0000929638-25-001796.txt : 20250506 0000929638-25-001796.hdr.sgml : 20250506 20250506170044 ACCESSION NUMBER: 0000929638-25-001796 CONFORMED SUBMISSION TYPE: ABS-15G PUBLIC DOCUMENT COUNT: 17 CONFORMED PERIOD OF REPORT: 20250506 ITEM INFORMATION: Findings and Conclusions of the Third Party Due Diligence Provider Obtained by the Issuer FILED AS OF DATE: 20250506 DATE AS OF CHANGE: 20250506 ABS RULE: RULE-15GA2 REGISTERED ENTITY: N ABS ASSET CLASS: Residential mortgages - Other/Combined FILER: COMPANY DATA: COMPANY CONFORMED NAME: GS MORTGAGE SECURITIES CORP CENTRAL INDEX KEY: 0000807641 STANDARD INDUSTRIAL CLASSIFICATION: ASSET-BACKED SECURITIES [6189] ORGANIZATION NAME: Office of Structured Finance EIN: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: ABS-15G SEC ACT: Dodd Frank Act SEC FILE NUMBER: 025-01949 FILM NUMBER: 25918144 BUSINESS ADDRESS: STREET 1: 85 BROAD STREET CITY: NEW YORK STATE: NY ZIP: 10004 BUSINESS PHONE: 212-357-8721 MAIL ADDRESS: STREET 1: 85 BROAD STREET CITY: NEW YORK STATE: NY ZIP: 10004 DEPOSITOR: COMPANY DATA: COMPANY CONFORMED NAME: GS MORTGAGE SECURITIES CORP CENTRAL INDEX KEY: 0000807641 STANDARD INDUSTRIAL CLASSIFICATION: ASSET-BACKED SECURITIES [6189] ORGANIZATION NAME: Office of Structured Finance EIN: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: ABS-15G SEC ACT: Dodd Frank Act BUSINESS ADDRESS: STREET 1: 85 BROAD STREET CITY: NEW YORK STATE: NY ZIP: 10004 BUSINESS PHONE: 212-357-8721 MAIL ADDRESS: STREET 1: 85 BROAD STREET CITY: NEW YORK STATE: NY ZIP: 10004 ABS-15G 1 abs15g.htm

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM ABS-15G
ASSET-BACKED SECURITIZER
REPORT PURSUANT TO SECTION 15G OF
THE SECURITIES EXCHANGE ACT OF 1934

Check the appropriate box to indicate the filing obligation to which this form is intended to satisfy:

___	Rule 15Ga-1 under the Exchange Act (17 CFR 240.15Ga-1) for the reporting period _______ to _______.

Date of Report (Date of earliest event reported):	__________________
Commission File Number of securitizer:	__________________
Central Index Key Number of securitizer:	__________________

Name and telephone number, including area code, of the person to contact in connection with this filing.

Indicate by check mark whether the securitizer has no activity to report for the initial period pursuant to Rule 15Ga-1(c)(1) [ ]

Indicate by check mark whether the securitizer has no activity to report for the quarterly period pursuant to Rule 15Ga-1(c)(2)(i) [ ]

Indicate by check mark whether the securitizer has no activity to report for the annual period pursuant to Rule 15Ga-1(c)(2)(ii) [ ]

X	Rule 15Ga-2 under the Exchange Act (17 CFR 240.15Ga-2)

Central Index Key Number of depositor: 0000807641

GS Mortgage-Backed Securities Trust 2025-PJ5

(Exact name of issuing entity as specified in its charter)

Central Index Key Number of issuing entity:

Manju Madhavan, (212) 902-5268

Name and telephone number, including area code, of the person to
contact in connection with this filing.

INFORMATION TO BE INCLUDED IN THE REPORT

Item 2.01.

Findings and Conclusions of a Third Party Due Diligence Report Obtained By the Issuer

The disclosures required by Rule 15Ga-2 (17 CFR 240.15Ga-2) are attached as Exhibits to this Form ABS-15G. Please see the Exhibit Index for the related information.

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the reporting entity has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.

Dated: May 6, 2025

GS Mortgage Securities Corp.
(Depositor)

By:    /s/ Manju Madhavan
        Name: Manju Madhavan
        Title:   President

EXHIBIT INDEX

Exhibit Number

99.1 Disclosures required by Rule 15Ga-2 for AMC Diligence, LLC

Schedule 1 – Executive Summary/Narrative

Schedule 2 – Rating Agency Grades

Schedule 3 – Exception Grades

Schedule 4 – Valuation Report

Schedule 5 – Supplemental Data

Schedule 6 – Data Compare

99.2 Disclosures required by Rule 15Ga-2 for Opus Capital Markets Consultants, LLC

Schedule 1 – Executive Summary/Narrative

Schedule 2 – Findings Report

Schedule 3 – Rating Agency Grades Report

Schedule 4 – ATR OR QM Report

Schedule 5 – Supplemental Data Extract

Schedule 6 – Valuation Report

Schedule 7 – Data Compare Report

EX-99.1 2 exhibit991-1.htm EXHIBIT 99.1, SCHEDULE 1 - EXECUTIVE SUMMARY/NARRATIVE

EXECUTIVE SUMMARY

DESCRIPTION OF SERVICES

(1) Type of assets that were reviewed.

AMC Diligence, LLC (“AMC”) performed certain due diligence services described below on conforming and non-conforming residential mortgages acquired from various parties. The review was conducted on behalf of Goldman Sachs Mortgage Company (“Client”) during multiple transactions from December 2023 to April 2025 via files imaged and provided by Goldman Sachs Mortgage Company (the “Review”).

The loans in the Review carried origination dates between February 2023 and March 2025.

(2) Sample size of the assets reviewed.

The Review was conducted on two hundred forty-four (244) mortgage loans with an aggregate original principal balance of approximately $265.837 million. The Review did not cover 100% of the loans in the securitization population; however, the Review did cover the portion of the securitization population reviewed by AMC.

(3) Determination of the sample size and computation.

AMC is not aware of the overall sample size for the securitization as the Review only covered the portion of the loans in the securitization reviewed by AMC.

(4) Quality or integrity of information or data about the assets: review and methodology.

AMC compared data fields on the bid tape provided by Client to the data found in the actual file as captured by AMC. This comparison, when data was available, included the following data fields:

# of Units	Investor: Qualifying Total Debt Ratio	Originator Loan Designation
Amortization Term	Lender	PITIA Reserves Months
Amortization Type	Lien Position	Product Description
Balloon Flag	Note Date	Property Type
Borrower First Name	Occupancy	Purpose
Borrower FTHB	Original CLTV	Refi Purpose
Borrower Last Name	Original HCLTV	Representative FICO
Borrower SSN	Original Interest Rate	State
City	Original Loan Amount	Street
Contract Sales Price	Original LTV	Zip
Decision System	Original Term
First Payment Date	Origination Channel

Additionally, AMC verified (i) listed borrowers signed documents requiring signature, (ii) borrowers signing documents were eighteen (18) years or older at the time of the mortgage loan origination, (iii) that all riders required by the terms of the mortgage and mortgage note were attached to the respective document, (iv) that social security numbers across documents were consistent, and (v) debt-to-income ratio (“DTI(s)”), and/or loan-to-value ratios (“LTV(s)”) used in the assessment of conformity guidelines.

(5) Origination of the assets and conformity to stated underwriting or credit extension guidelines, standards, criteria or other requirements: review and methodology.

AMC reviewed asset origination to determine conformity to the stated underwriting or credit extension guidelines, standards, criteria or other requirements, including, as applicable, the Ability to Repay and Qualified Mortgage requirements described below, that were provided to AMC and/or as directed by Client. When applicable, a review of the mortgage loan file to the Automated Underwriting System output within the file was also performed.

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Credit Application: For the Credit Application, AMC verified that the application: (i) was signed by all listed borrowers, (ii) was substantially filled out, (iii) contained all known borrower-owned properties on the Real Estate Owned section 2, and (iv) included the borrower’s employment history.

Credit Report: AMC’s review included confirming that a credit report, that met guideline requirements, was present for each borrower and that such borrower’s credit profile adhered to guidelines. In order to make this determination, AMC: (i) captured the monthly consumer debt payments for use in relevant calculations, (ii) noted and researched the Real Estate Owned and fraud alerts, (iii) gathered liabilities listed on the credit report to be included in the debt to income ratio as appropriate, and (iv) gathered data required for the ASF tape submission including (a) the most recent FICO (scores from Equifax, Experian, and Transunion if available), (b) the most recent FICO date, (c) the longest trade line, (d) the maximum trade line, (e) the number of trade lines, and (f) the credit usage ratio.

Employment and Income: AMC determined whether applicable supporting employment and income documentation required by the guidelines, and as applicable Appendix Q or ATR, was present in the mortgage loan file and where possible, wasn’t fraudulent. This documentation was used to verify whether the income used to qualify the mortgage loan was calculated in accordance with guidelines and may have included items such as: (i) verbal or written verification of employment, (ii) pay stubs, (iii) W-2 forms, (iv) tax returns, (v) financial statements, and (vi) IRS tax transcripts.

Asset Review: AMC assessed whether the asset documentation required by the guidelines, and as applicable, Appendix Q or ATR, was present in the mortgage loan file. Utilizing this documentation, AMC completed a review of the reserve calculation and any large deposits. Documentation verifying assets for down payment, closing costs, prepaid items and reserves may have included: (i) verification-of-deposit (“VOD(s)”), (ii) depository account statements, (iii) stock or security account statements, (iv) gift funds, (v) escrow or earnest money deposits, and (vi) settlement statements or other evidence of conveyance and transfer of funds (if a sale of assets was involved).

Hazard/Flood Insurance/Taxes: A review of the insurance present on the mortgage loan was also performed by AMC. During the course of this review, AMC (i) verified that the hazard insurance met the minimum required amount of coverage in the guidelines, (ii) confirmed that the mortgage clause listed the lender’s name and “its successors and assigns,”, (iii) confirmed that the premium amount on both the hazard and flood insurance matched what was used in the debt-to-income (“DTI”) calculations, (iv) reviewed the tax certificate to verify and compare monthly escrows used to calculate DTI matched and that taxes were current, (v) confirmed that the flood certification was for the correct borrower, property, lender and mortgage loan number and was a “Life of Loan” certification, and (vi) completed other property specific items including (a) for condominium properties, confirming that the blanket policy met the minimum amount of coverage in the guidelines and (b) for properties in a flood zone per the flood certification, confirming that flood insurance met guideline requirements and met the minimum required amount of coverage in the guidelines.

DU/LP Review: When a DU/LP form is provided, AMC (i) confirmed and captured recommendations and (ii) verified that (a) red flags listed on the DU/LP were addressed by the underwriter, (b) listed credit conditions were cleared by the underwriter, and (c) the final DU/LP in the file contained data that matched the data gathered from documents in the file. All mortgage loans are manually underwritten with documentation requirements determined by Client guidelines and the AUS findings.

Occupancy Review: AMC confirmed the property occupancy is consistent with the mortgage loan approval and borrowers’ application disclosure based solely on information contained in the mortgage loan file and any fraud report obtained in connection with the mortgage loan.

Guideline Review: During the course of the review, AMC confirmed the mortgage loan was originated in accordance with required guidelines by reviewing conformity of mortgage loan, transaction type, and borrower characteristics to stated guidelines. Mortgage characteristics examined included (i) DTI of the borrower, (ii) the LTV/TLTV/HTLTV, (iii) the credit score for each borrower, (iv) asset reserves of the borrower, (v) property type, (vi) property usage, and (vii) other property specific items including (a) for condominium or cooperative properties, assessing whether the condominium or cooperative project adheres to required guidelines.

Fraud Review: AMC reviewed fraud report results in each mortgage loan file, to the extent present, in conjunction with source documents found in the mortgage loan file to assess the likelihood of any misrepresentations associated with the origination of the mortgage loan. If the mortgage loan file did not contain a fraud report and the counterparty did not produce one, AMC conditioned the mortgage loan for the missing fraud report product.

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If a report was present, AMC reviewed the report for (i) any name variations for the borrowers, (ii) any social security number variations for the borrowers, (iii) any potential occupancy issues based on the borrower’s address history, (iv) any noted employment issues, and (v) any additional consumers associated with the borrower’s profile. If any findings were noted, AMC confirmed that such findings and/or variations were addressed by the originator in the origination of the asset or that such red flag issues were fully addressed via mortgage loan documentation provided.

Title Review: AMC’s review included a verification of whether the appropriate vestee was on the title documentation (if a purchase, the seller; if a refinance, the borrower) and that the title commitment addressed issues such as assessments; covenants, conditions and restrictions; access problems; vicinity of property to military airports; prior leases; court orders/divorce decrees; public probate issues; foreclosures; bankruptcies; judgment liens; state and federal tax liens; environmental liens, and oil/gas leases.

Additional Review of Mortgage Loan File: AMC also reviewed the closing documents to ensure that the mortgage loan file information is complete, accurate, and contains consistent documentation. Included in the portion of the review are items such as reviewing for (i) evidence of primary mortgage insurance, (ii) if the property is located in an area(s) listed as a FEMA disaster zone post origination, (iii) the presence of loan modification documents, and (iv) general conformity to Fannie Mae or Freddie Mac approved formats at the time of origination.

If standard GSE forms were not used for the mortgage loan, AMC sought to confirm the existence of: (i) a “due on sale” clause, (ii) mortgagor’s requirement to maintain adequate insurance at the mortgagor’s own expense, and (iii) the holder’s right to foreclose and to confirm that any homestead exemption has been waived as required by applicable law within the forms utilized.

(6) Value of collateral securing the assets: review and methodology.

AMC’s review included a review of the valuation materials utilized during the origination of the loan and in confirming the value of the underlying property. AMC’s review included verifying the appraisal report was (i) on the appropriate GSE form, (ii) materially complete, (iii) in conformity with the guideline requirements for the property type in question, (iv) completed by an appraiser that was actively licensed to perform the valuation, (v) completed such that the named client on the appraisal report is the lender or a related entity that is permitted to engage the lender per Title XI of FIRREA, (vi) made and signed prior to the final approval of the mortgage loan application, (vii) completed and dated within the guidelines restrictions, (vii) made on an “as is” basis or provides satisfactory evidence of completion of all material conditions including all inspections, licenses, and certificates (including certificates of occupancy) to be made or issued with respect to all occupied portions of the mortgaged property and with respect to the use and occupancy of the same, have been made or obtained from the appropriate authorities.

With regard to the use of comparable properties, AMC’s review (i) captured the relative comparable data (gross and net adjustments, sale dates and distance from subject property) and ensured that such comparable properties are within standard appraisal guidelines; (ii) confirmed the property value and square footage of the subject property was bracketed by comparable properties, (iii) verified that comparable properties used are similar in size, style, and location to the subject, and (iv) checked for the reasonableness of adjustments when reconciling value between the subject property and comparable properties.

Other aspects of AMC’s review included (i) verifying that the address matched the mortgage note, (ii) verifying that the appraisal and the policies and procedures with regard to appraisal, including the appropriate level of review, when originating the mortgage loan, were followed, (iii) noting whether the property zip code was declared a FEMA disaster area after the valuation date and notifying client of same (iv) confirming the appraisal report does not include any apparent environmental problems, (v) confirming the appraisal notes the current use of the property is legal or legal non-conforming (grandfathered), (vi) reviewing pictures to ensure (a) that the property is in average or better condition and any repairs are noted where required and (b) that the subject property is the one for which the valuation was ordered and that there are no negative external factors; and (vii) confirming that the value product that was used as part of the origination decision was directly accessible to AMC or if it was not directly accessible that another valuation product that was directly accessible to AMC was ordered in accordance with the Client’s specific valuation waterfall process.

If more than one valuation was provided, AMC confirmed consistency among the valuation products and if there were discrepancies that could not be resolved, AMC created an exception and worked with the client on the next steps which may include the ordering of additional valuation products such as collateral desktop analyses, broker’s price opinions, and

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full appraisals. If the property valuation products included in AMC’s review resulted in a variance of more than 10% then the client was notified of such variance and a second independent valuation product was ordered.

AMC also considered processes that included Fannie Mae’s Collateral Underwriter (CU) or Freddie Mac Loan Collateral Advisor (LCA) on one-unit single-family homes and condos for GSE eligible loans. No additional property value due diligence was completed in cases where CU/LCA indicated that appraisal risk was consistent with the respective GSE’s day one RW&E relief. Freddie Mac’s Home Value Explorer (HVE) was also considered an acceptable secondary valuation product for GSE-related transactions. If the CU/LCA risk score was ineligible for GSE RW&E relief, then AMC compared a third valuation product (such as a field review) to the original appraisal.

(7) Compliance of the originator of the assets with federal, state and local laws and regulations: review and methodology.

Please be advised that AMC did not make a determination as to whether the mortgage loans complied with federal, state or local laws, constitutional provisions, regulations or ordinances that are not expressly enumerated below. There can be no assurance that the Review uncovered all relevant factors relating to the origination of the mortgage loans, their compliance with applicable law and regulations and the original appraisals relating to the mortgaged properties or uncovered all relevant factors that could affect the future performance of the mortgage loans. Furthermore, the findings reached by AMC are dependent upon its receiving complete and accurate data regarding the mortgage loans from mortgage loan originators and other third parties upon which AMC is relying in reaching such findings.

With regard to TILA-RESPA Integrated Disclosure (“TRID”) testing, AMC implemented the TRID scope of review referenced within the Regulatory Compliance section (III) based on (i) the RMBS 3.0 TRID Compliance Review Scope published by the Structured Finance Association (“SFA”) (formerly, the Structured Finance Industry Group, “SFIG”) (the "SFA Compliance Review Scope") and (ii) outside counsel’s interpretations of the published regulations as of the date of review of each mortgage loan. AMC worked with outside counsel and continues to obtain updated interpretations relative to the informal guidance provided by the Consumer Financial Protection Bureau (“CFPB”) which has caused alterations in the review scope and severity of TRID related exceptions, including applicable cures. (This will continue as necessary as additional guidance becomes available, as well as any future rulemaking.) While AMC continues to make a good faith effort to identify material TRID exceptions and apply the appropriate grading, the implementation of new regulations (including TRID) that impact residential mortgages carries certain interpretive risk and continues to evolve, impacting the review scope and exception severity. AMC has worked closely with the NRSROs and the Client to disclose, as mutually agreed upon by the parties, the relevant exceptions per AMC’s suggested review implementation as reviewed by outside counsel; however, no assurances can be provided and/or are given that AMC has included within its Review all areas that may represent risk to the securitization trust, or that areas of risk identified by AMC will result in the potential level of risk indicated by an Event Level or NRSRO grade.

Please be further advised that AMC does not employ personnel who are licensed to practice law in the various jurisdictions, and the findings set forth in the reports prepared by AMC do not constitute legal advice or opinions. They are recommendations or conclusions based on information provided to AMC. Information contained in any AMC report related to the applicable statute of limitations for certain claims may not be accurate or reflect the most recent controlling case law. Further, a particular court in a particular jurisdiction may extend, not enforce or otherwise allow claims beyond the statute of limitations identified in the report based on certain factors, including the facts and circumstances of an individual mortgage loan. All final decisions as to whether to purchase or enter into a transaction related to any individual mortgage loan or the mortgage loans in the aggregate, any investment strategy and any legal conclusions, including the potential liability related to the purchase or other transaction involving any such mortgage loan or mortgage loans, shall be made solely by the Client, or other agreed upon party, that has engaged AMC to prepare its reports pursuant to its instructions and guidelines. The Client, or other agreed upon party, acknowledges and agrees that the scoring models applied by AMC are designed to identify potential risk and the Client, or other agreed upon party, assumes sole responsibility for determining the suitability of the information for its particular use. AMC does not make any representation or warranty as to the value of any mortgage loan or mortgage loans collateral that has been reviewed by AMC.

AMC reviewed each residential mortgage loan to determine, as applicable, to the extent possible and subject to the caveats below, whether the mortgage loan complies with:

(I) Federal Truth in Lending Act (“TILA”), as implemented by Regulation Z, 12 C.F.R. Part 1026, as set forth below:

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Rescission (§1026.23, §1026.15):

failure to provide the right of rescission notice;

ii)

failure to provide the right of rescission notice in a timely manner and to the correct consumer(s);

iii)

errors in the right of rescission notice;

iv)

failure to provide the correct form of right of rescission notice;

failure to provide the three (3) business day rescission period;

vi)

any material disclosure violation on a rescindable mortgage loan that gives rise to the right of rescission under TILA, which means the required disclosures of the annual percentage rate, the finance charge, the amount financed, the total of payments, the payment schedule, the HOEPA disclosures, or those related to prepayment penalties on covered transactions; and

vii)

with respect to applicable exception remediation measures, confirm that a letter of explanation, a refund if applicable, new corrected material disclosures and a new notice of right to cancel was provided.

TIL Disclosure (§§1026.17, 18 and 19) as applicable for loans with application dates prior to October 3, 2015:

review and comparison of the initial and final TIL disclosures, and any re-disclosed TIL(s);

ii)

proper execution by all required parties;

iii)

principal and interest calculations, and proper completion of the interest rate and payment summary; and

iv)

timing of initial and re-disclosed TIL(s).

