comment (2020-03-10): COC - Loan repriced due to credit score changed Reviewer Comment (2020-03-03): COC XXXXX does not specify what occurred to justify the Points increasing on the Final CD. Additional details required to justify the fee increase or cure is due to borrower.

03/10/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208817801

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-17): Exception cleared

01/17/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208817801

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Pending Secondary Valuation as required for securitization

Reviewer Comment (2020-01-16): Secondary product provided supporting original value

01/16/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208817801

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Acknowledgement of Borrower Receipt of Notice of Special Flood Hazard Disclosure Missing

FDPA Notification Rule: Creditor did not retain record of borrower's receipt of Notice of Special Flood Hazard Disclosure.

Borrower did not signed Initial disclosure and the Final disclosure did not reflect any signature lines.

Reviewer Comment (2020-01-17): Client elects to waive.

01/17/2020

2

B

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208817801

[Redact]

[Redact]

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 information was not provided

Reviewer Comment (2020-01-17): Client elects to waive.

01/17/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208817801

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-16): Secondary product provided supporting original value

01/16/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208819109

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-07): The client has accepted the collateral package

02/07/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

No

208819109

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-02-03): Secondary product provided to support origination value.

02/03/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

No

208819109

[Redact]

[Redact]

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Reviewer Comment (2020-01-30): 1008 uploaded w/UW name uploaded as a trailing doc

01/30/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

No

208819109

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-02-03): Secondary product provided to support origination value.

02/03/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

No

208819109

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Sole Proprietorship Income Documentation Test

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Sole Proprietorship).

Missing most recent signed 2 years personal and business tax returns. Missing a signed and dated YTD P&L. Missing a signed and date Balance sheet.

Reviewer Comment (2020-02-07): Uploaded as trailing docs

02/07/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

No

208819109

[Redact]

[Redact]

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.

Once we receive most recent signed 2 years personal & business tax returns, a signed and dated YTD P&L, signed and date Balance sheet and a 3rd party verification, this exceptions will clear based on loan now meets Appendix Q.

Reviewer Comment (2020-02-07): XXXXX & XXXXX P&L & Balance Sheets provided along with XXXXX/XXXXX transcripts reporting Sch C Income

02/07/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

No

208819109

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 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 which is based on $2XXXXX Hazard, $XXXXX taxes and $XXXXXHOA, however, the lender did not added on page 4 section for escrow account for "flood insurance monthly of $XXXXX". To cure, provided corrected PC CD along with LOE to borrower and evidence of delivery.

Reviewer Comment (2020-02-18): The lender provided a PCCD correcting the cost year 1 estimate Reviewer Comment (2020-02-07): Based on the 1003/1008 which reflected HOI ($XXXXX), Tax ($XXXXX), HOA ($XXXXX) and XXXXX Ins ($XXXXX), estimated monthly property costs are $XXXXX or $XXXXX annually. Final CD reflects incorrect total as $XXXXX.

02/18/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

Yes

208819109

[Redact]

[Redact]

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 third party verification

Reviewer Comment (2020-02-07): CPA letter uploaded as trailing doc confirms existence

02/07/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

No

208819109

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - Schedule C

Ability to Repay (Dodd-Frank 2014): Unable to verify Sole Proprietorship income using reasonably reliable third-party records.

Once we receive all missing income documentation this exception will clear based on loan now meets Appendix Q.

Reviewer Comment (2020-02-07): XXXXX & XXXXX P&L & Balance Sheets provided along with XXXXX/XXXXX transcripts reporting Sch C Income

02/07/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

No

208819109

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

NonQM ATR

Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.

Once we receive all missing income documentation this exception will clear based on loan now meets Appendix Q.

Reviewer Comment (2020-02-07): XXXXX & XXXXX P&L & Balance Sheets provided along with XXXXX/XXXXX transcripts reporting Sch C Income

02/07/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

No

208819109

[Redact]

[Redact]

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.

Once we receive all missing income documentation this exception will clear based on loan now meets Appendix Q.

Reviewer Comment (2020-02-26): 1040's were provided Reviewer Comment (2020-02-11): The loan designation remains as a Non QM due to the lender excluding debts belonging to the borrower which does not meet Appendix Q

02/26/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

Yes

208819109

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Will Have Escrow Account

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXX incorrectly disclosed whether the loan will have an escrow account.

Final CD disclosed loan will not have escrows, however, disclosed there is Flood Insurance Escrow.

Reviewer Comment (2020-02-07): PCCD and LOE uploaded as trailing doc

02/07/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

Yes

208819109

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Will Not Have Escrow Account

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXX incorrectly disclosed whether the loan will have an escrow account.

Final CD disclosed loan will not have escrows, however, disclosed there is Flood Insurance Escrow.

Reviewer Comment (2020-02-07): PCCD and LOE to Borrower uploaded as trailing docs

02/07/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

Yes

208819109

[Redact]

[Redact]

Credit

Loan Package Documentation

Application / Processing

Missing Document: Flood Certificate not provided

Reviewer Comment (2020-03-02): Flood cert uploaded as trailing doc Buyer Comment (2020-02-27): XXXXX assisted with upload of Flood cert due to "black out" upload difficulty XXXXX experiencing Reviewer Comment (2020-02-26): Please provide pages that are not blacked out. Reviewer Comment (2020-02-18): Please provide an actual Flood Certificate showing the life of loan. The CertMap is not sufficient to cure. Reviewer Comment (2020-02-11): Pending a flood cert Reviewer Comment (2020-02-07): Flood Map is legible; however, actual Flood Certificate and it's required verbiage (i.e. Life of Loan, etc.) are on a page that is black.

03/02/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

No

208819109

[Redact]

[Redact]

Property

Property - Appraisal

Appraisal Reconciliation

Appraisal is required to be in name of Lender

-

Appraisal reflects lender as XXXXX and Note reflects XXXXX

Buyer Comment (2020-02-26): Waived by XXXXX: ok to accept; Comp Factors Include: Credit History; 20% Reduced housing payment; XXXXX mthly residual income Reviewer Comment (2020-02-21): No uploaded docs to rectify name discrepancy between Note (XXXXX) and Appraisal lender (XXXXX) Reviewer Comment (2020-02-11): Pending documentation Buyer Comment (2020-01-28): **Seller to fulfill

02/26/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

No

208819109

[Redact]

[Redact]

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 (2020-03-06): Pay off provided Reviewer Comment (2020-02-11): Pending documentation Buyer Comment (2020-01-28): **Seller to fulfill

03/06/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

No

208819109

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Appendix Q Liabilities - Payments by other party

Qualified Mortgage (Dodd-Frank 2014): One or more liabilities have been excluded from DTI calculation for a prohibited reason ("Payments by other party").

Lender omitted XXXXX auto loan according to AUS in file.

Reviewer Comment (2020-02-26): Additional review of income shows a higher income source allowing the car to be included. Reviewer Comment (2020-02-07): No documentation was provided to support the omission of the $XXXXX installment payment to XXXXX (being paid by another party) in accordance with guidelines.

02/26/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

No

208819109

[Redact]

[Redact]

Credit

Title

Lien

Missing evidence of lien position on Other Financing.

-

Missing HELOC Note and subordination agreement.

Reviewer Comment (2020-02-03): Note for the second was provided

02/03/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

No

208819109

[Redact]

[Redact]

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Missing Document: Note - Subordinate Lien not provided

Missing HELOC Note

Reviewer Comment (2020-02-05): Copy of recorded subordination agreement for HELOC was uploaded as a trailing doc Reviewer Comment (2020-02-03): Provided was the note however the HELOC was obtained prior to the current lien and the images are missing the subordination agreement.

02/05/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

No

208819109

[Redact]

[Redact]

Credit

Loan Package Documentation

Application / Processing

Missing Document: Loan Underwriting and Transmittal Summary (1008) / MCAW not provided

Missing Final 1008.

Reviewer Comment (2020-02-03): 1008 provided

02/03/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

No

208819109

[Redact]

[Redact]

Credit

Property - Appraisal

Appraisal Documentation

Missing Document: Appraisal not provided

Appraisal in file is not legible some of the pages are blacked out.

Reviewer Comment (2020-02-26): A complete copy with all pages were provided Reviewer Comment (2020-02-07): 1004 uploaded as trailing doc still contains blacked out / illegible pages; therefore incomplete.

02/26/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

No

208819109

[Redact]

[Redact]

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.

Missing disclosure within 3 days of loan application.

Reviewer Comment (2020-02-04): Client elected to waive.

02/04/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

No

208819109

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

SSPL was not provided for review

Reviewer Comment (2020-02-06): Client elects to waive

02/06/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

No Defined Cure

D

B

D

A

C

B

C

B

Safe Harbor QM

Safe Harbor QM

No

208819135

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-22): Client has accepted the collateral package

01/22/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208819135

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Missing Secondary Valuation.

Reviewer Comment (2020-01-22): Uploaded as trailing doc

01/22/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208819135

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Missing copy of the second valuation.

Reviewer Comment (2020-01-22): Uploaded as a trailing doc

01/22/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208819135

[Redact]

[Redact]

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 provided on XXXXX did not disclose the required lender contact information.

Reviewer Comment (2020-01-23): Client Elects to Waive

01/23/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208826240

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2019-12-13): Received per client. Exception cleared.

12/13/2019

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208826240

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-02): Secondary product provided supporting origination value

01/02/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

208829502

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-23): The client has accepted the final collateral package

01/23/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208829502

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Missing Secondary Valuation.

Reviewer Comment (2020-01-06): Secondary valuation provided supporting origination value.

01/06/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208829502

[Redact]

[Redact]

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 points and fees exceeding allowable maximum.

Reviewer Comment (2020-01-17): Exception cleared Seller Comment (2020-01-14): XXXXX Please review the actual QM test associated with this file. The entire appraisal invoice fee does not need to be included in the QM test. Please see the breakdown and justification for discount points being excluded.

01/17/2020

1

A

[Redact]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208829502

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

QM Points and Fees

Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of 3.61014% is in excess of the allowable maximum of 3.00000% 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 .61014%).

Points and fees of $XXXXX (3.61014%) exceed allowable maximum of $XXXXX (3%).

Reviewer Comment (2020-01-17): Exception cleared Seller Comment (2020-01-14): XXXXXPlease review the actual QM test associated with this file. The entire appraisal invoice fee does not need to be included in the QM test. Please see the breakdown and justification for discount points being excluded.

01/17/2020

1

A

[Redact]

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

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208829502

[Redact]

[Redact]

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).

Disclosure does not reflect Lender Contact and Contact NMLS ID.

Reviewer Comment (2020-01-07): Client Elects to Waive

01/07/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208840858

[Redact]

[Redact]

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 of being provided to borrower not in file.

Reviewer Comment (2020-01-30): Client elected to waive.

01/30/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

B

B

A

A

B

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

208840858

[Redact]

[Redact]

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 of being provided to borrower not in file.

Reviewer Comment (2020-01-30): Client elected to waive.

01/30/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

B

B

A

A

B

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

208840858

[Redact]

[Redact]

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 $4XXXXX exceeds tolerance of $XXXXX. Sufficient or excess cure was provided to the borrower at Closing.

VOE fee disclosed as $0 on the LE dated XXXXX; but disclosed as $XXXXX on the Final Closing Disclosure. Cure was provided.

01/13/2020

1

A

[Redact]

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

208840872

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Missing copy of the second valuation.

Reviewer Comment (2020-01-29): Secondary valuation provided with no variance, exception cleared.

01/29/2020

1

A

[Redact]

Primary

Purchase

C

A

C

A

A

A

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

208840872

[Redact]

[Redact]

Credit

Property - Appraisal

General Appraisal Requirements

Valuation Error: Appraiser's state certification or license number not provided.

Copy of current license was not provided at the time of audit review.

Reviewer Comment (2020-01-21): Uploaded as trailing doc

01/21/2020

1

A

[Redact]

Primary

Purchase

C

A

C

A

A

A

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

208840872

[Redact]

[Redact]

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.

01/13/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

A

C

A

A

A

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

208840872

[Redact]

[Redact]

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

AUS Findings: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds AUS total debt ratio of ___.

Income $XXXXX (borrower $XXXXX , co-borrower $XXXXX and 2nd unit on subject REO $XXXXX) Subject PITIA $XXXXX Investment REO $XXXXX (lender did not include homeowners insurance). Consumer debts $XXXXX

Reviewer Comment (2020-01-21): Uploaded as trailing doc Reviewer Comment (2020-01-18): Provide updated AUS as noted in correspondence dated XXXXX and indexed as Lender correspondence.

01/21/2020

1

A

[Redact]

Primary

Purchase

C

A

C

A

A

A

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

208840876

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-01-29): 0% variance

01/29/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

A

A

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

208840876

[Redact]

[Redact]

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 10% or $XXXXX. Sufficient or excess cure was provided to the borrower at Closing.

Cure provided

01/27/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Final CD evidences Cure

C

A

A

A

A

A

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

208840883

[Redact]

[Redact]

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.

Appraisal 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 initial 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 (2020-01-22): $XXXXX cure provided at closing Seller Comment (2020-01-17): There is already a $XXXXX lender credit applied to cover for this cure. Please waive.

01/22/2020

1

A

[Redact]

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

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

208840883

[Redact]

[Redact]

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.

Title - Abstract / Title Search 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 initial 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 (2020-01-22): SSPL - borrowers shopped for fees Seller Comment (2020-01-17): This title fee was disclosed correctly on the initial CD once the title fees were made available. Please waive.

01/22/2020

1

A

[Redact]

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

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

208840883

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Municipal Lien Certificate Fee (MLC). Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

Title - Municipal Lien Certificate Fee (MLC) 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 initial 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 (2020-01-22): SSPL - borrowers shopped for fees Seller Comment (2020-01-17): This fee was disclosed correctly on the initial CD once Title figures were available. Please waive.

01/22/2020

1

A

[Redact]

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

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

208840883

[Redact]

[Redact]

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 cure provided at closing

01/22/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

A

A

A

C

A

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

208840894

[Redact]

[Redact]

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 copy of the secondary valuation, required on all securitized loans.

Reviewer Comment (2020-01-13): 0% variance

01/13/2020

1

A

[Redact]

Second Home

Purchase

C

A

A

A

C

A

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

208840894

[Redact]

[Redact]

Compliance

Compliance

State Compliance

Note Error: Note late charge percentage exceeds maximum per state

XXXXX% late charge on note exceeds max state XXXXX%

Reviewer Comment (2020-01-23): Revised note uploaded as a trailing doc

01/23/2020

1

A

[Redact]

Second Home

Purchase

C

A

A

A

C

A

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

208840894

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Attorney's Fee (Closing Agent Only). Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

Fee disclosed as $0.00 on LE dated XXXXX, but disclosed as $XXXXX on Final Closing Disclosure. No evidence of a valid COC in file.

Reviewer Comment (2020-01-22): XXXXX reviewed and address the Fee Recon Section and cleared exception. No tolerance cure needed. Seller Comment (2020-01-22): Hello please advise on this. This is not a required fee and not subject to tolerance. Seller Comment (2020-01-17): Attorney fee is not something we or closing required, which section would you like this fee to be in?

01/22/2020

1

A

[Redact]

Second Home

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

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

208840901

[Redact]

[Redact]

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 Subordination 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 0% tolerance violation of $XXXXX.

01/02/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Final CD evidences Cure

C

A

A

A

A

A

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

208840901

[Redact]

[Redact]

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 copy of the secondary valuation, required on all securitized loans.

Reviewer Comment (2020-01-13): 0% variance

01/13/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

A

A

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

208840907

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-01-13): 0% variance

01/13/2020

1

A

[Redact]

Primary

Purchase

C

A

A

A

C

A

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

208840907

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 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 Final Closing Disclosure reflects monthly escrows at $XXXXX or $XXXXX annually, Estimated Property Costs over Year 1 indicate $XXXXX is based on 11 months. Documentation in file reads for hazard $XXXXX and $XXXXX taxes = $XXXXX or XXXXX annually.

Reviewer Comment (2020-01-23): XXXXX received tax cert. Exception Cleared. Seller Comment (2020-01-20): HOI is $XXXXX per month and $XXXXX taxes . tax bill is attached.

01/23/2020

1

A

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

A

A

C

A

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

208840908

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-02-06): Desk review provided. Exception cleared.

02/06/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

C

A

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

208840908

[Redact]

[Redact]

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, the actual Finance Charge for the loan is $XXXXX

Reviewer Comment (2020-01-27): XXXXX received required documents, exception is cleared. Seller Comment (2020-01-26): Please see mavent confirming our finance charge is correct. What is your calculation?

01/27/2020

1

A

[Redact]

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

A

A

A

C

A

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

208840908

[Redact]

[Redact]

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 Final CD disclosed $XXXXX. Final CD disclosed a Lender Credit of $XXXXX for increase in Closing Costs above legal limit which is sufficient to cure 0% tolerance violation.

01/03/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Final CD evidences Cure

C

A

A

A

C

A

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

208841070

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-21): The client has accepted the collateral package

01/21/2020

1

A

[Redact]

Primary

Purchase

B

A

B

A

B

A

A

A

Safe Harbor QM

Safe Harbor QM

No

208841070

[Redact]

[Redact]

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 (2020-01-21): Exception cleared

01/21/2020

1

A

[Redact]

Primary

Purchase

B

A

B

A

B

A

A

A

Safe Harbor QM

Safe Harbor QM

No

208841070

[Redact]

[Redact]

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 (2020-01-21): Exception cleared

01/21/2020

1

A

[Redact]

Primary

Purchase

B

A

B

A

B

A

A

A

Safe Harbor QM

Safe Harbor QM

No

208844540

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-27): Client has accepted the collateral package

02/27/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

208844540

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 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 of XXXXX on Final Closing Disclosure provided on XXXXX not accurate. Actual amount of Estimated Property Costs over Year 1 is $XXXXX. HOI Annual $XXXXX, Taxes annual $XXXXX and HOA $XXXXX

Reviewer Comment (2020-03-03): XXXXX received a PCCD correcting total property costs and LOE.

03/03/2020

2

B

[Redact]

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

208844540

[Redact]

[Redact]

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 preliminary appraisal at least 3 business days prior to closing was not provided.

Reviewer Comment (2020-02-26): Client has elected to accept and waive

02/26/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

208844540

[Redact]

[Redact]

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 application date was XXXXX, the prior year tax returns may have been extended, but the qualification of the consumer was based on tax returns that were not for the most recent year

Reviewer Comment (2020-03-19): Client elects to waive Reviewer Comment (2020-03-03): Pending client review and acceptance

03/19/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

208844540

[Redact]

[Redact]

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 (2020-02-26): Client has elected to accept and waive

02/26/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

208844540

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-25): XXXXX provided to support original value

02/25/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

208846786

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-29): The client has accepted the final collateral package

01/29/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208846786

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-29): Secondary product provided supporting original value

01/29/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208846786

[Redact]

[Redact]

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, the actual Finance Charge for the loan is $XXXXX. The variance is $XXXXX which is the value of the Post close fee provided by the SSPL and not included in the total charges

Reviewer Comment (2020-02-25): XXXXX received required documents, exception is cured. Reviewer Comment (2020-02-20): Updated XXXXXThe Post Closing fee was not included in the APR calculation. PCCD, LOE, copy of refund check and proof of delivery required to cure. Reviewer Comment (2020-02-14): The Preclosing verification control fee was not included in the APR calculation. PCCD, LOE, copy of refund check and proof of delivery required to cure. Reviewer Comment (2020-02-05): XXXXX received PCCD with updated finance charge however the cure is a PCCD indicating cure for underdisclosed amount, LOE, refund check, and proof of delivery.

02/25/2020

2

B

[Redact]

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

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208846786

[Redact]

[Redact]

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.

Evidence that borrower received revised LE provided on XXXXX at least 4 business days prior to closing was not provided.

Reviewer Comment (2020-02-14): XXXXX received required documents, exception is cleared. Reviewer Comment (2020-02-05): XXXXX received XXXXX LE without a receipt therefore reciept date is XXXXX, less than 4 business from consummation date of XXXXX. If the LE was received prior please provide documentation for review.

02/14/2020

1

A

[Redact]

Primary

Purchase

No Defined Cure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208902684

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-27): Client has accepted the collateral package.

01/27/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208902684

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-27): Secondary product provided supporting original value

01/27/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208902684

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-01-27): Secondary product provided supporting original value

01/27/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208902684

[Redact]

[Redact]

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 reflects a Report Date of XXXXX, however the Appraisal Receipt Confirmation indicates the report was provided to the Borrowers on XXXXX.

Reviewer Comment (2020-01-27): Client elects to waive

01/27/2020

2

B

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208902684

[Redact]

[Redact]

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 the Compensation to Officers decline from XXXXX to XXXXX.

Reviewer Comment (2020-03-19): YTD P&L provided supporting income

03/19/2020

1

A

[Redact]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208902684

[Redact]

[Redact]

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).

Provide required Lender Contact name & NMLS ID.

Reviewer Comment (2020-01-27): Client elects to waive

01/27/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

208902684

[Redact]

[Redact]

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.

The income has declined over a period with no evidence of a reason

Reviewer Comment (2020-03-19): YTD P&L provided supporting income Seller Comment (2020-03-19): XXXXX: Please clear and see attached. Income is stable.

03/19/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

208902684

[Redact]

[Redact]

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.

The income has declined over a period with no evidence of a reason

Reviewer Comment (2020-03-19): YTD P&L provided supporting income Seller Comment (2020-03-19): XXXXX: Please clear and see attached. Income is stable.

03/19/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209077678

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-21): Client has accepted the collateral package

02/21/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209077678

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-02-24): Secondary product provided to support origination value.

02/24/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209077678

[Redact]

[Redact]

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. Missing change in circumstance. To cure, provided corrected PC CD along with LOE to borrower and evidence of delivery.

Reviewer Comment (2020-02-27): COC- rate was re-locked as Initial rate lock was expiring Seller Comment (2020-02-25): XXXXX On XXXXX the borrower requested to relock their loan (NO COC required to relock the rate) which affected the pricing. Please see the lock confirmation from XXXXX included in the file page 463 and the redisclosed LE to the borrower on XXXXX included in the file pages XXXXX. Please clear this conditon.

02/27/2020

1

A

[Redact]

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

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209077678

[Redact]

[Redact]

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).

Disclosure does not reflect Lender Contact and Contact NMLS ID.

Reviewer Comment (2020-02-20): Client elects to waive

02/20/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209138263

[Redact]

[Redact]

Credit

Missing Document

General

Missing Document: Desk Review not provided

Documentation is missing from subject file.

Reviewer Comment (2020-01-06): Exception cleared Seller Comment (2019-12-31): Attached is the internal case form our Appraisal department confirming the desk review was completed.

01/06/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209138263

[Redact]

[Redact]

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. Evidence borrower received a copy of the revised appraisal was not provided.

Reviewer Comment (2019-12-31): Client elects to waive

12/31/2019

2

B

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209138263

[Redact]

[Redact]

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 the Lender's Contact Name and NMLS ID number.

Reviewer Comment (2019-12-31): Client elects to waive

12/31/2019

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209138263

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-06): 0% variance

01/06/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209138264

[Redact]

[Redact]

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 of being provided to borrower not in file.

Reviewer Comment (2019-12-31): Client elects to waive

12/31/2019

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209138264

[Redact]

[Redact]

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).

Disclosure does not reflect Lender Contact and Contact NMLS ID.

Reviewer Comment (2019-12-31): Client elects to waive

12/31/2019

2

B

[Redact]

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

209138264

[Redact]

[Redact]

Credit

Missing Document

General

Missing Document: Desk Review not provided

Per guidelines an Appraisal Desk Review is required; copy not provided in file.

Reviewer Comment (2020-01-06): Exception cleared Seller Comment (2019-12-31): Attached is the internal case from our Appraisal Department confirming the Desk Review was completed.

01/06/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209138265

[Redact]

[Redact]

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's no evidence appraisal was sent/received by borrowers in the loan file.

Reviewer Comment (2019-12-31): Client elects to waive

12/31/2019

2

B

[Redact]

Primary

Purchase

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209138265

[Redact]

[Redact]

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.

Federal LO Compensation disclosure was not provided.

Reviewer Comment (2019-12-31): Client elects to waive

12/31/2019

2

B

[Redact]

Primary

Purchase

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209138265

[Redact]

[Redact]

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 for lender was not provided on CD on page 5 of the Final CD.

Reviewer Comment (2019-12-31): Client elects to waive

12/31/2019

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209138265

[Redact]

[Redact]

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 in documents is dated XXXXX. There's no tracking info in the file of when it was sent/received.

Reviewer Comment (2020-01-02): XXXXX received disclosure tracking indicating the initial CD was received the next day issued. Exception Cleared. Seller Comment (2019-12-31): Please review the attached compliance tracker which shows the CD was generated and emailed to the borrower on XXXXX, acknowledged on XXXXX, which is the required 3 days prior to consummation which occurred on XXXXX.

01/02/2020

1

A

[Redact]

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209138268

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-01-06): 0% variance

01/06/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209138268

[Redact]

[Redact]

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.

Delivery or receipt of appraisal is not documented.

Reviewer Comment (2019-12-31): Client elects to waive

12/31/2019

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209138269

[Redact]

[Redact]

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.

Nothing was provided to verify delivery of the appraisal to the borrower.

Reviewer Comment (2019-12-31): Client elects to waive

12/31/2019

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209138269

[Redact]

[Redact]

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 for lender was not provided on CD.

