EX-99.2 10 exhibit992-4.htm EXHIBIT 99.2, SCHEDULE 4 - COMPLIANCE FINDINGS LOAN LEVEL

GS Loan Number
Seller/Servicing Loan Number
Borrower Last Name
Overall Event Level Grade
Final Credit Event
Credit Exception(s)
Credit Comment(s)
Final Compliance Event
Compliance Exception(s)
Compliance Comment(s)
Subject to Predatory
Fees Captured for Testing
Document Used for Testing
State
Origination Date
Purpose at Origination
Occupancy at Origination
Originator
Original Principal Balance
Unpaid Principal Balance
Missing Final Til
Missing Final HUD
Missing Title Policy
18937933
7090822
XXXX
2
0
 
 
2

*** (Open) Right to Rescind Missing > 36 Mos:- EV2
*** (Open) Compliance

COMMENT:XXXX

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).
Yes
Yes
Final HUD1
XXXX
XXXX
Refinance-No Cash Out
XXXX
 
XXXX
 
1
1
1
18937952
7148679
XXXX
1
0
 
 
1

*** (Open) The loan is in compliance with all applicable laws and regulations:- EV1
*** (Open) Compliance

COMMENT: XXXX

The loan is in compliance with all applicable laws and regulations.
Yes
Yes
Final HUD1
XXXX
XXXX
Refinance-Equity Takeout
XXXX
 
XXXX
 
1
1
0
18938077
11664893
XXXX
2
0
 
 
2

*** (Open) Disclosed Finance Charge Must Be > = Actual Finance Charge - $100 > 36 Mos:- EV2

*** (Open) Disclosed Finance Charge Must Be > = Actual Finance Charge - $35 > 36 Mos:- EV2
*** (Open) Compliance

COMMENT: XXXX

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)..



*** (Open) Compliance

COMMENT: 2018-06-08:

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 $119,913.38. The disclosed finance charge of $119,698.38 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).
Yes
Yes
Final HUD1
XXXX
XXXX
Refinance-Equity Takeout
XXXX
 
XXXX
 
1
1
1
18938454
13074380
XXXX
1
0
 
 
1

*** (Open) The loan is in compliance with all applicable laws and regulations:- EV1
*** (Open) Compliance

COMMENT: XXXX

The loan is in compliance with all applicable laws and regulations.
Yes
Yes
Final HUD1

TIL Itemization
XXXX
XXXX
Refinance-No Cash Out
XXXX
 
XXXX
 
1
1
1
18939998
16398208
XXXX
1
0
 
 
1

*** (Open) The loan is in compliance with all applicable laws and regulations:- EV1
*** (Open) Compliance

COMMENT: XXXX

The loan is in compliance with all applicable laws and regulations
Yes
Yes
Final HUD1
XXXX
XXXX
Refinance-No Cash Out
XXXX
 
XXXX
 
1
1
1
18939884
7602131853
XXXX
4
0
 
 
4

*** (Open) HUD-1 Final:- EV2

*** (Open) Missing HUD:- EV4

*** (Open) TIL Missing:- EV4

*** (Open) Missing Note:- EV4

*** (Open) Right to Rescind Missing:- EV4
*** (Open) Closing

COMMENT: XXXX

It could not be determined that the HUD-1 provided in the loan file was the FINAL binding HUD-1. Missing



*** (Open) Compliance

COMMENT: 2018-06-09:

There is no evidence of a HUD-1 Settlement Statement provided in the loan file. The auditor could not evaluate compliance to agency guidelines.



*** (Open) Compliance

COMMENT: 2018-06-09:

There was no evidence of any TILs in the loan file. The auditor could not evaluate compliance to agency guidelines.



*** (Open) Compliance

COMMENT: 2018-06-09:

The Note was missing from the file. The auditor could not evaluate compliance to agency guidelines.



*** (Open) Compliance

COMMENT: 2018-06-09:

The file contains no evidence of the Right to Cancel Notice.
No
No
Missing
XXXX
XXXX
Other
XXXX
 
XXXX
 
0
0
1
18939644
17307943
XXXX
1
0
 
 
1

*** (Open) The loan is in compliance with all applicable laws and regulations:- EV1
*** (Open) Compliance

COMMENT: XXXX

The loan is in compliance with all applicable laws and regulations
Yes
Yes
Final HUD1
XXXX
XXXX
Refinance-Equity Takeout
XXXX
 
XXXX
 
1
1
1
18934347
17590043
XXXX
2
0
 
 
2

*** (Open) Disclosures Federal Late:- EV2
*** (Open) Compliance

COMMENT: XXXX

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.
 
 
 
XXXX
XXXX
Refinance-No Cash Out
XXXX
 
XXXX
 
1
1
0
18934362
17589854
XXXX
4
0
 
 
4

*** (Open) Final TIL:- EV4

*** (Open) Missing HUD:- EV4

*** (Open) Disclosures Federal Missing:- EV4

*** (Open) Miscellaneous Closing Documentation:- EV4

*** (Open) Right to Rescind:- EV4
*** (Open) Compliance

COMMENT: XXXX

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.