Home Equity Plans Disclosures (§§1026.6, 40) as applicable

failure to provide the applicable home equity initial and account opening disclosures

ii)

failure to provide the applicable home equity initial and account opening disclosures in a timely manner

Tolerances (§§1026.18, 22 23, and 38):

inaccurate Annual Percentage Rate (APR) outside of applicable tolerance by comparing disclosed APR to re-calculated APR; and

ii)

inaccurate Finance Charge outside of applicable tolerance by comparing disclosed Finance Charge to re-calculated Finance Charge.

iii)

inaccurate Total of Payments outside of applicable tolerance by comparing disclosed Total of Payments to re-calculated Total of Payments.

High-cost Mortgage (§§1026.31, 32 and 34):

points and fees threshold test;

ii)

APR threshold test;

iii)

prepayment penalty threshold test; and

iv)

compliance with the disclosure requirements, limitation on terms and prohibited acts or practices in connection with a high-cost mortgage.

Higher-priced Mortgage Loan (§1026.35):

APR threshold test; and

ii)

compliance with the escrow account and appraisal requirements as applicable.

With respect to brokered mortgage loans, the Prohibitions and Restrictions related to Loan Originator Compensation and Steering (§1026.36):

review relevant documentation to determine if compensation to a Loan Originator was based on a term of the transaction;

ii)

review relevant document to determine if there was dual compensation; and

iii)

review the presence of the mortgage loan option disclosure and to determine if the Steering Safe Harbor provisions were satisfied.

(1)

Note: Where available, AMC reviewed the relevant documents in the mortgage loan file and, as necessary, attempted to obtain the mortgage loan originator compensation agreement and/or governing policies and procedures of the mortgage loan originator. In the absence of the mortgage loan originator compensation agreement and/or governing policies and procedures, AMC’s review was limited to formal general statements of entity compliance provided by the mortgage loan originator, if any. These statements, for example, were in the form of a letter signed by the seller correspondent/mortgage loan originator or representations in the mortgage loan purchase agreement between the Client and seller correspondent;

Homeownership counseling (§1026.36):

determine if the creditor obtained proof of homeownership counseling in connection with a mortgage loan to a first time homebuyer that contains a negative amortization feature.

Mandatory Arbitration Clauses (§1026.36):

determine if the terms of the mortgage loan require arbitration or any other non-judicial procedure to resolve any controversy or settle any claims arising out of the transaction.

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Prohibition on Financing Credit Insurance (§1026.36):

determine if the creditor financed, directly or indirectly, any premiums or fees for credit insurance.

Nationwide Mortgage Licensing System (NMLS) & Registry ID on Loan Documents (§1026.36):

review for presence of mortgage loan originator organization and individual mortgage loan originator name and NMLSR ID, as applicable, on the credit application, note or mortgage loan contract, security instrument, Loan Estimate and Closing Disclosure; and

ii)

verify the data against the NMLSR database, as available.

(II) Federal Real Estate Settlement Procedures Act (“RESPA”), as implemented by Regulation X, 12 C.F.R. Part 1024, as set forth below:

Good Faith Estimate (GFE) (§1024.7) as applicable for loans with application dates prior to October 3, 2015:

confirm the presence of the current GFE form in effect at the time of origination;

ii)

verify GFE was provided to the borrower(s) within three (3) business days of application;

iii)

verify all sections of the GFE were accurately completed and that information was reflected in the appropriate locations;

iv)

determine whether a valid and properly documented changed circumstance accompanies any changes to mortgage loan terms and/or fees on any revised GFEs over the applicable tolerance(s); and

confirm the presence of a settlement service provider list, as applicable.

Final HUD-1/A Settlement Statement (HUD) (§1024.8) as applicable for loans with application dates prior to October 3, 2015:

confirm current applicable HUD form was provided;

ii)

determination that the mortgage loan file contains the final HUD;

iii)

escrow deposit on the final HUD matches the initial escrow statement amount; and

iv)

verify all sections of the final HUD were accurately completed and that information was reflected in the appropriate locations.

GFE and Final HUD Comparison (§1024.7) as applicable for loans with application dates prior to October 3, 2015:

review changes disclosed on the last GFE provided to the borrower(s) to determine that such changes were within the allowed tolerances;

ii)

confirm mortgage loan terms and fees disclosed on the third page of the final HUD accurately reflect how such items were disclosed on the referenced GFE, page 2 of the final HUD and mortgage loan documents; and

iii)

review any documented cure of a tolerance violation to determine that the proper reimbursement was made and a revised HUD was provided at or within 30 days of settlement.

Additional RESPA/Regulation X Disclosures and Requirements (§1024.6, 15, 17, 20, and 33):

confirm the presence of the Servicing Disclosure Statement form in the mortgage loan file;

ii)

verify the Servicing Disclosure Statement was provided to the borrower(s) within three (3) business days of application;

iii)

confirm the presence of the Special Information Booklet in the mortgage loan file or that the mortgage loan file contains documentary evidence that the disclosure was provided to the borrower;

iv)

confirm the Special Information Booklet was provided within three (3) business days of application;

confirm the presence of the Affiliated Business Arrangement Disclosure in the mortgage loan file in the event the lender has affiliated business arrangements;

vi)

confirm the Affiliated Business Arrangement Disclosure was provided no later than three (3) business days of application;

vii)

confirm the Affiliated Business Arrangement Disclosure is executed; and

viii)

confirm the presence of the Initial Escrow Disclosure Statement in the mortgage loan file and proper timing;

ix)

confirm that the creditor provided the borrower a list of homeownership counselling organizations within three (3) business days of application; and

confirm that the list of homeownership counselling organizations was obtained no earlier than 30 days prior to when the list was provided to the mortgage loan applicant.

(III) Sections 1098 and 1100A of Dodd-Frank amending TILA and RESPA, as implemented by Regulation Z, 12 C.F.R. Part 1026, as set forth below (applicable only for mortgage loans with application dates on or after October 3, 2015):

Loan Estimate (LE) (§§1026.19 and 37):

confirm the presence of LE for applications on or after October 3, 2015;

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ii)

confirm the initial LE date indicates it was delivered or placed in the mail within three (3) business days of application;

iii)

confirm that certain sections of each LE determined to carry assignee liability under the SFA Compliance Review Scope were accurately completed and that information was reflected in the appropriate locations, which, in certain instances, was based solely on the information disclosed on the LE;

iv)

confirm the initial LE was delivered or placed in the mail not later than seven (7) business days prior to consummation of the transaction, or such period was waived due to a bona fide financial emergency;

confirm that each revised LE is accompanied by valid written documentation explaining the reason for re-disclosure to allow for fee increases based on a valid change of circumstance and was timely provided within 3 business days of issuance;

vi)

capture whether a settlement service provider list (“SSPL”) was provided (in instances when a consumer is given an opportunity to shop for services). Failure to provide SSPL is not cited separately under SFA compliance review scope, however, absence of SSPL from loan file is treated as not provided and impacts fee tolerance categories as prescribed by regulation.

vii)

confirm borrower received LE not later than four (4) business days prior to consummation; and

viii)

confirm LE was not provided to the borrower on or after the date of the CD.

Closing Disclosure (CD) (§§1026.19 and 38):

confirm the presence of CD for applications on or after October 3, 2015;

ii)

confirm the borrower received CD at least three (3) business days prior to consummation, or that such period was waived due to a bona fide financial emergency;

iii)

confirm that certain sections of each CD determined to carry assignee liability under the SFA Compliance Review Scope were accurately completed and that information was reflected in the appropriate locations, which, in certain instances, was based solely on the information disclosed on the CD;

iv)

confirm that a revised CD was received in a timely manner if the initial or any revised CD became inaccurate;

identify tolerance violations based on the charges disclosed on the initial and interim LE’s, initial CD, and reflected on the final CD;

vi)

with respect to tolerance violations based on the disclosed charges on the LE and CD, confirm that the creditor cured the violations no later than 60 days after consummation, or within 60 days of discovery; and

vii)

with respect to applicable exception remediation measures for numerical exceptions, confirm that a letter of explanation, as well as a refund as applicable, was delivered or placed in the mail no later than 60 days after discovery of the exception establishing the need for a revised CD or with respect to exception remediation measures for non-numerical exceptions, that a corrected CD was delivered or placed in the mail no later than 60 days after consummation. (In an attempt to establish a best practices approach to pre-securitization due diligence, as it applies to TILA RESPA Integrated Disclosure testing, the Structured Finance Association (“SFA”) has a working group that consists of industry participants including third party review providers and law firms who agreed to a standardized approach to remediation considerations. This approach is intended to be based on a reasoned legal analysis that expressly assumes that courts will interpret TRID in accordance with the principals of liability set forth in the letter to the MBA from Richard Cordray, the Director of the CFPB. No assurances can be provided that the courts in question will interpret TRID in accordance with the SFA Compliance Review Scope.)

Your Home Loan Toolkit (§1026.19):

confirm the presence of Your Home Loan Toolkit in the mortgage loan file or that the mortgage loan file contains documentary evidence that the disclosure was provided to the borrower; and

ii)

confirm Your Home Loan Toolkit was delivered or placed in the mail not later than three (3) business days after receipt of application.

(IV) Sections 1411 and 1412 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) amending TILA, as implemented by Regulation Z, 12 C.F.R. 1026.43, as set forth below:

The general Ability to Repay (ATR) underwriting standards (12 C.F.R. 1026.43(c));

Refinancing of non-standard mortgages (12 C.F.R. 1026.43(d));

Qualified Mortgages (QM) (12 C.F.R. 1026.43(e) (including qualified mortgages as separately defined by the Department of Housing and Urban Development (24 C.F.R. 201 and 203 et seq.), and the Department of Veterans Affairs (38 C.F.R. Part 36 et seq.); and

Balloon-payment qualified mortgages made by certain creditors (12 C.F.R. 1026.43(f)).

AMC reviews applicable mortgage loans for compliance with the ATR and QM rule requirements based upon each mortgage loan’s originator designation (Safe Harbor QM, Higher-priced QM, Temporary SHQM, Temporary HPQM,

7 | Page

Non-QM, Exempt from ATR). AMC determines the mortgage loan’s status under the ATR or QM rule requirements and assigns a due diligence mortgage loan designation. Generally, AMC notes as a material exception if the due diligence findings do not confirm the originator’s mortgage loan designation. Additionally, AMC notes if an originator mortgage loan designation was not provided.

Qualified Mortgage

With respect to QM (Safe Harbor and Higher-priced) designated mortgage loans, AMC reviews the mortgage loan to determine whether, based on available information in the mortgage loan file: (i) the mortgage loan contains risky mortgage loan features and terms (e.g. an interest only feature or negative amortization), (ii) the “points and fees” exceed the applicable QM threshold, (iii) the monthly payment was calculated appropriately, (iv) the creditor considered and verified income or assets at or before consummation, (v) the creditor appropriately considered debt obligations, alimony and child support, and (vi) depending on the application date, defined in accordance with 1026.2(a)(3)(ii) and the loan designation provided on the subject loan, either:

1.)

for loans with an application date, defined in accordance with § 1026.2(a)(3)(ii), prior to 3/1/2021, at the time of consummation, if the debt-to-income ratio exceeds 43% (calculated in accordance with Appendix Q to Regulation Z). This portion of the Review includes a recalculation of all income and liabilities with attention to the appropriate documentation of each source,

2.)

for loans with an application date, defined in accordance with § 1026.2(a)(3)(ii), on or after 3/1/2021, but before 10/1/2022, submitted with a loan designation of Safe Harbor QM, Higher Priced QM, Safe Harbor QM (43-Q), or Higher Priced QM (43-Q), whether at the time of consummation, the debt-to-income ratio exceeds 43% (calculated in accordance with Appendix Q to Regulation Z). This portion of the Review includes a recalculation of all income and liabilities with attention to the appropriate documentation of each source, or

3.)

for loans with an application date, defined in accordance with § 1026.2(a)(3)(ii), taken on or after 3/1/2021, submitted with a loan designation of Safe Harbor QM (APOR), or Higher Priced QM (APOR), “Revised QM”, whether the APR exceeds the average prime offer rate by 2.25 or more percentage points, (additional thresholds applicable for lower loan balances, subordinate lien covered transactions and certain manufactured homes loan amounts), and whether the loan does not meet the credit guidelines without a documented exception and compensating factors.

For the loans determined to be Safe Harbor QM (APOR), in the event the lender provided a Verification Safe Harbor, (“VSH”) indicator of “Yes” on the loans, that would be reflected as such in the reports. In the event the lender provided a VSH indicator of “No” on the loans that would be reflected in the reports. In the event the lender did not provide a VSH indicator on the loans, the loans would be identified as “Not Stated” in the reports.

* Note, for loans in which the lender provided the VSH indicator, AMC captured it, but did not verify the VSH indicator.

Notwithstanding the above, for loans with the variance evaluation of VSH performed by AMC on QM (APOR) loans, the Lender provided a VSH Indicator of “Yes”. The VSH indicator was provided within the loan images, on the data tape, deal notes, or as part of the loan program/guidelines being originated to. The loan guidelines utilized one of the specified GSE June 2020 guidelines to meet VSH. In the event the lender identified the loan to have VSH status, then AMC reviewed to identify documentation variances that would cause one to question the VSH attestation from the lender. If variances were identified, then the loan would not be identified by AMC to meet the VSH documentation requirements under either the Fannie Mae guidelines or under the Freddie Mac guidelines. The results of the variance analysis is reflected in the reports.

This portion of the Review includes a recalculation of all income and liabilities with attention to the appropriate documentation of each source.

If a mortgage loan was designated as QM and identified as eligible for guarantee, purchase, or insurance by an applicable agency as permitted under the QM final rule, AMC reviews the mortgage loan to determine whether, based on available information in the mortgage loan file, if the mortgage loan satisfied (i), (ii) and (iii) in the preceding paragraph. In addition, AMC reviews the Automated Underwriting System output within the file to confirm agency eligibility.

For each QM designated mortgage loan that satisfied the applicable requirements enumerated above, AMC then determines whether the mortgage loan is a Safe Harbor QM or Higher Priced QM by comparing the mortgage loan’s actual annual percentage rate, as recalculated, to the applicable average prime offer rate plus a certain applicable percentage. The Review also includes determining, as applicable, whether a mortgage loan is a qualified mortgage as defined by the

8 | Page

Department of Housing and Urban Development (24 C.F.R. 201 and 203 et seq.), and the Department of Veterans Affairs (38 C.F.R. Part 36 et seq.).

For each QM designated mortgage loan that does not satisfy the applicable requirements enumerated above, AMC then determines whether the mortgage loan complies with the ATR rule consideration and verification requirements and provides a due diligence designation of Non-QM compliant or non-compliant.

General Ability to Repay

AMC reviews the mortgage loan to determine whether, based on available information in the mortgage loan file, the creditor considered, as applicable, the following eight underwriting factors, and verified such information using reasonably reliable third-party records, at or before consummation: (i) the consumer's current or reasonably expected income or assets, (ii) if the creditor relied on income from the consumer's employment in determining repayment ability (the consumer's current employment status); (iii) the consumer's monthly payment; (iv) the consumer's monthly payment on any simultaneous loan that the creditor knows or has reason to know will be made; (v) the consumer's monthly payment for mortgage-related obligations; (vi) the consumer's current debt obligations, alimony, and child support; (vii) the consumer's monthly debt-to-income ratio or residual income; and (viii) the consumer's credit history. This portion of the Review also focuses on full recalculation of income and debts, as well as the documentation provided to support each item used in originator’s determination of the ability to repay.

AMC reviews mortgage loans to determine their conformity with the ATR/QM factors above, and is not rendering an independent assessment or opinion, warranting or representing that a mortgage loan will be deemed to conform to Safe Harbor, Rebuttable Presumption, ATR or other status based on any additional or revised factors that may be considered by legislative, regulatory, administrative or judicial authorities (“Authorities”). AMC does not represent or warrant that the factors for which it is reviewing the mortgage loans constitute all of the factors and/or criteria that Authorities may consider in determining the status of a mortgage loan. AMC’s review is based on information contained in the mortgage loan file at the time it is provided to AMC to review, and only reflects information as of that point in time.

(V) The Equal Credit Opportunity Act, as implemented by Regulation B, 12 C.F.R. Part 1002, as set forth below:

Providing Appraisals and Other Valuations (12 C.F.R. 1002.14):

timing and content of the right to receive copy of appraisal disclosure;

ii)

charging of a fee for a copy of the appraisal or other written valuation;

iii)

timing of creditor providing a copy of each appraisal or other written valuation; and

iv)

with respect to a borrower that has waived the three (3) business day disclosure requirement, confirm that (a) the borrower has signed the waiver or other acknowledgment at least three (3) business days prior to consummation; and (b) that the lender has provided copies of appraisals and other written valuations at or prior to consummation.

(VI) Fannie Mae points and fees limitations and HOEPA restrictions as addressed in Fannie Mae Announcement 04-06, as amended by Lender Letters LL-2013-05 and LL-2013-06 and Selling Guide Announcement SEL-2013-06;

(VII) The disclosure requirements and prohibitions of Section 50(a)(6), Article XVI of the Texas Constitution and associated regulations;

(VIII) The disclosure requirements and prohibitions of state, county and municipal laws and ordinances with respect to “high-cost” mortgage loans, “covered” mortgage loans, “higher-priced” mortgage loans, “home” mortgage loans or any other similarly designated mortgage loan as defined under such authorities, or subject to any other laws that were enacted to combat predatory lending, as may have been amended from time to time;

(IX) Federal and state specific late charge and prepayment penalty provisions.

(X) Recording Review

AMC noted the presence of recorded documents, when available. However, the majority of mortgage loans in the review population were new production and have only been closed for days or weeks at the time AMC reviewed the mortgage loans and thus have not yet been recorded. AMC verified that documents in the mortgage loan file (most typically closing instructions) included lender instructions for recording, and as applicable, the date the documents were sent for recording, and/or the date that the documents will be recorded.

9 | Page

As part of the portion of the Review described in this section, AMC will analyze and capture data from the source documents identified in the Document Review below, as applicable.

(XI) FIRREA Review

AMC confirmed that the appraiser and the appraisal made by such appraiser both satisfied the requirements of Title XI of FIRREA. Specifically, AMC reviewed the appraisal for conformity to industry standards, including ensuring the appraisal was complete, that the comparable properties and adjustments were reasonable and that pictures were provided and were accurate.

In addition, AMC accessed the ASC database to verify that the appraiser, and if applicable the appraiser’s supervisor, were licensed and in good standing at the time the appraisal was completed.

(XII) Document Review

AMC reviewed each mortgage loan file and verified if the following documents, if applicable, were included in the file and if the data on these documents was consistent (where applicable):

◾

Initial application (1003);

◾

Underwriting summary / loan approval (1008);

◾

Credit report;

◾

Income and employment documentation;

◾

4506T;

◾

Asset documentation;

◾

Sales contract;

◾

Hazard and/or flood insurance policies;

◾

Copy of note for any junior liens;

◾

Appraisal;

◾

Title/Preliminary Title;

◾

Final 1003;

◾

Changed circumstance documentation;

◾

Right of Rescission Disclosure;

◾

Mortgage/Deed of Trust;

◾

Note;

◾

Mortgage Insurance;

◾

Tangible Net Benefit Disclosure;

◾

Subordination Agreement;

◾

FACTA disclosures;

◾

Notice of Special Flood Hazards;

◾

Initial and final GFE’s;

◾

HUD from sale of previous residence;

◾

Final HUD-1;

◾

Initial TIL;

◾

Final TIL;

◾

Loan Estimates;

◾

Closing Disclosures; and

◾

Certain other disclosures related to the enumerated tests set forth herein.

(8) Other: review and methodology.

The final review results reflected in the Overall Review Results Summary herein may include additional exceptions identified after AMC’s initial review was completed where loan level issues were identified by external parties as a result of separate, distinct quality control evaluation of the loan files. In such cases, any additional exceptions cited by any such quality control evaluation would either be reflected (i) as an open exception or (ii) remediated if required documentation and/or curative actions were provided to AMC. The exception totals reflected herein, and corresponding Exception Rating, include exceptions that were so subsequently identified, if any. Please note that only a limited number of loans, if any, reflected in the Review Results Summary were subject to such external quality control evaluations.

(9) Disclaimer.

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Except as expressly enumerated above, please be advised that SitusAMC has not performed any review to determine whether the mortgage loans covered in this Report complied with federal, state or local laws, constitutional provisions, regulations, ordinances or any other laws or guidance, including, without limitation, licensing and general usury laws (“Applicable Law”). Further, there can be no assurances that in performing the review and preparing this Report that SitusAMC has uncovered all relevant factors and potential issues relating to the origination of the mortgage loans, their compliance with Applicable Law, or the original appraisals relating to the mortgaged properties, or that SitusAMC has uncovered all relevant factors that could affect the future performance of the mortgage loans. Please note that the results set forth in this Report are dependent upon receipt of complete and accurate data regarding the mortgage loans from mortgage loan originators, sponsors, issuers, underwriters, and other third parties upon which SitusAMC is relying in reaching such results. Except as expressly stated herein, SitusAMC did not verify the data relied upon in performing its review and producing this Report. In addition, the findings and conclusions set forth in this Report are provided on an “as is” basis and are based on available information and Applicable Law as of the date of this Report, and SitusAMC does not undertake any obligation to update or provide any revisions to this Report to reflect events, circumstances, changes in Applicable Law, or changes in expectations after the date this Report was issued. SitusAMC also hereby disclaims any representation or warranty as to accuracy or completeness of the Report, the inclusion or omission of any facts or information, or as to its suitability, sufficiency or appropriateness for the purposes of the transaction parties or investors or the use of the Report in preparation of any other document in connection with the subject transaction.).