Reviewer Comment (2019-12-31): Client elects to waive

12/31/2019

2

B

[Redact]

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

209138269

[Redact]

[Redact]

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Guidelines calls for 12 months reserves for subject and 6 months for each additional financed property. Loan requires 18 months reserves.

Reviewer Comment (2020-01-06): Exception cleared Seller Comment (2019-12-31): Please re-review. I show the total reserves required as $XXXXX (12 months for subject = $XXXXX and 6 months for rental = $XXXXX). The 1003 and assets in file show we have $XXXXX documented between the borrower's liquid and retirement accounts.

01/06/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209138269

[Redact]

[Redact]

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.

No cure provided.

12/26/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

Final CD evidences Cure

C

B

C

A

B

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209170254

[Redact]

[Redact]

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 name not completed on CD.

Reviewer Comment (2020-01-08): Per Client.

01/08/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Home Improvement

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

209193475

[Redact]

[Redact]

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Both Lender approval and 1008 provided in file reflect a higher loan amount and payment than that disclosed on the Note. Please provide the final lender approval or final 1008.

Reviewer Comment (2020-01-08): Exception cleared

01/08/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209193475

[Redact]

[Redact]

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 was reduced from $-XXXXX to XXXXX with no valid changed circumstance provided in file.

Reviewer Comment (2020-01-21): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided Seller Comment (2020-01-16): Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD uploaded covering both conditions for a total of $XXXXX

01/21/2020

2

B

[Redact]

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

209193475

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Closing Protection Letter Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

The Closing Protection Letter fee was not disclosed to the borrower on the LE's. No valid changed circumstance provided and no evidence of cure.

Reviewer Comment (2020-01-21): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided Seller Comment (2020-01-16): Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD uploaded covering both conditions for a total of $XXXXX

01/21/2020

2

B

[Redact]

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

209193475

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

The Title - Endorsement fee increased from time initially disclosed on LE with no valid changed circumstance or evidence of cure.

Reviewer Comment (2020-01-08): XXXXX reviewed and address the Fee Recon Section and cleared exception. No tolerance cure needed.

01/08/2020

1

A

[Redact]

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

209193475

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Lender's Title Insurance. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

The Lender's Title Insurance increased due to a change in loan amount, however, there was no valid changed circumstance or cure provided to borrower.

Reviewer Comment (2020-01-08): XXXXX reviewed and address the Fee Recon Section and cleared exception. No tolerance cure needed.

01/08/2020

1

A

[Redact]

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

209193477

[Redact]

[Redact]

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.

Preliminary Report indicates current Lender is the original Lender. 1. Current payoff balance $XXXXX 2. New loan amount w/same lender $XXXXX. 3. Borrower is bringing $XXXXX to closing

Reviewer Comment (2020-01-07): Confirmed no new money on same lender refinance.

01/07/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

B

A

A

A

B

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209193478

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-01-08): Secondary valuation provided with no variation, exception cleared.

01/08/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209193480

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Secondary appraisal product is missing.

Reviewer Comment (2020-01-08): Secondary valuation provided with no variance, exception cleared.

01/08/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

A

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209193481

[Redact]

[Redact]

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.

Binding LE reads -$XXXXX and no lender credit provided on the final CD.

Reviewer Comment (2020-01-21): XXXXX received required documents, exception is cleared.

01/21/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

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

209193482

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-01-08): Secondary valuation provided with no variance, exception cleared.

01/08/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

C

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209193482

[Redact]

[Redact]

Credit

1003

Document Error

Borrower(s) is not a U.S. Citizen, and the guideline required documentation was not provided.

-

Per Final 103 borrowers are Permanent Resident Aliens and documentation to verify was not provided.

Reviewer Comment (2020-01-13): Exception cleared

01/13/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

C

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209193482

[Redact]

[Redact]

Credit

Missing Document

General

Missing Document: Verification of Non-US Citizen Status not provided

Per Final 1003 borrowers are Permanent Resident Aliens, however, verification was not provided.

Reviewer Comment (2020-01-13): Exception cleared

01/13/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

C

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209193482

[Redact]

[Redact]

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Reviewer Comment (2020-01-13): Exception cleared

01/13/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

C

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209193483

[Redact]

[Redact]

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 (2020-01-08): Secondary valuation provided with no variance, exception cleared.

01/08/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209193484

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Escrowed Property Costs Year 1 - October 2018 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.

Confirmed monthly escrows to be $XXXXX ($XXXXX hazard and $XXXXX taxes) and $XXXXX for 1 year for Taxes and Insurance.

Reviewer Comment (2020-01-27): XXXXX reviewed exception. Upon further review exception may be cleared.

01/27/2020

1

A

[Redact]

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

209193484

[Redact]

[Redact]

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.

Appraisal Fee was disclosed on the initial LE in the amount of $XXXXX but on the final CD reads $XXXXX. It appears the borrower was not notified of this increased fee after initial 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 (2020-01-23): XXXXX received a Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD to cure this exception.

01/23/2020

2

B

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209193484

[Redact]

[Redact]

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.

Title - Insurance Binder 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 initial 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 (2020-01-23): XXXXX received a Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD to cure this exception.

01/23/2020

2

B

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209193484

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Pending Secondary Valuation as required for securitization

Reviewer Comment (2020-01-08): Secondary valuation provided with no variance, exception cleared.

01/08/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209193485

[Redact]

[Redact]

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 (2020-01-08): Secondary valuation provided with no variance, exception cleared.

01/08/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

A

A

B

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209193485

[Redact]

[Redact]

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.

Transcripts were provided for XXXXX, but signed personal tax returns for the same year were not. Only un-signed.

Reviewer Comment (2020-01-14): Exception cleared

01/14/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

A

A

B

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209193486

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

n/a 2 appraisals required for loan amounts greater than $XXXXX

Reviewer Comment (2020-01-08): Secondary valuation provided with no variance, exception cleared.

01/08/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209193486

[Redact]

[Redact]

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.

Final CD did not indicate monthly. Appraisal reads $XXXXX monthly.

Reviewer Comment (2020-01-15): XXXXX received LOE. Exception Cured. Reviewer Comment (2020-01-10): XXXXX received a corrected CD. Please provide a LOE to cure. Seller Comment (2020-01-08): PCCD

01/15/2020

2

B

[Redact]

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

209193489

[Redact]

[Redact]

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Missing Document: Note - Subordinate Lien not provided

A copy of the Subordinate Lien is not included in the file.

Reviewer Comment (2020-01-08): Exception cleared

01/08/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

A

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209193489

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-01-08): Secondary valuation provided with no variance, exception cleared.

01/08/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

A

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209193489

[Redact]

[Redact]

Credit

Title

Lien

Missing evidence of lien position on Other Financing.

-

The Borrower has a HELOC which is to be subordinated, a copy of the HELOC is not included in the file.

Reviewer Comment (2020-01-08): Exception cleared

01/08/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

A

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209193489

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Draw Deed Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

Draw Deed 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 initial 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 (2020-01-28): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided Seller Comment (2020-01-24): Scheduled to deliver today Reviewer Comment (2020-01-22): Letter of Explanation, Shipping Label, Copy of Refund Check, and Corrected CD provided. Per XXXXX package has not shipped label was created. Please provide confirmation the package has shipped to the borrower.

01/28/2020

2

B

[Redact]

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

A

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209193490

[Redact]

[Redact]

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 on Loan Estimate to Consumer(s), however the credit indicated on Consumer(s) Final CD at the time of consummation was not the dollar figure initially disclosed.

Reviewer Comment (2020-01-28): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided Seller Comment (2020-01-24): Scheduled to deliver today Reviewer Comment (2020-01-23): Letter of Explanation, Shipping Label, Copy of Refund Check, and Corrected CD provided. Per XXXXX tracking the package has not shipped to the borrower. Please provide confirmation the package has shipped.

01/28/2020

2

B

[Redact]

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

209193490

[Redact]

[Redact]

Credit

Credit

General

Initial Rate Lock rate date is not documented in file.

Reviewer Comment (2020-01-08): Exception cleared. Seller Comment (2020-01-08): Pricing Summary

01/08/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209193490

[Redact]

[Redact]

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Need a written or Verbal Verification of Employment (VVOE) must be obtained within 10 business days prior to the Note date per gudilelines

Reviewer Comment (2020-01-15): Exception cleared

01/15/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209193491

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-01-08): Secondary valuation provided with no variance, exception cleared.

01/08/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209193491

[Redact]

[Redact]

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.

The Final Closing Disclosure reflects $XXXXX Points Fee, the Loan Estimate disclosed $XXXXX.

Reviewer Comment (2020-01-27): XXXXX received a Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD to cure this exception. Seller Comment (2020-01-24): Scheduled to deliver today Reviewer Comment (2020-01-23): XXXXX received PCCD indicating cure, LOE, refund check, and shipping label. Exception may be cured once proof of mailing is available.

01/27/2020

2

B

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209193491

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Notice of Right to Cancel Missing

Truth in Lending Act: Notice of Right to Cancel was not provided.

A Right to Cancel was not included in the file for either borrower.

Reviewer Comment (2020-01-07): Exception cleared Seller Comment (2020-01-06): Notice of Right To Cancel attached

01/07/2020

1

A

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209193492

[Redact]

[Redact]

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 signed waiver XXXXX. Missing evidence of the appraisal being sent to the borrower prior to closing.

Reviewer Comment (2020-01-08): Exception cleared

01/08/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

B

A

A

A

B

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209229194

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-13): Client has accepted the collateral package

01/13/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209229194

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization

Reviewer Comment (2020-01-13): Secondary product provided supporting original value

01/13/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209229194

[Redact]

[Redact]

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.

Fee disclosed as $XXXXX on LE dated XXXXX, but disclosed as $XXXXX on Final Closing Disclosure. Cure of $XXXXX reflected on Final CD.

01/08/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209229194

[Redact]

[Redact]

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

Reviewer Comment (2020-01-13): Client has elected to Waive

01/13/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209229194

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Pending Secondary Valuation as required for securitization

Reviewer Comment (2020-01-13): Secondary product provided supporting original value

01/13/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209229194

[Redact]

[Redact]

Credit

Asset

Asset Documentation

Guideline Issue: Insufficient asset documentation.

-

2 months required and only 1 month was provided.

Reviewer Comment (2020-01-30): Exception cleared.

01/30/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209230540

[Redact]

[Redact]

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. To cure, provided corrected PC CD along with LOE to borrower and evidence of deliver

Reviewer Comment (2020-01-15): COC - re-lock - pricing changed confirmed from initial rate lock that LTV was less than XXXXX% property value changed and new rate lock on XXXXX was over XXXXX% thus pricing changed.

01/15/2020

1

A

[Redact]

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

C

A

C

A

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

209230540

[Redact]

[Redact]

Credit

Credit

Credit Documentation

Missing Document: Verification of Rent (VOR) / Verification of Mortgage (VOM) not provided

Per AUS # 12; Mortgage with Homepoint with balance of $XXXXX is not on the credit report; verification of payment history is required. Documentation not provided. Transaction appears to be a refinance; copy of CD from closing not provided either to verify escrows included in payment.

Reviewer Comment (2020-01-07): Exception cleared

01/07/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209237787

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-30): Exception cleared

01/30/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209237787

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-29): Secondary product provided supporting origination value

01/29/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209237787

[Redact]

[Redact]

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 (2020-02-04): Client elected to waive.

02/04/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209237787

[Redact]

[Redact]

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.

Binding LE disclosed a Credit Report Fee of $XXXXX and Final CD disclosed $XXXXX. Final CD disclosed a Lender Credit of $18.88 for increase in Closing Costs above legal limit which is sufficient to cure 0% tolerance violation.

01/27/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209238353

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-05): Client verified tracking on collateral. Exception cleared

02/05/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209238353

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-02-06): Exception cleared

02/06/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209238353

[Redact]

[Redact]

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 information was not provided on Final CD

Reviewer Comment (2020-02-06): Client elects to waive

02/06/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209238353

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-06): Exception cleared

02/06/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209278915

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-21): Client has accepted the collateral package

02/21/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209278915

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-02-21): Desk Review uploaded as trailing doc; -0- variance

02/21/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209278915

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-02-21): Secondary product provided to support origination value.

02/21/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209278915

[Redact]

[Redact]

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 (2020-02-20): Client elects to waive

02/20/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209278915

[Redact]

[Redact]

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 Lender's Contact Name and NMLS ID.

Reviewer Comment (2020-02-20): Client elects to waive

02/20/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209280806

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-07): The client has accepted the collateral package

02/07/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209280806

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-01-31): Exception cleared

01/31/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209280806

[Redact]

[Redact]

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 a signed document at closing acknowledging their receipt of the valuation 3 days prior to closing. There's no evidence borrower(s) received a copy of the appraisal in the loan file.

Reviewer Comment (2020-02-10): Client elects to waive. Reviewer Comment (2020-02-06): Reviewed trailing docs. Missing a signed document at closing acknowledging their receipt of the valuation 3 days prior to closing. Exception remains. Seller Comment (2020-02-05): per regulations were are only required to show that we sent the appraisal which is what we did. tks Reviewer Comment (2020-02-03): The email provided was reviewed at initial audit and shows the appraisal was emailed to the borrower however there is no indication from the borrower regarding receipt.

02/10/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209280894

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-29): The client has accepted the final collateral package

01/29/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209280894

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

Binding LE did not disclosed Collateral Desktop Analysis Fee of $XXXXX disclosed on the Final CD. Cure for 0% tolerance violation was not provided.

Reviewer Comment (2020-02-05): XXXXX received PCCD indicating principal reduction, LOE, and Payment History indicating cure. Exception Cleared.

02/05/2020

1

A

[Redact]

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

209280894

[Redact]

[Redact]

Credit

Income / Employment

Income Documentation

REO Documents are missing.

- ___

PITIA verification for XXXXX and XXXXX was not provided.

Reviewer Comment (2020-01-29): The statement was provided and the designation is XXXXX who's currency can be validated through several sources Reviewer Comment (2020-01-29): Please provide currency conversion for property in India. Mortgage statement still missing for property on Lockwood Dr (to reflect inclusion of escrows or tax/HOI/HOA verification is required). May result in additional conditions

01/29/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209280894

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Sufficient or excess cure was provided to the borrower.

Reviewer Comment (2020-02-05): XXXXX received PCCD indicating principal reduction, LOE, and Payment History indicating cure. Exception Cured.

02/05/2020

2

B

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209282978

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-11): The client has accepted the final collateral package

02/11/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209282978

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

"Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-02-13): Desk Review uploaded as trailing doc; -0- variance

02/13/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209282978

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-02-13): XXXXX Desk review uploaded as a trailing doc; -0- variance

02/13/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209282978

[Redact]

[Redact]

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.

Non-escrowed property costs over 1 year on CD of $XXXXX is based on HOA monthly of $XXXXX, however, the HOA fee is $XXXXX x 12 = $XXXXX per file documentation. To clear, provide evidence of $XXXXX. monthly HOA fee, or to cure, provided corrected PC CD along with LOE to borrower and evidence of delivery.

Reviewer Comment (2020-03-09): XXXXX received PCCD correcting non escrowed property costs and LOE. Seller Comment (2020-03-06): (XXXXX) XXXXX Please see attached.

03/09/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209282978

[Redact]

[Redact]

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's Contact Name and NMLS ID.

Reviewer Comment (2020-02-10): Client elects to waive. Reviewer Comment (2020-02-10): Client elects to Waive

02/10/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209299988

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-24): Client has accepted the collateral package

02/24/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209299988

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-14): 0% variance

02/14/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209299988

[Redact]

[Redact]

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 was provided to the borrowers on XXXXX which is prior to the report date of XXXXX.

Reviewer Comment (2020-02-10): Client elects to waive.

02/10/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209299988

[Redact]

[Redact]

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. The H-8 form was used, the H-9 form should have been used. (The property state is in the 1st, 4th, 6th, or 11th circuit.)

H-8 was used, H-9 should have been used.

02/06/2020

2

A

[Redact]

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

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209299992

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-11): The client has accepted the final collateral package

02/11/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209299992

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-07): Secondary product provided to support origination value.

02/07/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209299992

[Redact]

[Redact]

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 required.

Reviewer Comment (2020-02-07): Secondary product provided to support origination value.

02/07/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209299992

[Redact]

[Redact]

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Coverage is insufficient replacement cost estimator was not provided.

Reviewer Comment (2020-03-04): RCE uploaded as a trailing doc Seller Comment (2020-03-04): Please see attachment

03/04/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209299992

[Redact]

[Redact]

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 is missing.

Reviewer Comment (2020-02-10): Client elects to waive. Reviewer Comment (2020-02-10): Client elects to Waive

02/10/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209299992

[Redact]

[Redact]

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.

Third party verification is missing for schedule C income/loss.

Reviewer Comment (2020-03-19): Compliance run, P&L and balance sheet provided as required Reviewer Comment (2020-03-19): incorrect action

03/19/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209299998

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-18): The client has accepted the collateral package

02/18/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209299998

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-02-20): Secondary product provided to support origination value.

02/20/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209299998

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-02-20): Secondary product provided to support origination value.

02/20/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209299998

[Redact]

[Redact]

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.

Document signed at closing and Appraisal Waiver provided, however, evidence of date appraisal received was not provided.

Reviewer Comment (2020-02-20): Client Elects to waive

02/20/2020

2

B

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209299998

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

QM Employment History

Qualified Mortgage (Dodd-Frank 2014): Employment history requirement not met.

Employment history reflects 30 day gap in employment and Employment Gap letter was not provided.

Reviewer Comment (2020-03-11): Uploaded revised trailing docs Seller Comment (2020-03-10): (XXXXX) Co-borrower income is not needed to qualify. See attached AUS, 1003 and 1008. Please clear thank you

03/11/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209299998

[Redact]

[Redact]

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.

Originator Loan Designation discrepancy is due to QM - Appendix Q Overall Fail. Over 30 day employment gap and gap letter was not provided.

Reviewer Comment (2020-03-11): Uploaded revised trailing docs Seller Comment (2020-03-10): (XXXXX) Co-borrower income is not needed to qualify. See attached AUS, 1003 and 1008. Please clear thank you

03/11/2020

1

A

[Redact]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209300004

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-18): The client has accepted the collateral package

02/18/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209300004

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-02-14): Secondary product provided to support origination value.

02/14/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209300004

[Redact]

[Redact]

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).

Disclosure does not reflect Lender Contact and Contact NMLS ID.

Reviewer Comment (2020-02-20): Client Elects to waive

02/20/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209300004

[Redact]

[Redact]

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.

Per Title Commitment transaction is Lender to Lender ; Form H-8 was used; Form H-9 should have been. 1. Current payoff balance $XXXXX 2. New loan amount w/same lender $XXXXX. 3. No new monies were taken out at closing. Borrower is bringing $XXXXX to closing

Reviewer Comment (2020-02-10): No new money on same lender refinance.

02/10/2020

1

A

[Redact]

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

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209300025

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-14): Collateral package accepted by client

02/14/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209300025

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-07): Secondary product provided to support origination value.

02/07/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209300025

[Redact]

[Redact]

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.

The Initial Escrow Account disclosure reflects $XXXXX initial deposit and $XXXXX monthly payment, the Final Closing Disclosure indicates $XXXXX initial deposit $XXXXX monthly escrow. This is corrected on the post-close Closing Disclosure dated XXXXX.

Reviewer Comment (2020-02-04): PCCD corrected the amount.

02/04/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209300025

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Escrowed Property Costs Year 1 - October 2018 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.

The Final Closing Disclosure reflects $XXXXX as Escrowed Property Costs over Year 1, this is corrected on the post closing Closing Disclosure dated XXXXX at $XXXXX.

Reviewer Comment (2020-02-04): Exception cleared on PCCD

02/04/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209300025

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment Over Disclosed

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 Final Closing Disclosure reflects the Estimated Escrow at $XXXXX, documentation provided indicates $XXXXX. This is corrected on the post close Closing Disclosure dated XXXXX.

Reviewer Comment (2020-02-04): PCCD cured this exception.

02/04/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, and Corrected CD

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209300025

[Redact]

[Redact]

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.

Charges for the total Recording Fees, Title - Endorsement Fee, and Title - Lender's Title Insurance exceed the 10% tolerance. No cure provided.

Reviewer Comment (2020-02-07): XXXXX reviewed exception. It it appears seller's final CD is XXXXX and intended to list Title-Endorsement and Title-Lender's Title Insurance in section C as indicated on PCCD. Exception Cured Seller Comment (2020-02-05): cd signed at closing the fees are in section C where they should be. tks Reviewer Comment (2020-02-05): Provide a Valid Change of Circumstance for this exception to re baseline fees increased. The Lender Title and Endorsement Fees were displayed in Section B on Final CD. A cure including A Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD is needed to satisfy this exception if a COC is not produced. Seller Comment (2020-02-04): title fees are not held to tolerance. Please see sspl list upld

02/07/2020

2

B

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209300025

[Redact]

[Redact]

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 Final Closing Disclosure reflects $XXXXX Appraisal Fee, the Initial Loan Estimate disclosed $XXXXX.

Reviewer Comment (2020-02-04): PCCD cured this exception.

02/04/2020

1

A

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209300032

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-14): Collateral package accepted by client

02/14/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

C

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209300032

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-10): 0% variance

02/10/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

C

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209300032

[Redact]

[Redact]

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

There is a coverage shortfall of $XXXXX. Provide a replacement cost estimator to document that the current coverage is sufficient.

Reviewer Comment (2020-02-10): exception cleared

02/10/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

C

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209300034

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-14): Collateral package accepted by client

02/14/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209300034

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-14): Secondary product provided to support origination value.

02/14/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209300137

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-05): Client has accepted the collateral package

03/05/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209300137

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-04): Seller provided third party source to verify value

03/04/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209305140

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-11): The client has accepted the collateral package

03/11/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209305140

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-03-15): XXXXX provided as a trailing doc; Variance of -XXXXX%

03/15/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209322826

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-18): The client has accepted the collateral package

02/18/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209322826

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-14): Secondary product provided to support origination value.

02/14/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209322826

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-02-14): Secondary product provided to support origination value.

02/14/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209322826

[Redact]

[Redact]

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 does not provide contact information for the Lender.

Reviewer Comment (2020-02-20): Client Elects to waive

02/20/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209322826

[Redact]

[Redact]

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

Reviewer Comment (2020-02-24): XXXXX received required documents, exception is cleared. Seller Comment (2020-02-20): On XXXXX the borrower requested to change their loan amount ( see COC request attached) which affected the pricing. Please see the lock confirmation included in the file, page 408 and the rediscosed CD to the borrower on XXXXX (see attached). Please clear this condition

02/24/2020

1

A

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209322894

[Redact]

[Redact]

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 (2020-01-27): Desk review provided. Exception cleared.

01/27/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

A

A

A

A

A

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209322908

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 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 final CD disclosed the Amount of Estimated Property Costs over Year 1 as $XXXXX on page 4; however the taxes $XXXXX, HOA $XXXXX, and HOI $XXXXX are $XXXXX per year. To cure, provided corrected PC CD along with LOE to borrower and evidence of delivery.

Reviewer Comment (2020-01-28): XXXXX received required documents, exception is cured. Seller Comment (2020-01-24): please see the attached revised CD

01/28/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

209322908

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Post Close Closing Disclosure Total Of Payments Test 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 $35 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 Section B 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 (2020-01-28): XXXXX received required documents, exception is cured. Seller Comment (2020-01-24): please see the attached revised CD

01/28/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

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

B

B

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

209322908

[Redact]

[Redact]

Credit

Insurance

Insurance Analysis

Hazard Insurance Policy expires within 90 days of the Note Date.

Hazard Insurance Policy Expiration Date ___, Note Date ___

Missing renewal and final CD did not collect 12 months at closing.

Reviewer Comment (2020-02-04): Client elects to waive.

02/04/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209322908

[Redact]

[Redact]

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.

Missing signature

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209322908

[Redact]

[Redact]

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.

Date provided to the borrower is XXXXX.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209322908

[Redact]

[Redact]

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.

Missing proof disclosure was provided within 3 days of application.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209322914

[Redact]

[Redact]

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 Final Closing Disclosure reflects a Date Issued of XXXXX, Closing Date is XXXXX.

Reviewer Comment (2020-01-28): XXXXX received tracking that indicates XXXXX CD was received by the borrower on XXXXX. Seller Comment (2020-01-24): CD XXXXX was provided to the borrower at least 3 days prior to closing. The Consummation CD was provided XXXXX and executed on XXXXX which is the consummation date. Condition Invalid. Please clear.

01/28/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

A

A

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209322914

[Redact]

[Redact]

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 Original Appraisal which was provided to the Borrower is dated XXXXX, a second Appraisal with the same value included in the file is dated XXXXX.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

A

A

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209322914

[Redact]

[Redact]

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.

The Affiliated Business Arrangement provided in the file is not signed by the Borrower.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

A

A

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209322918

[Redact]

[Redact]

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 Title - Document Preparation Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Sufficient or excess cure was provided to the borrower at Closing.

Fee was not disclosed on Loan Estimate. File contains a lenders credit for $XXXXX

01/16/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Final CD evidences Cure

C

A

A

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209322918

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-01-28): Secondary valuation provided with no variance, exception cleared.

01/28/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209322919

[Redact]

[Redact]

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.

Disclosure is not signed by the borrower.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

B

B

A

A

B

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209322919

[Redact]

[Redact]

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 10% or $XXXXX. Sufficient or excess cure was provided to the borrower at Closing.

$XXXXX violation due to increase in Recording fee(s). Cure of $XXXXX is reflected on the Final CD.

