EX-99.2 9 exhibit992-3.htm EXHIBIT 99.2, SCHEDULE 3 - COMPLIANCE FINDINGS EXCEPTIONS

Goldman Sachs - GSMBS 2020-RPL2 - Compliance Findings Exception Detail
                             
                                                         
                                                         
GS Loan Number
Seller/Servicer Loan Number
Seller Loan ID
Last Name
Purpose
Occupancy
Note Date
State
Original Loan Amount
Loan Status
Exception Date
Exception Category
Exception Sub Category
Exception Type
Exception Status
Status Change Date
Exception Grade
Loan Exception ID
Exception
Exception Detail
Exception Information
Compensating Factors
Seller Comments
Buyer Comments
Reviewer Comments
Exception Remediation
Missing Final Til
Missing Final HUD
Missing Title Policy
18937933
7090822
XXXX
XXXX
Refinance-No Cash Out
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
Right to Rescind Missing > 36 Mos
Compliance
 
XXXX
B
21752670
Right to Rescind Missing > 36 Mos
The file contains no evidence of the Right to Cancel Notice. The loan reviewed contains a note dated more than 36 months old, outside the applicable statute of limitations per 15 USC 1640(e).
           
Included
Included
Included
18937952
7148679
XXXX
XXXX
Refinance-Equity Takeout
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
The loan is in compliance with all applicable laws and regulations
Compliance
 
XXXX
A
21751886
The loan is in compliance with all applicable laws and regulations
The loan is in compliance with all applicable laws and regulations.
           
Included
Included
Missing
18938077
11664893
XXXX
XXXX
Refinance-Equity Takeout
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
Disclosed Finance Charge Must Be > = Actual Finance Charge - $100 > 36 Mos
Compliance
 
XXXX
B
21752632
Disclosed Finance Charge Must Be > = Actual Finance Charge - $100 > 36 Mos
This loan failed the TILA finance charge test.(12 CFR §1026.18(d)(1), transferred from 12 CFR §226.18(d)(1))The finance charge is XXXX The disclosed finance charge of XXXX is not considered accurate because it is understated by more than XXXX loan reviewed contains a note dated more than 36 months old, outside the applicable statute of limitations per 15 USC 1640(e)..
           
Included
Included
Included
18938077
11664893
XXXX
XXXX
Refinance-Equity Takeout
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
Disclosed Finance Charge Must Be > = Actual Finance Charge - $35 > 36 Mos
Compliance
 
XXXX
B
21752635
Disclosed Finance Charge Must Be > = Actual Finance Charge - $35 > 36 Mos
This loan failed the TILA foreclosure rescission finance charge test. (12 CFR §1026.23(h), transferred from 12 CFR §226.23(h)) The finance charge is XXXX The disclosed finance charge of XXXX is not considered accurate for purposes of rescission because it is understated by more than $35The loan reviewed contains a note dated more than 36 months old, outside the applicable statute of limitations per 15 USC 1640(e).
           
Included
Included
Included
18938454
13074380
XXXX
XXXX
Refinance-No Cash Out
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
The loan is in compliance with all applicable laws and regulations
Compliance
 
XXXX
A
21752827
The loan is in compliance with all applicable laws and regulations
The loan is in compliance with all applicable laws and regulations.
           
Included
Included
Included
18939998
16398208
XXXX
XXXX
Refinance-No Cash Out
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
The loan is in compliance with all applicable laws and regulations
Compliance
 
XXXX
A
21753129
The loan is in compliance with all applicable laws and regulations
The loan is in compliance with all applicable laws and regulations
           
Included
Included
Included
18939884
7602131853
XXXX
XXXX
Other
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Closing
HUD-1 Final
Closing
 
XXXX
B
21752931
HUD-1 Final
It could not be determined that the HUD-1 provided in the loan file was the FINAL binding HUD-1. Missing
           
Missing
Missing
Included
18939884
7602131853
XXXX
XXXX
Other
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
Missing HUD
Compliance
 
XXXX
 
21752933
Missing HUD
There is no evidence of a HUD-1 Settlement Statement provided in the loan file. The auditor could not evaluate compliance to agency guidelines.
           
Missing
Missing
Included
18939884
7602131853
XXXX
XXXX
Other
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
TIL Missing
Compliance
 
XXXX
 
21752934
TIL Missing
There was no evidence of any TILs in the loan file. The auditor could not evaluate compliance to agency guidelines.
           