Please be further advised that SitusAMC does not employ personnel who are licensed to practice law in the various jurisdictions covered in this Report, and the results set forth in this Report do not constitute legal advice or legal opinions whatsoever. The findings are recommendations or conclusions based on information provided to SitusAMC, and are not statements of fact or legal conclusions. Information contained in the Report related to the applicable statute of limitations for certain claims may not be accurate or reflect the most recent controlling case law. Further, a particular court in a particular jurisdiction may extend, not enforce or otherwise allow claims beyond the statute of limitations identified in the Report based on certain factors, including the facts and circumstances of an individual mortgage loan. The authorities administering the Applicable Law that was part of the review have broad discretionary powers which may permit such authorities, among other things, to withdraw exemptions accorded by statute or regulation, to impose additional requirements or to reach a conclusion that is not consistent with the results set forth in the Report. All decisions as to whether to issue, purchase, hold, sell or otherwise transact in securities backed by the mortgage loans reviewed in this Report, any investment strategy and any legal conclusions, including the potential liability related to the purchase or other transaction involving any such securities, shall be made solely by the parties to or investors in the transaction. The results set forth in this Report do not constitute tax or investment advice. The scoring models in this Report are designed to identify potential risk in the securities backed by the mortgage loans reviewed, and each party or investor assumes sole responsibility for determining the suitability of the information for its particular use. SitusAMC does not make any representation or warranty (express or implied) as to the value of any mortgage loan or mortgage loan’s collateral that has been reviewed by SitusAMC.

SUMMARY OF FINDINGS & CONCLUSIONS OF REVIEW

The NRSRO criteria referenced for this report and utilized for grading descriptions is based upon the requirements of Fitch Ratings, Inc. (“Fitch”), Kroll Bond Rating Agency, LLC (“Kroll”), Moody’s Investors Service, Inc. (“Moody’s”), and DBRS, Inc. (“DBRS”).

OVERALL REVIEW RESULTS SUMMARY

There were two hundred forty-four (244) mortgage loans in the securitization population reviewed by AMC. After all documents were presented, under the applicable Fitch, Kroll, Moody’s, and DBRS NRSRO grading criteria one hundred fifty-two (152) (62.30%) had an Overall grade of “A”, ninety-two (92) (37.70%) had an Overall grade of “B”, and no loans had exceptions that generated an Overall grade of “C” or “D”.

NRSRO Grade (Fitch, Kroll, Moody’s, DBRS)	# of Loans	Percentage of Loans
A	152	62.30%
B	92	37.70%
C	0	0.00%
D	0	0.00%

CREDIT REVIEW RESULTS SUMMARY

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Two hundred seven (207) (84.84%) mortgage loans of the total received an “A” Credit Review grade. The thirty-seven (37) (15.16%) “B” Credit Review grades were due to missing documentation and/or guideline adherence (see exception detail below). Exceptions were offset by strong compensating factors such as high disposable income, low LTV, and/or high liquid assets.

NRSRO Grade (Fitch, Kroll, Moody’s, DBRS)	# of Loans	Percentage of Loans
A	207	84.84%
B	37	15.16%
C	0	0.00%
D	0	0.00%

COMPLIANCE REVIEW RESULTS SUMMARY

Under the applicable Fitch, Kroll, Moody’s, and DBRS NRSRO grading criteria one hundred seventy-nine (179) (73.36%) had a Compliance Review grade of “A” and sixty-five (65) (26.64%) had a Compliance Review grade of “B”. Loans with a Compliance Review grade of “B” may have multiple compliance exceptions (see exception detail below); however, none are lower than a grade of “B”.

NRSRO Grade (Fitch, Kroll, Moody’s, DBRS)	# of Loans	Percentage of Loans
A	179	73.36%
B	65	26.64%
C	0	0.00%
D	0	0.00%

PROPERTY/VALUATION REVIEW RESULTS SUMMARY

Under the applicable NRSRO grading criteria two hundred forty-three (243) (99.59%) loans had a Property/Valuation grade of “A”. One (1) (0.41%) of the loans generated a Property/Valuation grade of “B” due to the loan being originated with an appraisal waiver with a secondary value supporting value; however, none are lower than a grade of “B.”

NRSRO Grade (Fitch, Kroll, Moody’s, DBRS)	# of Loans	Percentage of Loans
A	243	99.59%
B	1	0.41%
C	0	0.00%
D	0	0.00%

REVIEW EXCEPTION SUMMARY (244 Mortgage Loans)

The summaries below detail the exceptions from the Compliance, Credit and Property Reviews that would have resulted in a “B”, “C”, or “D” grade for a given mortgage loan under the Fitch, Kroll, Moody’s, and DBRS grading criteria. Please note that exception grades of EV1, EV2, and EV3 may not result in a corresponding “B”, “C”, or “D” grade per relevant rating agency guidelines due to considerations including statute of limitations and specific characteristics of ratings by a given NRSRO. Also note that some mortgage loans may have multiple exceptions and, as a result, may have an exception or multiple exceptions in any one exception category.

Exception Type	Fitch Final Exception Rating	Exception Category	Total
Compliance	B	ECOA	56
		TRID Defect	39
		TRID	3
		RESPA	2
		Misc. State Level	2
		TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form	1

12 | Page

		Missing Disclosure	1
		Total Compliance Grade (B) Exceptions:	104
Total Compliance Exceptions:			104
Credit	B	Title	29
		Loan Package Documentation	4
		Guideline	3
		Income / Employment	2
		Credit	1
		Property - Appraisal	1
		Total Credit Grade (B) Exceptions:	40
Total Credit Exceptions:			40
Property	B	Appraisal Reconciliation	1
Property	B	Total Property Grade (B) Exceptions:	1
Total Property Exceptions:			1
Grand Total:			145

TAPE INTEGRITY REVIEW RESULTS SUMMARY

Of the two hundred forty-four (244) mortgage loans reviewed, three (3) of the mortgage loans had three (3) tape discrepancies across one (1) data field.

Field Label	Loans With Discrepancy	Total Times Compared	% Variance	# Of Loans
# of Units	0	13	0.00%	244
Amortization Term	0	3	0.00%	244
Amortization Type	0	3	0.00%	244
Balloon Flag	0	231	0.00%	244
Borrower First Name	0	234	0.00%	244
Borrower FTHB	0	3	0.00%	244
Borrower Last Name	0	234	0.00%	244
Borrower SSN	0	231	0.00%	244
City	0	234	0.00%	244
Contract Sales Price	0	10	0.00%	244
Decision System	0	3	0.00%	244
First Payment Date	0	10	0.00%	244
Investor: Qualifying Total Debt Ratio	0	244	0.00%	244
Lender	0	231	0.00%	244
Lien Position	0	3	0.00%	244
Note Date	0	13	0.00%	244
Occupancy	0	244	0.00%	244
Original CLTV	0	212	0.00%	244
Original HCLTV	0	70	0.00%	244
Original Interest Rate	0	244	0.00%	244
Original Loan Amount	0	244	0.00%	244
Original LTV	0	244	0.00%	244

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Original Term	0	10	0.00%	244
Origination Channel	0	10	0.00%	244
Originator Loan Designation	0	231	0.00%	244
PITIA Reserves Months	0	60	0.00%	244
Product Description	0	231	0.00%	244
Property Type	3	244	1.23%	244
Purpose	0	244	0.00%	244
Refi Purpose	0	13	0.00%	244
Representative FICO	0	234	0.00%	244
State	0	244	0.00%	244
Street	0	234	0.00%	244
Zip	0	244	0.00%	244
Total	3	4,957	0.06%	244

ADDITIONAL LOAN POPULATION SUMMARY*

Amortization Type	Loan Count	% of Loans	Original Balance	% of Balance
Fixed	244	100.00%	$265,836,551.00	100.00%
Total	244	100.00%	$265,836,551.00	100.00%

Lien Position	Loan Count	% of Loans	Original Balance	% of Balance
1	244	100.00%	$265,836,551.00	100.00%
Total	244	100.00%	$265,836,551.00	100.00%

Loan Purpose	Loan Count	% of Loans	Original Balance	% of Balance
Cash Out: Other/Multi-purpose/Unknown Purpose	16	6.56%	$19,160,200.00	7.21%
First Time Home Purchase	28	11.48%	$24,919,333.00	9.37%
Other-than-first-time Home Purchase	184	75.41%	$197,823,867.00	74.42%
Rate/Term Refinance - Borrower Initiated	16	6.56%	$23,933,151.00	9.00%
Total	244	100.00%	$265,836,551.00	100.00%

Original Term	Loan Count	% of Loans	Original Balance	% of Balance
241-360 Months	244	100.00%	$265,836,551.00	100.00%
Total	244	100.00%	$265,836,551.00	100.00%

Property Type	Loan Count	% of Loans	Original Balance	% of Balance
Single Family Detached	129	52.87%	$145,369,142.00	54.68%
Condo, Low Rise	15	6.15%	$11,648,381.00	4.38%
Condo, High Rise	7	2.87%	$8,511,400.00	3.20%
PUD	85	34.84%	$91,205,328.00	34.31%
Townhouse	3	1.23%	$748,500.00	0.28%

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2 Family	4	1.64%	$6,821,800.00	2.57%
3 Family	1	0.41%	$1,532,000.00	0.58%
Total	244	100.00%	$265,836,551.00	100.00%

Occupancy	Loan Count	% of Loans	Original Balance	% of Balance
Primary	193	79.10%	$236,445,455.00	88.94%
Second Home	51	20.90%	$29,391,096.00	11.06%
Total	244	100.00%	$265,836,551.00	100.00%

TPR Loan Designation	Loan Count	% of Loans	Original Balance	% of Balance
Safe Harbor QM (APOR)	244	100.00%	$265,836,551.00	100.00%
Total	244	100.00%	$265,836,551.00	100.00%

*Tables may not add to 100% due to rounding.

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EX-99.1 3 exhibit991-2.htm EXHIBIT 99.1, SCHEDULE 2 - RATING AGENCY GRADES

Rating Agency Grades

Run Date - 5/5/2025 11:12:18 AM

LOAN INFORMATION

INITIAL CREDIT LOAN GRADES

INITIAL COMPLIANCE LOAN GRADES

INITIAL PROPERTY LOAN GRADES

INITIAL OVERALL LOAN GRADES

FINAL CREDIT LOAN GRADES

FINAL COMPLIANCE LOAN GRADES

FINAL PROPERTY LOAN GRADES

FINAL OVERALL LOAN GRADES

AMC Loan ID

Customer Loan ID

Seller Loan ID

Investor Loan Number

Unique Loan ID

Deal Number

Original Loan Amount

DBRS

Fitch

Kroll

Moody's

S&P

Morningstar

DBRS

Fitch

Kroll

Moody's

S&P

Morningstar

DBRS

Fitch

Kroll

Moody's

S&P

Morningstar

DBRS

Fitch

Kroll

Moody's

S&P

Morningstar

DBRS

Fitch

Kroll

Moody's

S&P

Morningstar

DBRS

Fitch

Kroll

Moody's

S&P

Morningstar

DBRS

Fitch

Kroll

Moody's

S&P

Morningstar

DBRS

Fitch

Kroll

Moody's

S&P

Morningstar

[redacted]

62137034

[redacted]

62410199

[redacted]

60887268

[redacted]

69580493

[redacted]

69277198

[redacted]

67363676

[redacted]

67418313

[redacted]

67777579

[redacted]

64135952

[redacted]

60975095

[redacted]

65729227

[redacted]

60381963

[redacted]

61771537

[redacted]

62595183

[redacted]

60231616

[redacted]

60238186

[redacted]

63942690

[redacted]

66910593

[redacted]

60349228

[redacted]

62705780

[redacted]

69869536

[redacted]

61567720

[redacted]

63143280

[redacted]

69263892

[redacted]

67684598

[redacted]

66122487

[redacted]

61390785

[redacted]

66975809

[redacted]

68537289

[redacted]

67110634

[redacted]

66662104

[redacted]

69002271

[redacted]

60236887

[redacted]

68957572

[redacted]

66023491

[redacted]

68709354

[redacted]

65595539

[redacted]

66466588

[redacted]

63330359

[redacted]

65958247

[redacted]

65733466

[redacted]

68574929

[redacted]

67100408

[redacted]

69332249

[redacted]

62814596

[redacted]

61417207

[redacted]

65362938

[redacted]

64409378

[redacted]

62267854

[redacted]

68687881

[redacted]

64310885

[redacted]

68612474

[redacted]

61916249

[redacted]

61085434

[redacted]

65326353

[redacted]

66118465

[redacted]

65013641

[redacted]

63626430

[redacted]

63232202

[redacted]

65124226

[redacted]

61324036

[redacted]

65276597

[redacted]

64082745

[redacted]

68313011

[redacted]

62691508

[redacted]

66916947

[redacted]

62511138

[redacted]

68983352

[redacted]

68884936

[redacted]

60503296

[redacted]

60687695

[redacted]

66960042

[redacted]

66609978

[redacted]

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EX-99.1 4 exhibit991-3.htm EXHIBIT 99.1, SCHEDULE 3 - EXCEPTION GRADES

Exception Grades
Run Date - 5/5/2025 11:12:18 AM

SitusAMC Loan ID

Customer Loan ID

Seller Loan ID

Investor Loan Number

Unique Loan ID

Loan Exception ID

Exception ID

Exception Date

Exception Type

Exception Category

Exception Subcategory

15E Category

Exception

Exception Detail

Exception Information

Compensating Factors

Compensating Factor Information

Applying Party

Follow-up Comments

Cleared Date

Cured Date

Waived Date

Exception Level Grade

DBRS Initial Exception Rating

DBRS Final Exception Rating

Fitch Initial Exception Rating

Fitch Final Exception Rating

Kroll Initial Exception Rating

Kroll Final Exception Rating

Moody's Initial Exception Rating

Moody's Final Exception Rating

S&P Initial Exception Rating

S&P Final Exception Rating

Note Date

Property State

Occupancy

Purpose

Exception Remediation

Overall

Initial Loan Grade

Overall

Final Loan Grade

Credit

Initial Loan Grade

Credit

Final Loan Grade

Compliance

Initial Loan Grade

Compliance

Final Loan Grade

Property

Initial Loan Grade

Property

Final Loan Grade

Originator QM ATR Status

TPR QM ATR Status

Is Curable

[redacted]

62410199

32436445

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Total Of Payments

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XX/XX/XX disclosed an inaccurate Total of Payments on page 5 that does not match the actual total of payments for the loan (fee amounts included in TOP calculation are based on Closing Disclosure dated XX/XX/XX). The disclosed Total of Payments in the amount of $2,259,402.91 is under disclosed by $200.00 compared to the calculated total of payments of $2,259,602.91 which exceeds the $100.00 threshold.

Loan Calculations: Final Closing Disclosure provided on XX/XX/XX disclosed an inaccurate Total of Payments on page 5 that does not match the actual total of payments for the loan (fee amounts included in TOP calculation are based on Closing Disclosure dated XX/XX/XX). The disclosed Total of Payments in the amount of $2,259,402.91 is under disclosed by $200.00 compared to the calculated total of payments of $2,259,602.91 which exceeds the $100.00 threshold.

Reviewer Comment (2025-01-30): XXXXX

Seller Comment (2025-01-29): XXXXX

Reviewer Comment (2025-01-28): XXXXX

Seller Comment (2025-01-27): XXXXX

01/30/2025

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

Safe Harbor QM (APOR)

Yes

[redacted]

62410199

32436473

Credit

Loan Package Documentation

Application / Processing

Loan Package Documentation

FEMA Disaster Issue: The most recent valuation inspection is dated prior to the most recent FEMA disaster.

The property is located in FEMA Disaster area. Provide a post-disaster inspection verifying there was no damage. The inspection must include exterior photos and the property must be re-inspected on or after XX/XX/XX declared end date.

Reviewer Comment (2025-01-06): XXXXX

Seller Comment (2025-01-06): XXXXX

01/06/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

69580493

32047021

Compliance

Federal Compliance

ECOA

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.

Verification appraisal was delivered to borrower was not provided.

11/04/2024

Primary

Refinance - Rate/Term

Safe Harbor QM (APOR)

[redacted]

69580493

32047022

Compliance

Federal Compliance

ECOA

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.

Verification appraisal was delivered to borrower was not provided.

11/04/2024

Primary

Refinance - Rate/Term

Safe Harbor QM (APOR)

[redacted]

69580493

32047027

Compliance

Federal Compliance

TRID

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 $875.00 exceeds tolerance of $850.00. Sufficient or excess cure was provided to the borrower at Closing.

Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $875.00 exceeds tolerance of $850.00. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2024-11-04): XXXXX

11/04/2024

Primary

Refinance - Rate/Term

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

69277198

31928646

Compliance

Federal Compliance

TRID Defect

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $4,163.00 exceeds tolerance of $1,980.00 plus 10% or $2,178.00. Insufficient or no cure was provided to the borrower.

10% tolerance was exceeded by $1,985.00 due to increase of title - premium for lender's coverage fee. No valid COC provided, nor evidence of cure in file. Provide a post-close CD disclosing the tolerance cure to include $1,985.00, a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made.

Reviewer Comment (2024-10-31): XXXXX

Seller Comment (2024-10-30): XXXXX

Reviewer Comment (2024-10-23): XXXXX

Seller Comment (2024-10-22): XXXXX

10/31/2024

Primary

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

67777579

31985373

Credit

Title

Document Error

Title

The Preliminary title policy is within XXXXX or XXXXX and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided.

The preliminary title report in file did not disclose the amount of title insurance coverage. Provide a copy of the final title policy or an addendum to the preliminary report verifying title insurance of at least the loan amount.

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-02-24): XXXXX

10/28/2024

Primary

Refinance - Rate/Term

Safe Harbor QM (APOR)

[redacted]

67777579

31985416

Compliance

Federal Compliance

TRID Defect

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.

Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Reviewer Comment (2024-11-01): XXXXX

Seller Comment (2024-10-31): XXXXX

11/01/2024

Primary

Refinance - Rate/Term

No Defined Cure

Safe Harbor QM (APOR)

[redacted]

64135952

32022508

Compliance

Federal Compliance

ECOA

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.

Verification appraisal was delivered to borrower 3 business days prior to closing was not provided.

10/30/2024

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

64135952

32022514

Compliance

Federal Compliance

TRID

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Review Fee. Fee Amount of $205.00 exceeds tolerance of $200.00. Sufficient or excess cure was provided to the borrower at Closing.

Appraisal Review Fee was last disclosed as $200.00 on LE but disclosed as $205.00 on Final Closing Disclosure. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2024-10-30): XXXXX

10/30/2024

Primary

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

64135952

32022515

Compliance

Federal Compliance

TRID

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 $102.86 exceeds tolerance of $50.00. Sufficient or excess cure was provided to the borrower at Closing.

Credit Report Fee was last disclosed as $50.00 on LE but disclosed as $102.86 on Final Closing Disclosure. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2024-10-30): XXXXX

10/30/2024

Primary

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

64135952

32022551

Credit

Title

General

Title

Title Policy Coverage is less than Original Loan Amount.

The Title Policy Amount of ___ is less than the note amount of ___ based on the ___ in file.

The preliminary title report in file disclosed an amount of title insurance coverage that is less than the loan amount. Provide a copy of the final title policy or an addendum to the preliminary report verifying title insurance of at least the loan amount.

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-02-24): XXXXX

10/30/2024

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

60975095

32148914

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Amount Financed Test

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XX/XX/XX disclosed an Amount Financed disclosed an inaccurate Amount Financed. The disclosed Amount Financed in the amount of $1,604,068.39 is over disclosed by $150.00 compared to the calculated Amount Financed of $1,603,918.39 and the disclosed Finance Charge is not accurate within applicable tolerances for Amount Financed to be considered accurate (fee amounts included in Amount Financed and Finance Charge calculations are based on Closing Disclosure dated XX/XX/XX).

Finance Charge disclosed is $1,604,068.39. Calculated finance charge is $1,603,918.39. Variance of $150. Based on review of Lender's compliance report, $150.00 fee was not included in finance charge calculation. 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 (2024-12-19): XXXXX

Reviewer Comment (2024-12-05): XXXXX

Seller Comment (2024-12-04): XXXXX

12/19/2024

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

Safe Harbor QM (APOR)

Yes

[redacted]

60975095

32148915

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XX/XX/XX disclosed an inaccurate Finance Charge on page 5 that does not match the actual Finance Charge for the loan. The disclosed Finance Charge in the amount of $1,876,324.02 is under disclosed by $150.00 compared to the calculated Finance Charge of $1,876,474.02 which exceeds the $100.00 threshold (fee amounts included in Finance Charge calculation are based on Closing Disclosure dated XX/XX/XX).