01/16/2020

1

A

[Redact]

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

209322934

[Redact]

[Redact]

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.

Cure provided at closing.

01/16/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

A

A

A

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209322940

[Redact]

[Redact]

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.

Affiliated Business Arrangement Disclosure provided was not signed by borrower.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

B

B

A

A

B

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209322940

[Redact]

[Redact]

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 provided to borrower on XXXXX, however, Appraisal was signed on XXXXX.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

B

B

A

A

B

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209322941

[Redact]

[Redact]

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.

Property was inspected XXXXX, report was signed XXXXX and the appraisal was sent to the borrower XXXXX.

Reviewer Comment (2020-02-06): Client elects to waive. Reviewer Comment (2020-01-28): Valuation Received Date XXXXX and Valuation Report Date XXXXX. Need proof the borrower was given a copy of the updated appraisal dated XXXXX. Seller Comment (2020-01-27): Please see attached appraisal report proof of delivery.

02/06/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209322941

[Redact]

[Redact]

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.

Disclosure is not signed by the borrower.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209322941

[Redact]

[Redact]

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.

E-sign consent was dated XXXXX.

Reviewer Comment (2020-01-28): Reviewed file and find Disclosure was sent both e docs and XXXXX. Exception cleared. Seller Comment (2020-01-27): Initial Disclosure package was mailed out on XXXXX. Please see attached Disclosure Tracking.

01/28/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209322941

[Redact]

[Redact]

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.

Cure of $XXXXX is reflected on the Final CD

Reviewer Comment (2020-01-24): The lender self cured at closing for the fee failure

01/24/2020

2

B

[Redact]

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

209322941

[Redact]

[Redact]

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.

01/24/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209322942

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Pending Secondary Valuation as required for securitization

Reviewer Comment (2020-01-28): Secondary valuation provided with no variance, exception cleared.

01/28/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209322942

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Commission Method of Calculation

Qualified Mortgage (Dodd-Frank 2014): Commission income required to be averaged over a period of at least two (2) years.

Lender used a 1 year average for XXXXX.

Reviewer Comment (2020-02-05): Exception cleared. Seller Comment (2020-02-04): Please clear condition. Refer to Income Worksheet and Approval in the file.

02/05/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209322942

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Rental Income Documentation - Schedule E Method Test

Qualified Mortgage (Dodd-Frank 2014): Rental income documentation requirement not met for XXXXX. Lease Agreement and/or Tax Return not provided.

Missing Lease Agreement

Reviewer Comment (2020-03-09): Lease uploaded as trailing doc Seller Comment (2020-03-05): Please see attached Lease Agreement for XXXXX. Reviewer Comment (2020-02-11): Per Appendix Q both tax returns and a current lease is required when rental income is used to qualify. Please provide a copy of the lease. Seller Comment (2020-02-10): Please see attached XXXXX and XXXXX Personal Tax Returns. This is how income was calculated for this property. Reviewer Comment (2020-02-05): Loan is subject to Appendix Q documentation and requires a current executed lease along with 1040 sch E for 2 years (which we have 1040s for both year). Exception remains. Seller Comment (2020-02-04): Please clear condition. Refer to Schedule E of the Personal Tax Returns in the file.

03/09/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209322942

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Rental Income Documentation - Schedule E Method Test

Qualified Mortgage (Dodd-Frank 2014): Rental income documentation requirement not met for XXXXX. Lease Agreement and/or Tax Return not provided.

Missing Lease Agreement

Reviewer Comment (2020-03-09): Lease uploaded as trailing doc Seller Comment (2020-03-05): Please see attached Lease Agreement for XXXXX. Reviewer Comment (2020-02-11): Per Appendix Q both tax returns and a current lease is required when rental income is used to qualify. Please provide a copy of the lease. Seller Comment (2020-02-10): Please see attached XXXXX and XXXXX Personal Tax Returns. This is how income was calculated for this property. Reviewer Comment (2020-02-05): Loan is subject to Appendix Q documentation and requires a current executed lease along with 1040 sch E for 2 years (which we have 1040s for both year). Exception remains. Seller Comment (2020-02-04): Please clear condition. Refer to Schedule E of the Personal Tax Returns in the file.

03/09/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209322942

[Redact]

[Redact]

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 Lease Agreements for REO's and Commission income used was less than 2 years.

Reviewer Comment (2020-03-09): Leases uploaded per trailing docs

03/09/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

A

A

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209322944

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 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.

Per the documents provided the taxes are $XXXXX annually and the HOI is $XXXXX annually for a total cost of $XXXXX. The final CD disclosed $XXXXX

Reviewer Comment (2020-02-07): XXXXX received a PCCD correcting total property costs and LOE. Seller Comment (2020-02-05): Please see attached PCCD, Letter to Borrower and Disclosure Tracking

02/07/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

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

209322944

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-01-28): Secondary valuation provided with no variance, exception cleared.

01/28/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

A

A

C

B

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209322947

[Redact]

[Redact]

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 (2020-01-28): Secondary valuation provided with no variance, exception cleared.

01/28/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

A

A

B

B

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209322947

[Redact]

[Redact]

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.

Disclosure in file was not signed by borrower.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

A

A

B

B

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209322950

[Redact]

[Redact]

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.

The Disclosure was not signed.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

A

A

B

B

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209322950

[Redact]

[Redact]

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 secondary valuation as required for securitization.

Reviewer Comment (2020-01-28): Secondary valuation provided with no variance, exception cleared.

01/28/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

A

A

B

B

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209322951

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-01-28): Secondary valuation provided with no variance, exception cleared.

01/28/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209322951

[Redact]

[Redact]

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 reflects XXXXX as the Date of Signature and Report, Effective Date of Appraisal XXXXX, the Appraisal Receipt document provided indicates the Appraisal was provided to the Borrower on XXXXX.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209322951

[Redact]

[Redact]

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 Final Closing Disclosure reflects a n Appraisal Fee of $XXXXX, the Initial Loan Estimate disclosed $XXXXX. No cure is provided.

Reviewer Comment (2020-02-14): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided Seller Comment (2020-02-12): Refund check, LOE, corrected CD, tracking

02/14/2020

2

B

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209322951

[Redact]

[Redact]

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 (2020-02-14): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided

02/14/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209322952

[Redact]

[Redact]

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.

Affiliated Business Arrangement Disclosure was not signed and dated by borrowers.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209322952

[Redact]

[Redact]

Credit

Income / Employment

Income Documentation

REO Documents are missing.

-

HOA Verification for XXXXX was not provided. (If Applicable)

Reviewer Comment (2020-01-26): Verification of HOA in trailing, exception cleared. Seller Comment (2020-01-24): Please see Bank Statements attached. HOA payments for XXXXX property highlighted.

01/26/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209322954

[Redact]

[Redact]

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.

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.

Reviewer Comment (2020-02-03): XXXXX received a CD correcting fee placement and LOE. Exception Cured. Seller Comment (2020-01-29): Attached is the updated CD XXXXX. Please recalculate and see if we still need a tolerance cure? Reviewer Comment (2020-01-28): Title - Owner policy disclosed on section B, rather than section H, on final CD. PCCD showing charge in section H and LOE to borrower required to cure. Seller Comment (2020-01-24): Can you please provide a breakdown of how you came up with $XXXXX vs $XXXXX? What was included in your calculation for $XXXXX? Also, what was included in our CD calculation $XXXXX? We need to see the breakdown of your calculation to determine if its is under tolerance.

02/03/2020

2

B

[Redact]

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

209322954

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Reinspection Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Reinspection Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

Reviewer Comment (2020-01-28): XXXXX received Changed Circumstance. Seller Comment (2020-01-24): COC

01/28/2020

1

A

[Redact]

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

209322962

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-01-29): 0% variance

01/29/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209322962

[Redact]

[Redact]

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.

Affiliated Business Arrangement Disclosure was not signed or dated.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209322962

[Redact]

[Redact]

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.

Binding LE did not disclose Transfer Tax Fee of $XXXXX disclosed on the Final CD. Cure for 0% tolerance violation was not provided.

Reviewer Comment (2020-02-03): XXXXX received PCCD indicating cure, LOE, and refund check. Exception Cleared.

02/03/2020

1

A

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209322962

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

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.

Reviewer Comment (2020-02-03): XXXXX received PCCD indicating cure, LOE, and refund check. Exception Cured.

02/03/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209322970

[Redact]

[Redact]

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 Title - Closing Protection Letter 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 0% tolerance violation of $XXXXX.

01/15/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

C

A

A

A

A

A

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

209322970

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Pending Secondary Valuation as required for securitization

Reviewer Comment (2020-01-28): Secondary valuation provided with no variance, exception cleared.

01/28/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

A

A

A

A

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209322971

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

RESPA - Initial Escrow Account Statement Missing

RESPA: Initial escrow account statement was not provided to the borrower.

The final signed Initial Escrow Account Statement was not provided. The one in file was not dated and signed.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

B

B

A

A

B

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

209322975

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-01-29): 0% variance

01/29/2020

1

A

[Redact]

Primary

Purchase

C

A

A

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209322975

[Redact]

[Redact]

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.)

Seller's and Borrower's CDs do not reflect any seller paid fees.

Reviewer Comment (2020-02-10): Confirmed no seller paid fees - Typical for new construction Seller Comment (2020-02-06): Final Settlement Statement confirms there were no seller fees.

02/10/2020

1

A

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

A

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209322976

[Redact]

[Redact]

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.

Verified that the finance charge entered matches the Final CD in the file. 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.

Reviewer Comment (2020-02-04): XXXXX received required documents, exception is cleared. Seller Comment (2020-02-04): Please advise, documents to clear the exception grade 3 condition where provided XXXXX. Seller Comment (2020-01-31): please see attached.

02/04/2020

1

A

[Redact]

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

A

A

A

C

A

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

209322976

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Rate Lock Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

XXXXX received required documents, exception is cleared.

Reviewer Comment (2020-02-04): XXXXX received required documents, exception is cleared.

02/04/2020

1

A

[Redact]

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

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

209322977

[Redact]

[Redact]

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Reviewer Comment (2020-02-07): Approval uploaded as a trailing doc

02/07/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209322977

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Tax Certificate Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

The initial Loan Estimate failed to disclose a Title - Tax Certificate fee as charged on the Borrower's final Closing Disclosure. No valid Change of Circumstance or cure was provided.

Reviewer Comment (2020-01-24): Lender self cured at closing with a credit to the borrower on the final CD

01/24/2020

2

B

[Redact]

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

209322977

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Settlement / Closing / Escrow Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

The initial Loan Estimate failed to disclose a Title - Settlement/Closing/Escrow fee as charged on the Borrower's final Closing Disclosure. No valid Change of Circumstance or cure was provided. The cure of $XXXXX on the final CD after curing other failures leaves a credit balance of $XXXXX which is insufficient to cover this failure

Reviewer Comment (2020-03-23): XXXXX received PCCD indicating cure, LOE, refund check, and proof of mailing. Seller Comment (2020-03-20): Airbill Reviewer Comment (2020-03-12): Letter of Explanation, Copy of Refund Check, and Corrected CD provided. Lender to provide proof of deliver (XXXXX) for the additional $XXXXX cure that was sent to the borrower.

03/23/2020

1

A

[Redact]

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

209322977

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title-Owner End (Optional). Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

The initial Loan Estimate failed to disclose a Title - Endorsement fee as charged on the Borrower's final Closing Disclosure. No valid Change of Circumstance or cure was provided.

Reviewer Comment (2020-01-24): Lender self cured at closing with a credit on the final CD

01/24/2020

2

B

[Redact]

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

209322977

[Redact]

[Redact]

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 point fee failure

Reviewer Comment (2020-03-04): Exception cleared

03/04/2020

1

A

[Redact]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209322977

[Redact]

[Redact]

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 3.00000% 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%).

Missing evidence of the unadjusted start rate

Reviewer Comment (2020-03-04): Exception cleared Seller Comment (2020-03-03): Bone fide worksheet Reviewer Comment (2020-02-07): The Max allowable is 3% or $XXXXX. The QM Points and fees consist of the Discount Points, YSP, Title Endorsement Fee, Lender's Title Insurance, Policy Guarantee Fee, Settlement/Closing/Escrow Fee and Tax Certificate. These fees total $XXXXX, which is $XXXXX over the maximum. Seller Comment (2020-02-06): Please confirm what fees are being included in XXXXX test. Thank you!

03/04/2020

1

A

[Redact]

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

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209322977

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Tax Certificate Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Sufficient or excess cure was provided to the borrower.

Letter of Explanation, Copy of Refund Check, and Corrected CD provided. Lender to provide proof of deliver (XXXXX) for the additional $XXXXXcure that was sent to the borrower.

Reviewer Comment (2020-03-16): Client elects to waive.

03/16/2020

2

B

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209322977

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Settlement / Closing / Escrow Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Sufficient or excess cure was provided to the borrower.

Letter of Explanation, Copy of Refund Check, and Corrected CD provided. Lender to provide proof of deliver (XXXXX) for the additional $XXXXX cure that was sent to the borrower.

Reviewer Comment (2020-03-16): Client elects to waive.

03/16/2020

2

B

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209322977

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title-Owner End (Optional). Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Sufficient or excess cure was provided to the borrower.

Letter of Explanation, Copy of Refund Check, and Corrected CD provided. Lender to provide proof of deliver (XXXXX) for the additional $XXXXX cure that was sent to the borrower.

Reviewer Comment (2020-03-16): Client elects to waive.

03/16/2020

2

B

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209322981

[Redact]

[Redact]

Credit

Loan Package Documentation

Closing / Title

Title Error: Title vesting does not concur with deed

Only one of the borrower is listed on the Security Instrument whereas 2 were underwritten.

Reviewer Comment (2020-01-29): Final Title confirms only B1 took title to the property, B2 to occupy based on 1003 Seller Comment (2020-01-29): Please see attached final title policy and deed. Vesting matches between the two, only showing XXXXX with vested interest in the property.

01/29/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209322981

[Redact]

[Redact]

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 documentation found to verify the appraisal was provided to the borrowers.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209322981

[Redact]

[Redact]

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.)

There were no seller-related Fees on the Final CD and no Seller CD was provided in the loan file.

Reviewer Comment (2020-02-03): Seller CD attached $XXXXX for seller fees. - Builder sale - typical for new construction no seller paid fees. Seller Comment (2020-01-29): seller CD attached.

02/03/2020

1

A

[Redact]

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

209322982

[Redact]

[Redact]

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 (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Purchase

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209322982

[Redact]

[Redact]

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.

Per the appraisal the HOA annual fee is $XXXXX

Reviewer Comment (2020-02-20): Letter of Explanation & Corrected Closing Disclosure provided Reviewer Comment (2020-02-07): Corrected CD provided. LOE to borrower still required to cure.

02/20/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209322992

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-02-12): 0% variance

02/12/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209322993

[Redact]

[Redact]

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 (2020-01-29): 0% variance

01/29/2020

1

A

[Redact]

Primary

Purchase

C

B

A

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209322993

[Redact]

[Redact]

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's no evidence of a rate lock in the loan file.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Purchase

C

B

A

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209322999

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-02-12): 0% variance

02/12/2020

1

A

[Redact]

Primary

Purchase

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209322999

[Redact]

[Redact]

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.

No evidence of a Valid COC for the survey fee

Reviewer Comment (2020-03-03): XXXXX received required documents, exception is cured. Reviewer Comment (2020-02-28): XXXXX received PCCD and LOE to borrower. As title fee was not required, it should be listed in section H instead of section C. Corrected CD and LOE required to clear. Seller Comment (2020-02-26): Per the Purchase Agreement, the Survey was not required and so we moved it from Section B. to Section C.

03/03/2020

2

B

[Redact]

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

209323002

[Redact]

[Redact]

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 (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Purchase

B

B

A

A

B

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209323002

[Redact]

[Redact]

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 10% or $XXXXX. Sufficient or excess cure was provided to the borrower at Closing.

A cure was provided at closing.

02/28/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

B

B

A

A

B

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209323003

[Redact]

[Redact]

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 (2020-02-12): 0% variance

02/12/2020

1

A

[Redact]

Primary

Purchase

C

A

A

A

A

A

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209323003

[Redact]

[Redact]

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.

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.

01/25/2020

1

A

[Redact]

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

209323008

[Redact]

[Redact]

Credit

Credit

General

Initial Rate Lock rate date is not documented in file.

Reviewer Comment (2020-02-19): Alternate source for rate lock uploaded as trailing doc

02/19/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209323008

[Redact]

[Redact]

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 delivery.

Reviewer Comment (2020-02-20): Letter of Explanation, Proof of Delivery, Refund check for under disclosed amount, Corrected CD provided. $XXXXX rate lock fee returned to borrower

02/20/2020

2

B

[Redact]

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

Safe Harbor QM

Safe Harbor QM

Yes

209323008

[Redact]

[Redact]

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.)

The file does not contain a Seller CD.

Reviewer Comment (2020-02-19): Seller CD uploaded as a trailing doc

02/19/2020

1

A

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209323008

[Redact]

[Redact]

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 1004 in the file reflects HOA fees in the amount of $XXXXX monthly, with the annual being $XXXXX vs the lender using $XXXXX monthly.

Reviewer Comment (2020-02-20): Letter of Explanation & Corrected Closing Disclosure provided

02/20/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209323013

[Redact]

[Redact]

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 documentation was provided to verify the borrower was provided a copy of the appraisal.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Purchase

B

B

A

A

B

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209323013

[Redact]

[Redact]

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.

Sufficient cure was provided.

01/29/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

B

B

A

A

B

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209323018

[Redact]

[Redact]

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 the appraisal was/sent received by the borrowers.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209323018

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Subordination Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Subordination Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

Reviewer Comment (2020-02-19): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided

02/19/2020

2

B

[Redact]

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

Safe Harbor QM

Safe Harbor QM

Yes

209323018

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Subordination 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 (2020-02-19): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided

02/19/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209323020

[Redact]

[Redact]

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.

Supporting documentation was not provided at the time of audit review to verify delivery/receipt of report.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

B

B

A

A

B

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209323023

[Redact]

[Redact]

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 (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Purchase

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209323023

[Redact]

[Redact]

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.

Fee was not disclosed on Loan Estimate. File does not contain a valid COC for this fee, nor evidence of cure.

Reviewer Comment (2020-03-31): XXXXX received Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD Reviewer Comment (2020-02-10): COC received for rate lock. Points added $XXXXX. Final CD reflects $XXXXX. Cure provided at closing is not sufficient Reviewer Comment (2020-02-10): Updated from: 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. (7200)

03/31/2020

2

B

[Redact]

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

209323024

[Redact]

[Redact]

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. The H-8 form was used, the H-9 form should have been used. (The property state is in the 1st, 4th, 6th, or 11th circuit.)

H-8 form used.

01/27/2020

2

A

[Redact]

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

A

A

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209323024

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-02-07): 0% variance

02/07/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209323026

[Redact]

[Redact]

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 10% or $XXXXX Sufficient or excess cure was provided to the borrower at Closing.

Cure for 0% tolerance violation ($XXXXX) was not provided.

01/27/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Final CD evidences Cure

C

A

A

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209323026

[Redact]

[Redact]

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.

LE appears to have been prepared and delivered to the borrower on time but the borrower did not review or e-sign until XXXXX and there is no evidence of the disclosure tracking to confirm a mail copy was sent.

Reviewer Comment (2020-02-05): Document 0163 confirms Initial LE was also sent XXXXX - E-delivery N/A Seller Comment (2020-02-03): please see attached disclosure tracking - paper requested and sent out on XXXXX

02/05/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209323028

[Redact]

[Redact]

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Missing Document: Note - Subordinate Lien not provided

Reviewer Comment (2020-02-03): Heloc Agreement uploaded as a trailing doc

02/03/2020

1

A

[Redact]

Primary

Purchase

C

A

C

A

A

A

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209323035

[Redact]

[Redact]

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. Title fees except for settlement fee were reported in section B instead of C. Title vendor was not listed on SSPL.

Reviewer Comment (2020-02-05): Final CD display closing fees in Section B. PCCD submitted with fees Borrower shopped for in Section C. There is no discrepancy and this exception cleared.

02/05/2020

1

A

[Redact]

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

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

209323035

[Redact]

[Redact]

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

AUS Findings: Investor qualifying total debt ratio discrepancy.

Lender income calculation is not supported by documentation. Borrower income is $XXXXX for XXXXX and CB is $XXXXX with debts of $XXXXX. The income used by the lender is higher and not supported as this other income source listed on the 1003.

Reviewer Comment (2020-02-13): Exception cleared. Seller Comment (2020-02-12): you have all the income docs the UW is explaining in his email...here they are again. What is it that you don't agree on? Seller Comment (2020-02-12): we're asking for a breakdown of your income calc Reviewer Comment (2020-02-12): File is missing trailing docs for this exception.

02/13/2020

1

A

[Redact]

Primary

Purchase

C

A

C

A

C

A

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209323039

[Redact]

[Redact]

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 (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209323039

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - REO Schedule E Method Test

Ability to Repay (Dodd-Frank 2014): Unable to verify Real Estate Owned income (Schedule E Method) using reasonably reliable third-party records.

The file is missing a current year to date P&L and balance sheet as the transaction is being tested against ATR and SHQM due to fee failure.

Reviewer Comment (2020-02-04): Exception cleared

02/04/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209323039

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - S-Corp

Ability to Repay (Dodd-Frank 2014): Unable to verify S-Corp income using reasonably reliable third-party records.

The file is missing a current year to date P&L and balance sheet as the transaction is being tested against ATR and SHQM due to fee failure.

Reviewer Comment (2020-02-04): Exception cleared

02/04/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209323039

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - S-Corp

Ability to Repay (Dodd-Frank 2014): Unable to verify S-Corp income using reasonably reliable third-party records.

Business tax returns provided are not signed/dated.

Reviewer Comment (2020-02-04): Exception cleared

02/04/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209323039

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

NonQM ATR

Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.

The file is missing a current year to date P&L and balance sheet as the transaction is being tested against ATR and SHQM due to fee failure.

Reviewer Comment (2020-02-04): Exception cleared

02/04/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209323039

[Redact]

[Redact]

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 3.00000% 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%).

Points and Fees on subject loan of XXXXX% exceeds the allowable maximum of 3.00000%. File is missing evidence of the unadjusted start rate.

Reviewer Comment (2020-02-04): Exception cleared

02/04/2020

1

A

[Redact]

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

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

209323039

[Redact]

[Redact]

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.)

Seller CD was not provided to verify fees if any.

Reviewer Comment (2020-02-04): Seller CD received. Exception cleared. Seller Comment (2020-02-04): Seller CD

02/04/2020

1

A

[Redact]

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

209323039

[Redact]

[Redact]

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.

Binding LE disclosed Loan Discount Points of $XXXXX and Final CD disclosed $XXXXX. Cure for 0% tolerance violation was not provided.

Reviewer Comment (2020-02-05): XXXXX reviewed and upon further review find issue resolved at close no violation exists. Seller Comment (2020-02-05): XXXXX, CD, COC and Tracking Log Reviewer Comment (2020-02-04): Reviewed documents submitted. COC is dated XXXXX with disclosure date XXXXX. These documents are not within compliance. A Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD is needed to cure this exception.

02/05/2020

1

A

[Redact]

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

209323039

[Redact]

[Redact]

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 ATR Fail.

Originator Loan Designation discrepancy is due to ATR fail.

Reviewer Comment (2020-02-04): Exception cleared

02/04/2020

1

A

[Redact]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

A

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

209323039

[Redact]

[Redact]

Credit

Income / Employment

Income Documentation

REO Documents are missing.

-

PITIA verification for XXXXX was not provided.

Reviewer Comment (2020-02-04): Exception cleared Seller Comment (2020-02-04): XXXXX

02/04/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209323041

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-02-07): 0% variance

02/07/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

A

A

B

B

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209323041

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

FACTA Disclosure Missing

FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.

Supporting documentation was not provided at the time of audit to verify delivery/receipt of disclosure.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

A

A

B

B

C

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209323042

[Redact]

[Redact]

Credit

Missing Document

General

Missing Document: Verification of Non-US Citizen Status not provided

Copy of non US Citizenship was not provided.

Reviewer Comment (2020-02-06): exception cleared Reviewer Comment (2020-02-04): Guidelines require a Passport with photo or Visa or USCIS Employment Authorization document (I-766). If the Visa has expired (none was provided), I-797 can be included with I-94 arrival/departure record imbedded. I797-A Notice of Action is not sufficient documentation per guidelines.

02/06/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209323042

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 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.

Estimated Property Costs over Year 1 of $XXXXX appears to be based on $XXXXX insurance & $XXXXX taxes and HOA $XXXXX ($XXXXX + $XXXXX + $XXXXX = XXXXX * 12 =$XXXXX), however, per file documentation the HOA is $XXXXX. 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 (2020-02-04): PCCD cured this exception Seller Comment (2020-02-04): the LOE was uploaded yesterday with the revised cd. we normally don't send proof of delivery unless there is money involved Reviewer Comment (2020-02-04): LOE and evidence of delivery for revised CD was not provided.

02/04/2020

2

B

[Redact]

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

209323042

[Redact]

[Redact]

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.

Due to Points and Fees exceeds the maximum allowable.