Missing
Missing
Included
18939884
7602131853
XXXX
XXXX
Other
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
Missing Note
Compliance
 
XXXX
 
21752935
Missing Note
The Note was missing from the file. The auditor could not evaluate compliance to agency guidelines.
           
Missing
Missing
Included
18939884
7602131853
XXXX
XXXX
Other
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
Right to Rescind Missing
Compliance
 
XXXX
 
21752937
Right to Rescind Missing
The file contains no evidence of the Right to Cancel Notice.
           
Missing
Missing
Included
18939644
17307943
XXXX
XXXX
Refinance-Equity Takeout
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
The loan is in compliance with all applicable laws and regulations
Compliance
 
XXXX
A
21754209
The loan is in compliance with all applicable laws and regulations
The loan is in compliance with all applicable laws and regulations
           
Included
Included
Included
18934347
17590043
XXXX
XXXX
Refinance-No Cash Out
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
Disclosures Federal Late
Compliance
 
XXXX
B
21695348
Disclosures Federal Late
The following disclosures provided in the loan file were not disclosed within 3 business days of the not able to application date. Service disclosures. The loan file does not contain an initial application to determine if the Servicing Disclosure was delivered within 3 business days from the application date.
           
Included
Included
Missing
18934362
17589854
XXXX
XXXX
Refinance-Equity Takeout
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Closing
Miscellaneous Closing Documentation
Closing
 
XXXX
 
21692071
Miscellaneous Closing Documentation
There were additional observations regarding the closing documentation. The flood cert was missing from the loan file.
           
Missing
Missing
Included
18934362
17589854
XXXX
XXXX
Refinance-Equity Takeout
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
Final TIL
Compliance
 
XXXX
 
21692064
Final TIL
The initial TIL and any revised TIL(s) could not be located in the loan file. As a result the following reviews could not be performed: Federal TILA, Section 32, Federal, State, and Local High Costs Test, Anti-Predatory Lending statutes.
           
Missing
Missing
Included
18934362
17589854
XXXX
XXXX
Refinance-Equity Takeout
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
Missing HUD
Compliance
 
XXXX
 
21692068
Missing HUD
There is no evidence of a HUD-1 Settlement Statement provided in the loan file. As a result the following reviews could not be performed: Federal TILA, Section 32, Federal, State, and Local High Costs Test, Anti-Predatory Lending statutes.
           
Missing
Missing
Included
18934362
17589854
XXXX
XXXX
Refinance-Equity Takeout
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
Disclosures Federal Missing
Compliance
 
XXXX
 
21692070
Disclosures Federal Missing
The file was found to be missing the following federally required disclosures: Servicing Disclosure.
           
Missing
Missing
Included
18934362
17589854
XXXX
XXXX
Refinance-Equity Takeout
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
Right to Rescind
Compliance
 
XXXX
 
21692077
Right to Rescind
The Right to Cancel was missing from the loan file. The loan reviewed contains a note date more than 36 months old and the statute of limitations have run out.
           
Missing
Missing
Included
18934582
17586983
XXXX
XXXX
Refinance-No Cash Out
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
The loan is in compliance with all applicable laws and regulations
Compliance
 
XXXX
A
21691407
The loan is in compliance with all applicable laws and regulations
The loan is in compliance with all applicable laws and regulations
           
Not Signed
Included
Included
18934762
17513060
XXXX
XXXX
Purchase
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
Disclosures Federal Missing
Compliance
 
XXXX
 
21691510
Disclosures Federal Missing
The file was found to be missing one or more of the federally required servicing disclosures. Service Provider List.
           
Included
Included
Included
18934783
17510868
XXXX
XXXX
Purchase
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
Disclosures Federal Missing
Compliance
 
XXXX
 
21694785
Disclosures Federal Missing
The file was found to be missing one or more of the federally required disclosures. Servicing Disclosure.
           
Included
Included
Included
18934784
17510819
XXXX
XXXX
Purchase
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
The loan is in compliance with all applicable laws and regulations
Compliance
 
XXXX
A
21691258
The loan is in compliance with all applicable laws and regulations
The loan is in compliance with all applicable laws and regulations
           
Included
Included
Included
18934796
17510041
XXXX
XXXX
Purchase
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
Missing ARM Disclosure
Compliance
 
XXXX
C
21691299
Missing ARM Disclosure
The file contains no evidence that the ARM Disclosure was provided to the borrower.
           