Reviewer Comment (2024-12-19): XXXXX

Reviewer Comment (2024-12-05): XXXXX

Seller Comment (2024-12-04): XXXXX

12/19/2024

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

Safe Harbor QM (APOR)

Yes

[redacted]

65729227

32053359

Credit

Property - Appraisal

Appraisal Documentation

Property - Appraisal

Missing Document: Appraisal not provided

File does not have Appraisal in the file.

Reviewer Comment (2024-11-08): XXXXX

Seller Comment (2024-11-07): XXXXX

11/08/2024

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

65729227

32053361

Credit

Loan Package Documentation

Application / Processing

Missing Document

Missing Document: AUS not provided

File does not have AUS in file.

Reviewer Comment (2024-11-08): XXXXX

Seller Comment (2024-11-07): XXXXX

11/08/2024

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

65729227

32053403

Credit

Loan Package Documentation

Application / Processing

Loan Package Documentation

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Reviewer Comment (2024-11-12): XXXXX

11/12/2024

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

65729227

32053411

Property

Property - Appraisal

Appraisal Documentation

Property - Appraisal

Loan is to be securitized. Appraisal is missing. Sec ID: 1

Appraisal is missing and secondary valuation was not provided.

Reviewer Comment (2024-11-12): XXXXX

11/12/2024

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

65729227

32073376

Compliance

Federal Compliance

ECOA

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.

Verification for secondary appraisal was delivered to borrower was not provided.

11/08/2024

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

60381963

32273562

Compliance

Federal Compliance

TRID Defect

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $4,103.00 exceeds tolerance of $2,855.00 plus 10% or $3,140.50. Insufficient or no cure was provided to the borrower.

Ten Percent Fee was last disclosed as $3140.50 on LE but disclosed as $4103.00 on Final Closing Disclosure. File does contain a valid COC for this fee.,

Reviewer Comment (2024-12-04): XXXXX

Seller Comment (2024-12-04): XXXXX

12/04/2024

Primary

Refinance - Cash-out - Other

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

Safe Harbor QM (APOR)

Yes

[redacted]

60381963

32273563

Compliance

Federal Compliance

TRID Defect

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 $450.00 exceeds tolerance of $225.00. Insufficient or no cure was provided to the borrower.

Credit Report Fee was last disclosed as $450.00 on LE but disclosed as$225.00 on Final Closing Disclosure. File does contain a valid COC for this fee.,

Reviewer Comment (2024-12-05): XXXXX

Seller Comment (2024-12-04): XXXXX

12/05/2024

Primary

Refinance - Cash-out - Other

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

Safe Harbor QM (APOR)

Yes

[redacted]

60381963

32324088

Credit

Loan Package Documentation

Closing / Title

Loan Package Documentation

Security Instrument Error: County was not provided

The security instrument reflects the incorrect county as XXXX. Per title and appraisal documents, the correct county is XXXX.

Reviewer Comment (2024-12-13): XXXXX

Seller Comment (2024-12-10): XXXXX

12/13/2024

Primary

Refinance - Cash-out - Other

Safe Harbor QM (APOR)

[redacted]

61771537

32089932

Compliance

Federal Compliance

TRID Defect

TRID Lender Credit Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure:Zero Percent Fee Tolerance exceeded for Lender Credits. Final Lender Credit of $-4,175.59 exceeds tolerance of $-4,466.00. Insufficient or no cure was provided to the borrower.

Lender Credits was last disclosed as $-4,466.00 on LE but disclosed as $-4,175.59 on Final Closing Disclosure. File does not contain a valid COC for this fee, nor evidence of cure in file.

Reviewer Comment (2024-11-19): XXXXX

Seller Comment (2024-11-15): XXXXX

11/19/2024

Second Home

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

61771537

32089934

Compliance

Federal Compliance

TRID Defect

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 $200.00 exceeds tolerance of $0.00. Insufficient or no cure was provided to the borrower.

Appraisal Re-Inspection Fee was not disclosed on Loan Estimate. File does not contain a valid COC for this fee, nor evidence of cure. Provide a post-close CD disclosing the tolerance cure to include $200.00, a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made.

Reviewer Comment (2024-12-02): XXXXX

Seller Comment (2024-11-27): XXXXX

12/02/2024

Second Home

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

62595183

32150289

Credit

Income / Employment

Income Documentation

Missing Document

REO Documents are missing.

Evidence the noted REO does or does not have an HOA fee was not located in file.

Reviewer Comment (2024-11-21): XXXXX

11/21/2024

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

62595183

32150298

Compliance

Federal Compliance

TRID Defect

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 (2024-11-20): XXXXX

11/20/2024

Second Home

Purchase

No Defined Cure

Safe Harbor QM (APOR)

[redacted]

63942690

32740743

Compliance

Federal Compliance

TRID Defect

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax. Fee Amount of $5,855.30 exceeds tolerance of $4,666.00. Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Transfer Tax. Fee Amount of $5,855.30 exceeds tolerance of $4,666.00. Insufficient or no cure was provided to the borrower.

Reviewer Comment (2025-02-10): XXXXX

Seller Comment (2025-02-10): XXXXX

02/10/2025

Second Home

Refinance - Cash-out - Other

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

Safe Harbor QM (APOR)

Yes

[redacted]

63942690

32740772

Credit

Loan Package Documentation

Application / Processing

Loan Package Documentation

FEMA Disaster Issue: The most recent valuation inspection is dated prior to the most recent FEMA disaster.

Most Recent Valuation Inspection Date: ___

Disaster End Date: ___

Disaster Name: ___

Disaster Declaration Date: ___

Borrower has been employed in the same industry for more than 5 years.

Borrower has worked in the same position for more than 3 years.

The representative FICO score is above 680.

SitusAMC

Reviewer Comment (2025-02-04): XXXXX

Reviewer Comment (2025-01-31): XXXXX

02/04/2025

Second Home

Refinance - Cash-out - Other

Safe Harbor QM (APOR)

[redacted]

66910593

32375327

Property

Property - Appraisal

Appraisal Documentation

Property - Appraisal

Missing Document: Appraisal was made "subject to" and Form 1004D/442 was not provided.

Appraisal was made subject to and 442 is not in file.

Reviewer Comment (2024-12-19): XXXXX

Seller Comment (2024-12-19): XXXXX

12/19/2024

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

60349228

32160796

Credit

Loan Package Documentation

Application / Processing

Loan Package Documentation

Missing Document: Missing Final 1003

1003 Final is missing.

Reviewer Comment (2024-12-09): XXXXX

Seller Comment (2024-12-09): XXXXX

12/09/2024

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

62705780

32323656

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Other Includes Insurance Costs

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XX/XX/XX disclosed whether Homeowners insurance is included in escrow in incorrect section. Creditor disclosed insurance to consumer in "Other" section where regulation requires disclosure under "Homeowner's Insurance" section of Projected Payments table. Disclosure requirement met, non-material exception for incorrect format/placement.

Final Closing Disclosure provided on XX/XX/XX disclosed whether Homeowners insurance is included in escrow in incorrect section. Creditor disclosed insurance to consumer in "Other" section where regulation requires disclosure under "Homeowner's Insurance" section of Projected Payments table. Disclosure requirement met, non-material exception for incorrect format/placement.

Reviewer Comment (2024-12-19): XXXXX

12/19/2024

Second Home

Purchase

Good Faith Redisclosure

Safe Harbor QM (APOR)

Yes

[redacted]

61567720

32483172

Compliance

Federal Compliance

ATR/QM Defect

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank XXXXX.): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail.

Loan designation failure due to QM failure. This exception will be cleared once all QM specific exceptions have been cured/cleared.

Reviewer Comment (2025-01-16): XXXXX

Seller Comment (2025-01-14): XXXXX

Reviewer Comment (2025-01-10): XXXXX

Seller Comment (2025-01-07): XXXXX

Reviewer Comment (2025-01-02): XXXXX

Seller Comment (2024-12-30): XXXXX

01/16/2025

Primary

Purchase

Lender to provide updated ATR/QM status

Safe Harbor QM (APOR)

Yes

[redacted]

61567720

32483173

Compliance

Federal Compliance

ATR/QM Defect

QM Points and Fees XXXXX

Qualified Mortgage (Dodd Frank XXXXX.): Points and Fees on subject loan of 3.54117% is in excess of the allowable maximum of 3.00000% of the Federal Total Loan Amount. Points and Fees total $31,998.80 on a Federal Total Loan Amount of $XXXXX vs. an allowable total of $XXXXX (an overage of $4,890.12 or .54117%).

Points and Fees exceed allowable threshold by $4,890.12 or .54117%.

Reviewer Comment (2025-01-16): XXXXX

Seller Comment (2025-01-14): XXXXX

Reviewer Comment (2025-01-10): XXXXX

Seller Comment (2025-01-07): XXXXX

Reviewer Comment (2025-01-02): XXXXX

Seller Comment (2024-12-30): XXXXX

01/16/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

63143280

32492413

Compliance

Federal Compliance

TRID Defect

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $2,728.00 exceeds tolerance of $2,475.00 plus 10% or $2,722.50. Insufficient or no cure was provided to the borrower.

Ten Percent Fee Tolerance exceeded. Total amount of $2,728.00 exceeds tolerance of $2,475.00 plus 10% or $2,722.50. Insufficient or no cure was provided to the borrower.

Reviewer Comment (2025-01-13): XXXXX

01/13/2025

Primary

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

67684598

32491856

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank XXXXX): 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.

Verification appraisal was delivered to borrower was not provided.

12/30/2024

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

66122487

32516446

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Appraisal Waiver Less than 3 Days From Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): Borrower provided appraisal waiver less than three (3) business days prior to consummation.

Borrower provided appraisal waiver less than three (3) business days prior to consummation.

Reviewer Comment (2025-01-08): XXXXX

Reviewer Comment (2025-01-07): XXXXX

01/08/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

66122487

32516453

Credit

Loan Package Documentation

Application / Processing

Insurance

Missing Document: Flood Certificate not provided

Flood certificate not provided in the file.

Reviewer Comment (2025-01-17): XXXXX

Reviewer Comment (2025-01-06): XXXXX

01/17/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

66122487

32518668

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

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.

01/03/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

66122487

32518669

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Appraisal Waiver Less than 3 Days From Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): Borrower provided appraisal waiver less than three (3) business days prior to consummation.

Borrower provided appraisal waiver less than three (3) business days prior to consummation.

Reviewer Comment (2025-01-08): XXXXX

Reviewer Comment (2025-01-07): XXXXX

01/08/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

61390785

32594534

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank XXXXX.): 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.

Verification appraisal was delivered to borrower was not provided.

01/10/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

61390785

32594946

Credit

Title

Document Error

Title

The Preliminary title policy is within XXXXX or XXXXX and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided.

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-03-20): XXXXX

01/10/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

61390785

32597331

Compliance

Federal Compliance

ATR/QM Defect

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank XXXXX.): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail.

Loan designation varaiance due to File failed QM Point and fees test.

Reviewer Comment (2025-01-16): XXXXX

Seller Comment (2025-01-13): XXXXX

01/16/2025

Primary

Purchase

Lender to provide updated ATR/QM status

Safe Harbor QM (APOR)

Yes

[redacted]

61390785

32597332

Compliance

Federal Compliance

ATR/QM Defect

QM Points and Fees XXXXX

Qualified Mortgage (Dodd Frank XXXXX.): Points and Fees on subject loan of 3.25294% is in excess of the allowable maximum of 3.00000% of the Federal Total Loan Amount. Points and Fees total $38,880.00 on a Federal Total Loan Amount of $XXXXX vs. an allowable total of $XXXXX (an overage of $3,023.19 or .25294%).

File failed QM Point and fees test.

Reviewer Comment (2025-01-16): XXXXX

Seller Comment (2025-01-13): XXXXX

01/16/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

66975809

32603033

Credit

Title

Document Error

Title

The Preliminary title policy is within XXXXX or XXXXX and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided.

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-03-20): XXXXX

01/13/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

66975809

32603037

Compliance

Federal Compliance

TRID Defect

TRID Lender Credit Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure:Zero Percent Fee Tolerance exceeded for Lender Credits. Final Lender Credit of $-775.57 exceeds tolerance of $-1,207.00. Insufficient or no cure was provided to the borrower.

Lender Credit of $-775.57 exceeds tolerance of $-1207.00 on Final Closing Disclosure. File does not contain a valid COC for this fee, nor evidence of cure in file. Provide a post-close CD disclosing the tolerance cure to include $431.43 a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made.

Reviewer Comment (2025-01-14): XXXXX

Seller Comment (2025-01-14): XXXXX

01/14/2025

Second Home

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

68537289

32549868

Credit

Title

Document Error

Title

The Preliminary title policy is within XXXXX or XXXXX and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided.

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

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-03-20): XXXXX

01/07/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

67110634

32665157

Credit

Insurance

Insurance Analysis

Insurance

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

HOI coverage is insufficient by $170,000.00. Provide updated policy reflecting minimum coverage of $XXXXX OR provide copy of insurer's replacement cost estimate supporting current coverage amount.

Reviewer Comment (2025-01-23): XXXXX

Seller Comment (2025-01-23): XXXXX

01/23/2025

Primary

Refinance - Rate/Term

Safe Harbor QM (APOR)

[redacted]

67110634

32665380

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Escrowed Property Costs Year 1 Overdisclosed - XXXXX

TILA-RESPA Integrated Disclosure - Loan Disclosures: Escrowed Property Costs over Year 1 of on Final Closing Disclosure provided on XX/XX/XX are overdisclosed.

Escrowed Property Costs over Year 1 of on Final Closing Disclosure provided on XX/XX/XX are overdisclosed.

Reviewer Comment (2025-01-31): XXXXX

Seller Comment (2025-01-30): XXXXX

Reviewer Comment (2025-01-28): XXXXX

Seller Comment (2025-01-27): XXXXX

Reviewer Comment (2025-01-24): XXXXX

Seller Comment (2025-01-23): XXXXX

01/31/2025

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

Safe Harbor QM (APOR)

Yes

[redacted]

67110634

32665381

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Escrowed Property Costs Year 1 Underdisclosed - XXXXX

TILA-RESPA Integrated Disclosure - Loan Disclosures: Escrowed Property Costs over Year 1 of on Final Closing Disclosure provided on XX/XX/XX are underdisclosed.

The final CD did not disclose the Amount of Escrowed Property Costs over Year 1 on page 4; however the Property Taxes $XXXXX, Insurance $XXXXX and HOA $1,920.00 total $38,066.32 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 (2025-01-31): XXXXX

Seller Comment (2025-01-30): XXXXX

Reviewer Comment (2025-01-28): XXXXX

Seller Comment (2025-01-27): XXXXX

Reviewer Comment (2025-01-24): XXXXX

Seller Comment (2025-01-23): XXXXX

01/31/2025

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

Safe Harbor QM (APOR)

Yes

[redacted]

67110634

32665382

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Will Have Escrow - Monthly Escrow Payment Overdisclosed Test

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XX/XX/XX did not disclose the Monthly Escrow Payment.

Final Closing Disclosure provided on XX/XX/XX did not disclose the Monthly Escrow Payment.

Reviewer Comment (2025-01-17): XXXXX

01/17/2025

Primary

Refinance - Rate/Term

Provide the following: Letter of Explanation notifying borrower or error and Corrected CD

Safe Harbor QM (APOR)

Yes

[redacted]

67110634

32665383

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Will Have Escrow Account

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

Final Closing Disclosure provided on XX/XX/XX incorrectly disclosed whether the loan will have an escrow account.

Reviewer Comment (2025-01-31): XXXXX

Seller Comment (2025-01-30): XXXXX

Reviewer Comment (2025-01-28): XXXXX

Seller Comment (2025-01-27): XXXXX

Reviewer Comment (2025-01-24): XXXXX

Seller Comment (2025-01-23): XXXXX

01/31/2025

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

Safe Harbor QM (APOR)

Yes

[redacted]

67110634

32665384

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Will Not Have Escrow Account

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

Final Closing Disclosure provided did not disclosed whether the loan will have an escrow account.

Reviewer Comment (2025-01-31): XXXXX

Seller Comment (2025-01-30): XXXXX

Reviewer Comment (2025-01-28): XXXXX

Seller Comment (2025-01-27): XXXXX

Reviewer Comment (2025-01-24): XXXXX

Seller Comment (2025-01-23): XXXXX

01/31/2025

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

Safe Harbor QM (APOR)

Yes

[redacted]

60236887

32604501

Compliance

Federal Compliance

TRID

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $349.00 exceeds tolerance of $309.00 plus 10% or $339.90. Sufficient or excess cure was provided to the borrower at Closing.

Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2025-01-09): XXXXX

01/09/2025

Primary

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

68957572

32417165

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Verification appraisal was delivered to borrower was not provided.

12/18/2024

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

68957572

32417166

Compliance

Federal Compliance

ATR/QM Defect

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank XXXXX.): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail.

Loan designation failure due to ATR failure. This exception will be cleared once all ATR specific exceptions have been cured/cleared.

Reviewer Comment (2025-01-09): XXXXX

Seller Comment (2025-01-06): XXXXX

01/09/2025

Primary

Purchase

Lender to provide updated ATR/QM status

Safe Harbor QM (APOR)

Yes

[redacted]

68957572

32417167

Compliance

Federal Compliance

ATR/QM Defect

QM Points and Fees XXXXX

Qualified Mortgage (Dodd Frank XXXXX): Points and Fees on subject loan of 4.80971% is in excess of the allowable maximum of 3.00000% of the Federal Total Loan Amount. Points and Fees total $86,194.70 on a Federal Total Loan Amount of $XXXXX vs. an allowable total of $XXXXX (an overage of $32,431.74 or 1.80971%).

Reviewer Comment (2025-01-09): XXXXX

Seller Comment (2025-01-06): XXXXX

01/09/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

68957572

32417187

Compliance

Federal Compliance

TRID Defect

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 $83,599.75 exceeds tolerance of $70,688.00. Insufficient or no cure was provided to the borrower.

Loan Discount Points Fee was last disclosed as $70,688.00 on LE but disclosed as $83,599.75 on Final Closing Disclosure. File does not contain a valid COC for this fee, nor evidence of cure in file.

Reviewer Comment (2025-01-07): XXXXX

Seller Comment (2025-01-06): XXXXX

01/07/2025

Primary

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

66023491

32713379

Compliance

Federal Compliance

TRID

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 $67.00 exceeds tolerance of $50.00. Sufficient or excess cure was provided to the borrower at Closing.

Credit Report Fee was last disclosed as $50.00 on LE but disclosed as $67.00 on Final Closing Disclosure. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2025-01-27): XXXXX

01/27/2025

Primary

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

68709354

32571529

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

Verification appraisal was delivered to borrower was not provided.

01/08/2025

Primary

Refinance - Rate/Term

Safe Harbor QM (APOR)

[redacted]

68709354

32571535

Compliance

Federal Compliance

TRID Defect

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

"Appraisal Re-Inspection fee was last disclosed as $0.00 on LE but disclosed as

$200.00 on Final Closing Disclosure. File does not contain a valid COC for this fee, nor evidence of cure in file. Provide a post-close CD disclosing the tolerance cure to include $200,a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made. "

Reviewer Comment (2025-01-22): XXXXX

Seller Comment (2025-01-21): XXXXX

Reviewer Comment (2025-01-16): XXXXX

Seller Comment (2025-01-15): XXXXX

01/22/2025

Primary

Refinance - Rate/Term

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

Safe Harbor QM (APOR)

Yes

[redacted]

65595539

32475922

Property

Property - Appraisal

Appraisal Documentation

Property - Appraisal

Loan is to be securitized. Secondary valuation is missing. Sec ID: 2

The file is missing a copy of the secondary valuation required for securitization purposes.

Reviewer Comment (2024-10-30): XXXXX

Buyer Comment (2024-10-28): XXXXX

10/30/2024

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

65595539

32475925

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure XX/XX/XX 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 paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.

Reviewer Comment (2024-11-04): XXXXX

Buyer Comment (2024-11-01): XXXXX

11/04/2024

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

Safe Harbor QM (APOR)

Yes

[redacted]

65595539

32475926

Credit

Loan Package Documentation

Application / Processing

Loan Package Documentation

Loan originated as Primary residence, yet URLA declarations indicates borrower will not occupy.

B2 1003 shows will not occupy as primary residence, need corrected final 1003.

Reviewer Comment (2024-10-30): XXXXX

Buyer Comment (2024-10-28): XXXXX

10/30/2024

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

66466588

32626218

Compliance

Federal Compliance

TRID

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Field Review Fee. Fee Amount of $325.00 exceeds tolerance of $0.00. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2025-01-13): XXXXX

01/13/2025

Second Home

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

66466588

32659019

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

Verification appraisal was delivered to borrower was not provided.

01/16/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

63330359

32729737

Compliance

Federal Compliance

TRID Defect

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

Appraisal Re-Inspection Fee was last disclosed as $0.00 on Initial closing disclosure but disclosed as $200.00 on Final Closing Disclosure. File does not contain a valid COC for this fee, nor evidence of cure in file. Provide a post-close CD disclosing the tolerance cure to include $200.00 a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made.