Reviewer Comment (2020-03-09): PCCD, LOE refund in file Seller Comment (2020-03-06): can you please clear this condition? Reviewer Comment (2020-02-28): After our compliance dept reviewed the PCCD and it has been determine the cure required is $XXXXX, Essentially the interest on the cure is approximately 10 cents per week, lender should be concerned about missing the check cut by a day or two, so they should request a little more than they expect. (e.g. 10 cents gets them an additional week. Documents Required to Cure 1) Letter of Explanation, Copy of Refund Check (in the amount of overage plus interest), Proof of Delivery and 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. Exception remains. Thank you. Seller Comment (2020-02-27): uploaded refund Reviewer Comment (2020-02-06): After reviewing undiscounted rate- Borrower paid XXXXX% is discounts points $XXXXX for XXXXX% rate. Undiscounted rate of XXXXX% - 3.25% Note rate = .XXXXX% / XXXXX% points paid = .XXXXX% less than .25. We use .25 as the minimum rate reduction per point paid to be considered Bona Fide. Exception remains. Reviewer Comment (2020-02-04): Borrower paid XXXXX% is discounts points $XXXXX for XXXXX% rate. Undiscounted rate of XXXXX% - XXXXX% Note rate = .XXXXX% / XXXXX% points paid = .XXXXX% less than .25. We use .25 as the minimum rate reduction per point paid to be considered Bona Fide. Need starting price. Exception remains Seller Comment (2020-02-03): see points & fees breakdown uploaded

03/09/2020

2

B

[Redact]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

A

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

209323042

[Redact]

[Redact]

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 3.00000% 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%).

No cure was provided for XXXXX% excess. Due to Fees and Points exceeding the max allowable. Compliance report reflects undiscounted rate of XXXXX%, however missing starting rate price.

Reviewer Comment (2020-03-06): We have a cure of $XXXXX on PCCD. LOE, refund check and proof of delivery in file. Seller Comment (2020-03-04): interest refund Reviewer Comment (2020-02-28): After our compliance dept reviewed the PCCD and it has been determine the cure required is $XXXXX, Essentially the interest on the cure is approximately 10 cents per week, lender should be concerned about missing the check cut by a day or two, so they should request a little more than they expect. (e.g. 10 cents gets them an additional week. Documents Required to Cure 1) Letter of Explanation, Copy of Refund Check (in the amount of overage plus interest), Proof of Delivery and 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. Exception remains. Thank you. Reviewer Comment (2020-02-04): Borrower paid XXXXX% is discounts points $XXXXX for XXXXX% rate. Undiscounted rate of XXXXX% - XXXXX% Note rate = .XXXXX% / XXXXX% points paid = .XXXXX% less than .25. We use .25 as the minimum rate reduction per point paid to be considered Bona Fide. Need starting price. Exception remains

03/06/2020

2

B

[Redact]

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

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

209323042

[Redact]

[Redact]

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.)

Seller CD was not provided, nor were fees charged to borrower.

Reviewer Comment (2020-02-04): Seller CD provided as post closing document Seller Comment (2020-02-03): seller cd

02/04/2020

1

A

[Redact]

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

209323043

[Redact]

[Redact]

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 10% or $XXXXX Sufficient or excess cure was provided to the borrower at Closing.

Due to incorrect amounts disclosed on the initial Loan Estimate, the Ten Percent Fee Tolerance exceeded. Total amount of $XXXXX exceeds tolerance of $XXXXX plus 10% or $XXXXX. Sufficient or excess cure was provided to the borrower at Closing.

01/29/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

A

A

A

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209323043

[Redact]

[Redact]

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 Title - Courier / Express Mail / Messenger Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Sufficient or excess cure was provided to the borrower at Closing.

The initial Loan Estimate failed to reflect the correct amount for the Title - Courier fee of $XXXXX as charged on the final Closing Disclosure. No valid Change of Circumstance or Cure was provided.

01/29/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

A

A

A

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209323043

[Redact]

[Redact]

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.

The initial Loan Estimate failed to reflect the correct amount for the XXXXX Fee of $XXXXX as charged on the final Closing Disclosure. No valid Change of Circumstance or Cure was provided.

01/29/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

A

A

A

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209323043

[Redact]

[Redact]

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 Title - Endorsement Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Sufficient or excess cure was provided to the borrower at Closing.

The initial Loan Estimate failed to reflect the correct amount for the Title - Endorsement Fee of $XXXXX as charged on the final Closing Disclosure. No valid Change of Circumstance or Cure was provided.

01/29/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

A

A

A

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209323044

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

Fee was not disclosed on Loan Estimate. File does not contain a valid COC for this fee, nor evidence of cure.

Reviewer Comment (2020-02-03): XXXXX reviewed and address the Fee Recon Section and cleared exception. Seller Comment (2020-01-30): Please see attached explanation on CD

02/03/2020

1

A

[Redact]

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

209323044

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 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 final CD disclosed the Amount of Non-Escrowed Property Costs over Year 1 as $XXXXX on page 4; however the taxes and insurance are $XXXXX per year. Provide a post-close CD correcting the Escrow Account section and a copy of the letter of explanation letter sent to the borrower disclosing the changes made.

Reviewer Comment (2020-02-06): XXXXX received required documents, exception is cured. Seller Comment (2020-02-04): Please see attached PCCD and LOE Reviewer Comment (2020-02-03): XXXXX received calculation and agrees however the total is $XXXXX. The allowable tolerance for the escrow account fields on page four of the CD is $0.02 per month of property costs or $0.24 for 12 months. Letter of Explanation and Corrected CD required to cure. Seller Comment (2020-01-30): Please see attached calculations

02/06/2020

2

B

[Redact]

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

209323045

[Redact]

[Redact]

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 ststement disclosed starting balance of $XXXXX and Final CD disclosed $XXXXX.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

209323045

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Processing Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

Processing 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 initial 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 (2020-02-04): confirmed borrower shopped for fees Seller Comment (2020-02-03): THe borrower chose their own settlement agent to close this loan therefore title fees are listed in section C, no tolerance section. However this fee was disclosed to them on the LE: XXXXX preparation & collateral review. It is listed as XXXXX processing fee on the CD. no refund needed

02/04/2020

1

A

[Redact]

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

209323045

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Settlement / Closing / Escrow Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

Processing 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 initial 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 (2020-02-04): confirmed borrower shopped for fees Seller Comment (2020-02-03): THe borrower chose their own settlement agent to close this loan therefore title fees are listed in section C, no tolerance section. Title fees can be added without being disclosed in this situation, no refund needed

02/04/2020

1

A

[Redact]

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

209323045

[Redact]

[Redact]

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.

Transfer Tax was disclosed on the initial LE in the amount $XXXXX but on the final CD reads $XXXXX. It appears the borrower was not notified of this increased fee after initial 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 (2020-02-20): XXXXX received PCCD indicating cure, LOE, and refund check. Seller Comment (2020-02-14): $XXXXX refund Reviewer Comment (2020-02-12): Initial LE disclosed $XXXXX. Cure due to borrower Seller Comment (2020-02-10): when we originally disclosed this loan, a recording guide was pulled and stated mortgage tax was $XXXXX, that is why it is higher than the broker LE Reviewer Comment (2020-02-07): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD required to cure unless a valid COC can be provided. Initial LE sent by broker has $XXXXX which is binding unless valid COC can be provided to justify the fee increase Seller Comment (2020-02-05): that is the Broker's initial LE, you wouldn't use that one. The last disclosed LE from loandepot is XXXXX & states $XXXXX. can you please clear? Reviewer Comment (2020-02-04): There is a Loan Estimate in the file issued XXXXX with transfer tax of $XXXXX - Appears to be a Brokers LE Seller Comment (2020-02-03): Not sure where the figure of $XXXXX came from, All LE's disclosed the transfer tax figure as $XXXXX - no refund need. please advise

02/20/2020

1

A

[Redact]

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

209323045

[Redact]

[Redact]

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.

Missing broker's initial disclosure.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

No

209323045

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

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.

XXXXX received PCCD indicating cure, LOE, and refund check.

Reviewer Comment (2020-02-20): XXXXX received PCCD indicating cure, LOE, and refund check.

02/20/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Temporary SHQM (GSE/Agency Eligible)

Temporary SHQM (GSE/Agency Eligible)

Yes

209323051

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

K-1 Documentation

Qualified Mortgage (Dodd-Frank 2014): Required K-1s or signed tax returns/transcripts not provided for K-1 (Less than 25% Ownership) income.

Personal 1040s for XXXXX and XXXXX are not signed an dated and Transcripts for XXXXX and XXXXX are not in file.

Reviewer Comment (2020-02-05): XXXXX Transcripts uploaded as trailing docs

02/05/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209323051

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

K-1 Documentation

Qualified Mortgage (Dodd-Frank 2014): Required K-1s or signed tax returns/transcripts not provided for K-1 (Less than 25% Ownership) income.

Personal 1040s for XXXXX and XXXXX are not signed an dated and Transcripts for XXXXX and XXXXX are not in file.

Reviewer Comment (2020-02-05): XXXXX Transcripts uploaded as trailing docs

02/05/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209323051

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

K-1 Documentation

Qualified Mortgage (Dodd-Frank 2014): Required K-1s or signed tax returns/transcripts not provided for K-1 (Less than 25% Ownership) income.

Personal 1040s for XXXXX and XXXXX are not signed an dated and Transcripts for XXXXX and XXXXX are not in file.

Reviewer Comment (2020-02-05): XXXXX Transcripts uploaded as trailing docs

02/05/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209323051

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application.

Broker's application is dated XXXXX, missing broker's initial LE.

Reviewer Comment (2020-02-05): XXXXX Transcripts uploaded as trailing docs

02/05/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209323051

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Employment - K-1 Less 25%

Ability-to-Repay (Dodd-Frank 2014): Unable to verify current K-1 (Less than 25% Ownership) status using reasonably reliable third-party records.

Once we receive signed XXXXX and XXXXX personal returns and/or transcripts this exception will cleared based on loan now meets Appendix Q.

Reviewer Comment (2020-02-05): XXXXX Transcripts uploaded as trailing docs

02/05/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209323051

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Employment - K-1 Less 25%

Ability-to-Repay (Dodd-Frank 2014): Unable to verify current K-1 (Less than 25% Ownership) status using reasonably reliable third-party records.

Once we receive signed XXXXX and XXXXX personal returns and/or transcripts this exception will cleared based on loan now meets Appendix Q.

Reviewer Comment (2020-02-05): XXXXX Transcripts uploaded as trailing docs

02/05/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209323051

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Employment - K-1 Less 25%

Ability-to-Repay (Dodd-Frank 2014): Unable to verify current K-1 (Less than 25% Ownership) status using reasonably reliable third-party records.

Once we receive signed XXXXX and XXXXX personal returns and/or transcripts this exception will cleared based on loan now meets Appendix Q.

Reviewer Comment (2020-02-05): XXXXX Transcripts uploaded as trailing docs

02/05/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209323051

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - K-1 Less 25%

Ability to Repay (Dodd-Frank 2014): Unable to verify K-1 (Less than 25% Ownership) income using reasonably reliable third-party records.

Once we receive signed XXXXX and XXXXX personal returns and/or transcripts this exception will cleared based on loan now meets Appendix Q.

Reviewer Comment (2020-02-05): XXXXX Transcripts uploaded as trailing docs

02/05/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209323051

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - K-1 Less 25%

Ability to Repay (Dodd-Frank 2014): Unable to verify K-1 (Less than 25% Ownership) income using reasonably reliable third-party records.

Once we receive signed XXXXX and XXXXX personal returns and/or transcripts this exception will cleared based on loan now meets Appendix Q.

Reviewer Comment (2020-02-05): XXXXX Transcripts uploaded as trailing docs

02/05/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209323051

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - K-1 Less 25%

Ability to Repay (Dodd-Frank 2014): Unable to verify K-1 (Less than 25% Ownership) income using reasonably reliable third-party records.

Once we receive signed XXXXX and XXXXX personal returns and/or transcripts this exception will cleared based on loan now meets Appendix Q.

Reviewer Comment (2020-02-05): XXXXX Transcripts uploaded as trailing docs

02/05/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209323051

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

NonQM ATR

Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.

The ATR is not satisfied due to missing tax return transcripts.

Reviewer Comment (2020-02-05): XXXXX Transcripts uploaded as trailing docs

02/05/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209323051

[Redact]

[Redact]

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 of safe harbor QM does not match ATR due to missing documentation for verification of income.

Reviewer Comment (2020-02-05): XXXXX Transcripts uploaded as trailing docs

02/05/2020

1

A

[Redact]

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

209323051

[Redact]

[Redact]

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 final lender credit of -$XXXXX is less than the binding lender credit of -$XXXXX.

Reviewer Comment (2020-02-20): XXXXX received required documents, exception is cured. Reviewer Comment (2020-02-06): When the loan was re-locked there was a total lender credit of $XXXXX. Final CD reflects a total of $XXXXX of lender credits and lender paid fees. Cure due to borrower. Seller Comment (2020-02-04): Borrower only paid $XXXXX - XXXXX paid the $XXXXX part of the Lender Credit - please clear condition.

02/20/2020

2

B

[Redact]

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

Safe Harbor QM

Safe Harbor QM

Yes

209323051

[Redact]

[Redact]

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.

Missing broker's initial disclosure.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209323052

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-02-07): 0% variance

02/07/2020

1

A

[Redact]

Primary

Purchase

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209323052

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 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.

Estimated Property Costs over Year 1 of XXXXX should be $XXXXX Taxes = XXXXX x 2 = XXXXX + Ins = $XXXXX = $XXXXX

Reviewer Comment (2020-02-11): XXXXX received a corrected CD and LOE. Seller Comment (2020-02-07): Please see attached PCCD.

02/11/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209323054

[Redact]

[Redact]

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 sent electronically prior to e-sign consent timing.

Reviewer Comment (2020-02-13): XXXXX received required documents, exception is cleared. Seller Comment (2020-02-11): Uploaded evidence of borrower e-sign consent

02/13/2020

1

A

[Redact]

Primary

Purchase

C

A

A

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209323054

[Redact]

[Redact]

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.

Binding LE disclosed total fees subject to 10% tolerance of $XXXXX plus 10% or $XXXXX and Final CD disclosed $XXXXX a difference of $XXXXX. Final CD disclosed a Lender Credit of $XXXXX for increase in Closing Costs above legal limit which is sufficient to cure 10% tolerance violation.

Reviewer Comment (2020-02-19): $XXXXX cure provided to borrower at closing Seller Comment (2020-02-13): Please provide clarity on cure amount

02/19/2020

1

A

[Redact]

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

209323054

[Redact]

[Redact]

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.

Binding LE disclosed a Lender Credit of $XXXXX and Final CD disclosed $XXXXX. Cure for 0% tolerance violation was not provided.

Reviewer Comment (2020-02-19): COC - rate lock Seller Comment (2020-02-13): The rate was not locked, market rate was used when LE was sent to the borrower

02/19/2020

1

A

[Redact]

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

209323054

[Redact]

[Redact]

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 10% or $XXXXX Sufficient or excess cure was provided to the borrower at Closing.

$XXXXX cure provided to borrower at closing

02/19/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

A

A

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209323058

[Redact]

[Redact]

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 amount of $XXXXX exceeds tolerance of $XXXXX. Sufficient or excess cure was provided to the borrower at closing.

01/29/2020

1

A

[Redact]

Second Home

Purchase

Final CD evidences Cure

A

A

A

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209323060

[Redact]

[Redact]

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.

A cure of $XXXXX was provided.

01/29/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

Final CD evidences Cure

A

A

A

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209323069

[Redact]

[Redact]

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 in the loan file as required for securitization.

Reviewer Comment (2020-02-07): 0% variance

02/07/2020

1

A

[Redact]

Primary

Purchase

C

B

A

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209323069

[Redact]

[Redact]

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 of appraisal sent date was prior to the signature date on the appraisal.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Purchase

C

B

A

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209323070

[Redact]

[Redact]

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 10% or $XXXXX. Sufficient or excess cure was provided to the borrower at Closing.

No cure, exceeded tolerance by $XXXXX

01/29/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Final CD evidences Cure

C

B

A

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209323070

[Redact]

[Redact]

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.

Missing a signed document at closing acknowledging their receipt of the valuation 3 days prior to closing.

Reviewer Comment (2020-02-06): Client elects to waive.

02/06/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209323070

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-02-07): 0% variance

02/07/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209323071

[Redact]

[Redact]

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.

Loan Estimate provided on XXXXX not received by borrower at least four (4) business days prior to closing.

Reviewer Comment (2020-02-10): XXXXX reviewed and upon further review find issue resolved at close no violation exists. Seller Comment (2020-02-08): The borrowers did a one time econsent on XXXXX and XXXXX. Please see attached Disclosure Tracking and econsent docs. Matthew did a one time econsent on XXXXX and Diana did a one time econsent on XXXXX. The Latest LE was sent out on XXXXX and borrowers viewed on XXXXX. Reviewer Comment (2020-02-05): Reviewed documentation submitted which reflects document sent and received XXXXX but there is no esign date listed. Provide a record of sending the Loan Estimate through another means such as XXXXXl in accordance with the official interpretation reflected in Comment 19(e)(1)(vi)-2. Seller Comment (2020-02-04): LE dated XXXXX was delivered and rec'd by the borrowers on XXXXX, Note is XXXXX. This is more than 4 days.

02/10/2020

1

A

[Redact]

Primary

Refinance - Limited Cash-out GSE

No Defined Cure

C

A

A

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209323073

[Redact]

[Redact]

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.

Binding LE disclosed Credit Report Fee of $XXXXX and Final CD disclosed $XXXXX. Final CD disclosed a Lender Credit of $XXXXX for increase in Closing Costs above legal limit which is sufficient to cure 0% tolerance violation.

01/29/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Final CD evidences Cure

A

A

A

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209324343

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-18): The client has accepted the collateral package

02/18/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209324343

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-02-21): Desk Review uploaded as trailing doc; -0- variance

02/21/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209324343

[Redact]

[Redact]

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.

Reviewer Comment (2020-02-21): Desk Review uploaded as trailing doc; -0- variance

02/21/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209324343

[Redact]

[Redact]

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 (2020-02-20): Client Elects to waive

02/20/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209324343

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Partnership Income Documentation Test

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Partnership).

Business started on XXXXX. Borrower provided unsigned XXXXX 1065, signed YTD P&L and balance sheet.

Reviewer Comment (2020-03-13): Received the signed business return for XXXXX. (Business started in XXXXX.) Reviewer Comment (2020-03-13): requires compliance review Reviewer Comment (2020-03-09): signed 1065 uploaded as trailing doc Seller Comment (2020-03-06): XXXXX XXXXX: Please clear and see attached

03/13/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209324343

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

S-Corp Income Documentation Test

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (S-Corp).

The personal and business tax returns were not signed and dated.

Reviewer Comment (2020-03-13): Received signed business returns Reviewer Comment (2020-03-13): requires compliance review Reviewer Comment (2020-03-09): uploaded as trailing docs Seller Comment (2020-03-06): XXXXX XXXXX: Please clear and see attached

03/13/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209324343

[Redact]

[Redact]

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.

File contains unsigned personal and business returns however we have XXXXX and XXXXX transcripts.

Reviewer Comment (2020-02-20): Client Elects to waive

02/20/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209324343

[Redact]

[Redact]

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.

Business started in XXXXX and were including loss in DTI, once we received required income docs this exception will clear based on loan now meets Appendix Q.

Reviewer Comment (2020-03-13): SHQM Loan Seller Comment (2020-03-13): XXXXX Attached is the signed and dated page for this business, please clear, thank you Reviewer Comment (2020-03-09): Third party verification (CPA letter, business license, etc.) are required per Appendix Q Seller Comment (2020-03-06): XXXXX XXXXX: XXXXX guidelines state authorized user accounts do not need to be included into ratios. Seller Comment (2020-03-06): XXXXX XXXXX: Please clear and see attached

03/13/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209324343

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

NonQM ATR

Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.

The personal and business tax returns were not signed and dated.

Reviewer Comment (2020-03-13): SHQM Loan

03/13/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209324343

[Redact]

[Redact]

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.

The personal and business tax returns were not signed and dated.

Reviewer Comment (2020-03-13): SHQM Loan Reviewer Comment (2020-03-13): requires compliance review Reviewer Comment (2020-03-09): uploaded as trailing docs Seller Comment (2020-03-06): XXXXX XXXXX: Please clear and see attached

03/13/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209324501

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-21): Client has accepted the collateral package

02/21/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209324501

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-02-20): Secondary product provided to support origination value.

02/20/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209324501

[Redact]

[Redact]

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.

02/14/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209324501

[Redact]

[Redact]

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).

Disclosure does not reflect Lender Contact and Contact NMLS ID.

Reviewer Comment (2020-02-20): Client Elects to waive

02/20/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209345940

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-18): The client has accepted the collateral package

02/18/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209345940

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-24): Secondary product provided to support origination value.

02/24/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209345940

[Redact]

[Redact]

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 provided XXXXX & XXXXX personal tax returns with Schedule C included.

Reviewer Comment (2020-02-20): Client elects to waive

02/20/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209345940

[Redact]

[Redact]

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 person was not provided on CD.

Reviewer Comment (2020-02-20): Client Elects to waive

02/20/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209345999

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-11): The client has accepted the final collateral package

02/11/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209345999

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-02-06): exception cleared

02/06/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209345999

[Redact]

[Redact]

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 statement is missing the lenders contact name and NMLS id number.

Reviewer Comment (2020-02-06): Client elects to waive

02/06/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209345999

[Redact]

[Redact]

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Missing Replacement Cost Estimator to determine Lender's Value.

Reviewer Comment (2020-02-22): Replacement Cost Estimate uploaded as trailing doc

02/22/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209357919

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-27): Client has accepted the collateral package

02/27/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209357919

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-25): XXXXX provided to support original value

02/25/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209357919

[Redact]

[Redact]

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 Initial Loan Estimate is dated XXXXX, however is not signed electronically until XXXXX, the Application Date is XXXXX.

Reviewer Comment (2020-03-03): XXXXX reviewed and upon further review find issue resolved at close no violation exists. Received proof document was mailed.

03/03/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209357919

[Redact]

[Redact]

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. The H-8 form was used, the H-9 form should have been used. (The property state is in the 1st, 4th, 6th, or 11th circuit.)

The Refinance transaction is with the same Lender as the previous note, the Right To Cancel form provided is an H-8, not the H-9 which is required.

02/24/2020

2

A

[Redact]

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

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209359215

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-27): Client has accepted the collateral package

02/27/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209359215

[Redact]

[Redact]

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.

Loan amount and points increased but a valid change circumstance is missing.

Reviewer Comment (2020-03-19): XXXXX received required documents, exception is cured.

03/19/2020

2

B

[Redact]

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

209359215

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Investor Review Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

Change circumstance for increase to investor review fee is missing.

Reviewer Comment (2020-03-09): COC - Additional Information - Loan program / Investor changed when loan was locked - fee updated Reviewer Comment (2020-03-03): Unable to determine why investor review fee increased on revised loan estimate based on documents provided - Additional details required or cure due to borrower.

03/09/2020

1

A

[Redact]

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

209359215

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-25): XXXXX provided to support original value

02/25/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209359215

[Redact]

[Redact]

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.

XXXXX received required documents, exception is cured.

Reviewer Comment (2020-03-19): XXXXX received required documents, exception is cured.

03/19/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209359607

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-24): Client has accepted the collateral package Seller Comment (2020-01-24): XXXXX Tracking Number XXXXX delivered on XXXXX

01/24/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209359607

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-27): Secondary product provided supporting original value

01/27/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209359607

[Redact]

[Redact]

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.

Right to Cancel is on Form H-8 however, subject loan is paying off an existing XXXXX loan. Right to Cancel should be on Form H-9.

Reviewer Comment (2020-03-10): Rescission expired. Exception cured. Reviewer Comment (2020-03-05): Able to clear the incorrect form on XXXXX after the three days Seller Comment (2020-03-05): XXXXX Uploaded updated signed H9 Form. Seller Comment (2020-03-04): XXXXX Uploaded signed H9 Form Reviewer Comment (2020-03-03): Please re-open rescission with the correct form date needs to match the date delivered as the open date and the expiration needs to be after midnight on the third date Seller Comment (2020-02-28): XXXXX Uploaded email sent showing proof of delivery. Reviewer Comment (2020-02-18): Provided was the old RTC form, a Letter of explanation and a fax cover sheet which are insufficient to cure. The borrower must be provided the new and correct form, and evidence of delivery with a date to track either XXXXX or XXXXX as the fax cover sheet does not list a date nor evidence of the esign delivery and receipt. Please send to the borrower the correct RTC form and evidence of delivery. Thank you Seller Comment (2020-02-13): XXXXX Uploaded LOX Reviewer Comment (2020-02-11): Letter of Explanation to the borrower, Proof of Delivery, and Re-open Rescission using the correct model form. Once borrower received the corrected form and after the rescission period ends we will be able to cure the exception Seller Comment (2020-02-09): XXXXX Hello, just a letter of explanation and we are able to proceed with form H8 or complete what was outlined below w/ a letter of explanation. Thx for the clarification Reviewer Comment (2020-02-07): In order to cure we would need a Letter of Explanation to the borrower, Proof of Delivery, and Re-open Rescission using the correct model form. Once borrower received the corrected form and after the rescission period ends we will be able to cure the exception. Seller Comment (2020-02-07): XXXXX Hello, this was done on the H8 form, if we send each consumer the Closing Disclosure and two copies of the H-9 notice, provides the three business day rescission period and the loan is not rescinded will satisfy the condition? Please advise. Reviewer Comment (2020-02-06): The H-8 form was used, the H-9 form should have been use. Exception remains. Seller Comment (2020-02-04): XXXXX Hello, I am not following your request, can you please advise which form you feel this should be on? Thx Reviewer Comment (2020-01-31): Provided was the RTC on the incorrect form, per the title the original lender and the current lender, XXXXX, are the same making the RTC form an H9. Rescission needs to be re-opened with the correct form, LOE to the borrower and evidence of mailing. Seller Comment (2020-01-30): XXXXX Hello, yes we understand and the Right to Cancel was provided. We have attached a copy of the disclosure for review. Thx Reviewer Comment (2020-01-30): Borrower is paying off an auto installment loan. Loan is subject recession. Seller Comment (2020-01-30): XXXXX Hello, the original transaction was closed by us as the lender however we paid off XXXXX and XXXXX respectively so a form H8 would be acceptable in this scenario as they were the note holders and servicers. Please advise. Buyer Comment (2020-01-28): **Seller to fulfill

03/10/2020

2

B

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209359607

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 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 Closing Disclosure disclosed Total Property Costs Year 1 of $XXXXX; calculated Total Property Costs Year 1 is $XXXXX. Difference is due to property taxes reflects an annual premium of $XXXXX or $XXXXX per month however, Final Closing Disclosure disclosed the annual premium as $XXXXX or $XXXXX per month.