*** (Open) Compliance

COMMENT: 2018-05-08:

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.



*** (Open) Compliance

COMMENT: 2018-05-08:

The file was found to be missing the following federally required disclosures: Servicing Disclosure.



*** (Open) Closing

COMMENT: 2018-05-08:

There were additional observations regarding the closing documentation. The flood cert was missing from the loan file.



*** (Open) Compliance

COMMENT: 2018-05-08:

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.
Yes
No
Missing
XXXX
XXXX
Refinance-Equity Takeout
XXXX
 
XXXX
 
0
0
1
18934582
17586983
XXXX
1
0
 
 
1

*** (Open) The loan is in compliance with all applicable laws and regulations:- EV1
*** (Open) Compliance

COMMENT: XXXX

The loan is in compliance with all applicable laws and regulations
Yes
Yes
Final HUD1
XXXX
XXXX
Refinance-No Cash Out
XXXX
 
XXXX
 
5
1
1
18934762
17513060
XXXX
4
0
 
 
4

*** (Open) Disclosures Federal Missing:- EV4
*** (Open) Compliance

COMMENT:XXXX

The file was found to be missing one or more of the federally required servicing disclosures. Service Provider List.
Yes
Yes
Missing
XXXX
XXXX
Purchase
XXXX
 
XXXX
 
1
1
1
18934783
17510868
XXXX
4
0
 
 
4

*** (Open) Disclosures Federal Missing:- EV4
*** (Open) Compliance

COMMENT:XXXX

The file was found to be missing one or more of the federally required disclosures. Servicing Disclosure.
Yes
Yes
Missing
XXXX
XXXX
Purchase
XXXX
 
XXXX
 
1
1
1
18934784
17510819
XXXX
1
0
 
 
1

*** (Open) The loan is in compliance with all applicable laws and regulations:- EV1
*** (Open) Compliance

COMMENT: XXXX

The loan is in compliance with all applicable laws and regulations
Yes
Yes
Final HUD1
XXXX
XXXX
Purchase
XXXX
 
XXXX
 
1
1
1
18934796
17510041
XXXX
3
0
 
 
3

*** (Open) Missing ARM Disclosure:- EV3

*** (Open) Disclosures Federal Missing:- EV4

*** (Open) Introductory Rate:- EV3
*** (Open) Compliance

COMMENT: XXXX

The file contains no evidence that the ARM Disclosure was provided to the borrower.



*** (Open) Compliance

COMMENT: 2018-05-07:

The file was found to be missing one or more of the federally required disclosures. Service Providers List.



*** (Open) Compliance

COMMENT: 2018-05-07:

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.
Yes
Yes
Missing

TIL Itemization
XXXX
XXXX
Purchase
XXXX
 
XXXX
 
1
1
1
18934828
17506601
XXXX
3
0
 
 
3

*** (Open) Disclosures Federal Missing:- EV4

*** (Open) Missing ARM Disclosure:- EV3
*** (Open) Compliance

COMMENT: XXXX

The file was found to be missing one or more of the federally required disclosures; Servicing Disclosure.



*** (Open) Compliance

COMMENT: 2018-05-08:

The file contains no evidence that the ARM Disclosure was provided to the borrower.
Yes
Yes
Missing
XXXX
XXXX
Purchase
XXXX
 
XXXX
 
1
1
1
18934832
17506114
XXXX
3
0
 
 
3

*** (Open) Missing ARM Disclosure:- EV3

*** (Open) Disclosures Federal Missing:- EV4

*** (Open) Introductory Rate:- EV3
*** (Open) Compliance

COMMENT: XXXX

The file contains no evidence that the ARM Disclosure was provided to the borrower.



*** (Open) Compliance

COMMENT: 2018-05-05:

The file was found to be missing the following federally required disclosures: Servicing Disclosure.



*** (Open) Compliance

COMMENT: 2018-05-05:

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.
Yes
Yes
Missing

TIL Itemization
XXXX
XXXX
Purchase
XXXX
 
XXXX
 
1
1
1
18934850
17504218
XXXX
3
0
 
 
3

*** (Open) Missing ARM Disclosure:- EV3

*** (Open) Introductory Rate:- EV3

*** (Open) Disclosures Federal:- EV2
*** (Open) Compliance

COMMENT: XXXX

The file contains no evidence that the ARM Disclosure was provided to the borrower.



*** (Open) Compliance

COMMENT: 2018-05-08:

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.



*** (Open) Compliance

COMMENT: 2018-05-08:

The file was found to be missing one or more of the federally required disclosures or they were found to contain errors. Servicing Disclosure.
Yes
Yes
Missing

TIL Itemization
XXXX
XXXX
Refinance-No Cash Out
XXXX
 
XXXX
 
1
1
0
18935983
17339136
XXXX
3
0
 
 
3

*** (Open) Introductory Rate:- EV3

*** (Open) Disclosures Federal Late:- EV2
*** (Open) Compliance

COMMENT: XXXX

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.