Reviewer Comment (2025-02-19): XXXXX

Seller Comment (2025-02-18): XXXXX

Reviewer Comment (2025-02-04): XXXXX

Seller Comment (2025-02-03): XXXXX

02/19/2025

Primary

Refinance - Cash-out - Other

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

Safe Harbor QM (APOR)

Yes

[redacted]

65958247

32654495

Property

Property - Appraisal

Appraisal Documentation

Property - Appraisal

Missing Document: Appraisal was made "subject to" and Form 1004D/442 was not provided.

File is missing copy of 442 - Final Inspection/Completion report.

Reviewer Comment (2025-01-23): XXXXX

Seller Comment (2025-01-23): XXXXX

01/23/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

65958247

32654526

Credit

Asset

Asset Calculation / Analysis

Asset

Available for Closing is insufficient to cover Cash From Borrower.

Qualifying Assets for Closing of $176,746.11 is less than Cash From Borrower $396,299.34.

Reviewer Comment (2025-01-23): XXXXX

Seller Comment (2025-01-23): XXXXX

01/23/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

65958247

32655693

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Verification appraisal was delivered to borrower was not provided.

01/21/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

65958247

32655694

Compliance

Federal Compliance

TRID Defect

TRID Temporary Buydown Terms Not Reflected on Disclosures Test

TRID: Terms on CD disclosed incorrectly. Temporary buydown terms paid by consumer or paid by other and reflected in the credit contract not accounted for accurately in disclosures provided to consumer.

Terms on CD disclosed incorrectly. Temporary buydown terms paid by consumer or paid by other and reflected in the credit contract not accounted for accurately in disclosures provided to consumer.

Reviewer Comment (2025-02-07): XXXXX

Seller Comment (2025-02-05): XXXXX

Reviewer Comment (2025-01-24): XXXXX

Seller Comment (2025-01-23): XXXXX

02/07/2025

Primary

Purchase

Provide the following: Letter of Explanation notifying borrower or error, Corrected CD, and Proof of Delivery (Proof of receipt and reopened rescission also required if transaction is rescindable and material disclosures are inaccurate)

Safe Harbor QM (APOR)

Yes

[redacted]

65958247

32655697

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Amount Financed Test

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XX/XX/XX disclosed an Amount Financed disclosed an inaccurate Amount Financed. The disclosed Amount Financed in the amount of $903,440.43 is over disclosed by $45.29 compared to the calculated Amount Financed of $903,395.14 and the disclosed Finance Charge is not accurate within applicable tolerances for Amount Financed to be considered accurate (fee amounts included in Amount Financed and Finance Charge calculations are based on Closing Disclosure dated XX/XX/XX).

Final Closing Disclosure provided on XX/XX/XX disclosed an Amount Financed disclosed an inaccurate Amount Financed. The disclosed Amount Financed in the amount of $903,440.43 is over disclosed by $45.29 compared to the calculated Amount Financed of $903,395.14 and the disclosed Finance Charge is not accurate within applicable tolerances for Amount Financed to be considered accurate (fee amounts included in Amount Financed and Finance Charge calculations are based on Closing Disclosure dated XX/XX/XX).

Reviewer Comment (2025-02-03): XXXXX

Seller Comment (2025-01-31): XXXXX

02/03/2025

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

Safe Harbor QM (APOR)

Yes

[redacted]

65958247

32655698

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure APR

TILA-RESPA Integrated Disclosure - Loan Calculations: APR of XXXX% on Final Closing Disclosure provided on XX/XX/XX is under-disclosed from the calculated APR of XXXX% outside of 0.125% tolerance.

APR of XXXX% on Final Closing Disclosure provided on XX/XX/XX is under-disclosed from the calculated APR of XXXX% outside of 0.125% tolerance.

Reviewer Comment (2025-03-05): XXXXX

Seller Comment (2025-03-04): XXXXX

Reviewer Comment (2025-03-03): XXXXX

Seller Comment (2025-02-27): XXXXX

Reviewer Comment (2025-02-21): XXXXX

Seller Comment (2025-02-20): XXXXX

Reviewer Comment (2025-02-17): XXXXX

Seller Comment (2025-02-14): XXXXX

Reviewer Comment (2025-02-07): XXXXX

Seller Comment (2025-02-05): XXXXX

Reviewer Comment (2025-02-03): XXXXX

03/05/2025

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

Safe Harbor QM (APOR)

Yes

[redacted]

65958247

32655699

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XX/XX/XX disclosed an inaccurate Finance Charge on page 5 that does not match the actual Finance Charge for the loan. The disclosed Finance Charge in the amount of $1,209,648.07 is under disclosed by $20,000.04 compared to the calculated Finance Charge of $1,229,648.11 which exceeds the $100.00 threshold (fee amounts included in Finance Charge calculation are based on Closing Disclosure dated XX/XX/XX).

Final Closing Disclosure provided on XX/XX/XX disclosed an inaccurate Finance Charge on page 5 that does not match the actual Finance Charge for the loan. The disclosed Finance Charge in the amount of $1,209,648.07 is under disclosed by $20,045.33 compared to the calculated Finance Charge of $1,229,693.40 which exceeds the $100.00 threshold (fee amounts included in Finance Charge calculation are based on Closing Disclosure dated XX/XX/XX).

Reviewer Comment (2025-03-05): XXXXX

Seller Comment (2025-03-04): XXXXX

Reviewer Comment (2025-03-03): XXXXX

Seller Comment (2025-02-27): XXXXX

Reviewer Comment (2025-02-21): XXXXX

Seller Comment (2025-02-20): XXXXX

Reviewer Comment (2025-02-17): XXXXX

Seller Comment (2025-02-14): XXXXX

Reviewer Comment (2025-02-07): XXXXX

Seller Comment (2025-02-05): XXXXX

Reviewer Comment (2025-02-03): XXXXX

03/05/2025

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

Safe Harbor QM (APOR)

Yes

[redacted]

65958247

32655700

Compliance

Federal Compliance

TRID

TRID Final Closing Disclosure Interest Rate Change After Closing Testing

TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on XX/XX/XX incorrectly disclosed whether the Interest Rate can change.

Final Closing Disclosure provided on XX/XX/XX incorrectly disclosed whether the Interest Rate can change.

Reviewer Comment (2025-02-07): XXXXX

Seller Comment (2025-02-05): XXXXX

Reviewer Comment (2025-01-24): XXXXX

Seller Comment (2025-01-23): XXXXX

02/07/2025

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

Safe Harbor QM (APOR)

Yes

[redacted]

65958247

32655701

Compliance

Federal Compliance

TRID

TRID Final Closing Disclosure Principal and Interest Change After Closing Testing

TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on XX/XX/XX incorrectly disclosed whether the Principal and Interest Payment can change.

Final Closing Disclosure provided on XX/XX/XX incorrectly disclosed whether the Principal and Interest Payment can change.

Reviewer Comment (2025-02-07): XXXXX

Seller Comment (2025-02-05): XXXXX

Reviewer Comment (2025-01-24): XXXXX

Seller Comment (2025-01-23): XXXXX

02/07/2025

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

Safe Harbor QM (APOR)

Yes

[redacted]

65958247

32655702

Compliance

Federal Compliance

TRID

TRID Final Closing Disclosure Principal and Interest Testing

TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on XX/XX/XX disclosed a Principal and Interest Payment that does not match the actual payment for the loan.

Final Closing Disclosure provided on XX/XX/XX disclosed a Principal and Interest Payment that does not match the actual payment for the loan.

Reviewer Comment (2025-02-07): XXXXX

Seller Comment (2025-02-05): XXXXX

Reviewer Comment (2025-01-24): XXXXX

Seller Comment (2025-01-23): XXXXX

02/07/2025

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

Safe Harbor QM (APOR)

Yes

[redacted]

65958247

32655703

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Product Testing

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XX/XX/XX disclosed a Product that does not match the actual product for the loan. Additional AIR/AP table failures could apply for loans with an adjustable rate or adjustable payment with incorrect Product disclosure.

Final Closing Disclosure provided on XX/XX/XX disclosed a Product that does not match the actual product for the loan. Additional AIR/AP table failures could apply for loans with an adjustable rate or adjustable payment with incorrect Product disclosure.

Reviewer Comment (2025-02-18): XXXXX

Seller Comment (2025-02-17): XXXXX

Reviewer Comment (2025-02-07): XXXXX

Seller Comment (2025-02-05): XXXXX

Reviewer Comment (2025-01-24): XXXXX

Seller Comment (2025-01-23): XXXXX

02/18/2025

Primary

Purchase

TRID Timing exception, no remediation available.

Safe Harbor QM (APOR)

[redacted]

65958247

32655704

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Projected P&I Min Payment Fixed Rate Subsequent Payments

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XX/XX/XX disclosed a periodic principal and interest payment for payment stream 2 that does not match the actual payment for the loan.

Final Closing Disclosure provided on XX/XX/XX disclosed a periodic principal and interest payment for payment stream 2 that does not match the actual payment for the loan.

Reviewer Comment (2025-02-07): XXXXX

Seller Comment (2025-02-05): XXXXX

Reviewer Comment (2025-01-24): XXXXX

Seller Comment (2025-01-23): XXXXX

02/07/2025

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

Safe Harbor QM (APOR)

Yes

[redacted]

65958247

32655705

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Projected P&I Payment Min Payment Fixed Rate Initial Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XX/XX/XX disclosed a periodic principal and interest payment for payment stream 1 that does not match the actual payment for the loan.

Final Closing Disclosure provided on XX/XX/XX disclosed a periodic principal and interest payment for payment stream 1 that does not match the actual payment for the loan.

Reviewer Comment (2025-02-07): XXXXX

Seller Comment (2025-02-05): XXXXX

Reviewer Comment (2025-01-24): XXXXX

Seller Comment (2025-01-23): XXXXX

02/07/2025

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

Safe Harbor QM (APOR)

Yes

[redacted]

65958247

32655707

Compliance

Federal Compliance

TRID Defect

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 $15,073.52 exceeds tolerance of $6,944.00. Insufficient or no cure was provided to the borrower.

Loan Discount Points was last disclosed as $6,944.00, but disclosed as $15,073.52 on Final Closing Disclosure. File does not contain a valid COC for this fee, nor evidence of cure in file. Provide a post-close CD disclosing the tolerance cure to include $8,129.52, a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made.

Reviewer Comment (2025-02-04): XXXXX

Seller Comment (2025-01-31): XXXXX

02/04/2025

Primary

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

65733466

32733741

Compliance

Federal Compliance

TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form

Notice of Right to Cancel Missing

Truth in Lending Act: Notice of Right to Cancel was not provided.

Notice of Right to Cancel not provided.

Reviewer Comment (2025-02-19): XXXXX

Seller Comment (2025-02-17): XXXXX

02/19/2025

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

Safe Harbor QM (APOR)

Yes

[redacted]

68574929

32789091

Compliance

Federal Compliance

TRID Defect

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 file was missing a copy of initial Closing Disclosure.

Reviewer Comment (2025-02-10): XXXXX

02/10/2025

Primary

Refinance - Cash-out - Other

No Defined Cure

Safe Harbor QM (APOR)

[redacted]

68574929

32789092

Compliance

Federal Compliance

TRID Defect

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 $12,188.40 exceeds tolerance of $4,200.00. Insufficient or no cure was provided to the borrower.

Loan Discount Points Fee was last disclosed as $4,200.00 on LE but disclosed as $12,188.40 on Final Closing Disclosure. File does contain a valid COC for this fee, cure was provided to the borrower at Closing.

Reviewer Comment (2025-02-10): XXXXX

02/10/2025

Primary

Refinance - Cash-out - Other

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

Safe Harbor QM (APOR)

Yes

[redacted]

67100408

32810364

Compliance

Federal Compliance

ATR/QM Defect

QM Points and Fees XXXXX

Qualified Mortgage (Dodd Frank XXXXX): Points and Fees on subject loan of 4.63085% is in excess of the allowable maximum of 3.00000% of the Federal Total Loan Amount. Points and Fees total $61,198.40 on a Federal Total Loan Amount of $XXXXX vs. an allowable total of $XXXXX (an overage of $21,552.29 or 1.63085%).

QM Points and Fees threshold exceeded by $21,552.29 or 1.63085%.

Reviewer Comment (2025-03-14): XXXXX

Reviewer Comment (2025-02-28): XXXXX

Seller Comment (2025-02-24): XXXXX

Reviewer Comment (2025-02-21): XXXXX

Reviewer Comment (2025-02-20): XXXXX

Reviewer Comment (2025-02-18): XXXXX

03/14/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

67100408

32811396

Compliance

Federal Compliance

ATR/QM Defect

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank XXXXX): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail.

Loan designation failure due to QM failure. This exception will be cleared once all QM specific exceptions have been cured/cleared.

Reviewer Comment (2025-03-14): XXXXX

Reviewer Comment (2025-02-28): XXXXX

Seller Comment (2025-02-24): XXXXX

Reviewer Comment (2025-02-21): XXXXX

Reviewer Comment (2025-02-20): XXXXX

Reviewer Comment (2025-02-18): XXXXX

03/14/2025

Primary

Purchase

Lender to provide updated ATR/QM status

Safe Harbor QM (APOR)

Yes

[redacted]

67100408

32811397

Compliance

Federal Compliance

TRID Defect

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.

Verification appraisal was delivered to borrower 3 business days prior to closing was not provided.

Reviewer Comment (2025-02-12): XXXXX

02/12/2025

Primary

Purchase

No Defined Cure

Safe Harbor QM (APOR)

[redacted]

67100408

32838665

Compliance

Federal Compliance

TRID Defect

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.

XXXXX Received CD dated XX/XX/XX received by borrower on XX/XX/XX which is within 3 days of the closing date XX/XX/XX. Provide CD provided to borrower 3 days prior to closing date XX/XX/XX which is XX/XX/XX or prior to XX/XX/XX.

Reviewer Comment (2025-02-14): XXXXX

02/14/2025

Primary

Purchase

No Defined Cure

Safe Harbor QM (APOR)

[redacted]

69332249

32861352

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Verification appraisal was delivered to borrower was not provided.

02/19/2025

Primary

Refinance - Rate/Term

Safe Harbor QM (APOR)

[redacted]

69332249

32861354

Compliance

Federal Compliance

ATR/QM Defect

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank XXXXX): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail.

Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail.

Reviewer Comment (2025-02-27): XXXXX

Seller Comment (2025-02-25): XXXXX

02/27/2025

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

Safe Harbor QM (APOR)

Yes

[redacted]

69332249

32861355

Compliance

Federal Compliance

ATR/QM Defect

General QM Provision Employment - S-Corp

General QM: Unable to verify current S-Corp status using reasonably reliable third-party records.

The File was missing a copy of the reliable third-party records.

Reviewer Comment (2025-02-27): XXXXX

Seller Comment (2025-02-26): XXXXX

02/27/2025

Primary

Refinance - Rate/Term

Safe Harbor QM (APOR)

[redacted]

69332249

32861356

Compliance

Federal Compliance

ATR/QM Defect

General QM Provision Employment - Schedule C

General QM: Unable to verify current Sole Proprietorship status using reasonably reliable third-party records.

The File was missing a copy of the reliable third-party records.

Reviewer Comment (2025-02-27): XXXXX

Seller Comment (2025-02-26): XXXXX

02/27/2025

Primary

Refinance - Rate/Term

Safe Harbor QM (APOR)

[redacted]

69332249

32861357

Compliance

Federal Compliance

ATR/QM Defect

General QM Provision Income and Assets - S-Corp

General QM: Unable to verify S-Corp income using reasonably reliable third-party records.

The File was missing a copy of the reliable third-party records.

Reviewer Comment (2025-02-27): XXXXX

Seller Comment (2025-02-26): XXXXX

02/27/2025

Primary

Refinance - Rate/Term

Safe Harbor QM (APOR)

[redacted]

69332249

32861358

Compliance

Federal Compliance

TRID

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $230.78 exceeds tolerance of $196.00 plus 10% or $215.60. Sufficient or excess cure was provided to the borrower at Closing.

Ten Percent Fee Tolerance exceeded. Total amount of $230.78 exceeds tolerance of $196.00 plus 10% or $215.60. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2025-02-17): XXXXX

02/17/2025

Primary

Refinance - Rate/Term

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

69332249

32861359

Compliance

Federal Compliance

TRID

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 $673.60 exceeds tolerance of $550.00. Sufficient or excess cure was provided to the borrower at Closing.

Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $673.60 exceeds tolerance of $550.00. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2025-02-17): XXXXX

02/17/2025

Primary

Refinance - Rate/Term

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

62814596

32865300

Credit

Title

General

Title

Title Policy Coverage is less than Original Loan Amount.

The Title Policy Amount of ___ is less than the note amount of ___ based on the ___ in file.

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-04-22): XXXXX

02/20/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

61417207

32860008

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Amount Financed Test

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XX/XX/XX disclosed an Amount Financed disclosed an inaccurate Amount Financed. The disclosed Amount Financed in the amount of $1,087,530.12 is over disclosed by $150.00 compared to the calculated Amount Financed of $1,087,380.12 and the disclosed Finance Charge is not accurate within applicable tolerances for Amount Financed to be considered accurate (fee amounts included in Amount Financed and Finance Charge calculations are based on Closing Disclosure dated XX/XX/XX).

Amount Financed disclosed is $1,087,530.12. Calculated Amount Financed of $1,087,380.12. Variance of $-362.50. Variance of -$150.00. Based on review discrepancy occurred due to APR variance of -0.00111%.Calculated APR XXX% however APR disclosed is XXX%. 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 (2025-03-10): XXXXX

Seller Comment (2025-03-07): XXXXX

Reviewer Comment (2025-03-06): XXXXX

03/10/2025

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

Safe Harbor QM (APOR)

Yes

[redacted]

61417207

32860009

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XX/XX/XX disclosed an inaccurate Finance Charge on page 5 that does not match the actual Finance Charge for the loan. The disclosed Finance Charge in the amount of $1,564,289.52 is under disclosed by $150.00 compared to the calculated Finance Charge of $1,564,439.52 which exceeds the $100.00 threshold (fee amounts included in Finance Charge calculation are based on Closing Disclosure dated XX/XX/XX).

Finance Charge disclosed is $1,564,289.52. Calculated finance charge is $1,564,439.52. Variance of -$150.00. Based on review discrepancy occurred due to APR variance of -0.00111%.Calculated APR XXX% however APR disclosed is 7.14700%. 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 (2025-03-10): XXXXX

Seller Comment (2025-03-07): XXXXX

Reviewer Comment (2025-03-06): XXXXX

03/10/2025

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

Safe Harbor QM (APOR)

Yes

[redacted]

65362938

32960286

Credit

Title

Document Error

Title

The Preliminary title policy is within XXXXX or XXXXX and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided.

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-04-22): XXXXX

03/05/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

62267854

33124261

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): 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.

03/31/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

62267854

33124262

Compliance

State Compliance

State Late Charge

XXXXX Late Charge Percent and Amount Testing

XXXXX Late Charge: Note late charge amount of $277.81 exceeds the state maximum of $100.

Reviewer Comment (2025-04-03): XXXXX

Seller Comment (2025-04-01): XXXXX

04/03/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

62267854

33124265

Compliance

Federal Compliance

TRID Defect

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $825.00 exceeds tolerance of $750.00. Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $825.00 exceeds tolerance of $750.00. Insufficient or no cure was provided to the borrower.

Reviewer Comment (2025-04-03): XXXXX

Seller Comment (2025-04-01): XXXXX

04/03/2025

Second Home

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

68687881

33096615

Compliance

Federal Compliance

ATR/QM Defect

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank XXXXX): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail.

Loan designation failure due to QM failure. This exception will be cleared once all QM specific exceptions have been cured/cleared.

Reviewer Comment (2025-04-02): XXXXX

Seller Comment (2025-03-31): XXXXX

04/02/2025

Primary

Purchase

Lender to provide updated ATR/QM status

Safe Harbor QM (APOR)

Yes

[redacted]

68687881

33096638

Compliance

Federal Compliance

ATR/QM Defect

QM Points and Fees XXXXX

Qualified Mortgage (Dodd Frank XXXXX): Points and Fees on subject loan of 4.25556% is in excess of the allowable maximum of 3.00000% of the Federal Total Loan Amount. Points and Fees total $39,086.96 on a Federal Total Loan Amount of $XXXXX vs. an allowable total of $XXXXX (an overage of $11,532.24 or 1.25556%).

QM Points and Fees threshold exceeded by $11,532.24 or 1.25556%. Loan was consummated after XX/XX/XX. For loans consummated after this date, there is no longer any cure mechanism available for QM points and fees violations.

Reviewer Comment (2025-04-02): XXXXX

Seller Comment (2025-03-31): XXXXX

04/02/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

64310885

32995391

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

Verification appraisal was delivered to borrower was not provided.

03/11/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

68612474

32902551

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): 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.

02/24/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

68612474

32902552

Compliance

Federal Compliance

ATR/QM Defect

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank XXXXX): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Risk.

Loan designation failure due to ATR failure. This exception will be cleared once all ATR specific exceptions have been cured/cleared.