Reviewer Comment (2020-02-19): Letter of Explanation & Corrected Closing Disclosure provided Seller Comment (2020-02-13): XXXXX Uploaded PCCD. This is the closest we can get to is the 0.60. If we rounded it up then we're surpassing the amount requested. Reviewer Comment (2020-02-11): XXXXX received PCCD. The allowable tolerance for the escrow account fields on page four of the CD is $0.02 per month of property costs or $0.24 for 12 months. Total disclosed on page four of CD is $XXXXX and documentation in images indicates total should be $XXXXX or $XXXXX ($XXXXX HOI, $XXXXX Taxes, $XXXXX HOA dues) Please provide verification if using an updated amount. Letter of Explanation and Corrected CD required to cure. Seller Comment (2020-02-07): XXXXX PCCD Attached

02/19/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209359624

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Pending Internal Customer Final Collateral Package Review.

Reviewer Comment (2020-01-24): Client has accepted the collateral package Seller Comment (2020-01-24): XXXXX Tracking Number XXXXX, delivered on XXXXX

01/24/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209359624

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-29): Secondary product provided supporting origination value

01/29/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209359624

[Redact]

[Redact]

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 (2020-01-29): Secondary product provided supporting origination value

01/29/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209359629

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-24): Client has accepted the collateral package Seller Comment (2020-01-24): XXXXX Tracking Number XXXXX delivered on XXXXX

01/24/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209359629

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-01-29): Secondary product provided supporting origination value

01/29/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209359629

[Redact]

[Redact]

Property

Property - Appraisal

Appraisal Documentation

Loan is to go into a securitization and secondary valuation is required. The secondary valuation in file is an invalid AVM (FSD is not 20% or less). Loan will require a supporting desk review or better.

There's no secondary valuation as required for securitization.

Reviewer Comment (2020-01-29): Secondary product provided supporting origination value

01/29/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209359630

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-01-31): Exception cleared Buyer Comment (2020-01-30): XXXXX XXXXX-please clear this condition. thanks Seller Comment (2020-01-30): XXXXX Original collateral delivered on XXXXX via XXXXX. Tracking # XXXXX

01/31/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209359630

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-03): Secondary product provided to support origination value.

02/03/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209360456

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-11): The client has accepted the final collateral package

02/11/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209360456

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-02-07): Secondary product provided to support origination value.

02/07/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209360456

[Redact]

[Redact]

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 (2020-02-06): Client elects to waive

02/06/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209360456

[Redact]

[Redact]

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.

A cure of $XXXXX was provided at closing.

02/03/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

Final CD evidences Cure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209360456

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

S-Corp Income Documentation Test

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (S-Corp).

The business tax returns were not signed and dated and/or missing XXXXX and XXXXX transcript in lieu of signed business returns.

Reviewer Comment (2020-03-10): Provided Seller Comment (2020-03-10): XXXXX Verification of business not needed when business is generating a loss, please rescind Reviewer Comment (2020-03-09): 1120s not signed by Borrower and missing reliable 3rd party verification (CPA letter, business license, etc.) as required per Appendix Q Seller Comment (2020-03-06): XXXXX XXXXX: Please clear and see attached.

03/10/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209360456

[Redact]

[Redact]

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.

Once we receive signed business returns this exception will clear based on loan now meets Appendix Q.

Reviewer Comment (2020-03-13): SHQM Loan Seller Comment (2020-03-13): XXXXX Please clear, see attached, thank you Reviewer Comment (2020-03-11): 3rd party verification (CPA letter, business license, etc.) for all businesses is required per Appendix Q or provide 2-3 compensating factors for review by Client. Seller Comment (2020-03-10): XXXXX Verification of business not needed when business is generating a loss, please clear Seller Comment (2020-03-10): XXXXX Please rescind and see page 767 and page 780 showing acceptable VOB and verifier information Reviewer Comment (2020-03-09): Missing reliable 3rd party verification (CPA letter, business license, etc.) as required per Appendix Q Seller Comment (2020-03-06): XXXXX XXXXX: Please clear and see attached.

03/13/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209360456

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Employment - S-Corp Test

Ability-to-Repay (Dodd-Frank 2014): Unable to verify current S-Corp status using reasonably reliable third-party records.

Once we receive signed business returns this exception will clear based on loan now meets Appendix Q.

Reviewer Comment (2020-03-13): SHQM Loan Seller Comment (2020-03-13): XXXXX Please clear, see attached, thank you Reviewer Comment (2020-03-11): 3rd party verification (CPA letter, business license, etc.) for all businesses is required per Appendix Q or provide 2-3 compensating factors for review by Client. Seller Comment (2020-03-10): XXXXX Verification of business not needed when business is generating a loss, please rescind Reviewer Comment (2020-03-09): 1120s not signed by Borrower; missing reliable 3rd party verification (CPA letter, business license, etc.) as required per Appendix Q Seller Comment (2020-03-06): XXXXX XXXXX: Please clear and see attached.

03/13/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209360456

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

NonQM ATR

Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.

The tax returns were not signed and dated.

Reviewer Comment (2020-03-13): SHQM Loan

03/13/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209360456

[Redact]

[Redact]

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 missing required income docs.

Reviewer Comment (2020-03-13): SHQM Loan Reviewer Comment (2020-03-11): 3rd party verification (CPA letter, business license, etc.) for all businesses is required per Appendix Q or provide 2-3 compensating factors for review by Client. Seller Comment (2020-03-10): XXXXX Please rescind and see page 767 and page 780 showing acceptable VOB and verifier information Reviewer Comment (2020-03-09): Missing reliable 3rd party verification (CPA letter, business license, etc.) for all businesses as required per Appendix Q Seller Comment (2020-03-06): XXXXX XXXXX: Please clear and see attached.

03/13/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

Lender to provide updated ATR/QM status

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209360457

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-21): Client has accepted the collateral package

02/21/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209360457

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-02-24): Secondary product provided to support origination value.

02/24/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209360457

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-02-24): Secondary product provided to support origination value.

02/24/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209360457

[Redact]

[Redact]

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 10% or $XXXXX. Sufficient or excess cure was provided to the borrower at Closing.

02/14/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209360457

[Redact]

[Redact]

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 Third party verification for XXXXX/S-Corp.

Reviewer Comment (2020-02-20): Client elects to waive

02/20/2020

2

B

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209360457

[Redact]

[Redact]

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.

File is missing third party verification of self employment for XXXXX/S-Corp

Reviewer Comment (2020-02-20): Client elects to waive

02/20/2020

2

B

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209360457

[Redact]

[Redact]

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 Lender's Contact Name and NMLS ID.

Reviewer Comment (2020-02-20): Client Elects to waive

02/20/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209360535

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-21): Client has accepted the collateral package

02/21/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209360535

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-02-24): Secondary product provided to support origination value.

02/24/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209360535

[Redact]

[Redact]

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Missing replacement cost estimator to determine the lender's value or evidence of the preferred protection plan percentage of coverage.

Reviewer Comment (2020-03-05): RCE uploaded as a trailing doc Seller Comment (2020-03-04): XXXXX XXXXX Please see attached.

03/05/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209360535

[Redact]

[Redact]

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 information was not provided.

Reviewer Comment (2020-02-20): Client elects to waive

02/20/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209361210

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-21): Client has accepted the collateral package

02/21/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209361210

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-02-26): Secondary product provided to support origination value.

02/26/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209361210

[Redact]

[Redact]

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 information was not provided.

Reviewer Comment (2020-02-20): Client Elects to waive

02/20/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209361210

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Federal Loan Originator Compensation - Individual LO Not NMLS Licensed at Time of Application

Truth in Lending Act (NMLSR Dodd- Frank 2014): Individual Loan Originator not NMLS licensed or registered at time of application.

Application is dated XXXXX and the license was active XXXXX.

Reviewer Comment (2020-03-05): Trailing uploaded NMLS licensure reflects originatl issue date as XXXXX and Voluntary Surrender XXXXX. Valid at time of application. Seller Comment (2020-03-04): Hello Team, Please clear this condition. The loan officer did not have a lapse in licensing. He was with XXXXX and is still with XXXXX. Please see the screen grabs from the attached license to approve the condition. Please see attachment. Reviewer Comment (2020-02-26): The Loan officer was employed by the lender with a start date of XXXXX however the license issued to conduct mortgage was issued on XXXXX which is after the application dated XXXXX. Was there another licence in which the application was taken then taken over by the loan officer XXXXX? Per XXXXX Seller Comment (2020-02-26): Please see attachment from our Compliance Team. the attached document shows LO was licensed XXXXX. LO received updated approval was XXXXX. Reviewer Comment (2020-02-19): The uploaded NMLS datat shows Loan Officer history with XXXXX as startingXXXXX and ending XXXXX, which is prior to the closing date of the subject transaction Seller Comment (2020-02-18): Please see attachment

03/05/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209361844

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-05): Client verified tracking on collateral. Exception cleared

02/05/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209361844

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-06): exception cleared

02/06/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209361844

[Redact]

[Redact]

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 name was not provided for lender.

Reviewer Comment (2020-02-06): Client elects to waive

02/06/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209361844

[Redact]

[Redact]

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.

Cure for transfer tax provided at closing.

02/03/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209361844

[Redact]

[Redact]

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Coverage is insufficient. Replacement cost estimator not located.

Reviewer Comment (2020-03-04): Per the policy it is stated the coverage is based on the cost to replace obtained by the Insurer within the policy

03/04/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209361844

[Redact]

[Redact]

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 required.

Reviewer Comment (2020-02-06): exception cleared

02/06/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209362811

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-26): Client has accepted the collateral package

02/26/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209362811

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-02): Secondary product provided to support origination value.

03/02/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209362811

[Redact]

[Redact]

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 does not indicate Lender contact information.

Reviewer Comment (2020-02-26): Client has elected to accept and waive

02/26/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209367181

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-02): The lender has accepted the collateral package

03/02/2020

1

A

[Redact]

Second Home

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209367181

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-28): 0% variance

02/28/2020

1

A

[Redact]

Second Home

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209367222

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-27): Client has accepted the collateral package

02/27/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209367222

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Sole Proprietorship Income Documentation Test

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Sole Proprietorship).

P&L was not provided.

Reviewer Comment (2020-03-03): The lender provided evidence the schedule C minor loss actually was dissolved and no further data is required

03/03/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209367222

[Redact]

[Redact]

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.

LE issued on XXXXX was electronically received on XXXXX which is not within 3 business day of application date of XXXXX.

Reviewer Comment (2020-03-03): XXXXX reviewed and upon further review find issue resolved at close no violation exists. Received proof of review date XXXXX.

03/03/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209367222

[Redact]

[Redact]

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.

Originator Loan Designation discrepancy is due to Appendix Q Overall Fail. P&L for borrower's Schedule C income was not provided.

Reviewer Comment (2020-03-03): The lender provided evidence the schedule C minor loss actually was dissolved and no further data is required Reviewer Comment (2020-03-03): Provided was the business license but this was reviewed at initial, the images are missing the YTD P&L and Balance sheet

03/03/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209367222

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-25): XXXXX provided to support original value

02/25/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209367229

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-05): Client has accepted the collateral package

03/05/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209367229

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-28): 0% variance

02/28/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209367229

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-02-28): 0% variance

02/28/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209369517

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-18): The client has accepted the collateral package

02/18/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209369517

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-02-14): Secondary product provided to support origination value.

02/14/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209369517

[Redact]

[Redact]

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).

Disclosure does not reflect Lender Contact and Contact NMLS ID.

Reviewer Comment (2020-02-20): Client Elects to waive

02/20/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209369517

[Redact]

[Redact]

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 is not signed and dated; calculated received date is XXXXX; Closing date is XXXXX.

Reviewer Comment (2020-02-24): Disclosure tracking provided Reviewer Comment (2020-02-20): History disclosure not located in the loan file. Please re-upload for review. Seller Comment (2020-02-17): History Disclosure provided shows the borrower received XXXXX CD provided in loan file. Please rescind condition.

02/24/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

No Defined Cure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209369517

[Redact]

[Redact]

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.

Credit report fee disclosed as $XXXXX on the LE dated XXXXX; but disclosed as $XXXXX on the Final Closing Disclosure. Cure was provided.

02/10/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Final CD evidences Cure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209369519

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-04): Client has accepted the collateral package

03/04/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209369519

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-03): Secondary product provided to support origination value.

03/03/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209369519

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-03-03): Secondary product provided to support origination value.

03/03/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209369519

[Redact]

[Redact]

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).

Provide required lender Contact Name & NMLS ID

Reviewer Comment (2020-03-03): Client has accepted to waive

03/03/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209377823

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-26): Client has accepted the collateral package

02/26/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209377823

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-02): Secondary product provided to support origination value.

03/02/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209377823

[Redact]

[Redact]

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 (2020-03-02): Secondary product provided to support origination value.

03/02/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209377823

[Redact]

[Redact]

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).

Provide required Lender Contact Name & Lender NMLS ID

Reviewer Comment (2020-02-26): Client has elected to accept and waive

02/26/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209377823

[Redact]

[Redact]

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 not consistant on all documments

Reviewer Comment (2020-03-18): XXXXX received required documents, exception is cleared. Seller Comment (2020-03-17): "Disagree - It appears that there were two lock actions on XXXXX - initial lock and a lock update, two lock confirmations provided. It looks like the difference between the two is the lock update has a XXXXX adjustment of XXXXX% which increased the lender credit from $XXXXX to $XXXXX. The initial XXXXX locked LE shows the higher credit of $XXXXX, rounded to $XXXXX. There were only two changes to the lender credit - XXXXX for a refi purpose change COC which decreased the credit to $XXXXX & XXXXX appraised value change which decreased the lender credit to that on the final CD of $XXXXX. Please see attached the lock confirmations from XXXXX included in the file (lock update page 835) and the initial lock from XXXXX included in the file, page 832 and the inital LE from XXXXX inluded in the file pages 726 - 728. The lock confirmation from XXXXX included in the file page 805 and the redisclosed LE to the borrower from XXXXX included in the file pages 742 - 744. and the screenshot showing the coc completed to change the purpose of refi on XXXXX (see attached). Lastly, please see the lock confirmation from XXXXX included in the file pages 761, the change of circumstance from XXXXX included in the file pages 751 - 753 and the redisclosed CD to the borrower from XXXXX included in the file pages 945-961. Please clear this condition " Reviewer Comment (2020-03-13): The pricing was changed on XXXXX, at which time the loan was locked and the final price became $XXXXX. A COC is in the file; however, there is no corresponding CD. Seller Comment (2020-03-12): The appraised value came in significantly lower ( COC XXXXX included in the file, pages 751 - 753) which affected the pricing. Please see attached the redisclosed CD on XXXXX to the borrower Iincluded in the file, pages 945 - 959. Attached is the said documents. Please rescind condition. Reviewer Comment (2020-03-10): The lender credit of $XXXXX was given on the initial LE XXXXX, prior to the loan being locked; $XXXXX in lender compensation. Lender credit only $XXXXX on the final CD and although it is the same as the final price on the XXXXX (XXXXX), no revised CD was issued at that time.

03/18/2020

1

A

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209377863

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-28): exception cleared

02/28/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209377863

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-02): Secondary product provided to support origination value.

03/02/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209377863

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Received one appraisal for review.

Reviewer Comment (2020-03-02): Secondary product provided to support origination value.

03/02/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209377863

[Redact]

[Redact]

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 for appraisal fee provided at closing.

02/26/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Final CD evidences Cure

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209453805

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-28): exception cleared

02/28/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209453805

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-27): Secondary product provided to support origination value.

02/27/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209453805

[Redact]

[Redact]

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 (2020-02-28): Client elects to waive

02/28/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209457677

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-17): exception cleared

03/17/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209457677

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-15): XXXXX uploaded as trailing doc; -6% variance

03/15/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209457677

[Redact]

[Redact]

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Per the appraisal the cost to replace is $XXXXX. The HOI with extended coverage is $XXXXX. The file is missing either a cost to replace estimate or a letter from the insurer regarding the maximum allowed coverage

Reviewer Comment (2020-03-13): RCE uploaded as a trailing doc

03/13/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209457677

[Redact]

[Redact]

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).

Provide required Lender Contact Name & NMLS ID

Reviewer Comment (2020-03-13): Client has waived exceptions

03/13/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209457677

[Redact]

[Redact]

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 not consistant

Reviewer Comment (2020-03-13): XXXXX received required documents, exception is cleared. Seller Comment (2020-03-12): XXXXX XXXXX The borrower requested to change the loan amount (COC XXXXX included in the file, pages 360 - 371) which affected pricing. Please see the re disclosed LE to the borrower on XXXXX included in the file, pages 305 - 307. Please clear this condition

03/13/2020

1

A

[Redact]

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

209458001

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-18): The client has accepted the collateral package

02/18/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209458001

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-20): Secondary product provided to support origination value.

02/20/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209458001

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

No secondary appraisal report was provided. The collateral score is a XXXXX.

Reviewer Comment (2020-02-20): Secondary product provided to support origination value.

02/20/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209458001

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan). Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

Tax Service Fee was disclosed on the initial LE in the amount of $XXXXX but on the final CD reads $XXXXX. It appears the borrower was not notified of this increased fee after initial LE was disclosed. Missing valid change in circumstance. To cure, provided corrected PC CD along with LOE to borrower and evidence of delivery.

Reviewer Comment (2020-02-21): XXXXX reviewed and upon further review find issue resolved at close no violation exists.

02/21/2020

1

A

[Redact]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209459267

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-04): Client has accepted the collateral package

03/04/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209459267

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-03-03): Secondary product provided to support origination value.

03/03/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209459267

[Redact]

[Redact]

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 information was not provided.

Reviewer Comment (2020-03-03): Client has accepted to waive

03/03/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209462485

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-26): Client has accepted the collateral package

02/26/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209462485

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-02-26): Secondary product provided to support origination value.

02/26/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209462485

[Redact]

[Redact]

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 the Lender's Contact Name and NMLS ID number.

Reviewer Comment (2020-02-26): Client has elected to accept and waive

02/26/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209462485

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-02-26): Secondary product provided to support origination value.

02/26/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209462486

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-04-01): Client has accepted the collateral package

04/01/2020

1

A

[Redact]

Second Home

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209462486

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-04-02): Secondary product provided to support origination value.

04/02/2020

1

A

[Redact]

Second Home

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209462486

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Acknowledgement of Borrower Receipt of Notice of Special Flood Hazard Disclosure Missing

FDPA Notification Rule: Creditor did not retain record of borrower's receipt of Notice of Special Flood Hazard Disclosure.

Lender to provide Notice of Special Flood hazards disclosure that is signed by borrower.

Reviewer Comment (2020-03-31): Client elects to Waive

03/31/2020

2

B

[Redact]

Second Home

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209463226

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-13): The client has accepted the collateral package

03/13/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209463226

[Redact]

[Redact]

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.

3 years tax return to support capital gains/losses were not provided.

Reviewer Comment (2020-03-05): XXXXX returns indicate a long term loss and XXXXXindicate a short term loss, indicating these were one time occurrences.

03/05/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209463226

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Commission Pay Stubs

Qualified Mortgage (Dodd-Frank 2014): Copies of signed tax returns for last two (2) years or most recent pay stub not provided for Commission income.

Copies of signed tax tax returns for most recent 2 years, 2 paystubs and income verification through XXXXX was provided.

Reviewer Comment (2020-03-05): The most recent paystubs prior to the application date were provided and the VOE breaks out the XXXXX and XXXXX comission income

03/05/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209463226

[Redact]

[Redact]

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 (2020-03-05): SHQM Loan

03/05/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209463226

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

NonQM ATR

Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.

Third party verification for XXXXX was not provided.

Reviewer Comment (2020-03-05): SHQM Loan

03/05/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209463226

[Redact]

[Redact]

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.

Originator Loan Designation discrepancy is due to employment status verification fail.

Reviewer Comment (2020-03-05): SHQM Loan

03/05/2020

1

A

[Redact]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

B

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209475516

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-26): Client has accepted the collateral package

02/26/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209475516

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-02-26): Secondary product provided to support origination value.

02/26/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209475516

[Redact]

[Redact]

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Approval or Underwriting Transmittal Summary are not provided.

Reviewer Comment (2020-02-28): exception cleared

02/28/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209475516

[Redact]

[Redact]

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's Contact Name and NMLS ID.

Reviewer Comment (2020-02-26): Client has elected to accept and waive

02/26/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209475517

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-18): The client has accepted the collateral package

02/18/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209475517

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-02-20): Secondary product provided to support origination value.

02/20/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209475517

[Redact]

[Redact]

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's Contact Name and NMLS ID.

Reviewer Comment (2020-02-20): Client Elects to waive

02/20/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209475554

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-13): The client has accepted the collateral package

03/13/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209475554

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 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 amount of estimated property costs over year 1 should have been listed as $XXXXX based on the verified property tax and hazard insurance.

Reviewer Comment (2020-03-12): Letter of Explanation & Corrected Closing Disclosure provided

03/12/2020

2

B

[Redact]

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

209475554

[Redact]

[Redact]

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Insufficient reserves verified. The images contain evidence of other funds with XXXXX however the Account Check is dated XXXXX

Reviewer Comment (2020-03-12): Per lender attestation the additional reserves for retained property is based on the PITIA of the property and not the subject. The total required reserves are $XXXXX

03/12/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209475554

[Redact]

[Redact]

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.

A payoff statement was not provided.

Reviewer Comment (2020-03-26): Uploaded as trailing doc; no PPP reflected Reviewer Comment (2020-03-12): Pending review Buyer Comment (2020-03-05): **Seller to fulfill

03/26/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209475578

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-04-01): Client has accepted the collateral package

04/01/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209475578

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending secondary Valuation as required for securitization.

Reviewer Comment (2020-04-01): Secondary product provided to support origination value.

04/01/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209475578

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Pending secondary Valuation as required for securitization.

Reviewer Comment (2020-04-01): Secondary product provided to support origination value.

04/01/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209475578

[Redact]

[Redact]

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.

Reviewer Comment (2020-04-02): COC - re-lock and rate extended - original rate lock expired Seller Comment (2020-04-01): XXXXX Please see the lock action on XXXXX and the loan estimate e-signed by the borrower

04/02/2020

1

A

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209475578

[Redact]

[Redact]

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).

Disclosure does not reflect Lender Contact and Contact NMLS ID.

Reviewer Comment (2020-03-31): Client elects to Waive

03/31/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209485756

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-27): Client has accepted collateral package.

03/27/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209485756

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-04-01): Secondary product provided to support origination value.

04/01/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209485756

[Redact]

[Redact]

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's Contact Name and NMLS ID.

Reviewer Comment (2020-03-27): Client elects to waive

03/27/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209485756

[Redact]

[Redact]

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.

Originator Loan Designation discrepancy is due to Points and Fees Fail.

Reviewer Comment (2020-04-01): Bona Fide rate provided Seller Comment (2020-03-30): QM worksheet included in the file shows that all of the discount points are considered bona fide and thus can be excluded from the QM points & fees.

04/01/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209485756

[Redact]

[Redact]

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 3.00000% 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%).

Points and Fees on subject loan of XXXXX% exceeds the allowable maximum of 3.00000%

Reviewer Comment (2020-04-01): Bona Fide rate provided Seller Comment (2020-03-30): QM worksheet included in the file shows that all of the discount points are considered bona fide and thus can be excluded from the QM points & fees. Please rescind condition.

04/01/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

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

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209485756

[Redact]

[Redact]

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 $XXXXXexceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

Binding LE disclosed Loan Discount Points of $XXXXX and Final CD disclosed $XXXXX. Cure for 0% tolerance violation was not provided.

Reviewer Comment (2020-03-31): XXXXX received XXXXX Closing Disclosure and Changed Circumstance.

03/31/2020

1

A

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209485756

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Reinspection Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower.

Binding LE did not disclose Reinspection Fee of $XXXXX disclosed on Final CD. Final CD disclosed a Lender Credit of $XXXXX for increase in Closing Costs above legal limit which is sufficient to cure 0% tolerance violation.

Reviewer Comment (2020-03-31): Sufficient cure shown on final Closing Disclosure. Seller Comment (2020-03-30): A tolerance credit of $XXXXX was given for this at closing. Please rescind condition.