Included
Included
Included
18934796
17510041
XXXX
XXXX
Purchase
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
Disclosures Federal Missing
Compliance
 
XXXX
 
21691300
Disclosures Federal Missing
The file was found to be missing one or more of the federally required disclosures. Service Providers List.
           
Included
Included
Included
18934796
17510041
XXXX
XXXX
Purchase
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
Introductory Rate
Compliance
 
XXXX
C
21691334
Introductory Rate
The interest rate used at consummation is determined to be a discounted introductory rate based on information provided in the loan file. Per Reg Z 1026.18(s)(iii), the Introductory Rate Notice required was not disclosed on the final TIL.
           
Included
Included
Included
18934828
17506601
XXXX
XXXX
Purchase
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
Disclosures Federal Missing
Compliance
 
XXXX
 
21692112
Disclosures Federal Missing
The file was found to be missing one or more of the federally required disclosures; Servicing Disclosure.
           
Included
Included
Included
18934828
17506601
XXXX
XXXX
Purchase
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
Missing ARM Disclosure
Compliance
 
XXXX
C
21692113
Missing ARM Disclosure
The file contains no evidence that the ARM Disclosure was provided to the borrower.
           
Included
Included
Included
18934832
17506114
XXXX
XXXX
Purchase
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
Missing ARM Disclosure
Compliance
 
XXXX
C
21684163
Missing ARM Disclosure
The file contains no evidence that the ARM Disclosure was provided to the borrower.
           
Included
Included
Included
18934832
17506114
XXXX
XXXX
Purchase
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
Disclosures Federal Missing
Compliance
 
XXXX
 
21684164
Disclosures Federal Missing
The file was found to be missing the following federally required disclosures: Servicing Disclosure.
           
Included
Included
Included
18934832
17506114
XXXX
XXXX
Purchase
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
Introductory Rate
Compliance
 
XXXX
C
21684486
Introductory Rate
The interest rate used at consummation is determined to be a discounted introductory rate based on information provided in the loan file. Per Reg Z 1026.18(s)(iii), the Introductory Rate Notice required was not disclosed on the final TIL.
           
Included
Included
Included
18934850
17504218
XXXX
XXXX
Refinance-No Cash Out
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
Missing ARM Disclosure
Compliance
 
XXXX
C
21694686
Missing ARM Disclosure
The file contains no evidence that the ARM Disclosure was provided to the borrower.
           
Included
Included
Missing
18934850
17504218
XXXX
XXXX
Refinance-No Cash Out
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
Introductory Rate
Compliance
 
XXXX
C
21694688
Introductory Rate
The interest rate used at consummation is determined to be a discounted introductory rate based on information provided in the loan file. Per Reg Z 1026.18(s)(iii), the Introductory Rate Notice required was not disclosed on the final TIL.
           
Included
Included
Missing
18934850
17504218
XXXX
XXXX
Refinance-No Cash Out
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
Disclosures Federal
Compliance
 
XXXX
B
21694710
Disclosures Federal
The file was found to be missing one or more of the federally required disclosures or they were found to contain errors. Servicing Disclosure.
           
Included
Included
Missing
18935983
17339136
XXXX
XXXX
Other
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
Introductory Rate
Compliance
 
XXXX
C
21691336
Introductory Rate
The interest rate used at consummation is determined to be a discounted introductory rate based on information provided in the loan file. Per Reg Z 1026.18(s)(iii), the Introductory Rate Notice required was not disclosed on the final TIL.
           
Included
Included
Missing
18935983
17339136
XXXX
XXXX
Other
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
Disclosures Federal Late
Compliance
 
XXXX
B
21691341
Disclosures Federal Late
The Servicing Disclosure provided in the loan file was not dated within 3 business days of the application date of XXXX
           
Included
Included
Missing
18936242
16370702
XXXX
XXXX
Refinance-Equity Takeout
XXXX
XXXX
XXXX
XXXX
In Print Batch
XXXX
Compliance
Disclosures Federal Late
Compliance
 
XXXX
B
21684070
Disclosures Federal Late
The following disclosures provided in the loan file were not disclosed within 3 business days of the application date, XXXX Servicing Disclosure.
           