*** (Open) Compliance

COMMENT: 2018-05-07:

The Servicing Disclosure provided in the loan file was not dated within 3 business days of the application date of 03/18/2005.
Yes
Yes
Missing

TIL Itemization
XXXX
XXXX
Other
XXXX
 
XXXX
 
1
1
0
18936242
16370702
XXXX
2
0
 
 
2

*** (Open) Disclosures Federal Late:- EV2
*** (Open) Compliance

COMMENT: XXXX

The following disclosures provided in the loan file were not disclosed within 3 business days of the application date, XXXX Servicing Disclosure.
Yes
Yes
Missing
XXXX
XXXX
Refinance-Equity Takeout
XXXX
 
XXXX
 
1
1
1
23227521
7602016249
XXXX
2
1

*** (Open) The loan meets all applicable credit guidelines:- EV1
*** (Open) Credit

COMMENT: XXXX

The loan meets all applicable credit guidelines.
2

*** (Open) Appraisal Notice Late:- EV2

*** (Open) TRID- SPL Late:- EV2
*** (Open) Compliance

COMMENT: XXXX

The Notice to Applicant of Right to Receive a Copy of an Appraisal Report was not disclosed within 3 days of the application date.



*** (Open) Compliance

COMMENT: 2018-07-02:

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.
Yes
Yes
Final HUD1
XXXX
XXXX
Purchase
XXXX
 
XXXX
 
1
1
1
23227529
7602016079
XXXX
3
0
 
 
3

*** (Open) TIL Missing:- EV3

*** (Open) Missing HUD:- EV3

*** (Open) Flood Cert Missing:- EV2
*** (Open) Compliance

COMMENT: XXXX

There was no evidence of any TILs in the loan file. The auditor could not evaluate compliance to agency guidelines.



*** (Open) Compliance

COMMENT: 2018-06-30:

There is no evidence of a HUD-1 Settlement Statement provided in the loan file. The auditor could not evaluate compliance to agency guidelines.



*** (Open) Compliance

COMMENT: 2018-06-30:

The Flood Cert is missing from the Loan file.
Yes
No
Missing
XXXX
XXXX
Purchase
XXXX
 
XXXX
 
0
0
1
23227694
7602017172
XXXX
3
0
 
 
3

*** (Open) Missing HUD:- EV3

*** (Open) TIL Missing:- EV3

*** (Open) Flood Cert Missing:- EV2
*** (Open) Compliance

COMMENT: XXXX

There is no evidence of a HUD-1 Settlement Statement provided in the loan file. The auditor could not evaluate compliance to agency guidelines.



*** (Open) Compliance

COMMENT: 2018-07-02:

There was no evidence of any TILs in the loan file. The auditor could not evaluate compliance to agency guidelines.



*** (Open) Compliance

COMMENT: 2018-07-02:

The Flood Cert is missing from the Loan file.
Yes
No
Missing
XXXX
XXXX
Cash out Refinance
XXXX
 
XXXX
 
0
0
1
23227725
7602016964
XXXX
2
0
 
 
2

*** (Open) Flood Cert Missing:- EV2
*** (Open) Compliance

COMMENT: XXXX

The Flood Cert was missing from the Loan file.
Yes
Yes
Final HUD1
XXXX
XXXX
Rate/Term Refinance
XXXX
 
XXXX
 
1
1
1
23227759
7602015405
XXXX
3
0
 
 
3

*** (Open) TIL Missing:- EV3

*** (Open) Flood Cert Missing:- EV2

*** (Open) Inaccurate Mortgage:- EV3
*** (Open) Compliance

COMMENT: XXXX

There was no evidence of any TILs in the loan file. The auditor could not evaluate compliance to agency guidelines.



*** (Open) Compliance

COMMENT: 2018-07-02:

The Flood Cert is missing from the Loan file.



*** (Open) Compliance

COMMENT: 2018-07-02:

The Mortgage was not completed accurately. Missing Manufactured Home Rider.
Yes
No
Missing

TIL Itemization
XXXX
XXXX
Purchase
XXXX
 
XXXX
 
0
1
0
23227784
7602015900
XXXX
2
0
 
 
2

*** (Open) Initial GFE Late:- EV2
*** (Open) Compliance

COMMENT: XXXX

The Initial GFE Date is more than 3 business days from the Application Date.
Yes
Yes
Final HUD1
XXXX
XXXX
Cash out Refinance
XXXX
 
XXXX
 
1
1
1
23227792
7602016883
XXXX
1
0
 
 
1

*** (Open) The loan is in compliance with all applicable laws and regulations:- EV1
*** (Open) Compliance

COMMENT: XXXX

The loan is in compliance with all applicable laws and regulations
Yes
Yes
Final HUD1
XXXX
XXXX
Cash Out Other
XXXX
 
XXXX
 
1
1
1