03/31/2020

1

A

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209485756

[Redact]

[Redact]

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 Reinspection Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Sufficient or excess cure was provided to the borrower at Closing.

Sufficient cure shown on final Closing Disclosure.

Reviewer Comment (2020-03-31): Sufficient Cure Provided At Closing

03/31/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Final CD evidences Cure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209485759

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-19): Client has accepted package.

03/19/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209485759

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-03-19): XXXXX uploaded as a trailing doc; -0- variance

03/19/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209485759

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-03-19): XXXXX uploaded as a trailing doc; -0- variance

03/19/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209485759

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Acknowledgement of Borrower Receipt of Notice of Special Flood Hazard Disclosure Missing

FDPA Notification Rule: Creditor did not retain record of borrower's receipt of Notice of Special Flood Hazard Disclosure.

Disclosure not signed.

Reviewer Comment (2020-03-17): Client elects to waive.

03/17/2020

2

B

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209485759

[Redact]

[Redact]

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 for lender/XXXXX was not provided on CD's.

Reviewer Comment (2020-03-17): Client elects to waive.

03/17/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209485759

[Redact]

[Redact]

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.

Binding LE disclosed a Lender Credit of $XXXXX and Final CD disclosed $XXXXX. Cure for 0% tolerance violation was not provided. Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

Reviewer Comment (2020-03-25): XXXXX received required documents, exception is cured. Seller Comment (2020-03-24): please see attached

03/25/2020

2

B

[Redact]

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

209486942

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-11): The client has accepted the collateral package

03/11/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209486942

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-03-05): Secondary product provided to support origination value.

03/05/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209486942

[Redact]

[Redact]

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 the Lender's Contact Name and NMLS ID number.

Reviewer Comment (2020-03-10): Client has elected to waive

03/10/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209486944

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-27): Client has accepted collateral package.

03/27/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209486944

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-31): XXXXX uploaded as a trailing doc; -0- variance

03/31/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209486944

[Redact]

[Redact]

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 10% or $XXXXX. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2020-03-25): Sufficient Cure Provided At Closing

03/25/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209503315

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-05): Client has accepted the collateral package

03/05/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209503315

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-04): Seller provided third party source to verify value

03/04/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209510754

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-04): Client has accepted the collateral package

03/04/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209510754

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-03-04): Secondary product provided to support origination value.

03/04/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209510754

[Redact]

[Redact]

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 3 days prior to closing.

Reviewer Comment (2020-03-03): Client has accepted to waive

03/03/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209510754

[Redact]

[Redact]

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 information was not provided.

Reviewer Comment (2020-03-03): Client has accepted to waive

03/03/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209510757

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-04): Client has accepted the collateral package

03/04/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209510757

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-03-04): Secondary product provided to support origination value.

03/04/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209510757

[Redact]

[Redact]

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).

Disclosure does not reflect Lender Contact and Contact NMLS ID.

Reviewer Comment (2020-03-03): Client has accepted to waive

03/03/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209510757

[Redact]

[Redact]

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.

Credit report fee disclosed as $XXXXX on the LE dated XXXXX; but disclosed as $XXXXX on the Final Closing Disclosure. Cure of $XXXXX was provided but insufficient for a cure required of $XXXXX. There is no valid COC showing the credit report fee increased from $XXXXX to $XXXXX on XXXXX

Reviewer Comment (2020-03-13): $XXXXX cure provided at closing (lender provided credit report fee which was $XXXXX lender rounded down to $XXXXX. .25 cents adjusted for rounded amount) Seller Comment (2020-03-12): XXXXX XXXXX Please see attached. Please clear condition. Reviewer Comment (2020-03-06): Cure remains short by $XXXXX. PCCD, LOE, and copy of refund check required to cure. Seller Comment (2020-03-06): XXXXX XXXXX Please see attached.

03/13/2020

1

A

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209510757

[Redact]

[Redact]

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.

Title Commitment reflects transaction is Lender to Lender; Form H-8 was used. Form H-9 should have been. Per the PCCD there were two principle reductions however the borrower received funds of $XXXXX at closing

Reviewer Comment (2020-03-13): Corrected RTC, letter and mailing label provided; confired delivery on XXXXX Reviewer Comment (2020-03-06): Form received, and exception can be cleared on XXXXX. Seller Comment (2020-03-06): XXXXX XXXXX Please see attached. Buyer Comment (2020-03-02): **Seller to fulfill

03/13/2020

2

B

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209510757

[Redact]

[Redact]

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.

$XXXXX cure provided at closing (lender provided credit report fee which was $XXXXX lender rounded down to $XXXXX. .25 cents adjusted for rounded amount)

Reviewer Comment (2020-03-13): Sufficient Cure Provided At Closing

03/13/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Final CD evidences Cure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209510759

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-04): Client has accepted the collateral package

03/04/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209510759

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-03-04): Secondary product provided to support origination value.

03/04/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209541151

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-26): Client has accepted the collateral package

02/26/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209541151

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-27): Secondary product provided to support origination value.

02/27/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209541151

[Redact]

[Redact]

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Hazard insurance coverage amount is insufficient reflecting a $XXXXX shortfall, please provide either a replacement cost estimator confirming the insurable value, a letter from the insurer stating maximum coverage allowance or evidence of the extended coverage percentage per the HOI

Reviewer Comment (2020-03-04): RCE uploaded as a trailing doc Seller Comment (2020-03-04): Please see attachment

03/04/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209541151

[Redact]

[Redact]

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 provided on XXXXX did not disclose the required lender contact information.

Reviewer Comment (2020-02-26): Client has elected to accept and waive

02/26/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209541151

[Redact]

[Redact]

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 on the Loan Estimate dated XXXXX.

Reviewer Comment (2020-03-02): XXXXX received required documents, exception is cleared. Seller Comment (2020-03-02): Please see attachment Seller Comment (2020-02-27): On XXXXX the borrower requested to lower the loan amount (COC) XXXXXincluded in the file pages 645 - 647) which affected pricing. Please see the redisclosed CD to the borrower on XXXXX included in the file, pages 543 - 552. Please clear this condition

03/02/2020

1

A

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209541160

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-04): Client has accepted the collateral package

03/04/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209541160

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-12): Desk Review uploaded as a trailing doc; -0- variance

03/12/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209541160

[Redact]

[Redact]

Credit

Loan Package Documentation

Application / Processing

Missing Document: AUS not provided

Reviewer Comment (2020-03-05): AUS uploaded as a trailing doc Seller Comment (2020-03-04): XXXXX XXXXX Please see attached.

03/05/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209541160

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

1 valuation required

Reviewer Comment (2020-03-12): Desk Review uploaded as trailing doc; -0- variance

03/12/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209541160

[Redact]

[Redact]

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 Borrower did not provide the number of years in business on the 1003 or any other documentation.

Reviewer Comment (2020-03-03): Client has accepted to waive Buyer Comment (2020-03-03): **Seller to fulfill

03/03/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209541160

[Redact]

[Redact]

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).

Provide required Lender Contact Name & NMLS ID as it is not reflected on the Final Closing Disclosure.

Reviewer Comment (2020-03-03): Client has accepted to waive

03/03/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209541160

[Redact]

[Redact]

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.

Reviewer Comment (2020-03-06): XXXXX received required documents, exception is cleared. Seller Comment (2020-03-06): XXXXX XXXXX Please see attached. Please clear.

03/06/2020

1

A

[Redact]

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

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209541160

[Redact]

[Redact]

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.

The Notice of Right to Cancel is issued on an H-8 form, as this is a same lender refinance, the correct form to be utilized is an H-9. The borrower received funds at closing making this a rescindable transaction

Reviewer Comment (2020-03-06): XXXXX received required documents, exception is cured. Seller Comment (2020-03-06): XXXXX XXXXX Please see attached. Buyer Comment (2020-03-03): **Seller to fulfill

03/06/2020

2

B

[Redact]

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

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209541162

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-17): Collateral received per client.

03/17/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209541162

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-19): Uploaded as a trailing doc; -0- variance

03/19/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209541162

[Redact]

[Redact]

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 (2020-03-17): Client elects to waive.

03/17/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209541162

[Redact]

[Redact]

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 information is not reflected on the Final Closing Disclosure.

Reviewer Comment (2020-03-17): Client elects to waive.

03/17/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209541162

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-03-19): Uploaded as a trailing doc; -0- variance

03/19/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209541162

[Redact]

[Redact]

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

The policy provided dwelling coverage is short to cover the cost to replace of $XXXXX per the appraisal. The images are missing evidence of the replacement cost estimate as defined by the Insurer.

Reviewer Comment (2020-03-19): RCE uploaded as a trailing doc

03/19/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209541289

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-17): exception cleared

03/17/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209541289

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-17): 0% variance

03/17/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209541289

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-03-17): 0% variance

03/17/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209549101

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-27): Client has accepted collateral package.

03/27/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209549101

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-04-01): Secondary product provided to support origination value.

04/01/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209549101

[Redact]

[Redact]

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Coverage is insufficient. Lender to provide evidence of replacement cost or other documentation that coverage is sufficient.

Reviewer Comment (2020-03-26): Replacement estimate provided Seller Comment (2020-03-26): (XXXXX) DS: PLease clear and see attached.

03/26/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209549101

[Redact]

[Redact]

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 not provided for Wholesale lender.

Reviewer Comment (2020-03-27): Client elects to waive

03/27/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209549101

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Additional product required.

Reviewer Comment (2020-04-01): Secondary product provided to support origination value.

04/01/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209559916

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-11): The client has accepted the collateral package

03/11/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209559916

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-03-15): XXXXX uploaded as trailing doc; -0- variance

03/15/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209559916

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-03-15): XXXXX uploaded as trailing doc; -0- variance

03/15/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209559916

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

C-Corp Income Documentation Test

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (C-Corp).

Lender income based upon business returns for fiscal years ending XXXXX/XXXXX. Signed business tax returns for fiscal year ending XXXXX was not provided.

Reviewer Comment (2020-03-31): 3 years business returns and 2 years personal returns provided

03/31/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209559916

[Redact]

[Redact]

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 XXXXX 1040's did not have the signature of the borrower, however, transcripts were provided.

Reviewer Comment (2020-03-17): Client elects to waive.

03/17/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209559916

[Redact]

[Redact]

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.

Third Party Verification of Self-Employment for co-borrower was not provided.

Reviewer Comment (2020-03-27): Income source removed

03/27/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209559916

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

NonQM ATR

Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.

XXXXX 1040's not signed and 1120 for fiscal year ending XXXXX is missing from file.

Reviewer Comment (2020-03-27): Income source removed

03/27/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209559916

[Redact]

[Redact]

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.

Income documentation insufficient causing ATR fail. XXXXX 1040's not signed and 1120 for fiscal year ending XXXXX is missing from file. Missing third party verification for Co-Borrower.

Reviewer Comment (2020-03-31): SHQM Loan

03/31/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209559916

[Redact]

[Redact]

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's contact was not disclosed on the final CD.

Reviewer Comment (2020-03-13): Client has waived exceptions

03/13/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209559916

[Redact]

[Redact]

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 that borrower received copy of CD at least 3 business days prior to closing was not provided.

Reviewer Comment (2020-03-11): XXXXX received XXXXX CD received the same day issued. Seller Comment (2020-03-11): (XXXXX) plesae see attached, please clear thank you

03/11/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

No Defined Cure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209559916

[Redact]

[Redact]

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 Final CD disclosed $XXXXX. Final CD disclosed a Lender Cure of $XXXXX for increase in Closing Costs above legal limit which is sufficient to cure 0% tolerance violation.

03/09/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Final CD evidences Cure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209559916

[Redact]

[Redact]

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 third party verification to confirm duration of employment as XXXXX.

Reviewer Comment (2020-03-19): Client elects to waive

03/19/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209559916

[Redact]

[Redact]

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 electronically sent to borrowers on XXXXX, however, evidence of date actually received by borrowers was not provided.

Reviewer Comment (2020-03-13): Client has waived exceptions

03/13/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209559916

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - C Corporation 1120

Ability to Repay (Dodd-Frank 2014): Unable to verify C Corp income using reasonably reliable third-party records.

Once we receive income docs this exception will clear based on loan now meets Appendix Q.

Reviewer Comment (2020-03-27): XXXXX Business return uploaded as a trailing doc

03/27/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209562438

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-19): Client has accepted package.

03/19/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209562438

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-03-20): Secondary product provided to support origination value.

03/20/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209562438

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-03-20): Secondary product provided to support origination value.

03/20/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209562438

[Redact]

[Redact]

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 and XXXXX tax returns are not signed and dated by the borrowers, however in lieu of the signed returns we have XXXXX and XXXXX Transcripts in file.

Reviewer Comment (2020-03-19): Client elects to waive

03/19/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209562438

[Redact]

[Redact]

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 (2020-03-19): Client elected to waive

03/19/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209565478

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-28): exception cleared

02/28/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209565478

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-27): Secondary product provided to support origination value.

02/27/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209565478

[Redact]

[Redact]

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).

A lender contact was not provided.

Reviewer Comment (2020-02-28): Client elects to waive

02/28/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209568490

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-19): Client accepted collateral package.

03/19/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209568490

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-16): Exception cleared

03/16/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209568490

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Rental Income Documentation - Schedule E Method Test

Qualified Mortgage (Dodd-Frank 2014): Rental income documentation requirement not met for XXXXX. Lease Agreement and/or Tax Return not provided.

Missing copy of the Lease Agreements

Reviewer Comment (2020-03-19): Exception cleared

03/19/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209568490

[Redact]

[Redact]

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 leases.

Reviewer Comment (2020-03-19): SHQM Loan

03/19/2020

1

A

[Redact]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209568490

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Rental Income Documentation - Schedule E Method Test

Qualified Mortgage (Dodd-Frank 2014): Rental income documentation requirement not met for XXXXX. Lease Agreement and/or Tax Return not provided.

Need proof of two years rented. Missing lease.

Reviewer Comment (2020-03-19): Exception cleared

03/19/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209568518

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-11): The client has accepted the collateral package

03/11/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209568518

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-11): XXXXX uploaded as trailing doc; -0- variance

03/11/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209568518

[Redact]

[Redact]

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 provided on XXXXX did not disclose the required lender contact information.

Reviewer Comment (2020-03-10): Client has elected to waive

03/10/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209568518

[Redact]

[Redact]

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.

Date valuation provided on XXXXX to applicant is prior to the date when valuation was performed on XXXXX.

Reviewer Comment (2020-03-10): Client has elected to waive

03/10/2020

2

B

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209569801

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-13): The client has accepted the collateral package

03/13/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209569801

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-11): Secondary product provided to support origination value.

03/11/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209569816

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-11): The client has accepted the collateral package

03/11/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209569816

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-03-10): Secondary product provided to support origination value

03/10/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209569816

[Redact]

[Redact]

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

HOI Coverage of $XXXXX is insufficient to cover the Estimated Cost New value that is $XXXXX resulting in a Coverage Shortfall of $XXXXX. Replacement cost from the insurer to determine coverage amount is sufficient was not provided.

Reviewer Comment (2020-03-24): Replacement provided Seller Comment (2020-03-24): (XXXXX) XXXXX Please see attached.

03/24/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209569816

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-03-10): Secondary product provided to support origination value

03/10/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209569816

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

RESPA - Initial Escrow Account Statement Missing

RESPA: Initial escrow account statement was not provided to the borrower.

Initial escrow account statement was not provided to the borrower.

Reviewer Comment (2020-03-10): Client has elected to waive

03/10/2020

2

B

[Redact]

Primary

Purchase

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209569816

[Redact]

[Redact]

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.

Binding LE disclosed an Appraisal Fee of $XXXXX and Final CD disclosed $XXXXX a difference of $XXXXX. Final CD disclosed a Lender Credit of $XXXXX for increase in Closing Costs above legal limit which is sufficient to cure 0% tolerance violation.

Reviewer Comment (2020-03-05): At closing the lender issued a cure to the borrower for the fee failure

03/05/2020

2

B

[Redact]

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

209569816

[Redact]

[Redact]

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.

Binding LE disclosed Credit Report Fee of $XXXXX and Final CD disclosed $XXXXX a difference of $XXXXX. Final CD disclosed a Lender Credit, however, it is insufficient to cure 0% tolerance violation by .10c

Reviewer Comment (2020-03-18): Sufficient cure shown on final Closing Disclosure. Seller Comment (2020-03-17): (XXXXX) XXXXX The tolerance for the credit report fee was given to the borrower at closing , included in the $XXXXX lender credit. The loan estimate never shows cents on the disclosure but the intiail fee that was based lined was $XXXXX so the tolerance is only $XXXXX. Please see attached the baselined amount and the current amount to show that no tolerance cure is needed. Reviewer Comment (2020-03-13): Tolerance difference of $XXXXX for Appraisal and $XXXXX for the credit report, resulted in 0% tolerance exceeded by $XXXXX. Cure required in the amount of $XXXXX; however, provided cure on PCCD only $XXXXX; short $XXXXX to cure. Seller Comment (2020-03-12): (XXXXX) XXXXX Please see attached fee tolerance. Please clear condition.

03/18/2020

1

A

[Redact]

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

209569816

[Redact]

[Redact]

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.

Sufficient cure shown on final Closing Disclosure.

Reviewer Comment (2020-03-18): Sufficient Cure Provided At Closing

03/18/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209569816

[Redact]

[Redact]

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.

Sufficient cure shown on final Closing Disclosure.

Reviewer Comment (2020-03-18): Sufficient Cure Provided At Closing

03/18/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209575189

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-27): Client has accepted the collateral package

02/27/2020

1

A

[Redact]

Second Home

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209575189

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

C-Corp Income Documentation Test

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (C-Corp).

Reviewer Comment (2020-03-11): Provided was additional documentation to support income as required by SHQM Reviewer Comment (2020-03-03): The images are missing a balance sheet dated XXXXX and a P&L dated XXXXX.

03/11/2020

1

A

[Redact]

Second Home

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209575189

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Partnership Income Documentation Test

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Partnership).

Reviewer Comment (2020-03-03): The lender provided documentation to support sources of income as required by SHQM

03/03/2020

1

A

[Redact]

Second Home

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209575189

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Partnership Income Documentation Test

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Partnership).

Reviewer Comment (2020-03-11): Provided was additional documentation to support income as required by SHQM Reviewer Comment (2020-03-03): Missing the CB XXXXX signed returns of 1040's. XXXXX only was provided

03/11/2020

1

A

[Redact]

Second Home

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209575189

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Sole Proprietorship Income Documentation Test

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Sole Proprietorship).

Reviewer Comment (2020-03-11): Provided was additional documentation to support income as required by SHQM Reviewer Comment (2020-03-03): The images are missing a P&L for the schedule C as required. Please provide the XXXXX P&L. The balance sheet and third party are present.

03/11/2020

1

A

[Redact]

Second Home

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209575189

[Redact]

[Redact]

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 (2020-02-26): Client has elected to accept and waive

02/26/2020

2

B

[Redact]

Second Home

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209575189

[Redact]

[Redact]

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.

Reviewer Comment (2020-03-03): The lender provided documentation to support sources of income as required by SHQM

03/03/2020

1

A

[Redact]

Second Home

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209575189

[Redact]

[Redact]

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.

Binding LE disclosed Loan Discount Points $XXXXX and Final CD disclosed $XXXXX. Cure for 0% tolerance violation was not provided.

Reviewer Comment (2020-03-19): XXXXX reviewed and upon further review find issue resolved. COC received and applied. Reviewer Comment (2020-03-03): XXXXX did not receive documentation or commentary regarding exemption. The fee increased on the XXXXX CD without a valid COC. Please provide COC indicating the changed circumstance that occurred or please provide a corrected CD, LOE, refund check, and proof of mailing to cure.

03/19/2020

1

A

[Redact]

Second Home

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

209575189

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

NonQM ATR

Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.

General Ability-to-Repay requirements not satisfied due to third party verification of self-employment for XXXXX was not provided.

Reviewer Comment (2020-03-03): The lender provided documentation to support sources of income as required by SHQM

03/03/2020

1

A

[Redact]

Second Home

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209575189

[Redact]

[Redact]

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.

Originator Loan Designation discrepancy is due to third party verification of self-employment for XXXXX was not provided.

Reviewer Comment (2020-03-11): Provided was additional documentation to support income as required by SHQM Reviewer Comment (2020-03-03): The images are missing a balance sheet dated XXXXX and a P&L dated XXXXX.

03/11/2020

1

A

[Redact]

Second Home

Purchase

Lender to provide updated ATR/QM status

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209575189

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-25): XXXXX provided to support original value

02/25/2020

1

A

[Redact]

Second Home

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209575189

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

C-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 12:00:00 AM, Creditor Application Date = XXXXX (C-Corp).

The images are missing a balance sheet dated XXXXX and a P&L dated XXXXX.

Reviewer Comment (2020-03-11): Provided

03/11/2020

1

A

[Redact]

Second Home

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209575200

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-11): The client has accepted the collateral package

03/11/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209575200

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-15): XXXXX uploaded as trailing doc; -0- variance

03/15/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209575200

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-03-15): XXXXX uploaded as trailing doc; -0- variance

03/15/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209575249

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-02): The lender has accepted the collateral package

03/02/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209575249

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-02): Secondary product provided to support origination value.

03/02/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209575249

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-03-02): Secondary product provided to support origination value.

03/02/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209575384

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-24): Client has accepted the collateral package

03/24/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209575384

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-23): XXXXX uploaded as a trailing doc; -0- variance

03/23/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209575384

[Redact]

[Redact]

Credit

Loan Package Documentation

Closing / Title

Missing Document: Rider - Other not provided

The file is missing a copy of the XXXXX Rider.

Reviewer Comment (2020-03-23): Uploaded as a trailing doc

03/23/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209575384

[Redact]

[Redact]

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 statement is missing the lenders contact name and NMLS ID number.

Reviewer Comment (2020-03-23): Client Elects to Waive

03/23/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209577178

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-24): Client has accepted the collateral package

03/24/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209577178

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization

Reviewer Comment (2020-03-24): XXXXX uploaded as a trailing doc; -0- variance

03/24/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209577178

[Redact]

[Redact]

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.

File contains CD's issued on XXXXX and XXXXX and loan closed on XXXXX.

Reviewer Comment (2020-03-23): XXXXX received XXXXX CD. Seller Comment (2020-03-23): Please see attachment

03/23/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

No Defined Cure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209577178

[Redact]

[Redact]

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's contact information was not provided.

Reviewer Comment (2020-03-19): Client elects to waive.

03/19/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209577181

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-11): The client has accepted the collateral package

03/11/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209577181

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-03-10): Secondary product provided to support origination value

03/10/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209577181

[Redact]

[Redact]

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 the Lender's Contact Name and NMLS ID number.

Reviewer Comment (2020-03-10): Client has elected to waive

03/10/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209578838

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-19): Client has accepted package.

03/19/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209578838

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-03-19): XXXXX uploaded as trailing doc; -8.1633% variance

03/19/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209578838

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Commission Pay Stubs

Qualified Mortgage (Dodd-Frank 2014): Copies of signed tax returns for last two (2) years or most recent pay stub not provided for Commission income.

The Commission income is broken out on the three pay stubs and also on the two WVOE's covering YTD and previous two years.

Reviewer Comment (2020-03-11): File contains two years tax returns, most recent paystub and VOE with comission income separately broken out.

03/11/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209578838

[Redact]

[Redact]

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 loan designation of Safe Harbor is acceptable due to the Commission income is broken out on the three pay stubs and also on the two WVOE's covering YTD and previous two years.

Reviewer Comment (2020-03-11): SHQM Loan

03/11/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209578838

[Redact]

[Redact]

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.

Document signed at closing acknowledging receipt of appraisal and appraisal waiver provided, however, evidence of the actual date the appraisal was received by borrower was not provided.

Reviewer Comment (2020-03-17): Client elects to waive.

03/17/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209578838

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Notice of Right To Cancel Not Provided to All Required Parties

Truth in Lending Act: Notice of Right to Cancel was not signed by all parties whose ownership interest is or will be subject to the security interest.

The RTC is not signed by the non borrowing spouse

Reviewer Comment (2020-03-24): The signed RTC was provided from the non borrowing spouse

03/24/2020

1

A

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209579099

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-04): Client has accepted the collateral package

03/04/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209579099

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-05): Secondary product provided to support origination value.

03/05/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209579099

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

RESPA - Initial Escrow Account Statement Missing

RESPA: Initial escrow account statement was not provided to the borrower.

The file is missing initial escrow account disclosure.

Reviewer Comment (2020-03-03): Client has accepted to waive

03/03/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209579099

[Redact]

[Redact]

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 statement is missing the lenders contact name and NMLS id number.

Reviewer Comment (2020-03-03): Client has accepted to waive

03/03/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209579137

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-16): Exception cleared per client.

03/16/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209579137

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-11): Secondary product provided to support origination value.

03/11/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209586056

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Credit Exception:

$XXXXX paid each by Borrower and Seller in Recordation Tax to XXXXX, an Affiliate company of the Lender (per Affiliated Business Arrangement Disclosure in loan file). Lender to provide an explanation for a Recording Tax paid to Lender Affiliate rather than the recording entity with the city/state/county.

Reviewer Comment (2019-12-26): Received attestation that the title company should be the payee on the fee rather than the government entity. Buyer Comment (2019-12-26): Title company's explanation that Recording fees are filed electronically and fees are payable to XXXXX

12/26/2019

1

A

[Redact]

Primary

Purchase

C

A

C

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209607443

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-20): Client has accepted the collateral package

03/20/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209607443

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-24): Secondary product provided to support origination value.