Included
Included
Included
23227521
7602016249
XXXX
XXXX
Purchase
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
Appraisal Notice Late
Compliance
 
XXXX
B
21774444
Appraisal Notice Late
The Notice to Applicant of Right to Receive a Copy of an Appraisal Report was not disclosed within 3 days of the application date.
           
Included
Included
Included
23227521
7602016249
XXXX
XXXX
Purchase
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
TRID- SPL Late
Compliance
 
XXXX
B
21774531
TRID- SPL Late
A written list of Service Providers was not disclosed within 3 business days of the application date or 7 business days before the Consummation Date.
           
Included
Included
Included
23227521
7602016249
XXXX
XXXX
Purchase
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Credit
The loan meets all applicable credit guidelines
Credit
 
XXXX
A
21774331
The loan meets all applicable credit guidelines
The loan meets all applicable credit guidelines.
           
Included
Included
Included
23227529
7602016079
XXXX
XXXX
Purchase
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
TIL Missing
Compliance
 
XXXX
C
21771135
TIL Missing
There was no evidence of any TILs in the loan file. The auditor could not evaluate compliance to agency guidelines.
           
Missing
Missing
Included
23227529
7602016079
XXXX
XXXX
Purchase
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
Missing HUD
Compliance
 
XXXX
C
21771138
Missing HUD
There is no evidence of a HUD-1 Settlement Statement provided in the loan file. The auditor could not evaluate compliance to agency guidelines.
           
Missing
Missing
Included
23227529
7602016079
XXXX
XXXX
Purchase
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
Flood Cert Missing
Compliance
 
XXXX
B
21771139
Flood Cert Missing
The Flood Cert is missing from the Loan file.
           
Missing
Missing
Included
23227694
7602017172
XXXX
XXXX
Cash out Refinance
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
Missing HUD
Compliance
 
XXXX
C
21771924
Missing HUD
There is no evidence of a HUD-1 Settlement Statement provided in the loan file. The auditor could not evaluate compliance to agency guidelines.
           
Missing
Missing
Included
23227694
7602017172
XXXX
XXXX
Cash out Refinance
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
TIL Missing
Compliance
 
XXXX
C
21771926
TIL Missing
There was no evidence of any TILs in the loan file. The auditor could not evaluate compliance to agency guidelines.
           
Missing
Missing
Included
23227694
7602017172
XXXX
XXXX
Cash out Refinance
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
Flood Cert Missing
Compliance
 
XXXX
B
21771927
Flood Cert Missing
The Flood Cert is missing from the Loan file.
           
Missing
Missing
Included
23227725
7602016964
XXXX
XXXX
Rate/Term Refinance
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
Flood Cert Missing
Compliance
 
XXXX
B
21772590
Flood Cert Missing
The Flood Cert was missing from the Loan file.
           
Included
Included
Included
23227759
7602015405
XXXX
XXXX
Purchase
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
TIL Missing
Compliance
 
XXXX
C
21771436
TIL Missing
There was no evidence of any TILs in the loan file. The auditor could not evaluate compliance to agency guidelines.
           
Missing
Included
Missing
23227759
7602015405
XXXX
XXXX
Purchase
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
Flood Cert Missing
Compliance
 
XXXX
B
21771467
Flood Cert Missing
The Flood Cert is missing from the Loan file.
           
Missing
Included
Missing
23227759
7602015405
XXXX
XXXX
Purchase
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
Inaccurate Mortgage
Compliance
 
XXXX
C
21771481
Inaccurate Mortgage
The Mortgage was not completed accurately. Missing Manufactured Home Rider.
           
Missing
Included
Missing
23227784
7602015900
XXXX
XXXX
Cash out Refinance
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
Initial GFE Late
Compliance
 
XXXX
B
21774004
Initial GFE Late
The Initial GFE Date is more than 3 business days from the Application Date.
           
Included
Included
Included
23227792
7602016883
XXXX
XXXX
Cash Out Other
XXXX
XXXX
XXXX
XXXX
Sent to Client
XXXX
Compliance
The loan is in compliance with all applicable laws and regulations
Compliance
 
XXXX
A
21773510
The loan is in compliance with all applicable laws and regulations
The loan is in compliance with all applicable laws and regulations
           
Included
Included
Included