Reviewer Comment (2025-03-11): XXXXX

03/11/2025

Second Home

Purchase

Lender to provide updated ATR/QM status

Safe Harbor QM (APOR)

Yes

[redacted]

68612474

32902553

Compliance

Federal Compliance

ATR/QM Defect

Income/Asset Guideline Deficiency - QM Impact

General QM: There are guideline deficiencies related to income and/or asset doc requirements which could result in a risk to the borrower's ability to repay. (Exception is eligible to be regraded with compensating factors.)

There are guideline deficiencies related to income and/or asset doc requirements which could result in a risk to the borrower's ability to repay.

Reviewer Comment (2025-03-07): XXXXX

Seller Comment (2025-03-06): XXXXX

03/07/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

68612474

32902554

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Amount Financed Test

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XX/XX/XX disclosed an Amount Financed disclosed an inaccurate Amount Financed. The disclosed Amount Financed in the amount of $565,162.48 is over disclosed by $275.00 compared to the calculated Amount Financed of $564,887.48 and the disclosed Finance Charge is not accurate within applicable tolerances for Amount Financed to be considered accurate (fee amounts included in Amount Financed and Finance Charge calculations are based on Closing Disclosure dated XX/XX/XX).

Final Closing Disclosure provided on XX/XX/XX disclosed an Amount Financed disclosed an inaccurate Amount Financed. The disclosed Amount Financed in the amount of $565,162.48 is over disclosed by $275.00 compared to the calculated Amount Financed of $564,887.48 and the disclosed Finance Charge is not accurate within applicable tolerances for Amount Financed to be considered accurate

Reviewer Comment (2025-03-18): XXXXX

Seller Comment (2025-03-17): XXXXX

Reviewer Comment (2025-03-13): XXXXX

Seller Comment (2025-03-12): XXXXX

Reviewer Comment (2025-03-10): XXXXX

Seller Comment (2025-03-07): XXXXX

Reviewer Comment (2025-03-06): XXXXX

Seller Comment (2025-03-05): XXXXX

Reviewer Comment (2025-03-03): XXXXX

Seller Comment (2025-02-28): XXXXX

03/18/2025

Second Home

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

Safe Harbor QM (APOR)

Yes

[redacted]

68612474

32902555

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XX/XX/XX disclosed an inaccurate Finance Charge on page 5 that does not match the actual Finance Charge for the loan. The disclosed Finance Charge in the amount of $834,667.71 is under disclosed by $275.00 compared to the calculated Finance Charge of $834,942.71 which exceeds the $100.00 threshold (fee amounts included in Finance Charge calculation are based on Closing Disclosure dated XX/XX/XX).

Final Closing Disclosure provided on XX/XX/XX disclosed an inaccurate Finance Charge on page 5 that does not match the actual Finance Charge for the loan. The disclosed Finance Charge in the amount of $834,667.71 is under disclosed by $275.00 compared to the calculated Finance Charge of $834,942.71 which exceeds the $100.00 threshold

Reviewer Comment (2025-03-18): XXXXX

Seller Comment (2025-03-17): XXXXX

Reviewer Comment (2025-03-13): XXXXX

Seller Comment (2025-03-12): XXXXX

Reviewer Comment (2025-03-10): XXXXX

Seller Comment (2025-03-07): XXXXX

Reviewer Comment (2025-03-06): XXXXX

Seller Comment (2025-03-05): XXXXX

Reviewer Comment (2025-03-03): XXXXX

Seller Comment (2025-02-28): XXXXX

03/18/2025

Second Home

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

Safe Harbor QM (APOR)

Yes

[redacted]

68612474

32902557

Compliance

Federal Compliance

TRID

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $75.00 exceeds tolerance of $47.00 plus 10% or $51.70. Sufficient or excess cure was provided to the borrower at Closing.

Ten Percent Fee Tolerance exceeded. Total amount of $75.00 exceeds tolerance of $47.00 plus 10% or $51.70. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2025-02-20): XXXXX

02/20/2025

Second Home

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

68612474

32902599

Compliance

Federal Compliance

ATR/QM Defect

General QM Provision Investor Guidelines Violation

General QM: Based on the loan failing one or more guideline components, the loan is at QM risk.

Based on the loan failing one or more guideline components, the loan is at QM risk.

Reviewer Comment (2025-03-11): XXXXX

03/11/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

61916249

32962494

Compliance

Federal Compliance

TRID Defect

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 file was missing a copy of the Closing Disclosure not provided to Borrower at least three business days prior to closing.

Reviewer Comment (2025-03-07): XXXXX

Seller Comment (2025-03-06): XXXXX

03/07/2025

Second Home

Purchase

No Defined Cure

Safe Harbor QM (APOR)

[redacted]

61916249

32962619

Credit

Title

Document Error

Title

The Preliminary title policy is within XXXXX or XXXXX and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided.

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-04-22): XXXXX

03/05/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

61085434

32996289

Compliance

Federal Compliance

TRID Defect

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.

Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Reviewer Comment (2025-03-12): XXXXX

Seller Comment (2025-03-12): XXXXX

03/12/2025

Second Home

Purchase

No Defined Cure

Safe Harbor QM (APOR)

[redacted]

65326353

32995572

Credit

Income / Employment

Income Documentation

Missing Document

REO Documents are missing.

The file was missing a copy of Insurance Verification, Tax Verification for REO XXXXX.

Reviewer Comment (2025-03-12): XXXXX

Seller Comment (2025-03-12): XXXXX

03/12/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

65013641

32733440

Compliance

Federal Compliance

Missing Disclosure

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.

Notice of Special Flood Hazard Disclosure is not signed by the borrower.

Reviewer Comment (2025-01-03): XXXXX

Buyer Comment (2025-01-02): XXXXX

01/03/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

65013641

32733441

Credit

Disclosure

Missing Document

Disclosure

E-sign Consent Agreement is missing.

Reviewer Comment (2025-01-03): XXXXX

Buyer Comment (2025-01-03): XXXXX

01/03/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

65013641

32733442

Credit

Income / Employment

Income Documentation

Missing Document

REO Documents are missing.

Insurance Verification for the REO property XXXXX is missing.

Reviewer Comment (2025-01-03): XXXXX

Buyer Comment (2025-01-03): XXXXX

01/03/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

65013641

32733443

Credit

Miscellaneous

Guideline

Credit Exception:

As per AUS and initial closing disclosure Credit liability XXXXX, XXXXX and XXXXX are excluded, but did not reflecting on final CD and we do not have any documents to verify it. Please provide relevant documents to verify the omitted credit liability.

Reviewer Comment (2025-01-06): XXXXX

Buyer Comment (2025-01-03): XXXXX

01/06/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

65013641

32733444

Credit

Miscellaneous

Guideline

Credit Exception:

XXXXX and XXXXX months primary housing mortgage payment are missing for the Borrower current address - XXXXX

Reviewer Comment (2025-01-06): XXXXX

Buyer Comment (2025-01-03): XXXXX

01/06/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

65013641

32733445

Credit

Asset

Asset Documentation

Asset

Guideline Issue:Insufficient asset documentation.

Need a bank statements covering a two month period for the account number ending with #XXXXX. We have in file from XX/XX/XX To XX/XX/XX and XX/XX/XX To XX/XX/XX.

Reviewer Comment (2025-01-03): XXXXX

Buyer Comment (2025-01-03): XXXXX

01/03/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

65013641

32733446

Property

Property - Appraisal

Appraisal Documentation

Property - Appraisal

Loan is to be securitized. Secondary valuation is missing. Sec ID: 2

XXXXX was not provided. Missing Collateral Underwriting Score.

Reviewer Comment (2025-01-03): XXXXX

Buyer Comment (2025-01-03): XXXXX

01/03/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

65013641

32733448

Credit

Insurance

Insurance Analysis

Insurance

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Hazard Insurance Coverage Amount is insufficient. Need an updated copy of hazard insurance policy or RCE.

Reviewer Comment (2025-01-03): XXXXX

Buyer Comment (2025-01-03): XXXXX

01/03/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

65013641

32733449

Credit

Asset

Asset Documentation

Asset

Missing Document: Gift Letter not provided

Gift Letter to verify gift amount i.e. $31,000 is missing.

Reviewer Comment (2025-01-03): XXXXX

Buyer Comment (2025-01-03): XXXXX

01/03/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

65013641

32733450

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Borrower and Mortgage Eligibility

AUS Findings: Investor qualifying total debt ratio discrepancy.

DTI is high due to missing evidence of XXXXX and XXXXX payoffs. The payoffs are not reflected on the final CD. They are on the initial CD.

Reviewer Comment (2025-01-06): XXXXX

Buyer Comment (2025-01-05): XXXXX

01/06/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

65013641

32733451

Compliance

Federal Compliance

ATR/QM Defect

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank XXXXX.): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Risk.

Loan designation failure due to QM failure. This exception will be cleared once all QM specific exceptions have been cured/cleared.

Reviewer Comment (2025-01-06): XXXXX

Buyer Comment (2025-01-03): XXXXX

01/06/2025

Second Home

Purchase

Lender to provide updated ATR/QM status

Safe Harbor QM (APOR)

Yes

[redacted]

65013641

32733452

Compliance

Federal Compliance

ATR/QM Defect

General QM Provision Investor Guidelines Violation

General QM: Based on the loan failing one or more guideline components, the loan is at QM risk.

Loan designation failure due to QM failure. This exception will be cleared once all QM specific exceptions have been cured/cleared.

Reviewer Comment (2025-01-06): XXXXX

Buyer Comment (2025-01-03): XXXXX

01/06/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

63232202

32733472

Credit

Missing Document

General

Missing Document

Missing Document: Trust Agreement (Asset) not provided

Trust agreement for "XXXXX" to confirm the trustees of the trust to have access to funds from XXXXX Account # XXXXX is missing. These assets were included in the loan approval per final 1003 but omitted from review pending unfettered access.

Reviewer Comment (2024-12-17): XXXXX

Buyer Comment (2024-12-17): XXXXX

Reviewer Comment (2024-12-13): XXXXX

Buyer Comment (2024-12-13): XXXXX

12/17/2024

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

63232202

32733473

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Non Escrow Costs Year 1 Overdisclosed - XXXXX

TILA-RESPA Integrated Disclosure - Loan Disclosures: Non Escrowed Property Costs over Year 1 of 26,400.00 on Final Closing Disclosure provided on XX/XX/XX are overdisclosed.

Loan Disclosures: Non Escrowed Property Costs over Year 1 of 26,400.00 on Final Closing Disclosure provided on XX/XX/XX are overdisclosed. HOA Dues are $631.33 per month or $7,575.96 per year.

Reviewer Comment (2024-12-12): XXXXX

Buyer Comment (2024-12-11): XXXXX

12/12/2024

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

Safe Harbor QM (APOR)

Yes

[redacted]

63232202

32733475

Credit

Missing Document

General

Missing Document

Missing Document: Account Statements - Personal not provided

Missing source of Earnest Money Deposit for $75,000.00 from XXXXX.

Reviewer Comment (2024-12-13): XXXXX

Buyer Comment (2024-12-13): XXXXX

12/13/2024

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

63232202

32733476

Credit

Miscellaneous

Guideline

Credit Exception:

Rural zoned properties ineligible.

The representative FICO score exceeds the guideline minimum by at least 40 points.

Borrower has been employed in the same industry for more than 5 years.

Borrower has verified disposable income of at least $2500.00.

Borrower has worked in the same position for more than 3 years.

Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months.

Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00.

The Combined Loan to Value (CLTV) on the loan is less than the guideline maximum by at least 10%.

The Loan to Value (LTV) on the loan is less than or equal to 70%.

The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%.

The representative FICO score is above 680.

810 vs 680

SitusAMC,Aggregator

SitusAMC

Reviewer Comment (2025-01-02): XXXXX

Buyer Comment (2025-01-02): XXXXX

Reviewer Comment (2024-12-11): XXXXX

Buyer Comment (2024-12-10): XXXXX

01/02/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

65124226

32970334

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Amount Financed Test

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XX/XX/XX disclosed an Amount Financed disclosed an inaccurate Amount Financed. The disclosed Amount Financed in the amount of $497,085.00 is over disclosed by $911.00 compared to the calculated Amount Financed of $496,174.00 and the disclosed Finance Charge is not accurate within applicable tolerances for Amount Financed to be considered accurate (fee amounts included in Amount Financed and Finance Charge calculations are based on Closing Disclosure dated XX/XX/XX).

Final Closing Disclosure provided on XX/XX/XX disclosed an Amount Financed disclosed an inaccurate Amount Financed. The disclosed Amount Financed in the amount of $497,085.00 is over disclosed by $911.00 compared to the calculated Amount Financed of $496,174.00 and the disclosed Finance Charge is not accurate within applicable tolerances for Amount Financed to be considered accurate (fee amounts included in Amount Financed and Finance Charge calculations are based on Closing Disclosure dated XX/XX/XX). (Final/XX/XX/XX)

Reviewer Comment (2025-03-10): XXXXX

Seller Comment (2025-03-07): XXXXX

03/10/2025

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

Safe Harbor QM (APOR)

Yes

[redacted]

65124226

32970335

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XX/XX/XX disclosed an inaccurate Finance Charge on page 5 that does not match the actual Finance Charge for the loan. The disclosed Finance Charge in the amount of $670,391.96 is under disclosed by $911.00 compared to the calculated Finance Charge of $671,302.96 which exceeds the $100.00 threshold (fee amounts included in Finance Charge calculation are based on Closing Disclosure dated XX/XX/XX).

Final Closing Disclosure provided on XX/XX/XX disclosed an inaccurate Finance Charge on page 5 that does not match the actual Finance Charge for the loan. The disclosed Finance Charge in the amount of $670,391.96 is under disclosed by $911.00 compared to the calculated Finance Charge of $671,302.96 which exceeds the $100.00 threshold (fee amounts included in Finance Charge calculation are based on Closing Disclosure dated XX/XX/XX). (Final/XX/XX/XX)

Reviewer Comment (2025-03-10): XXXXX

Seller Comment (2025-03-07): XXXXX

03/10/2025

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

Safe Harbor QM (APOR)

Yes

[redacted]

61324036

32771292

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Verification appraisal was delivered to borrower was not provided.

02/05/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

61324036

32771295

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Amount Financed Test

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XX/XX/XX disclosed an Amount Financed disclosed an inaccurate Amount Financed. The disclosed Amount Financed in the amount of $1,491,964.52 is over disclosed by $813.90 compared to the calculated Amount Financed of $1,491,150.62 and the disclosed Finance Charge is not accurate within applicable tolerances for Amount Financed to be considered accurate (fee amounts included in Amount Financed and Finance Charge calculations are based on Closing Disclosure dated XX/XX/XX).

The disclosed Amount Financed in the amount of $1,491,964.52 is over disclosed by $813.90 compared to the calculated Amount Financed of $1,491,150.62 and the disclosed Finance Charge is not accurate within applicable tolerances for Amount Financed to be considered accurate

Reviewer Comment (2025-02-18): XXXXX

Seller Comment (2025-02-17): XXXXX

Reviewer Comment (2025-02-10): XXXXX

Seller Comment (2025-02-07): XXXXX

Seller Comment (2025-02-06): XXXXX

02/18/2025

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

Safe Harbor QM (APOR)

Yes

[redacted]

61324036

32771296

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XX/XX/XX disclosed an inaccurate Finance Charge on page 5 that does not match the actual Finance Charge for the loan. The disclosed Finance Charge in the amount of $2,055,452.90 is under disclosed by $813.90 compared to the calculated Finance Charge of $2,056,266.80 which exceeds the $100.00 threshold (fee amounts included in Finance Charge calculation are based on Closing Disclosure dated XX/XX/XX).

Reviewer Comment (2025-02-18): XXXXX

Seller Comment (2025-02-17): XXXXX

Reviewer Comment (2025-02-10): XXXXX

Seller Comment (2025-02-07): XXXXX

Seller Comment (2025-02-06): XXXXX

02/18/2025

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

Safe Harbor QM (APOR)

Yes

[redacted]

65276597

32951019

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

Verification appraisal was delivered to borrower 3 business days prior to closing was not provided.

03/04/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

64082745

32900536

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Verification appraisal was delivered to borrower was not provided.

02/24/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

64082745

32900548

Credit

Income / Employment

Income Documentation

Missing Document

REO Documents are missing.

File does not have Statement in file.

Reviewer Comment (2025-02-25): XXXXX

Seller Comment (2025-02-25): XXXXX

02/25/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

64082745

32900573

Credit

Insurance

Insurance Analysis

Insurance

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Hazard insurance amount is insufficient, required additional insurance coverage to cover the amount. Please provide additional insurance coverage document.

Reviewer Comment (2025-02-25): XXXXX

Seller Comment (2025-02-25): XXXXX

02/25/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

64082745

32901039

Credit

Income / Employment

Income Documentation

Income / Employment

Verification(s) of employment is not within 10 business days of the Note.

Reviewer Comment (2025-02-25): XXXXX

Seller Comment (2025-02-25): XXXXX

02/25/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

64082745

32901040

Credit

Income / Employment

Income Documentation

Income / Employment

Verification(s) of employment is not within 10 business days of the Note.

Reviewer Comment (2025-03-06): XXXXX

Seller Comment (2025-03-05): XXXXX

03/06/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

68313011

32979422

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Verification appraisal was delivered to borrower was not provided.

03/07/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

62691508

32926528

Credit

Title

Document Error

Title

The Preliminary title policy is within XXXXX or XXXXX and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided.

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-04-22): XXXXX

02/27/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

66916947

32978822

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

Verification appraisal was delivered to borrower was not provided.

03/07/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

62511138

32986344

Compliance

Federal Compliance

RESPA

RESPA Disclosure - List of Homeownership Counseling Organizations Older Than 30 days When Provided to Borrower

RESPA Disclosure Rule (Dodd-Frank XXXXX): List of Homeownership Counseling Organizations was older than 30 days when provided to borrower.

List of Homeownership Counseling Organizations was older than 30 days when provided to borrower.

Reviewer Comment (2025-03-13): XXXXX

03/13/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

62511138

32986346

Compliance

Federal Compliance

TRID Defect

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Certificate Fee. Fee Amount of $100.00 exceeds tolerance of $87.00. Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Tax Certificate Fee. Fee Amount of $100.00 exceeds tolerance of $87.00. Insufficient or no cure was provided to the borrower.

Reviewer Comment (2025-03-12): XXXXX

Seller Comment (2025-03-11): XXXXX

03/12/2025

Primary

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

68983352

32912001

Compliance

Federal Compliance

TRID

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee. Fee Amount of $92.70 exceeds tolerance of $0.00. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2025-02-21): XXXXX

02/21/2025

Second Home

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

60503296

33057100

Compliance

Federal Compliance

TRID Defect

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $85.00 exceeds tolerance of $70.00 plus 10% or $77.00. Insufficient or no cure was provided to the borrower.

10% tolerance was exceeded by $85.00 due to increase of Tax service fee. No valid COC provided, nor evidence of cure in file. Provide a post-close CD disclosing the tolerance cure to include $77.00, a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made.

Reviewer Comment (2025-03-21): XXXXX

Seller Comment (2025-03-20): XXXXX

03/21/2025

Primary

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

60503296

33093318

Compliance

Federal Compliance

TRID

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $85.00 exceeds tolerance of $70.00 plus 10% or $77.00. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2025-03-21): XXXXX

03/21/2025

Primary

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

60687695

33039232

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Verification appraisal was delivered to borrower was not provided.

03/18/2025

Second Home

Refinance - Rate/Term

Safe Harbor QM (APOR)

[redacted]

60687695

33039277

Credit

Title

Document Error

Title

The Preliminary title policy is within XXXXX or XXXXX and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided.

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-04-22): XXXXX

03/18/2025

Second Home

Refinance - Rate/Term

Safe Harbor QM (APOR)

[redacted]

66609978

32993780

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

Verification appraisal was delivered to borrower was not provided.

03/11/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

66609978

32993782

Compliance

Federal Compliance

TRID Defect

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Review Fee. Fee Amount of $165.00 exceeds tolerance of $0.00. Insufficient or no cure was provided to the borrower.

Appraisal Review Fee was last disclosed as $0.00 on LE but disclosed as $165.00 on Final Closing Disclosure. File does not contain a valid COC for this fee, nor evidence of cure in file. Provide a post-close CD disclosing the tolerance cure to include $165.00, a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made.

Reviewer Comment (2025-03-13): XXXXX

Seller Comment (2025-03-12): XXXXX

03/13/2025

Primary

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

64070103

33090412

Credit

Income / Employment

Income Documentation

Income / Employment

The verification of employment is not within 10 business days of the Note.

The verification of employment is not within 10 business days of the Note for XXXXX.

Reviewer Comment (2025-03-26): XXXXX

Seller Comment (2025-03-25): XXXXX

03/26/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

64070103

33090419

Compliance

Federal Compliance

ATR/QM Defect

General QM Provision Investor Guidelines Violation

General QM: Based on the loan failing one or more guideline components, the loan is at QM risk.

Reviewer Comment (2025-03-28): XXXXX

Seller Comment (2025-03-25): XXXXX

03/28/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

64070103

33090422

Compliance

Federal Compliance

ATR/QM Defect

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank XXXXX): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Risk.

Waterfall exception triggered due to income documentation not meeting guides.