03/24/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209616490

[Redact]

[Redact]

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 (2020-02-20): Client elects to waive.

02/20/2020

2

B

[Redact]

Primary

Purchase

B

B

A

A

B

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209616490

[Redact]

[Redact]

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 Reinspection Fee. Fee Amount of $XXXXX exceeds tolerance of $XXXXX. Sufficient or excess cure was provided to the borrower at Closing.

The Final Closing Disclosure reflects a Reinspection Fee of $XXXXX, the Initial Loan Estimate disclosed $XXXXX, a $XXXXX cure is included in the CD.

02/11/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

B

B

A

A

B

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209616492

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-02-24): 0% variance

02/24/2020

1

A

[Redact]

Primary

Purchase

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209616492

[Redact]

[Redact]

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 (2020-02-20): Client elects to waive.

02/20/2020

2

B

[Redact]

Primary

Purchase

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209616492

[Redact]

[Redact]

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.

Final CD disclosed Amount of Non-Escrowed Property Costs over Year 1 of $XXXXX, however, the actual amount is $XXXXX based on the appraisal HOA fee of $XXXXX per month. Per the 1008 the HOA monthly fee was disclosed as $XXXXX but there is no evidence of this value.

Reviewer Comment (2020-02-20): XXXXX received PCCD correcting non escrowed property costs and LOE. Seller Comment (2020-02-17): Please see attached PCCD, updated appraisal and UW docs correcting for the HOA amount which is actually $XXXXX/year.

02/20/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209616495

[Redact]

[Redact]

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.

Delivery of updated appraisal is not documented.

Reviewer Comment (2020-02-20): Client elects to waive.

02/20/2020

2

B

[Redact]

Primary

Purchase

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209616495

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Property Taxes Included In Escrow

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXX incorrectly disclosed whether property taxes are included in escrow.

No property taxes are collected in section G.

Reviewer Comment (2020-02-20): IEADs indicates a cushion was not collected, but the property taxes are paid throughout the year. Seller Comment (2020-02-19): Hello there is tax escrows just no cushion in NV. please refer to page 1 and 4 of the CD please clear thank you

02/20/2020

1

A

[Redact]

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

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209616495

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-02-21): 0% variance

02/21/2020

1

A

[Redact]

Primary

Purchase

C

B

A

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209616503

[Redact]

[Redact]

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.

Provide documentation of appraisal delivery at or before closing.

Reviewer Comment (2020-02-20): Client elects to waive.

02/20/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209616503

[Redact]

[Redact]

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 required.

Reviewer Comment (2020-02-21): 0% variance

02/21/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

A

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209616509

[Redact]

[Redact]

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 Fees and Points exceeding the max allowable. Compliance report reflects undiscounted rate of XXXXX%, however missing starting rate price.

Reviewer Comment (2020-02-20): Exception cleared

02/20/2020

1

A

[Redact]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209616509

[Redact]

[Redact]

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 3.00000% 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%).

Points for subject loan of XXXXX% exceed the 3.00% maximum of the Federal total loan amount of $XXXXX, and fees totaling $XXXXX exceed the allowable maximum of $XXXXX, which is an overage of $XXXXX or .XXXXX%.

Reviewer Comment (2020-02-20): Exception cleared

02/20/2020

1

A

[Redact]

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

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209616509

[Redact]

[Redact]

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 that borrower received copy of updated appraisal at least 3 business days prior to closing was not provided.

Reviewer Comment (2020-02-20): Client elects to waive.

02/20/2020

2

B

[Redact]

Primary

Purchase

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209617408

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-19): Client has accepted package.

03/19/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209617408

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-23): XXXXX uploaded as a trailing doc; -9.79% variance.

03/23/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209617408

[Redact]

[Redact]

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 include the contact information on page 5 of the disclosure.

Reviewer Comment (2020-03-19): Client elects to waive.

03/19/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209617408

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-03-23): XXXXX uploaded as a trailing doc; -9.79% variance.

03/23/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209617409

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-24): Client has accepted the collateral package

03/24/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209617409

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-23): Uploaded as a trailing doc; -0- variance

03/23/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209617409

[Redact]

[Redact]

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

There is a coverage shortfall of $XXXXX. Provide a replacement cost estimator to evidence that the current coverage is sufficient.

Reviewer Comment (2020-03-24): Replacement cost provided Seller Comment (2020-03-24): (XXXXX) DS: Please clear and see attached

03/24/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209617409

[Redact]

[Redact]

Credit

Document Inventory

General

Evidence of Taxpayer Consent is Missing, and Taxpayer documentation is present.

Reviewer Comment (2020-03-24): Provided Seller Comment (2020-03-23): Please see attachment

03/24/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209617409

[Redact]

[Redact]

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 (2020-03-23): Client Elects to Waive

03/23/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209617409

[Redact]

[Redact]

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 10% or $XXXXX. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2020-03-19): Sufficient Cure Provided At Closing

03/19/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209617409

[Redact]

[Redact]

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.

Reviewer Comment (2020-03-19): Sufficient Cure Provided At Closing

03/19/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209618377

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-17): Collateral received per client.

03/17/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209618377

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-20): XXXXX uploaded as a trailing doc; -0- variance

03/20/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209618377

[Redact]

[Redact]

Credit

Loan Package Documentation

Application / Processing

Missing Document: AUS not provided

Reviewer Comment (2020-03-17): Uploaded as a trailing doc Reviewer Comment (2020-03-16): AUS provided does not correspond with the final closing transaction.

03/17/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209618377

[Redact]

[Redact]

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 Info only provided for broker.

Reviewer Comment (2020-03-17): Client elects to waive.

03/17/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209620931

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-26): Client has accepted the collateral package

02/26/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209620931

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-02-26): Secondary product provided to support origination value.

02/26/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209620931

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-02-26): Secondary product provided to support origination value.

02/26/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209620931

[Redact]

[Redact]

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.

The date that the updated appraisal was provided to the borrower was not found in the file.

Reviewer Comment (2020-02-26): Client has elected to accept and waive

02/26/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209620931

[Redact]

[Redact]

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 (2020-02-26): Client has elected to accept and waive

02/26/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209620931

[Redact]

[Redact]

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.

A credit of $XXXXX was provided.

02/21/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

Final CD evidences Cure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209620935

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-17): Collateral received per client.

03/17/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209620935

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-20): XXXXX uploaded as trailing doc; -0- variance

03/20/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209620935

[Redact]

[Redact]

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Hazard Insurance coverage amount is insufficient and has a shortfall, there are statements regarding replacement cost and other coverage however the percentages were not provided. Provide a replacement cost estimator confirming the insurable value.

Reviewer Comment (2020-03-18): RCE uploaded as a trailing doc Seller Comment (2020-03-17): (XXXXX) DS: please clear and see attached.

03/18/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209620935

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Missing copy of the second valuation.

Reviewer Comment (2020-03-20): XXXXX uploaded as trailing doc; -0- variance

03/20/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209620935

[Redact]

[Redact]

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 provided on XXXXX did not disclose the required Lender Contact Information.

Reviewer Comment (2020-03-17): Client elects to waive.

03/17/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209620936

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-24): Client has accepted the collateral package

03/24/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209620936

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization

Reviewer Comment (2020-03-27): -7.3359% variance.

03/27/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209620936

[Redact]

[Redact]

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 person was not provided on CD for Lender.

Reviewer Comment (2020-03-27): Client elects to waive

03/27/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209620936

[Redact]

[Redact]

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.

No cure was provided for zero percent fee tolerance of $XXXXX.

Reviewer Comment (2020-03-24): XXXXX received Changed Circumstance. Seller Comment (2020-03-23): (XXXXX) XXXXX The appraised value came in significantly lower (COC XXXXX included in the file, pages 207 - 209), the borrower requested to extend their lock (NO coc required for lock extensions XXXXX) and the borrower requested to change their loan amount (COC XXXXX included in the file 204 - 206). Please see the LE from XXXXX included in the file 201 - 203, the CD from XXXXX redisclosed to the borrower included in the file, pages 291 - 300 and the CD from XXXXX redisclosed to the borrower included in the file, pages 281 - 290. Please clear this condition.

03/24/2020

1

A

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209621376

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-19): Client accepted collateral package.

03/19/2020

1

A

[Redact]

Primary

Purchase

D

B

D

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209621376

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-17): 0% variance

03/17/2020

1

A

[Redact]

Primary

Purchase

D

B

D

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209621376

[Redact]

[Redact]

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 personal returns were not signed. XXXXX personal returns were signed. File contains transcripts for both years so they were used in lieu of signed XXXXX 1040s.

Reviewer Comment (2020-03-19): Client elects to waive

03/19/2020

2

B

[Redact]

Primary

Purchase

D

B

D

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209621376

[Redact]

[Redact]

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 charges are $XXXXX, resulting in a variance of -$XXXXX. To cure, 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).

Reviewer Comment (2020-03-19): XXXXX received required documents, exception is cured. Buyer Comment (2020-03-18): Per the seller "On the Final CD; the settlement fee was included in the APR as it was a split fee; we refunded the settlement fee on the post-consummation CD - $XXXXX - $XXXXX threshold; there is the variance of the $XXXXX. PCCD and Final Settlement Statement attached."

03/19/2020

2

B

[Redact]

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

D

B

D

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209621376

[Redact]

[Redact]

Credit

Loan Package Documentation

Closing / Title

Missing Document: Security Instrument not provided

Reviewer Comment (2020-03-20): Provided

03/20/2020

1

A

[Redact]

Primary

Purchase

D

B

D

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209621436

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-04): Desk Review uploaded as a trailing doc; -0- variance

03/04/2020

1

A

[Redact]

Primary

Purchase

C

A

A

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209621436

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-04): Client has accepted the collateral package

03/04/2020

1

A

[Redact]

Primary

Purchase

C

A

A

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209634863

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-11): The client has accepted the collateral package

03/11/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209634863

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-15): XXXXX uploaded as trailing doc; -0- variance

03/15/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209634863

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-03-15): XXXXX uploaded as trailing doc; -0- variance

03/15/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209634863

[Redact]

[Redact]

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.

03/07/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209634863

[Redact]

[Redact]

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 contact info for lender.

Reviewer Comment (2020-03-13): Client has waived exceptions

03/13/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209634866

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-04-01): Client has accepted the collateral package

04/01/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209634866

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization

Reviewer Comment (2020-04-01): Secondary product provided to support origination value.

04/01/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209634866

[Redact]

[Redact]

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).

Provide required Lender Contact Name & NMLS ID #.

Reviewer Comment (2020-03-31): Client elects to Waive

03/31/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209637108

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-02-27): Client has accepted the collateral package

02/27/2020

1

A

[Redact]

Primary

Purchase

B

A

B

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209637201

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-19): Client has accepted package.

03/19/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209637201

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-23): XXXXX provided as trailing doc; -5.59% variance

03/23/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209637201

[Redact]

[Redact]

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.

Verified the waiver signed date of XXXXX. An update of the appraisal was done on XXXXX.

Reviewer Comment (2020-03-19): Client elected to waive

03/19/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209637201

[Redact]

[Redact]

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).

There is no contact name for the lender, just Broker.

Reviewer Comment (2020-03-19): Client elects to waive.

03/19/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209637202

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-27): Client has accepted collateral package.

03/27/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209637202

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-04-01): Secondary product provided to support origination value.

04/01/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209640981

[Redact]

[Redact]

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.

Reviewer Comment (2020-02-21): 0% variance

02/21/2020

1

A

[Redact]

Primary

Purchase

C

A

C

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209640981

[Redact]

[Redact]

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Property type discrepancy.

Appraisal reflects property as a PUD Single Family; 1008, approval & Security Instrument reflect property as a Condo.

Reviewer Comment (2020-02-25): exception cleared Seller Comment (2020-02-25): CORRECT APPRAISAL

02/25/2020

1

A

[Redact]

Primary

Purchase

C

A

C

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209640983

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Validated

Reviewer Comment (2020-02-21): 0% variance

02/21/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209640986

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-02-21): 0% variance

02/21/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209640987

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Missing copy of the second valuation.

Reviewer Comment (2020-02-21): 0% variance

02/21/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209640991

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 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 the HOI of $XXXXX, HOA $XXXXX and annual tax of $XXXXX for a variance of $XXXXX

Reviewer Comment (2020-02-28): Exception cleared. Reviewer Comment (2020-02-25): XXXXX received policy however the total property costs are costs that are required by lender. As the file does not indicate it was required it should not be included in property costs. Please provide a corrected CD and LOE to cure. Seller Comment (2020-02-24): Supporting docs for the earthquake insurance were uploaded - please review and advise thanks Seller Comment (2020-02-21): Hi, you have not added/included the Earthquake Insurance for $XXXXX due XXXXX

02/28/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

A

A

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209640992

[Redact]

[Redact]

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 borrower consented to e-signatures 1 day after the initial LE was provided.

Reviewer Comment (2020-02-20): Document 0177 confirms paper docs mailed on XXXXX the 3rd business day thus e-delivery N/A

02/20/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

A

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209640993

[Redact]

[Redact]

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 Final Closing Disclosure reflects a Disbursement Date of XXXXX, Closing Date XXXXX however the first day to disburse would be XXXXX due to the holiday

Reviewer Comment (2020-02-28): ALTA settlement statement provided evidencing transaction date of XXXXX. Loan disbursed correctly.Exception cleared. Reviewer Comment (2020-02-26): CD issued on XXXXX reflects a closing date of XXXXX and borrowers signed on XXXXX. CD issued on XXXXX reflects a closing date of XXXXX and disbursement date of XXXXX borrower signed on XXXXX. Since the CD issued on XXXXX is considered the final CD. RTC was signed XXXXX however the system is using the CD issued on XXXXX as final CD. Exception remains. Reviewer Comment (2020-02-24): Subject was for the refinance of a primary home. Per final CD; subject closed XXXXX and disbursed XXXXX; however, the final CD wasn't signed until XXXXX, which extended the allowable disbursement date to 2XXXXX.

02/28/2020

1

A

[Redact]

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

A

A

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209640993

[Redact]

[Redact]

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 Final Closing Disclosure reflects a Disbursement Date of XXXXX, Closing Date XXXXX however the first day to disburse would be XXXXX due to the holiday

Reviewer Comment (2020-02-28): ALTA settlement statement provided evidencing transaction date of XXXXX. Loan disbursed correctly.Exception cleared. Reviewer Comment (2020-02-26): CD issued on XXXXX reflects a closing date of XXXXX and borrowers signed on XXXXX. CD issued on XXXXX reflects a closing date of XXXXX and disbursement date of XXXXX borrower signed on XXXXX. Since the CD issued on XXXXX is considered the final CD. RTC was signed XXXXX however the system is using the CD issued on XXXXX as final CD. Exception remains. Reviewer Comment (2020-02-24): The final CD wasn't signed until XXXXX, which changed the allowable disbursement date to XXXXX.

02/28/2020

1

A

[Redact]

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

A

A

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

209640994

[Redact]

[Redact]

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. Insufficient or no cure was provided to the borrower.

Provide evidence of cure for items exceeding tolerance, Combined title fees and recording fees.

Reviewer Comment (2020-03-04): PCCD, LOE, mailing label and refund check cin file. Reviewer Comment (2020-02-25): COC provided does not specify why title fees increase, COC was for rate lock and loan amount decrease. The Initial LE only disclosed Endorsements, Lenders Tittle Insurance and Settlement Closing Fee. The Final CD has all fees disclosed in Section B (Non Shopable Section). The Final CD adds a $XXXXX Doc Prep Fee, $XXXXX Notary Fee, Recording Fee increased, $XXXXX Recording Service Fee added as well as a $XXXXX Wire Fee added. Need more detail to why fees were added or cure is due to borrower.

03/04/2020

2

B

[Redact]

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

Safe Harbor QM

Safe Harbor QM

Yes

209640994

[Redact]

[Redact]

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 10% or $XXXXX. Sufficient or excess cure was provided to the borrower.

Sufficient or excess cure was provided to the borrower

Reviewer Comment (2020-03-04): PCCD, LOE, refund and mailing label in file.

03/04/2020

2

B

[Redact]

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

Safe Harbor QM

Safe Harbor QM

Yes

209640995

[Redact]

[Redact]

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 (2020-02-20): Evidence of appraisal delivery uploaded as trailing doc

02/20/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

B

A

A

A

B

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209640996

[Redact]

[Redact]

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. Evidence borrower received a copy of the revised appraisal was not provided.

Reviewer Comment (2020-02-20): Client elects to waive

02/20/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

B

B

A

A

B

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209640997

[Redact]

[Redact]

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.

The initial LE was disclosed with $XXXXX in points with a loan amount of $XXXXX, the loan amount increased to $XXXXX on XXXXX, the points went up to $XXXXX.

Reviewer Comment (2020-02-25): Exception cleared Seller Comment (2020-02-24): NORTC is for primary residence only, this loan is for 2nd home. Please waive.

02/25/2020

1

A

[Redact]

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

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209640997

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Notice of Right to Cancel Missing

Truth in Lending Act: Notice of Right to Cancel was not provided.

Disclosure not located in the file

Reviewer Comment (2020-02-25): Exception cleared

02/25/2020

1

A

[Redact]

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

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209640997

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-02-21): 0% variance

02/21/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209640997

[Redact]

[Redact]

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. Insufficient or no cure was provided to the borrower.

The total of the Title - Settlement/Closing/Escrow Fee, title - Lender's Title Insurance, and the Recording Fee reflected $XXXXX on the Final Closing Disclosure, the Initial Loan Estimate disclosed $XXXXX.

Reviewer Comment (2020-03-04): PCCD, LOE, mailing label and refund check in file, Reviewer Comment (2020-02-25): Provide a Valid Change of Circumstance for this exception to re baseline fee increase or addition of fees in the amount of $XXXXX or a valid COC. A cure including A Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD is needed to satisfy this exception if a COC is not produced.

03/04/2020

2

B

[Redact]

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

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209640997

[Redact]

[Redact]

Credit

Document Inventory

General

Evidence of Taxpayer Consent is Missing, and Taxpayer documentation is present.

Reviewer Comment (2020-02-24): exception cleared

02/24/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209640997

[Redact]

[Redact]

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 10% or $XXXXX. Sufficient or excess cure was provided to the borrower at Closing.

Sufficient or excess cure was provided to the borrower at Closing.

03/04/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209640997

[Redact]

[Redact]

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 10% or $XXXXX. Sufficient or excess cure was provided to the borrower.

PCCD, LOE, refund and mailing label in file. Sufficient or excess cure was provided to the borrower

Reviewer Comment (2020-03-04): Sufficient or excess cure was provided to the borrower

03/04/2020

2

B

[Redact]

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

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209640999

[Redact]

[Redact]

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 borrower received a copy of the appraisal.

Reviewer Comment (2020-02-20): Client elects to waive Seller Comment (2020-02-18): Certificate (s) of Mailing uploaded (for all) valuations sent

02/20/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209640999

[Redact]

[Redact]

Credit

Income / Employment

Income Documentation

Income Docs Missing:

- ___ ___

Per guidelines: A written or Verbal Verification of Employment (VVOE) must be obtained within 10 business days prior to the Note date. Verbal VOE in file are dated XXXXX exceeds 10 business days.

The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%. Borrower has worked in the same position for more than XXXXX years. Borrower has verified disposable income of at least $XXXXX. Borrower has owned the subject property for at least XXXXX years. Borrower has been employed in the same industry for more than XXXXX years.

AMC AMC AMC AMC AMC

Reviewer Comment (2020-03-03): Client elects to waive. Post Close VVOE acceptable as borrower is still employed; FICO XXXXX; DTI XXXXX%; Reserves >$XXXXX Seller Comment (2020-02-26): Exception Request: VVOE we had on missed the 10day mark by 1 day - VVOE dated XXXXX. May we please have an exception to this condition Reviewer Comment (2020-02-25): Both VVOE's are dated XXXXX and our Note date XXXXX. Guidelines require within 10 business days of the Note date. Exception remains since VVOE's are after Note date. Thank you. Seller Comment (2020-02-24): VVOEs uploaded

03/03/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209641000

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-02-21): 0% variance

02/21/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

A

A

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209641001

[Redact]

[Redact]

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

The file is missing a gap of employment letter for over 30 days.

Reviewer Comment (2020-02-24): Exception cleared.

02/24/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

C

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209641002

[Redact]

[Redact]

Credit

Missing Document

General

Missing Document: Verification of Non-US Citizen Status not provided

Reviewer Comment (2020-02-24): exception cleared

02/24/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209641002

[Redact]

[Redact]

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 Final Closing Disclosure reflects a $XXXXX Appraisal Fee, the Initial Loan Estimated disclosed $XXXXX. Please provide evidence of a sufficient cure.

Reviewer Comment (2020-02-19): The lender self cured the failure with a credit to the borrower at closing

02/19/2020

2

B

[Redact]

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

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209641002

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-02-21): 0% variance

02/21/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209641002

[Redact]

[Redact]

Credit

1003

Document Error

Borrower(s) is not a U.S. Citizen, and the guideline required documentation was not provided.

-

Please provide evidence of the Borrower's Resident Alien status.

Reviewer Comment (2020-02-24): exception cleared

02/24/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209641002

[Redact]

[Redact]

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 evidence of the borrower business while listing as a schedule C business.

Reviewer Comment (2020-02-20): Client elects to waive

02/20/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209641002

[Redact]

[Redact]

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.

No Changed Circumstance was located in the loan file that would explain the need for the increase of the Appraisal fee. Please provide documentation of the need for increase, or PCCD, LOE, copy of the refund check, and proof of delivery.

02/26/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

C

B

C

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209641003

[Redact]

[Redact]

Credit

Missing Document

General

Missing Document: Verification of Non-US Citizen Status not provided

Documents to support borrower permanent resident alien ability to live and work in the US is missing.

Reviewer Comment (2020-02-20): Permanent Resident card provided as trailing doc

02/20/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

C

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209641003

[Redact]

[Redact]

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 required.

Reviewer Comment (2020-02-21): 0% variance

02/21/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

C

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209641004

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Validated

Reviewer Comment (2020-02-21): 0% variance

02/21/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209641286

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-19): Client has accepted package.

03/19/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209641286

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-03-21): XXXXX uploaded as a trailing doc; -0- variance

03/21/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209641286

[Redact]

[Redact]

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 the Lender's Contact Name and NMLS ID number.

Reviewer Comment (2020-03-19): Client elects to waive.

03/19/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209641286

[Redact]

[Redact]

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.

Cure of $XXXXX was disclosed on the Final Closing Disclosure, which is sufficient to cure the 0% tolerance violation of $XXXXX.

Reviewer Comment (2020-03-16): Sufficient Cure Provided At Closing

03/16/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209641286

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-03-21): XXXXX uploaded as a trailing doc; -0- variance

03/21/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209654709

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-24): Client has accepted the collateral package

03/24/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209654709

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

There's no evidence of a secondary valuatin

Reviewer Comment (2020-03-23): XXXXX uploaded as a trailing doc; -0- variance

03/23/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209654709

[Redact]

[Redact]

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 provided on XXXXX did not disclose the required lender contact information.

Reviewer Comment (2020-03-23): Client Elects to Waive

03/23/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209654709

[Redact]

[Redact]

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 evidence of business license or third party verification of employment to verify start dates and active status.

Reviewer Comment (2020-03-23): Client Elects to Waive

03/23/2020

2

B

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209654711

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-19): Client has accepted package.

03/19/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209654711

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-21): XXXXX uploaded as a trailing doc; -0- variance

03/21/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209654711

[Redact]

[Redact]

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 NMLS name or ID for the lender. However, the broker NMLS name is ID is listed and is sufficient. nothing further is required.

Reviewer Comment (2020-03-19): Client elects to waive.

03/19/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209654749

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-04-01): Client has accepted the collateral package

04/01/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209654749

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Secondary valuation required.

Reviewer Comment (2020-03-24): Secondary value provided

03/24/2020

1

A

[Redact]

Primary

Purchase

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209654751

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-26): Client has accepted the collateral package

03/26/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209654751

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-03-23): Secondary valuation product provided to support original value

03/23/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209654751

[Redact]

[Redact]

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 signed acknowledgement of receipt of appraisal at closing, however, evidence of actual date appraisal was received was not provided.

Reviewer Comment (2020-03-27): Client elect to waive Reviewer Comment (2020-03-26): Client to review Seller Comment (2020-03-25): per regulations we are only required proof sent not received. thanks,

03/27/2020

2

B

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209671926

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-17): Client has accepted collateral package.

03/17/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

A

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209671926

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-17): -14.5636% variance.

03/17/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

A

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209671926

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Missing copy of second valaution.

Reviewer Comment (2020-03-17): -14.5636% variance.

03/17/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

A

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209671926

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

Unable to determine if the borrower signed a valuation receipt acknowledgment due to missing information.

Missing a signed document at closing acknowledging their receipt of the valuation 3 days prior to closing

Reviewer Comment (2020-03-23): Client Elects to Waive Reviewer Comment (2020-03-18): Missing dates on acknowledgment form. Exception remains.

03/23/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

A

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209671926

[Redact]

[Redact]

Property

Property - Appraisal

Appraisal Documentation

Loan is to go in a securitization and secondary valuation does not support the appraised value within a 10% tolerance. The lower value was not used to calculate LTV.