Reviewer Comment (2025-03-28): XXXXX

03/28/2025

Primary

Purchase

Lender to provide updated ATR/QM status

Safe Harbor QM (APOR)

Yes

[redacted]

68854989

32970883

Credit

Income / Employment

Income Documentation

Missing Document

REO Documents are missing.

Reviewer Comment (2025-03-07): XXXXX

Seller Comment (2025-03-07): XXXXX

03/07/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

66070707

33005902

Compliance

Federal Compliance

TRID Defect

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

Appraisal Re-Inspection fee was not disclosed on Loan Estimate. File does not contain a valid COC for this fee, nor evidence of cure. Provide a post-close CD disclosing the tolerance cure to include $200.00, a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made.

Reviewer Comment (2025-03-16): XXXXX

Seller Comment (2025-03-13): XXXXX

03/16/2025

Primary

Refinance - Cash-out - Other

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

Safe Harbor QM (APOR)

Yes

[redacted]

62686336

32935370

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Verification appraisal was delivered to borrower was not provided.

02/28/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

65328717

32942596

Compliance

State Compliance

Misc. State Level

Washington Residential Mortgage Loan (Disclosure of Material Terms Not Provided Timely)

XXXXX HB 2770: Mortgage loan file does not contain a disclosure summary of all material terms provided to borrower within three (3) business days of receipt of the loan application.

Mortgage loan file does not contain a disclosure summary of all material terms provided to borrower within three (3) business days of receipt of the loan application.

Reviewer Comment (2025-03-05): XXXXX

Seller Comment (2025-03-04): XXXXX

03/05/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

65328717

32942597

Compliance

Federal Compliance

TRID Defect

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.

Disclosures were sent to borrower prior to obtain consent for electronic disclosure from borrower. Lender to provide proof of consent within initial 3 days of application OR proof of disclosure sent to borrower using another method within 3 days of application.

Reviewer Comment (2025-03-11): XXXXX

Seller Comment (2025-03-07): XXXXX

Reviewer Comment (2025-03-07): XXXXX

Seller Comment (2025-03-06): XXXXX

03/11/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

65328717

32966785

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank XXXXX): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements.

Secondary appraisal appears to have been updated per the effective date, evidence the updated appraisal was sent to the borrower was not in file.

Reviewer Comment (2025-03-05): XXXXX

Seller Comment (2025-03-04): XXXXX

03/05/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

65328717

32966786

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank XXXXX): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements.

Primary appraisal was documented to have been delivered to the borrower prior to the updated effective date.

Reviewer Comment (2025-03-05): XXXXX

03/05/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

65328717

32966787

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

Primary appraisal appears to have been updated per the effective date, evidence the updated appraisal was sent to the borrower was not in file.

Reviewer Comment (2025-03-05): XXXXX

03/05/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

65328717

32966788

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

Secondary appraisal was documented to have been delivered to the borrower prior to the updated effective date.

Reviewer Comment (2025-03-05): XXXXX

Seller Comment (2025-03-04): XXXXX

03/05/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

67194548

32850215

Credit

Title

Document Error

Title

The Preliminary title policy is within XXXXX or XXXXX and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided.

The Preliminary Title Policy is within XXXXX and does not reflect a coverage amount (no final title policy in file).

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-04-22): XXXXX

02/18/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

61525731

33005408

Compliance

Federal Compliance

TRID Defect

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.

Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Reviewer Comment (2025-03-30): XXXXX

Seller Comment (2025-03-27): XXXXX

03/30/2025

Primary

Purchase

No Defined Cure

Safe Harbor QM (APOR)

[redacted]

65357756

33003739

Compliance

Federal Compliance

TRID

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 $55.00 exceeds tolerance of $30.00. Sufficient or excess cure was provided to the borrower at Closing.

Credit Report Fee was last disclosed as $30.00 on LE but disclosed as $55.00 on Final Closing Disclosure. Sufficient cure was provided to the borrower.

Reviewer Comment (2025-03-10): XXXXX

03/10/2025

Primary

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

69475901

33016007

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

Verification appraisal was delivered to borrower was not provided.

Reviewer Comment (2025-03-18): XXXXX

Seller Comment (2025-03-14): XXXXX

03/18/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

69475901

33016030

Compliance

Federal Compliance

RESPA

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.

The file was missing a copy of the executed Affiliated Business Arrangement Disclosure or proof of the borrower's electronic receipt of the disclosure.

Reviewer Comment (2025-03-18): XXXXX

Seller Comment (2025-03-14): XXXXX

03/18/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

69475901

33016042

Credit

Title

Document Error

Title

The Preliminary title policy is within XXXXX or XXXXX and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided.

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-04-22): XXXXX

03/13/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

67900501

32962324

Credit

Income / Employment

Income Documentation

Missing Document

REO Documents are missing.

Tax Verification doc is missing for property XXXXX

Reviewer Comment (2025-03-11): XXXXX

Seller Comment (2025-03-10): XXXXX

03/11/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

62026661

33005370

Credit

Title

Document Error

Title

The Preliminary title policy is within XXXXX or XXXXX and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided.

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-04-22): XXXXX

03/12/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

62026661

33005384

Compliance

Federal Compliance

TRID

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee. Fee Amount of $150.00 exceeds tolerance of $0.00. Sufficient or excess cure was provided to the borrower at Closing.

Sufficient or excess cure was provided to the borrower at Closing for Second Appraisal Fee.

Reviewer Comment (2025-03-10): XXXXX

03/10/2025

Primary

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

62834145

32867261

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

Verification appraisal was delivered to borrower was not provided.

02/20/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

62834145

32867262

Compliance

Federal Compliance

Missing Disclosure

Notice of Special Flood Hazard Disclosure Not Provided Timely

FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.

Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.

Reviewer Comment (2025-02-27): XXXXX

Reviewer Comment (2025-02-21): XXXXX

Seller Comment (2025-02-21): XXXXX

02/27/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

62834145

32867263

Compliance

Federal Compliance

TRID Defect

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Re-Issue Fee. Fee Amount of $308.00 exceeds tolerance of $154.00. Insufficient or no cure was provided to the borrower.

Credit Report Re-issue Fee was last disclosed as $154.00 on LE but disclosed as $308.00 on Final Closing Disclosure. File does not contain a valid COC for this fee, nor evidence of cure in file. Provide a post-close CD disclosing the tolerance cure to include $154.00, a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made.

Reviewer Comment (2025-03-04): XXXXX

Seller Comment (2025-03-03): XXXXX

03/04/2025

Second Home

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

62834145

32867265

Compliance

Federal Compliance

TRID Defect

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 $85.00 exceeds tolerance of $60.00. Insufficient or no cure was provided to the borrower.

Credit Report Fee was last disclosed as $60.00 on LE but disclosed as $85.00 on Final Closing Disclosure. File does not contain a valid COC for this fee, nor evidence of cure in file. Provide a post-close CD disclosing the tolerance cure to include $25.00, a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made.

Reviewer Comment (2025-03-06): XXXXX

Reviewer Comment (2025-02-21): XXXXX

Seller Comment (2025-02-21): XXXXX

03/06/2025

Second Home

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

62834145

32867291

Compliance

Federal Compliance

TRID Defect

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 (2025-02-21): XXXXX

Seller Comment (2025-02-21): XXXXX

02/21/2025

Second Home

Purchase

No Defined Cure

Safe Harbor QM (APOR)

[redacted]

62834145

32867293

Compliance

Federal Compliance

TRID Defect

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $978.50 exceeds tolerance of $836.00 plus 10% or $919.60. Insufficient or no cure was provided to the borrower.

10% tolerance was exceeded by $58.90 due to increase of recording fee. No valid COC provided, nor evidence of cure in file. Provide a post-close CD disclosing the tolerance cure to include $58.90, a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made.

Reviewer Comment (2025-03-06): XXXXX

Seller Comment (2025-03-05): XXXXX

Reviewer Comment (2025-02-26): XXXXX

Seller Comment (2025-02-25): XXXXX

Reviewer Comment (2025-02-21): XXXXX

Seller Comment (2025-02-21): XXXXX

03/06/2025

Second Home

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

64243660

33022831

Credit

Loan Package Documentation

Loan File

Missing Document

Missing Document: Hazard Insurance Policy not provided

Hazard Insurance Policy is missing in file.

Reviewer Comment (2025-03-17): XXXXX

03/17/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

64885485

33123922

Credit

Title

Document Error

Title

The Preliminary title policy is within XXXXX or XXXXX and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided.

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-04-22): XXXXX

03/31/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

64885485

33123989

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure XX/XX/XX on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2.

Final cd in file did not disclose any seller paid fees , no seller cd in file

Reviewer Comment (2025-04-03): XXXXX

04/03/2025

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

Safe Harbor QM (APOR)

Yes

[redacted]

64885485

33124360

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Verification appraisal was delivered to borrower was not provided.

03/31/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

62357776

33030393

Compliance

Federal Compliance

TRID

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 $68.50 exceeds tolerance of $60.00. Sufficient or excess cure was provided to the borrower at Closing.

Zero Percent Fee Tolerance exceeded for Credit Report Fee. Fee Amount of $68.50 exceeds tolerance of $60.00. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2025-03-13): XXXXX

03/13/2025

Primary

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

66668917

33023202

Compliance

Federal Compliance

TRID

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee. Fee Amount of $169.95 exceeds tolerance of $0.00. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2025-03-12): XXXXX

03/12/2025

Primary

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

69439611

32988543

Credit

Guideline

Guideline Issue

Guideline

Ineligible Property Type.

Property Type: ___

Subject is a non-warrantable condo which is not allowed per XXXXX selling guide. Loan was submitted under an Agency program.

Reviewer Comment (2025-03-18): XXXXX

Reviewer Comment (2025-03-13): XXXXX

Seller Comment (2025-03-12): XXXXX

Seller Comment (2025-03-10): XXXXX

03/18/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

67846700

32950999

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): 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.

03/04/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

67846700

32951080

Credit

Title

Document Error

Title

The Preliminary title policy is within XXXXX or XXXXX and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided.

Preliminary title policy does not state a coverage amount.

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-04-22): XXXXX

03/04/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

67846700

32975728

Compliance

Federal Compliance

ATR/QM Defect

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank XXXXX): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail.

Exception triggered due to loan failing QM. Exceptipn will update once all QM exceptions are addressed.

Reviewer Comment (2025-03-11): XXXXX

03/11/2025

Primary

Purchase

Lender to provide updated ATR/QM status

Safe Harbor QM (APOR)

Yes

[redacted]

67846700

32975729

Compliance

Federal Compliance

ATR/QM Defect

General QM Provision Employment - Schedule C

General QM: Unable to verify current Sole Proprietorship status using reasonably reliable third-party records.

Third party verification of the sole proprietorship business was not located in file.

Reviewer Comment (2025-03-11): XXXXX

Seller Comment (2025-03-06): XXXXX

03/11/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

69662218

32994714

Compliance

Federal Compliance

TRID

ECOA Appraisal Disclosure - ECOA Timing

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

Reviewer Comment (2025-03-13): XXXXX

Seller Comment (2025-03-12): XXXXX

03/13/2025

Second Home

Refinance - Cash-out - Other

Safe Harbor QM (APOR)

[redacted]

69662218

32994715

Compliance

Federal Compliance

RESPA

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.

Reviewer Comment (2025-03-14): XXXXX

Seller Comment (2025-03-12): XXXXX

03/14/2025

Second Home

Refinance - Cash-out - Other

Safe Harbor QM (APOR)

[redacted]

69662218

32994716

Compliance

Federal Compliance

RESPA

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

RESPA Disclosure Rule (Dodd-Frank XXXXX): List of Homeownership Counseling Organizations not provided to applicant within three (3) business days of application.

The file was missing proof the disclosure was provided to the borrower(s) within 3 days of the application date.

03/11/2025

Second Home

Refinance - Cash-out - Other

Safe Harbor QM (APOR)

[redacted]

69662218

32994717

Compliance

Federal Compliance

TRID Defect

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.

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2025-03-13): XXXXX

Seller Comment (2025-03-12): XXXXX

03/13/2025

Second Home

Refinance - Cash-out - Other

Safe Harbor QM (APOR)

[redacted]

69662218

32994722

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Amount Financed Test

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XX/XX/XX disclosed an Amount Financed disclosed an inaccurate Amount Financed. The disclosed Amount Financed in the amount of $1,379,766.71 is over disclosed by $222.00 compared to the calculated Amount Financed of $1,379,544.71 and the disclosed Finance Charge is not accurate within applicable tolerances for Amount Financed to be considered accurate (fee amounts included in Amount Financed and Finance Charge calculations are based on Closing Disclosure dated XX/XX/XX).

Final Closing Disclosure provided on XX/XX/XX disclosed an Amount Financed disclosed an inaccurate Amount Financed. The disclosed Amount Financed in the amount of $1,379,766.71 is over disclosed by $222.00 compared to the calculated Amount Financed of $1,379,544.71 and the disclosed Finance Charge is not accurate within applicable tolerances for Amount Financed to be considered accurate (fee amounts included in Amount Financed and Finance Charge calculations are based on Closing Disclosure dated XX/XX/XX).

Reviewer Comment (2025-03-19): XXXXX

Seller Comment (2025-03-18): XXXXX

Reviewer Comment (2025-03-17): XXXXX

Seller Comment (2025-03-14): XXXXX

03/19/2025

Second Home

Refinance - Cash-out - Other

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

Safe Harbor QM (APOR)

Yes

[redacted]

69662218

32994723

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XX/XX/XX disclosed an inaccurate Finance Charge on page 5 that does not match the actual Finance Charge for the loan. The disclosed Finance Charge in the amount of $2,015,774.01 is under disclosed by $222.00 compared to the calculated Finance Charge of $2,015,996.01 which exceeds the $100.00 threshold (fee amounts included in Finance Charge calculation are based on Closing Disclosure dated XX/XX/XX).

Final Closing Disclosure provided on XX/XX/XX disclosed an inaccurate Finance Charge on page 5 that does not match the actual Finance Charge for the loan. The disclosed Finance Charge in the amount of $2,015,774.01 is under disclosed by $222.00 compared to the calculated Finance Charge of $2,015,996.01 which exceeds the $100.00 threshold (fee amounts included in Finance Charge calculation are based on Closing Disclosure dated XX/XX/XX).

Reviewer Comment (2025-03-19): XXXXX

Seller Comment (2025-03-18): XXXXX

Reviewer Comment (2025-03-17): XXXXX

Seller Comment (2025-03-14): XXXXX

03/19/2025

Second Home

Refinance - Cash-out - Other

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

Safe Harbor QM (APOR)

Yes

[redacted]

60314693

33075924

Compliance

Federal Compliance

TRID

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 $1,800.00 exceeds tolerance of $900.00. Sufficient or excess cure was provided to the borrower at Closing.

Appraisal Fee. Fee Amount of $1,800.00 exceeds tolerance of $900.00. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2025-03-18): XXXXX

03/18/2025

Primary

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

67905543

33061029

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Verification of appraisal was delivered to borrower was not provided

03/19/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

66096293

33008502

Credit

Title

General

Title

Title Policy Coverage is less than Original Loan Amount.

The Title Policy Amount of ___ is less than the note amount of ___ based on the ___ in file.

The Title Policy Amount of $XXXXX is less than the note amount of $XXXXX based on the Commitment in file.

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-04-22): XXXXX

03/13/2025

Primary

Refinance - Rate/Term

Safe Harbor QM (APOR)

[redacted]

66096293

33008507

Credit

Asset

Asset Calculation / Analysis

Asset

Available for Closing is insufficient to cover Cash From Borrower.

Documented qualifying Assets for Closing of $0.00 is less than Cash From Borrower $1,225.00.

Reviewer Comment (2025-03-17): XXXXX

Seller Comment (2025-03-14): XXXXX

03/17/2025

Primary

Refinance - Rate/Term

Safe Harbor QM (APOR)

[redacted]

66096293

33009112

Compliance

Federal Compliance

TRID

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee 3. Fee Amount of $85.00 exceeds tolerance of $0.00. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2025-03-11): XXXXX

03/11/2025

Primary

Refinance - Rate/Term

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

65523454

33082062

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Verification appraisal was delivered to borrower was not provided.

03/21/2025

Primary

Refinance - Rate/Term

Safe Harbor QM (APOR)

[redacted]

65523454

33082063

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Verification appraisal was delivered to borrower was not provided.

03/21/2025

Primary

Refinance - Rate/Term

Safe Harbor QM (APOR)

[redacted]

65523454

33082066

Compliance

State Compliance

Misc. State Level

Colorado Consumer Credit Code (First Lien Refinance Notice Not Provided)

XXXXX Consumer Credit Code: Borrower not provided First Lien Refinance Notice.

Borrower not provided First Lien Refinance Notice.

Reviewer Comment (2025-03-27): XXXXX

Seller Comment (2025-03-24): XXXXX

03/27/2025

Primary

Refinance - Rate/Term

Safe Harbor QM (APOR)

[redacted]

65523454

33082067

Compliance

Federal Compliance

TRID Defect

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s). The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing. Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $7,738.00 XXXXX be required.

Loan Estimate not provided within loan images to evidence delivery to the Borrower(s). The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing. Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $7,738.00 XXXXX be required.

Reviewer Comment (2025-03-25): XXXXX

Seller Comment (2025-03-24): XXXXX

03/25/2025

Primary

Refinance - Rate/Term

No Defined Cure

Safe Harbor QM (APOR)

[redacted]

65523454

33114116

Compliance

Federal Compliance

TRID Defect

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee. Fee Amount of $1,100.00 exceeds tolerance of $1,000.00. Insufficient or no cure was provided to the borrower.

Receipt of invoice is not valid increase in fees. Cure is required.

Reviewer Comment (2025-04-02): XXXXX

Seller Comment (2025-04-01): XXXXX

Reviewer Comment (2025-03-27): XXXXX

Seller Comment (2025-03-26): XXXXX

04/02/2025

Primary

Refinance - Rate/Term

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

Safe Harbor QM (APOR)

Yes

[redacted]

69137365

33005501

Credit

Title

Document Error

Title

The Preliminary title policy is within XXXXX or XXXXX and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided.

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-04-22): XXXXX

03/12/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

65701914

32968957

Compliance

Federal Compliance

TRID

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 $38.50 exceeds tolerance of $30.00. Sufficient or excess cure was provided to the borrower at Closing.

Zero Percent Fee Tolerance exceeded for Credit Report Fee. Fee Amount of $38.50 exceeds tolerance of $30.00. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2025-03-04): XXXXX

03/04/2025

Primary

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

63349716

32988723

Compliance

Federal Compliance

ATR/QM Defect

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank XXXXX): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail.

Exception triggered due to loan failing QM and will be updated once all QM items have been addressed.

Reviewer Comment (2025-03-07): XXXXX

Seller Comment (2025-03-07): XXXXX

03/07/2025

Second Home

Purchase

Lender to provide updated ATR/QM status

Safe Harbor QM (APOR)

Yes

[redacted]

63349716

32988724

Compliance

Federal Compliance

ATR/QM Defect

General QM Provision Employment - C-Corp 1120

General QM: Unable to verify current C-Corp status using reasonably reliable third-party records.

Third party business verification source document is not dated and therefore cannot be confirmed to have been obtained per guideline requirements.

Reviewer Comment (2025-03-07): XXXXX

Seller Comment (2025-03-07): XXXXX

03/07/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

63612890

32934173

Compliance

Federal Compliance

TRID

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 $500.00 exceeds tolerance of $0.00. Sufficient or excess cure was provided to the borrower at Closing.

Zero Percent Fee Tolerance exceeded for Processing Fee. Fee Amount of $500.00 exceeds tolerance of $0.00. Sufficient cure was provided to the borrower at Closing.

Reviewer Comment (2025-02-26): XXXXX

02/26/2025

Primary

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

66538862

32982121

Compliance

Federal Compliance

TRID Defect

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 $4,536.27 exceeds tolerance of $4,436.00. Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Loan Discount Points. Fee Amount of $4,536.27 exceeds tolerance of $4,436.00. Insufficient or no cure was provided to the borrower.

Reviewer Comment (2025-03-12): XXXXX

Seller Comment (2025-03-10): XXXXX

03/12/2025

Primary

Refinance - Cash-out - Other

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

Safe Harbor QM (APOR)

Yes

[redacted]

65255731

32895826

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Verification appraisal was delivered to borrower was not provided.

02/19/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

68027028

32893938

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

Verification appraisal was delivered to borrower was not provided.

02/20/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

62868539

32908004

Compliance

Federal Compliance

TRID Defect

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax. Fee Amount of $7,915.60 exceeds tolerance of $7,421.00. Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Transfer Tax. Fee Amount of $7,915.60 exceeds tolerance of $7,421.00. Insufficient or no cure was provided to the borrower.

Reviewer Comment (2025-02-26): XXXXX

Seller Comment (2025-02-24): XXXXX

Reviewer Comment (2025-02-24): XXXXX

Seller Comment (2025-02-21): XXXXX

02/26/2025

Primary

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

67914486

32894816

Compliance

Federal Compliance

ATR/QM Defect

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank XXXXX): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail.

Loan designation failure due to failing QM points and fees. This exception will be cleared once all QM specific exceptions have been cured/cleared.

Reviewer Comment (2025-02-27): XXXXX

Seller Comment (2025-02-24): XXXXX

02/27/2025

Primary

Purchase

Lender to provide updated ATR/QM status

Safe Harbor QM (APOR)

Yes

[redacted]

67914486

32894817

Compliance

Federal Compliance

ATR/QM Defect

QM Points and Fees XXXXX

Qualified Mortgage (Dodd Frank XXXXX): Points and Fees on subject loan of 3.45529% is in excess of the allowable maximum of 3.00000% of the Federal Total Loan Amount. Points and Fees total $29,945.00 on a Federal Total Loan Amount of $XXXXX vs. an allowable total of $XXXXX (an overage of $3,945.75 or .45529%).

QM Points and Fees threshold exceeded by $3,945.75 or .45529%. Loan was consummated after XX/XX/XX. For loans consummated after this date, there is no longer any cure mechanism available for QM points and fees violations.

Reviewer Comment (2025-02-27): XXXXX

Seller Comment (2025-02-24): XXXXX

02/27/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

65083131

32895414

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Legal / Regulatory / Compliance

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

Title Final or Preliminary is missing.

Reviewer Comment (2025-02-27): XXXXX

Seller Comment (2025-02-21): XXXXX

02/27/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

67378252

32887001

Compliance

Federal Compliance

TRID Defect

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.

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2025-02-24): XXXXX

Seller Comment (2025-02-21): XXXXX

02/24/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

62585363

32894539

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Title

Title Policy is Preliminary or Commitment, and not a Final Title Policy.

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

Reviewer Comment (2025-02-25): XXXXX

02/25/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

62585363

32894543

Credit

Title

Document Error

Title

The Preliminary/Commitment does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided.

Reviewer Comment (2025-02-25): XXXXX

Seller Comment (2025-02-21): XXXXX

02/25/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

62585363

32894552

Credit

Documents

Missing Document

Documents

File does not contain documentation from lender/seller confirming the condo is warrantable.

File does not contain documentation from lender/seller confirming the condo is warrantable

Reviewer Comment (2025-02-25): XXXXX

Seller Comment (2025-02-21): XXXXX

02/25/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

63089861

32896355

Credit

Insurance

Insurance Analysis

Insurance

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

HOI coverage is insufficient by $200.00. Provide updated policy reflecting minimum coverage of $XXXXX OR provide copy of insurer's replacement cost estimate supporting current coverage amount.

Reviewer Comment (2025-02-25): XXXXX

Seller Comment (2025-02-25): XXXXX

Reviewer Comment (2025-02-24): XXXXX

Seller Comment (2025-02-21): XXXXX

02/25/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

68914969

32894704

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): 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.

02/19/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

68914969

32894705

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): 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.

02/19/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

65318013

32993850

Compliance

Federal Compliance

TRID Defect

TRID Lender Credit Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure:Zero Percent Fee Tolerance exceeded for Lender Credits. Final Lender Credit of $-390.88 exceeds tolerance of $-690.00. Insufficient or no cure was provided to the borrower.

Lender Credits Fee was last disclosed as -$690.00 on LE but disclosed as -$390.88 on Final Closing Disclosure. File does not contain a valid COC for this fee, nor evidence of cure in file. Provide a post-close CD disclosing the tolerance cure to include $299.12, a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made.

Reviewer Comment (2025-03-13): XXXXX

Seller Comment (2025-03-12): XXXXX

03/13/2025

Primary

Refinance - Rate/Term

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

Safe Harbor QM (APOR)

Yes

[redacted]

61035656

33073702

Compliance

Federal Compliance

TRID Defect

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 $722.19 exceeds tolerance of $673.00. Insufficient or no cure was provided to the borrower.

Loan Discount Points Fee was last disclosed as $673.00 on LE but disclosed as $722.19 on Final Closing Disclosure. File does not contain a valid COC for this fee, nor evidence of cure in file.

Reviewer Comment (2025-04-03): XXXXX

Seller Comment (2025-04-02): XXXXX

Reviewer Comment (2025-03-27): XXXXX

Seller Comment (2025-03-25): XXXXX

04/03/2025

Second Home

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

60139733

33003576

Compliance

Federal Compliance

TRID

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Review Fee. Fee Amount of $300.00 exceeds tolerance of $0.00. Sufficient or excess cure was provided to the borrower at Closing.

Zero Percent Fee Tolerance exceeded for Appraisal Review Fee. Fee Amount of $300.00 exceeds tolerance of $0.00. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2025-03-10): XXXXX

03/10/2025

Primary

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

60525056

33094653

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Amount Financed Test

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XX/XX/XX disclosed an Amount Financed disclosed an inaccurate Amount Financed. The disclosed Amount Financed in the amount of $1,060,215.06 is over disclosed by $910.00 compared to the calculated Amount Financed of $1,059,305.06 and the disclosed Finance Charge is not accurate within applicable tolerances for Amount Financed to be considered accurate (fee amounts included in Amount Financed and Finance Charge calculations are based on Closing Disclosure dated XX/XX/XX).

Loan Calculations: Final Closing Disclosure provided on XX/XX/XX disclosed an Amount Financed disclosed an inaccurate Amount Financed. The disclosed Amount Financed in the amount of $1,060,215.06 is over disclosed by $910.00 compared to the calculated Amount Financed of $1,059,305.06 and the disclosed Finance Charge is not accurate within applicable tolerances for Amount Financed to be considered accurate (fee amounts included in Amount Financed and Finance Charge calculations are based on Closing Disclosure dated XX/XX/XX)

Reviewer Comment (2025-03-27): XXXXX

Seller Comment (2025-03-26): XXXXX

03/27/2025

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

Safe Harbor QM (APOR)

Yes

[redacted]

60525056

33094654

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XX/XX/XX disclosed an inaccurate Finance Charge on page 5 that does not match the actual Finance Charge for the loan. The disclosed Finance Charge in the amount of $1,406,260.34 is under disclosed by $910.00 compared to the calculated Finance Charge of $1,407,170.34 which exceeds the $100.00 threshold (fee amounts included in Finance Charge calculation are based on Closing Disclosure dated XX/XX/XX).

The disclosed Finance Charge in the amount of $1,406,260.34 is under disclosed by $910.00 compared to the calculated Finance Charge of $1,407,170.34 which exceeds the $100.00 threshold.

Reviewer Comment (2025-03-27): XXXXX

Seller Comment (2025-03-27): XXXXX

03/27/2025

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

Safe Harbor QM (APOR)

Yes

[redacted]

67371803

33082401

Compliance

Federal Compliance

TRID Defect

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $852.00 exceeds tolerance of $389.00 plus 10% or $427.90. Insufficient or no cure was provided to the borrower.

Ten Percent Fee Tolerance exceeded. Total amount of $852.00 exceeds tolerance of $389.00 plus 10% or $427.90. Insufficient or no cure was provided to the borrower.

Reviewer Comment (2025-04-02): XXXXX

Seller Comment (2025-04-01): XXXXX

Reviewer Comment (2025-03-27): XXXXX

Seller Comment (2025-03-25): XXXXX

04/02/2025

Primary

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

66826463

33038556

Credit

Title

Document Error

Title

The Preliminary title policy is within XXXXX or XXXXX and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided.

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-04-22): XXXXX

03/18/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

66826463

33038684

Compliance

Federal Compliance

TRID Defect

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.

Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Reviewer Comment (2025-03-26): XXXXX

Seller Comment (2025-03-24): XXXXX

03/26/2025

Primary

Purchase

No Defined Cure

Safe Harbor QM (APOR)

[redacted]

66826463

33117777

Compliance

Federal Compliance

TRID

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 $200.00 exceeds tolerance of $0.00. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2025-03-26): XXXXX

03/26/2025

Primary

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

69783143

33142314

Compliance

Federal Compliance

TRID Defect

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 $28,717.20 exceeds tolerance of $97.00. Insufficient or no cure was provided to the borrower.

Loan Discount Points fee amount of $28,717.20 exceeds tolerance of $97.00. Insufficient or no cure was provided to the borrower.

Reviewer Comment (2025-04-03): XXXXX

Seller Comment (2025-04-02): XXXXX

04/03/2025

Primary

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

69783143

33142315

Compliance

Federal Compliance

TRID Defect

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 $55.00 exceeds tolerance of $30.00. Insufficient or no cure was provided to the borrower.

Credit Report Fee amount of $55.00 exceeds tolerance of $30.00. Insufficient or no cure was provided to the borrower.

Reviewer Comment (2025-04-03): XXXXX

Seller Comment (2025-04-02): XXXXX

04/03/2025

Primary

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

69783143

33180621

Compliance

Federal Compliance

TRID

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

Reviewer Comment (2025-04-03): XXXXX

04/03/2025

Primary

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

68616251

33021716

Compliance

Federal Compliance

TRID

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Review Fee. Fee Amount of $205.00 exceeds tolerance of $0.00. Sufficient or excess cure was provided to the borrower at Closing.

Zero Percent Fee Tolerance exceeded for Appraisal Review Fee. Fee Amount of $205.00 exceeds tolerance of $0.00. Sufficient cure was provided to the borrower at Closing.

Reviewer Comment (2025-03-12): XXXXX

03/12/2025

Primary

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

68616251

33021732

Credit

Missing Document

General

Missing Document

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

Verification of Non-US Citizen document not provided.

Reviewer Comment (2025-03-19): XXXXX

Seller Comment (2025-03-19): XXXXX

03/19/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

61445844

33023248

Credit

Loan Package Documentation

Application / Processing

Loan Package Documentation

FEMA Disaster Issue: The most recent valuation inspection is dated prior to the most recent FEMA disaster.

Most Recent Valuation Inspection Date: ___

Disaster End Date: ___

Disaster Name: ___

Disaster Declaration Date: ___

Borrower has verified disposable income of at least $2500.00.

Borrower has worked in the same position for more than 3 years.

Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00.

The Combined Loan to Value (CLTV) on the loan is less than the guideline maximum by at least 10%.

The Loan to Value (LTV) on the loan is less than or equal to 70%.

The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%.

The qualifying DTI on the loan is at least 10% less than the guideline maximum.

The qualifying DTI on the loan is less than or equal to 35%.

The representative FICO score is above 680.

SitusAMC

Reviewer Comment (2025-03-18): XXXXX

03/18/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

63954032

33031322

Credit

Title

Document Error

Title

The Preliminary title policy is within XXXXX or XXXXX and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided.

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-04-22): XXXXX

03/17/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

63954032

33031349

Credit

AUS Discrepancy / Guidelines Discrepancy

Credit

Guideline Requirement: Maximum Loan Amount discrepancy.

Note loan amount of ___ is greater than Guideline maximum loan amount of ___.

Borrower has been employed in the same industry for more than 5 years.

Borrower has worked in the same position for more than 3 years.

Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00.

The Loan to Value (LTV) on the loan is less than or equal to 70%.

The qualifying DTI on the loan is at least 10% less than the guideline maximum.

The qualifying DTI on the loan is less than or equal to 35%.

The representative FICO score exceeds the guideline minimum by at least 40 points.

The representative FICO score is above 680.

SitusAMC

Reviewer Comment (2025-03-25): XXXXX

Reviewer Comment (2025-03-24): XXXXX

Seller Comment (2025-03-19): XXXXX

03/25/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

63954032

33031376

Compliance

Federal Compliance

TRID

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 $85.00 exceeds tolerance of $30.00. Sufficient or excess cure was provided to the borrower at Closing.

Credit Report Fee Amount of $85.00 exceeds tolerance of $30.00. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2025-03-13): XXXXX

03/13/2025

Primary

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

64896985

33011909

Credit

Insurance

Insurance Analysis

Insurance

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

HOI coverage is insufficient by $125,160.00. Provide updated policy reflecting minimum coverage of $1,125,160.00 OR provide copy of insurer's replacement cost estimate supporting current coverage amount.

Reviewer Comment (2025-03-25): XXXXX

Seller Comment (2025-03-24): XXXXX

03/25/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

64896985

33011923

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Verification appraisal was delivered to borrower was not provided.

03/13/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

64896985

33011924

Compliance

Federal Compliance

TRID Defect

TRID Final Closing Disclosure Other Includes Insurance Costs

Projected Payments: Final Closing Disclosure provided on XX/XX/XX disclosed whether Homeowners insurance is included in escrow in incorrect section. Creditor disclosed insurance to consumer in "Other" section where regulation requires disclosure under "Homeowner's Insurance" section of Projected Payments table. Disclosure requirement met, non-material exception for incorrect format/placement.

Reviewer Comment (2025-03-20): XXXXX

03/20/2025

Primary

Purchase

Good Faith Redisclosure

Safe Harbor QM (APOR)

Yes

[redacted]

64896985

33011926

Compliance

Federal Compliance

TRID Defect

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Examination Fee. Fee Amount of $225.00 exceeds tolerance of $150.00. Insufficient or no cure was provided to the borrower.

Title - Examination Fee was last disclosed as $150.00 on LE but disclosed as $225.00 on Final Closing Disclosure. File does not contain a valid COC for this fee, nor evidence of cure in file. Provide a post-close CD disclosing the tolerance cure to include $75.00, a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made.

Reviewer Comment (2025-03-17): XXXXX

Seller Comment (2025-03-14): XXXXX

03/17/2025

Primary

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

60531780

32929811

Compliance

Federal Compliance

ATR/QM Defect

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank XXXXX): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail.

Loan designation failure due to ATR failure. This exception will be cleared once all ATR specific exceptions have been cured/cleared.

Reviewer Comment (2025-03-05): XXXXX

Seller Comment (2025-03-04): XXXXX

Reviewer Comment (2025-02-28): XXXXX

Seller Comment (2025-02-28): XXXXX

03/05/2025

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM status

Safe Harbor QM (APOR)

Yes

[redacted]

60531780

32929812

Compliance

Federal Compliance

ATR/QM Defect

General QM Provision Employment - Schedule C

General QM: Unable to verify current Sole Proprietorship status using reasonably reliable third-party records.

Missing 3rd party verification for schedule C business

Reviewer Comment (2025-03-05): XXXXX

Seller Comment (2025-03-04): XXXXX

Seller Comment (2025-03-03): XXXXX

Reviewer Comment (2025-02-28): XXXXX

Seller Comment (2025-02-28): XXXXX

03/05/2025

Primary

Refinance - Cash-out - Other

Safe Harbor QM (APOR)

[redacted]

62290017

32996856

Compliance

Federal Compliance

TRID Defect

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee. Fee Amount of $250.00 exceeds tolerance of $0.00. Insufficient or no cure was provided to the borrower.

Second Appraisal Fee was not disclosed on Loan Estimate. File does not contain a valid COC for this fee, nor evidence of cure. Provide a post-close CD disclosing the tolerance cure to include $250.00, a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made.

Seller Comment (2025-03-13): XXXXX

Reviewer Comment (2025-03-13): XXXXX

03/13/2025

Primary

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

64619734

32987771

Compliance

Federal Compliance

ATR/QM Defect

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank XXXXX): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail.

Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. Waterfall exception due to loan failing point and fees and will be cleared once the points and fees exception is addressed.

Reviewer Comment (2025-03-14): XXXXX

Seller Comment (2025-03-11): XXXXX

03/14/2025

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM status

Safe Harbor QM (APOR)

Yes

[redacted]

64619734

32987772

Compliance

Federal Compliance

ATR/QM Defect

QM Points and Fees XXXXX

Qualified Mortgage (Dodd Frank XXXXX): Points and Fees on subject loan of 3.24679% is in excess of the allowable maximum of 3.00000% of the Federal Total Loan Amount. Points and Fees total $43,620.00 on a Federal Total Loan Amount of $XXXXX vs. an allowable total of $XXXXX (an overage of $3,315.55 or .24679%).

Points and Fees on subject loan of 3.24679% is in excess of the allowable maximum of 3.00000% of the Federal Total Loan Amount. Points and Fees total $43,620.00 on a Federal Total Loan Amount of $XXXXX vs. an allowable total of $40,304.45

Reviewer Comment (2025-03-14): XXXXX

Seller Comment (2025-03-11): XXXXX

03/14/2025

Primary

Refinance - Cash-out - Other

Safe Harbor QM (APOR)

[redacted]

63909740

33021119

Compliance

Federal Compliance

ECOA

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank XXXXX): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Verification appraisal was delivered to borrower was not provided.

03/14/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

63909740

33023090

Credit

Title

Document Error

Title

The Preliminary title policy is within XXXXX or XXXXX and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided.

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-04-22): XXXXX

03/14/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

67609532

33103498

Credit

Title

Document Error

Title

The Preliminary title policy is within XXXXX or XXXXX and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided.

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-04-22): XXXXX

03/26/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

68253363

33095854

Compliance

Federal Compliance

TRID Defect

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 $1,405.61 exceeds tolerance of $716.59. Insufficient or no cure was provided to the borrower.

Loan Discount Points was last disclosed as $716.59 on LE but disclosed as $1,405.61 on Final Closing Disclosure. File does not contain a valid COC for this fee, nor evidence of cure in file.

Reviewer Comment (2025-03-27): XXXXX

Seller Comment (2025-03-26): XXXXX

03/27/2025

Primary

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

68253363

33095855

Compliance

Federal Compliance

TRID Defect

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax. Fee Amount of $5,052.85 exceeds tolerance of $2,888.00. Insufficient or no cure was provided to the borrower.

Transfer Tax was last disclosed as $2,888 on LE but disclosed as $5,052.85 on Final Closing Disclosure. File does not contain a valid COC for this fee, nor evidence of cure in file.

Reviewer Comment (2025-03-27): XXXXX

Seller Comment (2025-03-26): XXXXX

03/27/2025

Primary

Purchase

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

Safe Harbor QM (APOR)

Yes

[redacted]

68253363

33130063

Compliance

Federal Compliance

TRID

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 $5,052.85 exceeds tolerance of $2,888.00. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2025-03-27): XXXXX

03/27/2025

Primary

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

69608368

32987688

Compliance

Federal Compliance

ATR/QM Defect

QM Points and Fees XXXXX

Qualified Mortgage (Dodd Frank XXXXX): Points and Fees on subject loan of 4.04022% is in excess of the allowable maximum of 3.00000% of the Federal Total Loan Amount. Points and Fees total $40,761.00 on a Federal Total Loan Amount of $XXXXX vs. an allowable total of $XXXXX (an overage of $10,494.60 or 1.04022%).

QM Points and Fees threshold exceeded by $10,494.60 or 1.04022%. Loan was consummated after XX/XX/XX. For loans consummated after this date, there is no longer any cure mechanism available for QM points and fees violations.

Reviewer Comment (2025-03-14): XXXXX

Seller Comment (2025-03-11): XXXXX

03/14/2025

Primary

Refinance - Cash-out - Other

Safe Harbor QM (APOR)

[redacted]

69608368

32988666

Compliance

Federal Compliance

ATR/QM

NonQM ATR

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

Loan designation failure due to ATR failure. This exception will be cleared once all ATR specific exceptions have been cured/cleared.

Reviewer Comment (2025-03-14): XXXXX

03/14/2025

Primary

Refinance - Cash-out - Other

Safe Harbor QM (APOR)

[redacted]

69608368

32988667

Compliance

Federal Compliance

ATR/QM Defect

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank XXXXX): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail.

Loan designation failure due to ATR failure. This exception will be cleared once all ATR specific exceptions have been cured/cleared.

Reviewer Comment (2025-03-17): XXXXX

Seller Comment (2025-03-11): XXXXX

03/17/2025

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM status

Safe Harbor QM (APOR)

Yes

[redacted]

69608368

32988717

Compliance

Federal Compliance

ATR/QM Defect

General Ability To Repay Provision Income and Assets - S-Corp

Ability to Repay (Dodd-Frank XXXXX): Unable to verify S-Corp income using reasonably reliable third-party records.

Waterfall exception due to loan failing QM points and fees.

Reviewer Comment (2025-03-14): XXXXX

Seller Comment (2025-03-13): XXXXX

03/14/2025

Primary

Refinance - Cash-out - Other

Safe Harbor QM (APOR)

[redacted]

67080713

33084167

Credit

Title

Document Error

Title

The Preliminary title policy is within XXXXX or XXXXX and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided.

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-04-22): XXXXX

03/21/2025

Primary

Purchase

Safe Harbor QM (APOR)

[redacted]

69084621

33061609

Credit

Title

General

Title

Title Policy Coverage is less than Original Loan Amount.

The Title Policy Amount of ___ is less than the note amount of ___ based on the ___ in file.

Final Title Policy will be provided as a trailing document.

Final Title Policy will be provided as a trailing document

SitusAMC,Aggregator

Reviewer Comment (2025-04-22): XXXXX

03/19/2025

Second Home

Purchase

Safe Harbor QM (APOR)

[redacted]

69084621

33062254

Compliance

Federal Compliance

TRID

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

Reviewer Comment (2025-03-17): XXXXX

03/17/2025

Second Home

Purchase

Final CD evidences Cure

Safe Harbor QM (APOR)

Yes

[redacted]

69084621

33084089

Credit

Property - Appraisal

Appraisal Documentation

Property - Appraisal

Subject Property is greater than 10 acres.

Subject is located on

60 acres of land. Lender exception noted in file.