The ancillary product provided did not support origination value

Reviewer Comment (2020-03-26): Drive by product supports value within 10%

03/26/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

A

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209671926

[Redact]

[Redact]

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 (2020-03-26): Client has elected to waive

03/26/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

A

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209685501

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-24): Client has accepted the collateral package

03/24/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209685501

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-23): XXXXX uploaded as a trailing doc; -0- variance

03/23/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209685501

[Redact]

[Redact]

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).

Provide required Lender Contact Name & Lender NMLS ID.

Reviewer Comment (2020-03-23): Client Elects to Waive

03/23/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209706497

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-24): Client has accepted the collateral package

03/24/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209706497

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-03-31): XXXXX provided as trailing doc; -7.5630% variance.

03/31/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209706497

[Redact]

[Redact]

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

HOI Coverage of $XXXXX is insufficient to cover 80% of the Appraised value that is $XXXXX resulting in a Coverage Shortfall of $XXXXX. Replacement cost from the insurer to determine coverage amount is sufficient was not provided.

Reviewer Comment (2020-03-26): RCE uploaded as a trailing doc Seller Comment (2020-03-25): (XXXXX) DS: Please clear and see attached.

03/26/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209706497

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-03-31): secondary product provided

03/31/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209706497

[Redact]

[Redact]

Compliance

Compliance

State Compliance

Colorado Consumer Credit Code (First Lien Refinance Notice Not Provided)

XXXXX: Borrower not provided First Lien Refinance Notice.

Evidence that borrower received copy of First Lien Refinance Notice was not provided.

Reviewer Comment (2020-03-27): Client elect to waive.

03/27/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209706497

[Redact]

[Redact]

Compliance

Compliance

State Compliance

Colorado Home Loan (Ability to Repay not Verified)

Colorado Home Loan (HB1322): 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.

Third Party Verification of Self Employment for XXXXX was not provided.

Reviewer Comment (2020-03-31): Client elects to Waive Reviewer Comment (2020-03-26): The images are missing the XXXXX required form First Lien Refinance Notice. State form XXXXX Ability to repay analysis Seller Comment (2020-03-25): (XXXXX) DS: Please rescind as self employed losses do not require an active VOB

03/31/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209706497

[Redact]

[Redact]

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's Contact Name and NMLS ID.

Reviewer Comment (2020-03-27): Client elects to waive

03/27/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209717701

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-27): Client has accepted collateral package.

03/27/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209717701

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-04-01): 0% variance

04/01/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209717701

[Redact]

[Redact]

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 the Lender's Contact Name and NMLS ID number.

Reviewer Comment (2020-03-27): Client elects to waive

03/27/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209717703

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-27): Client has accepted collateral package.

03/27/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209717703

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Pending Secondary Valuation as required for securitization.

Reviewer Comment (2020-03-31): XXXXX uploaded as a trailing doc; -0- variance

03/31/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209717703

[Redact]

[Redact]

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's Contact Name and NMLS ID.

Reviewer Comment (2020-03-27): Client elects to waive

03/27/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209717703

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Credit Exception:

HELOC payoff statement included verbiage to close out account, however, it was not signed by borrower. Verification that HELOC account paid off at closing was closed out was not provided.

Reviewer Comment (2020-03-26): Signature provided on closing the HELOC

03/26/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209718434

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-04-01): Client has accepted the collateral package

04/01/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209718434

[Redact]

[Redact]

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Reviewer Comment (2020-03-31): Uploaded as a trailing doc Seller Comment (2020-03-30): (XXXXX) DS: Please clear and see attached

03/31/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209718434

[Redact]

[Redact]

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 was provided to the borrower after the Effective Date but prior to the Signature Date.

Reviewer Comment (2020-03-31): Client elects to Waive

03/31/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209718434

[Redact]

[Redact]

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).

There was no Contact Information provided on the Final CD for the Lender.

Reviewer Comment (2020-03-31): Client elects to Waive

03/31/2020

2

B

[Redact]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209718434

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-04-02): Secondary product provided to support origination value.

04/02/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209718434

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-04-02): Secondary product provided to support origination value.

04/02/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209747064

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

S-Corp Income Documentation Test

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (S-Corp).

Reviewer Comment (2020-01-07): Exception cleared. Buyer Comment (2020-01-07): P & L and balance sheet now attached Reviewer Comment (2020-01-07): No trailing docs were provided. Exception remains. Buyer Comment (2020-01-06): See YTD P & L and Balance sheet

01/07/2020

1

A

[Redact]

Primary

Purchase

C

A

A

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209747064

[Redact]

[Redact]

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 file does not contain a YTD P&L or a Balance sheet for the Self employed income.

Reviewer Comment (2020-01-07): Exception cleared. Buyer Comment (2020-01-07): P & L and balance sheet now attached Reviewer Comment (2020-01-07): No trailing docs were provided. Exception remains. Buyer Comment (2020-01-06): See YTD P & L and balance sheet attached

01/07/2020

1

A

[Redact]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

A

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209747066

[Redact]

[Redact]

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 valuation provided was prior to the signature date on the appraisal.

Reviewer Comment (2020-01-08): Exception cleared Buyer Comment (2020-01-07): ECOA

01/08/2020

1

A

[Redact]

Primary

Purchase

C

A

A

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209747066

[Redact]

[Redact]

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.

12/31/2019

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

A

A

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209747066

[Redact]

[Redact]

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.

2yr employment history confirmed, End date of previous employment not documented, less than 30 days gap between jobs

Reviewer Comment (2020-01-07): Exception cleared

01/07/2020

1

A

[Redact]

Primary

Purchase

C

A

A

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209747066

[Redact]

[Redact]

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.

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.

Reviewer Comment (2020-01-07): XXXXX received required document reviewed document and upon further review find issue resolved at close no violation exists. Exception cleared. Buyer Comment (2020-01-07): COC

01/07/2020

1

A

[Redact]

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

No

209747066

[Redact]

[Redact]

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.

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.

Reviewer Comment (2020-01-07): XXXXX find issue resolved at close no violation exists. Exception cleared. Buyer Comment (2020-01-07): Lender cured at closing. Please see lender credit of $XXXXX on final CD.

01/07/2020

1

A

[Redact]

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

No

209747067

[Redact]

[Redact]

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 Employment Dates to verify two years current employment, however we are using a minimal loss for this borrower.

Reviewer Comment (2020-01-07): The loan file contains three years K-1s and the YTD P&L/Balance sheet to evidence SE employment oer 2 years. Buyer Comment (2020-01-07): S/E income thatis a loss verification is not required, theres no positive income being used for this bororwer. please waive

01/07/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

B

A

A

A

B

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209747068

[Redact]

[Redact]

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.

We have documentation in file the shows monthly HOA is $XXXXX, however page 4 of final CD is based upon a monthly amount of $XXXXX.

Reviewer Comment (2020-01-17): PCCD and LOE in file Buyer Comment (2020-01-15): Cure

01/17/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209747068

[Redact]

[Redact]

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Missing loan approval.

Reviewer Comment (2020-01-15): Exception cleared Buyer Comment (2020-01-15): See apaporval attached

01/15/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209747068

[Redact]

[Redact]

Credit

Loan Package Documentation

Application / Processing

Missing Document: Loan Underwriting and Transmittal Summary (1008) / MCAW not provided

Final 1008 in file does not belong to our borrower.

Reviewer Comment (2020-01-15): Exception cleared. Buyer Comment (2020-01-14): See 1008 attached

01/15/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

209750083

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-13): Client has accepted the collateral package

03/13/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209750083

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-19): Uploaded as a trailing doc; -0- variance

03/19/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209750083

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-03-19): XXXXX Uploaded as a trailing doc; -0- variance

03/19/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209750083

[Redact]

[Redact]

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).

Provide required Lender Contact Name & NMLS ID.

Reviewer Comment (2020-03-13): Client has waived exceptions

03/13/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209750486

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-19): Client has accepted package.

03/19/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209750486

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-21): XXXXX uploaded as a trailing doc; -0- variance

03/21/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209750486

[Redact]

[Redact]

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Short coverage by $XXXXX.

Reviewer Comment (2020-03-27): RCE uploaded as a trailing doc

03/27/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209750486

[Redact]

[Redact]

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 a signed document at closing acknowledging their receipt of the valuation 3 days prior to closing

Reviewer Comment (2020-03-19): Client elects to waive.

03/19/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209750486

[Redact]

[Redact]

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 (2020-03-19): Client elects to waive.

03/19/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209750486

[Redact]

[Redact]

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.

Review of Preliminary Title indicates originating Lender was the initial mortgage holder. File is subject to recession.

Reviewer Comment (2020-04-01): All provided and recission period ended XXXXX Reviewer Comment (2020-03-26): Amended RTC, LOE and shipping label provided; pending conf of non-rescission by mid-night XXXXX Seller Comment (2020-03-25): Please see attachment Buyer Comment (2020-03-23): Hi Deborah, this is considered a cash out because of the non-mortgage debt that was also paid off at closing. Thanks Seller Comment (2020-03-23): Disagree - Loan is not a cash-out refinance. Per TILA 1026.23(f)(2) The right to rescind does not apply to a A refinancing or consolidation by the same creditor of an extension of credit already secured by the consumer's principal dwelling. The right of rescission shall apply, however, to the extent the new amount financed exceeds the unpaid principal balance, any earned unpaid finance charge on the existing debt, and amounts attributed solely to the costs of the refinancing or consolidation. Buyer Comment (2020-03-17): **Seller to fulfill

04/01/2020

2

B

[Redact]

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

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209751879

[Redact]

[Redact]

Credit

Asset

Asset Documentation

Asset Issue: Gift funds are missing evidence of receipt

Bank statements provided are joint with spouse. Gift from spouse of $XXXXX - Missing Donor's ability and proof of transfer.

Reviewer Comment (2019-12-05): Exception cleared Reviewer Comment (2019-11-04): Per guidelines we need Evidence of funds transfer since the gift letter states funds will be transferred "at closing to be wired directly to escrow". Exceptions remains. Buyer Comment (2019-11-04): Please clarify this exception is requesting transfer of funds only as guidelines do not require donor ability.

12/05/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

C

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209751879

[Redact]

[Redact]

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

The 4506T transcripts need to be obtained from the IRS prior to closing and used to validate the income documentation used to underwrite the loan. Wage transcripts are acceptable

Reviewer Comment (2019-11-04): Exception cleared. Buyer Comment (2019-11-04): Please see attached transcripts

11/04/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

C

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209751879

[Redact]

[Redact]

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.

Missing LO compensation disclosure.

Reviewer Comment (2019-11-05): Exception cleared. Buyer Comment (2019-11-05): MLO

11/05/2019

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

C

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

No

209866857

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-24): Client has accepted the collateral package

03/24/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209866857

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-23): XXXXX uploaded as a trailing doc; -9.09% variance

03/23/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209866857

[Redact]

[Redact]

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Final Title Policy is missing. No evidence of title in file.

Final title is missing and preliminary title provided but not legible.

Reviewer Comment (2020-03-23): Preliminary title provided. Exception cleared. Reviewer Comment (2020-03-20): My apologies, but again the uploaded title is just black pages. This is the only incidence of this occuring with your docs or any of the file being reviewed. Reviewer Comment (2020-03-19): For whatever reason, the initially submitted pre-lim and the trailing pre-lim are both totally black. Unable to clear Seller Comment (2020-03-19): (XXXXX) Please see attached legible preliminary title commitment which was originally upload, please waive thank you

03/23/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209866857

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Received and reviewed one appraisal.

Reviewer Comment (2020-03-23): XXXXX uploaded as a trailing doc; -9.09% variance.

03/23/2020

1

A

[Redact]

Primary

Purchase

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209866857

[Redact]

[Redact]

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).

Lenders contact person was not provided on CD.

Reviewer Comment (2020-03-23): Client Elects to Waive

03/23/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209866857

[Redact]

[Redact]

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 at closing.

Reviewer Comment (2020-03-18): Sufficient Cure Provided At Closing

03/18/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

B

C

A

B

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209878986

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-17): Collateral received per client.

03/17/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Home Improvement

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209878986

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-03-13): The lender provided a secondary product supporting value

03/13/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Home Improvement

C

A

B

A

A

A

C

A

Safe Harbor QM

Safe Harbor QM

No

209907498

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-03-27): Client has accepted collateral package.

03/27/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209907498

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

Reviewer Comment (2020-04-01): 0% variance

04/01/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209907498

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2020-04-01): 0% variance

04/01/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209907498

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Commission Pay Stubs

Qualified Mortgage (Dodd-Frank 2014): Copies of signed tax returns for last two (2) years or most recent pay stub not provided for Commission income.

Pay stubs provided are within 90 days, however most recent tax return, XXXXX, was not provided and is not yet available.

Reviewer Comment (2020-03-25): File contains most recent paystub, 2 years tax returns, and the WVOE that provides a breakdown of the YTD and last two years commission income

03/25/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

No

209907498

[Redact]

[Redact]

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 missing most recent tax return for commission income.

Reviewer Comment (2020-03-25): SHQM Loan

03/25/2020

1

A

[Redact]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209907498

[Redact]

[Redact]

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).

Not provided

Reviewer Comment (2020-03-31): Client elects to Waive

03/31/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

C

B

C

A

Safe Harbor QM

Safe Harbor QM

Yes

209920335

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Pending Internal Customer Final Collateral Package Review

Pending Internal Customer Final Collateral Package Review

Reviewer Comment (2020-04-01): Client has accepted the collateral package

04/01/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

A

C

B

Safe Harbor QM

Safe Harbor QM

No

209920335

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Missing Secondary Valuation.

There's no evidence of a secondary valuation in the loan file.

Reviewer Comment (2020-03-26): Secondary product provided at time of review

03/26/2020

1

A

[Redact]

Primary

Purchase

C

B

B

A

B

A

C

B

Safe Harbor QM

Safe Harbor QM

No

209920335

[Redact]

[Redact]

Property

Property - Appraisal

Appraisal Reconciliation

Appraisal is required to be in name of Lender

-

The appraisal lists XXXXX as the lender/client.

Reviewer Comment (2020-03-31): Lender is waiving this requirement as guidelines do not require OA to be in lender name and it is transferable. Seller Comment (2020-03-30): plz note the appraisal in question was a transfer appraisal. I have upld the transfer letter. thanks,

03/31/2020

2

B

[Redact]

Primary

Purchase

C

B

B

A

B

A

C

B

Safe Harbor QM

Safe Harbor QM

No

209920335

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Will Have Escrow - Initial Escrow Payment By All Parties

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXX disclosed an Initial Escrow Payment that includes both borrower and non-borrower paid amounts.

The seller paid a portion of the borrowers initial hazard insurance escrow.

Reviewer Comment (2020-03-31): XXXXX received required documents, exception is cleared. Seller Comment (2020-03-30): Seller paid XXXXX. Escrow account is an all or none item. Seller paid updated to show portion for HOI premium paid.

03/31/2020

1

A

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

A

B

A

C

B

Safe Harbor QM

Safe Harbor QM

Yes

209920335

[Redact]

[Redact]

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.

Reviewer Comment (2020-03-25): Sufficient Cure Provided At Closing

03/25/2020

1

A

[Redact]

Primary

Purchase

Final CD evidences Cure

C

B

B

A

B

A

C

B

Safe Harbor QM

Safe Harbor QM

Yes

210709851

[Redact]

[Redact]

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Missing copy of the second valuation.

Reviewer Comment (2020-02-26): 0% variance

02/26/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

B

A

C

A

Safe Harbor QM

Safe Harbor QM

No

210709851

[Redact]

[Redact]

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 VVOE for borrower prior employer XXXXX.

Reviewer Comment (2020-02-28): Exception cleared. Reviewer Comment (2020-02-26): Final 1003 will not be acceptable for VVOE. Appendix Q requires to have the lender verify consumers' employment for the most recent two full years. Exception remains. Thank you. Buyer Comment (2020-02-26): XXXXX bought XXXXX. Loan application reflects end date of XXXXX.

02/28/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

A

A

B

A

C

A

Safe Harbor QM

Safe Harbor QM

No

210709852

[Redact]

[Redact]

Credit

System

General

Valuation address does not match Note address.

Security instrument APN reads: XXXXX and appraisals reads: XXXXX

Reviewer Comment (2020-02-20): APN confirmed as trailing doc Buyer Comment (2020-02-20): XXXXX uploaded

02/20/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

C

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

No

210709852

[Redact]

[Redact]

Credit

Income / Employment

Income Documentation

Tax returns were used for income documentation and tax transcripts are missing .

Guidelines require Two years tax transcripts needed to be obtained prior to closing, File is missing 2 years transcripts for XXXXX and XXXXX.

Reviewer Comment (2020-02-20): Transcripts uploaded as trailing doc Buyer Comment (2020-02-20): See 2 yrs transcripts uploaded

02/20/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

C

A

A

A

A

A

Safe Harbor QM

Safe Harbor QM

No

210709855

[Redact]

[Redact]

Credit

Asset

Asset Documentation

Aged document: Asset Account date is more than 90 days prior to the note.

-

Missing copy of most recent bank statement for XXXXX.

Reviewer Comment (2020-03-05): uploaded as a trailing doc

03/05/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

No

210709855

[Redact]

[Redact]

Credit

Asset

Asset Documentation

Aged document: Asset Account date is more than 90 days prior to the note.

-

Missing copy of the most recent statement for XXXXX.

Reviewer Comment (2020-03-05): Uploaded as a trailing doc

03/05/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

No

210709855

[Redact]

[Redact]

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.

Creditor did not provide List of Homeownership Counseling Organizations to borrower.

Reviewer Comment (2020-02-28): Exception cleared Buyer Comment (2020-02-27): RESPA

02/28/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

No

210709855

[Redact]

[Redact]

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.

Loan Discount Points fee amount of $XXXXX exceeds tolerance of $XXXXX. Insufficient or no cure was provided to the borrower. Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD.

Reviewer Comment (2020-02-28): Exception cleared Buyer Comment (2020-02-27): COC

02/28/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

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

210709856

[Redact]

[Redact]

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 $15,615.60 exceeds tolerance of $14,913.60. Insufficient or no cure was provided to the borrower.

Loan Discount Points fee was disclosed on the interim LE issued on XXXXX in the amount of $XXXXX but on the final CD reads $XXXXX. It appears the borrower was not notified of this increased fee after interim LE was disclosed. Missing valid change in circumstance. To cure, provided corrected PC CD along with LOE to borrower and evidence of delivery.

Reviewer Comment (2020-02-25): XXXXX received Changed Circumstance. Buyer Comment (2020-02-24): coc Reviewer Comment (2020-02-18): Reviewed COC sent to clear exception. COC occurrence date is XXXXX which is after the CD dated XXXXX. Provide a Valid Change of Circumstance for this exception or a cure including A Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD is needed to satisfy this exception. Buyer Comment (2020-02-18): coc

02/25/2020

1

A

[Redact]

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

Safe Harbor QM

Safe Harbor QM

Yes

210709856

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Document Preparation Fee. Fee Amount of $250.00 exceeds tolerance of $125.00. Insufficient or no cure was provided to the borrower.

Document Preparation fee was disclosed on the initial LE in the amount of $XXXXX but on the final CD reads $XXXXX. It appears the borrower was not notified of this increased fee after initial 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 (2020-02-26): XXXXX received corrected Closing Disclosure, letter of explanation, copy of refund check and proof of mailing. Buyer Comment (2020-02-25): cure docs

02/26/2020

2

B

[Redact]

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

Safe Harbor QM

Safe Harbor QM

Yes

210709856

[Redact]

[Redact]

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 $9.60 exceeds tolerance of $6.00. Insufficient or no cure was provided to the borrower.

Loan file does not show proper COC, or cure.

Reviewer Comment (2020-02-26): XXXXX received corrected Closing Disclosure, letter of explanation, copy of refund check and proof of mailing. Buyer Comment (2020-02-25): cure docs

02/26/2020

2

B

[Redact]

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

Safe Harbor QM

Safe Harbor QM

Yes

210709858

[Redact]

[Redact]

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.

Valid change circumstance missing for increase to recording fee.

Reviewer Comment (2020-01-28): PCCD, LOE and canceled check in file Buyer Comment (2020-01-24): cashed check/proof of receipt Reviewer Comment (2020-01-17): From our compliance dept: Per TRID Grid 3.0 Remediation for cures are: Within 60 days of discovery 1. Letter of Explanation (Other evidence of borrower notification of the error will be considered.) 2. Proof of Refund or Principal Reduction or Loan Modification (if permissible - see Row 6 of Remediation Considerations) 3. Corrected PCCD or detailed LOE re-disclosing correct information 4. Proof of Delivery (see row 6 of "Remediation Considerations") Row 6 States the following for Proof of Delivery: Proof of Delivery / Proof of Receipt If the remediation includes funds going to the consumer of more than $35.00, then the proof of shipment for check refunds would include evidence the remediation package was in transit via a carrier such as XXXXX, etc. (Remediation can be completed prior to the package receipt by the consumer.) Refunds less than or equal to $35.00 will not require the evidence of shipment via courier. If the remediation includes principal curtailments performed post-closing, then the servicing screen-print of the applied reduction will serve as evidence. If the remediation was performed post closing and prior to the TPR file review, the TPR would not require evidence the remediation package was sent via a carrier such as XXXXX, etc. (Excluding Material Disclosure exceptions on loans subject to rescission.) Remediation for Material Disclosure violations on reacindable transactions require proof of receipt. Proof of receipt can be evidenced through receipt/delivery confirmation from courier, executed NORTC, email acknowledgement, etc. Since the lender sent the remediation via XXXXX we need some sort of proof it was received either the cashed check or communication from the borrower they received it. Reviewer Comment (2020-01-17): Letter of Explanation, Mailing Label, Copy of Refund Check, and Corrected CD provided. Confirmed recording fees were reduced to $XXXXX via Settlement Statement. Lender to provide cancelled check or communication from borrower confirming receipt of the cure. check. Typically Proof of Delivery is via tracking information from XXXXX etc. Lender provided XXXXX post mark envelope. Buyer Comment (2020-01-14): cure docs

01/28/2020

2

B

[Redact]

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

210709858

[Redact]

[Redact]

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Per guidelines: The 4506T transcripts need to be obtained from the IRS prior to closing and used to validate the income documentation used to underwrite the loan. Wage transcripts are acceptable.

Reviewer Comment (2020-01-14): Exception cleared Buyer Comment (2020-01-13): Please see attached transcripts

01/14/2020

1

A

[Redact]

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

No

210709871

[Redact]

[Redact]

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.

02/21/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

Final CD evidences Cure

C

B

C

B

A

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

210709871

[Redact]

[Redact]

Credit

Employment

Miscellaneous

The verification of employment was not obtained within 10 days of the note date.

The VOE for the co-borrower was ordered XXXXX, the day after the note date.

The representative FICO score exceeds the guideline minimum by at least XXXXX points. The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines. Borrower has worked in the same position for more than XXXXX years. Borrower has verified disposable income of at least $XXXXX. Borrower has been employed in the same industry for more than XXXXX years. The qualifying DTI on the loan is at least 10% less than the guideline maximum.

DTI at 19.74%

AMC AMC AMC AMC AMC AMC AMC,Aggregator

Reviewer Comment (2020-03-24): Client elects to waive.

03/24/2020

2

B

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

A

A

A

A

Safe Harbor QM

Safe Harbor QM

No

210709874

[Redact]

[Redact]

Compliance

Compliance

Federal Compliance

Social Security Documentation

Qualified Mortgage (Dodd-Frank 2014): Social Security income documentation insufficient.

Failed QM due to missing the required Social Security Award letter.

Reviewer Comment (2020-03-31): SSI Award letter uploaded as a trailing doc

03/31/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

A

A

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

No

210709874

[Redact]

[Redact]

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.

Failed QM due to missing the required Social Security Award letter.

Reviewer Comment (2020-03-31): SSI Award letter uploaded as a trailing doc

03/31/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

Lender to provide updated ATR/QM status

C

A

A

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

210709874

[Redact]

[Redact]

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.

Reviewer Comment (2020-03-24): Sufficient Cure Provided At Closing

03/24/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

Final CD evidences Cure

C

A

A

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

Yes

210709874

[Redact]

[Redact]

Credit

Credit

Miscellaneous

Credit Exception:

File is missing E-sign consent form.

Reviewer Comment (2020-03-30): Uploaded as a trailing doc Buyer Comment (2020-03-27): e consent uploaded

03/30/2020

1

A

[Redact]

Primary

Refinance - Cash-out - Debt Consolidation

C

A

A

A

C

A

A

A

Safe Harbor QM

Safe Harbor QM

No

210709883

[Redact]

[Redact]

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.

Page 4 does not specify the reason why this loan does not have escrows that box is blank. To cure, Letter of Explanation & Corrected Closing Disclosure

Reviewer Comment (2020-03-23): XXXXX received a corrected CD and LOE. Buyer Comment (2020-03-23): cure docs

03/23/2020

2

B

[Redact]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

210709883

[Redact]

[Redact]

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.

Credit Report Fee was disclosed on the initial LE in the amount of $XXXXX but on the final CD reads $XXXXX. It appears the borrower was not notified of this increased fee after initial LE was disclosed. Missing valid change in circumstance. To cure, PCCD, LOE, copy of refund check and proof of delivery are required.

Reviewer Comment (2020-03-23): XXXXX received PCCD indicating cure, LOE, and, refund check. Buyer Comment (2020-03-23): cure docs

03/23/2020

1

A

[Redact]

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

210709883

[Redact]

[Redact]

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 (2020-03-23): XXXXX received PCCD indicating cure, LOE, and refund check.

03/23/2020

2

B

[Redact]

Primary

Purchase

C

B

A

A

C

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes