GSMBS 2025-HE2

Opus Capital Markets Consultants, LLC

300 Tri-State International – Suite 320 | Lincolnshire, IL 60069 | www.opuscmc.com | 224.632.1300

Executive Narrative

October 10, 2025

Performed by

Opus Capital Markets Consultants, LLC

For

Goldman Sachs Mortgage Company

The report summarizes the results of a due diligence review performed on a pool of 115 loans, of which were purchased by Goldman Sachs Mortgage Company (“Customer”) from an originator (the “Originator”) who is a client of Opus Capital Markets Consultants, LLC (“Consultant”) under a reliance letter, and for which the Originator provided Consultant with a data tape, from which, in each case, 100% of the loan population was chosen and loaded into the LauraMac underwriting software. Consultant performed a detailed credit and compliance review of all loans.

As detailed herein, the pool contains a total of 115 HELOC ARM loans, of which 13 were first liens and 102 were second liens, and were re-underwritten in accordance with the lender guidelines in terms of Exhibit A.

EXHIBIT A

HELOC Review Scope

Credit Qualification

A re-underwriting review will be conducted in order to verify that the requisite underwriting Guidelines as specified by Client (“Guidelines”) are met. Confirmation of the loan terms will be performed through recalculation and review of documentation contained in the loan file provided to the Consultant. The Credit Qualification review will consist of the following:

a)	Guidelines: Determine whether each mortgage loan meets the requisite Guidelines requirements as specified by the Client. Guidelines

b)	Employment: Review the file documentation for minimum required level of employment, income and asset verifications pursuant to Client provided underwriting Guidelines.

c)	Income: Recalculate borrower(s) monthly gross income and verify calculations of income as used by the original loan underwriter at origination to determine compliance with the Client provided underwriting Guidelines.

d)	Assets: Confirm the presence of adequate asset documentation to comply with the Client provided underwriting Guidelines requirements for closing funds, reserves and borrower liquidity.

e)	Debt Ratio: Recalculate the debt-to-income ratio and verify the ratio accuracy used by the loan underwriter at origination to determine compliance with Client provided underwriting Guidelines and regulatory requirements.

f)	Property Valuation: Verify the valuation products are contained in the loan file and meet underwriting guide requirements. Ensure property type meets underwriting Guidelines. Guidelines

g)	Loan-to-Value Ratio: Recalculate and verify the loan-to-value ratio and combined loan-to-value ratio were accurate at origination and meet Client provided underwriting Guidelines and regulatory requirements.

h)	Credit History: Review the credit report to verify that the borrower(s) demonstrate adequate credit depth to comply with the

Client provided underwriting Guidelines requirements.

i)	Credit Scores: Verify that borrower(s) meet minimum credit score requirements of the Client provided underwriting Guidelines.

j)	Compensating Factors: Verify exceptions to the Client provided underwriting Guidelines approved by the credit or aggregator are documented and reasonable.

Document Review

A review of each loan file will be performed to confirm the presence of material documentation as applicable to the specifics of the loan transaction. The Document Review will consist of the following:

a) Collateral Docs

•

Title Commitment / Policy: To the extent a final title policy or commitment is required by the Guidelines, verify the presence of the title commitment or final title policy. Confirm vested parties and the description of the property, liens, tax assessments and lien position.

•

Mortgage Note / Security Instrument: Verify the presence of the mortgage note or security instrument. Confirm that the document has been executed by all borrowers and that all riders, addendums and endorsement are present and duly executed.

•

Mortgage / Deed of Trust: Verify the presence of a copy Mortgage or Deed of Trust. Confirm that the documents have been executed by all required parties and that all riders, addendums and exhibits are present and duly executed. Conveyance Deed: Verify as applicable that a proper conveyance deed is present in the loan file. Confirm the proper transfer of ownership interest of the subject parties is detailed on the deed.

b) Closing Docs

•

Final Hud-1 Settlement Statement: If required, verify the presence of a final HUD-1. Verify the completeness of required data and signatures or certification depending upon state compliance requirements.

•

Final Truth-in-Lending Disclosure: If required, verify the presence of a final Truth-in-Lending Disclosure. Verify the completeness of required data and that all required signatures are present.

•

Notice of Right to Cancel: If required based on the specifics of the loan transaction, confirm the presence and required execution of the Notice of Right to Cancel.

•

Verify presence of the HELOC Agreements and execution by all parties including: HELOC Early Program Disclosure along with the Home Equity Brochure Entitled “What you should know about Home Equity Lines of Credit”; Account Opening Disclosures or Credit Agreement and the HELOC Billing Statement.

c) Credit Docs

•

Loan Application: Verify the presence, timeliness, and completeness of both the initial and final loan applications.

•

Underwriting Worksheet: Verify the presence of the relative underwriting worksheet i.e. form 1008, FHA MCAW and VA’s Loan Analysis.

•

Credit Report: Verify the presence of a credit report for each borrower. Confirm that the credit report was pulled within the timing requirements allowable per the Client provided underwriting Guidelines.

•

Housing Payment History: In the absence of housing payment histories on the borrower(s) credit report(s), verify that that the file contains a verification of rent or a verification of mortgage form.

•

Letters of Explanation: When Letters of Explanation are required by the Client provided underwriting Guidelines, verify the presence of any such letters exist in the loan file.

•

Gift Letters: When Gift Letters are required by the Client provided underwriting Guidelines, verify the presence of any such letters exist in the loan file.

•

Income Documentation: Verify the presence of income and employment related documentation required by the Client provided underwriting Guidelines for all borrowing parties contributing income to the debt ratio calculation.

•

Asset Documentation: Verify the presence of asset documentation required by the Client provided underwriting Guidelines in the loan file.

•

Property Valuation Tools: Verify that each loan file contains adequate appraisal and other third-party valuation tools to satisfy the minimum required documentation under the relative Client provided underwriting Guidelines.

•

Proof of Insurance: Verify the presence of insurance certificates for mortgage, hazard, and flood insurance on an as needed basis depending upon the specifics of the loan. Confirm that adequate coverage is present to meet the requirements of the Client provided underwriting Guidelines.

Regulatory Compliance

HELOC Compliance Review Testing Scope

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

1. Rescission (§§1026.14, and 15):

a)	Failure to provide the right of rescission notice;

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

c)	Errors in the right of rescission notice;

d)	Failure to provide the correct form of right of rescission notice;

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

f)	Purchase money HELOC’s

g)	Failure to provide an extended rescission period when a violation of a material disclosure is present. A material disclosure is as follows:

(1)

the APR, including variable rate disclosures if applicable, and the circumstances under which the rate may increase, the limitations on the increase, and the effect of the increase;

(2)

the method of determining the finance charge and the balance upon which a finance charge will be imposed, as explained in section 1026.6 of Reg Z;

(3)

the amount or method of determining any membership or participation fees;

(4)

the HELOC plan’s payment terms, including the length of the draw period and repayment period;

(5)

an explanation, for both the draw period and the repayment period, of how the minimum periodic payment will be determined;

(6)

the timing of the payments; and

(7)

if applicable, that the minimum repayment would not repay any of the principal or may repay less than the outstanding balance, and a statement that a balloon payment may result.

2. High Cost

High-cost Mortgage (§§1026.31, 32 and 33):

Points and fees threshold test;

ii.

APR threshold test;

iii.

Prepayment penalty test; and

iv.

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

Additional Disclosures and Requirements:

1.	Home Equity Line of Credit (“HELOC”) Initial Disclosure

Confirm the presence of the HELOC Initial Disclosure in file

Confirm the HELOC Initial Disclosure was provided within three general business days of "Application" (Consultant reviews for this disclosure to be provided within three general business days, as the lender will typically know at the time of application if borrower(s) will be referred to affiliates for provision of third party services) ( §1026.40)

2.	HELOC “What You Should Know about Home Equity Lines of Credit” booklet

Confirm the presence of the “What You Should Know about Home Equity Lines of Credit” booklet in file

Confirm the “What You Should Know about Home Equity Lines of Credit” booklet was provided within three general business days of “Application” (Consultant reviews for this disclosure to be provided within three general business days as the lender will typically know at the time of application if borrower(s) will be referred to affiliates for provision of third party services)

3.	Review and compare a report including a recalculation of disclosed finance charge and recalculation of disclosed APR to determine disclosure differences were within the allowed tolerances.

Other Provisions

Texas: The disclosure requirements and prohibitions of Section 50(a)(6), 50(f)(2) and 50(t), of Article XVI of the Texas Constitution and associated regulations;

State & Local Anti- Predatory Lending (“APL”): The requirements and prohibitions applicable to HELOC’s subject to state, county and municipal anti-predatory lending 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. Attached as Exhibit A is a summary of the state and local anti-predatory lending regulations applicable to HELOC’s.

Prepayment Penalties and Late Fees:

State specific late charge and grace period provisions, but only in the four (4) states that impose Assignee Liability

– New Mexico, New Jersey, West Virginia and Georgia On loans listed as Consumer loans, check for all proper disclosures for late charges and prepayment penalties.

4. Mandatory Arbitration Clause: The presence of mandatory arbitration as prohibited by the Dodd-Frank Amendment to TILA;

5. Credit Insurance: The prohibition of financing credit insurance, when involuntary and where the creditor is the beneficiary;

6. Consultant will confirm compliance with current documentation and timing requirements in effect at origination of the Mortgage Loan including:

•

Servicing Transfer Disclosure (for applications prior to 10/03/2015):

Confirm the presence of the Servicing Transfer Disclosure form in file

Verify the Servicing Transfer Disclosure was provided to the borrower(s) within three general business days of “Application”

•

Special Information Booklet (for applications prior to 10/03/2015)/ Home Loan Tool Kit (for applications on or after 10/03/2015):

Confirm the presence of the Home Loan Tool Kit is in file for covered loans.

Confirm the Home Loan Tool Kit is provided within three general business days of “Application”

•

Affiliated Business Disclosure

Confirm the presence of the Affiliated Business Disclosure in file in the event the lender has affiliated business arrangements

Confirm the Affiliated Business Disclosure provided within three general business days of “Application” (Consultant reviews for this disclosure to be provided within three general business days, as the lender will typically know at the time of application if borrower(s) will be referred to affiliates for provision of third party services)

Confirm the Affiliated Business Disclosure is executed.

•

Initial Escrow Disclosure Statement

Confirm the presence of the Initial Escrow Disclosure Statement in file

Confirm the Initial Escrow Disclosure Statement was provided at closing or within 45 days after settlement

•

Homeownership Counseling Disclosure

Confirm the presence of the Homeownership Counseling Disclosure in file

Confirm the Homeownership Counseling Disclosure is provided within three general business days of “Application”

Exclusions. Service Provider will NOT test (as part of standard scope HELOC testing):

For compliance with TRID/QM/ATR.

State or Local APL HELOC Disclosures.

Technical formatting of disclosures.

For compliance with HPML regulations.

For compliance with state usury laws and limitations.

Other Post-Account Opening disclosures, including Escrow Closing Notice; and Mortgage servicing transfer and partial payment notices.

For Loans made by an FDIC-supervised institution or servicer, extended or renewed on or after January 1, 2016, whether prohibited fees were collected prior to the initial LE being issued

Whether any fee is a “bona fide” fee for third-party services

Whether the loans comply with all federal, state or local laws, constitutional provisions, regulations or ordinances that are not expressly enumerated above.

Regulatory Compliance Disclaimer

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

Please be further advised that Consultant does not employ personnel who are licensed to practice law in various jurisdictions, and the findings set forth in the reports prepared by Consultant do not constitute legal advice or opinions. They are recommendations or conclusions based on information provided to Consultant. 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 potential liability related to the purchase or other transaction involving any such loans, shall be made solely by the Client, or other agreed upon party, that has engaged Consultant to prepare its reports pursuant to its instructions and Guidelines. Client, or other agreed upon party, acknowledges and agrees that the scoring models applied by Consultant 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.

Seasoning And Certain Compliance Exceptions

Pursuant to the applicable NRSRO criteria, Consultant graded certain compliance exceptions as non-material based on seasoning of the mortgage loan. Certain mortgage loans were seasoned beyond the applicable period under TILA in which affirmative claims could be brought by a consumer. The time period is not limited for claims, other than recession, which are raised as a defense to foreclosure. Information contained in any Consultant reports 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 loan.

State & Local Anti-Predatory Lending (“APL”) Regulations Including High-Cost, Higher Priced, Rate Spread Regulations Governing HELOC’s

In addition to federal thresholds, Consultant will review the anti-predatory lending statutes in the following states and local municipalities, as applicable, as well as any additional applicable regulations implemented during the Term of this SOW.

•

Arkansas Home Loan Protection Act, Ark. Stat. Ann. § 23-53-101 et seq.

•

Connecticut Abusive Home Loan Lending Practices Act, Conn. Stat. Ann. §36a- 746 et seq., as amended from time to time.

•

Connecticut Nonprime Home Loans Statute, Conn. Gen. Stat. §§ 36a-760 et seq. (as originally enacted and as amended by Senate Bill 949).

•

District of Columbia Home Loan Protection Act, D.C. Official Code § 26-1151.01 et seq., as implemented by 20 D.C. Municipal Reg § 2000.1 et seq.

•

Florida Fair Lending Act, Fla. Stat. Ann. § 494.0078 et seq. (for loans closed before July 1, 2014).

•

Georgia Fair Lending Act, Ga. Stat. Ann. § 7-6A-1 et seq. (as originally enacted by House Bill 02-1361 and as modified by Senate Bill 03-53).

•

Illinois High Risk Home Loan Act, Public Act. 93-0561 (2003) codified at 815, ILCS §§ 137/5 et seq., and as amended by SB 1692 (2012), effective January 10, 2014

•

IL Residential Real Property Disclosure Act (SB 1167, SB 1894). SB 1167, SB 1894

•

Chicago, IL Predatory Lending Ordinance, 2-32-455 Public Act 95-0691 (SB 1167)

•

Cook County, IL Predatory Lending Ordinance, 765 ILCS 77/70 Public Act 95-0691 (SB 1167) Amended by Public Act 096-0856 (SB 186)

•

MA High-Cost Home Loan Regulations (pre-and post-amendments) 209 CMR 32.32.40 and 32.32.42

•

MA Predatory Home Loan Practices Act, M.G.L. Chapter 183C, §§ 1 et seq

•

MD Credit Regulations (includes MD HB 649, MD SB 270/HB 363 amendments, and COMAR Higher-Priced Mortgage Loan Provisions), HB 649, MD SB 270/HB 363

•

ME Title 9-A High-Rate, High Fee Provisions, High-Cost, Rate Spread Home Loan, and Higher-Priced Mortgage Loas Provisions (original provisions and 2008, 2009, & 2011 amendments), 9-A MRSA § 8-209(5) 8-206(1)

•

NC Restrictions and Limitations on High-Cost Home Loans 2009 NC Code Chapter 24 §24.1E 24.6(b)4

•

NC Rate Spread Home Loan Provisions (original 2008 provisions and 2009, 2013 amendments) §1F

•

NJ Home Ownership Security Act (pre-and post-amendments) NJ Stat. Ann. § C:46:10B-22 et seq., as amended from time to time

•

NM Home Loan Protection Act (Pre-and post-amendments) Senate Bill 449 (Regular Session 2003), Codified at NM Rev. Stat, § 58-21A-1 et seq and as amended from time to time

•

NV Unfair Lending Practices Act Chapter 598D §598.D110

•

NY GRBB Part 41 (pre-and post-amendments) 3CRR-NY §41.1 et seq

•

NY Banking Law 6-L NYSBL6-L (1 et seq)

•

OH – Predatory Lending Act (pre-and post-amendments) SB185

•

OH – Summit County, OH-Consumer Protection Ordinance 201.02 Office of Consumer Affairs §201.02 (b)(1)

•

RI Home Loan Protection Act and Regulation 3 - R.I. Gen. L, 34-25.1-2 et seq, as implemented by Emergency Banking Regulation 3 (2006) and Final Banking Regulation 3 (2007) and amended by Senate Bill 371 (2007)

•

RI Providence Ordinance Regarding Predatory Lending (post-amendment) Act, R.I. Gen Laws §34-25.2-1 et seq.

•

SC High-Cost and Consumer Home Loan Act (original provisions & 2010 ARM amendments) – S.C. Code §37-23-10 et seq.

•

TX Constitution “A6” (Article 16, Section 50(a)(6)) (pre-and post-amendments – Article 16, Section 50(a)(6)

•

TX Home Loan Act – Title 7. Banking and Securities Part 8. Joint Financial Regulatory Agencies Chapter 153. Home Equity Lending § 153.1 et seq.

•

UT High-Cost Home Loan Act – Utah Code § 61-2d-101 et seq

•

VT High-Rate Loans – 1024 Vermont Statutes Title 9 – Commerce and Trade Chapter 4 – INTEREST Subchapter 2: DISCLOSURE § High-Rate Loans.

Flood Insurance Testing

National Flood Insurance Program (NFIP)

Each mortgage loan will be reviewed to ensure adherence to flood insurance coverage requirements as outlined under the NFIP, including identification of flood zones and subsequent policy documentation for evidence of adequate coverage amounts.

Homeowner’s Flood Affordability Act (HFIAA)

Each mortgage loan made by an FDIC-supervised institution or servicer acting on its behalf shall require the escrow of all premiums and fess for flood insurance for any designated loan secured by residential improved real estate or a mobile home, made, increased, extended or renewed on or after January 1, 2016.

Frequency – Payable with same frequency as payments designated for the loans

Exceptions

•

Loan is an extension of credit primarily for business, commercial or agricultural purposes

•

Loan is in a subordinate position to a senior lien secured by the same residential improved real estate or mobile for which the borrower has obtained flood insurance

•

Flood Insurance coverage for the residential real estate is provided by a policy that

Meets requirements

Provided by a condominium association, cooperative or other applicable group and

The premium for which is paid by the condominium associate, cooperative, homeowners association, or other group as a common expense.

Misrepresentation and Third-Party Review

Validate that fraud reports and independent third-party property valuations reports are in the file. The review will consist of the following:

Misrepresentation Review and Valuation Review

Review on each loan to identify potential misrepresentations of income, employment, identity, occupancy, transaction and appraisal misrepresentation or other areas of potential misrepresentation. The Misrepresentation may include the following:

•

Signatures: Validate signature consistency across documents. To the extent imaged or hard copy files are provided, Consultant will utilize reasonable efforts to validate the consistency of signatures across documents.

•

Alerts: Assess credit report alerts for accuracy and potential issues.

•

Social Security Numbers: Compare SSN(s) across all file documents.

•

Document Integrity: Review for apparent alterations to loan documents. To the extent imaged or hard copy files are provided, Consultant will utilize reasonable review of alterations to the loan documents.

•

Data Consistency: Review the documents contained in the loan file for consistency of data.

•

Third Party Fraud Tools: To the extent a third-party fraud tool is contained in the loan file, the Consultant will ensure high level or critical warnings are reviewed and addressed.

Independent Third-Party Values

Review each loan to determine whether a third-party valuation product was required and if required, that the third party product value was compared to the valuation products required by the underwriting guidles.to identify a value variance and apply the appropriate rating agency grade after reviewing the required valuation products. Consultant will work with the Client to ensure third party products meet rating agency requirements given the different valuation products utilized to originate HELOCS. i) To the extent an appraisal is required by the underwriting guides and contained in the file, Consultant will perform the following steps.

•

Property is complete

•

Value is based on as-is condition or provides satisfactory completion of all material conditions including inspections, licenses, and certifications (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.

•

Property is described in average or better condition

•

No apparent appraiser independence violation statements

•

Appraisal addresses any adverse comments

•

Appraisal is completed on appropriate GSE Forms

•

Appraisal contains required attachments.

•

Appraiser was appropriately licensed at the time the appraisal was signed

If the valuation vendor des not supply the updated valuation product directly to the Consultant, the Client will authorize the valuation vendor to issue an attestation with sufficient information for the Consultant to determine the correct valuation product was utilized to verify the accuracy of the origination appraisal.

Value Review Disclaimer

•

The individuals performing the above procedures are not person providing valuations for the purpose of the Uniform Standards of Professional Appraisal Practice (“USPAP”) or necessarily licensed as appraiser under Federal or State law, and the services being performed do not constitute appraisal reviews for the purposes of USPAP or Federal or State law.

•

Opus makes no representation or warranty as to the value of the mortgaged property, notwithstanding that Opus may have reviewed the valuation information for reasonableness.

•

Opus is not an Appraisal Management Company (“AMC”) and therefore does not opine on the actual value of the underlying property.

•

Opus is not a creditor within the meaning of the Equal Credit Opportunity Act (“ECOA”) or other lending laws and regulations, and therefore Opus will not have and communications with or responsibility to any individual concerning property valuations.

Properties in FEMA declared disaster zones.

If a FEMA declared disaster occurs after the inspection date on the appraisal, Consultant will review the file to determine if an exterior inspection to ensure:

•

No apparent damage to the property

•

Property appears to be occupied

Closed End Second

Credit Qualification

A re-underwriting review will be conducted in order to verify that the requisite underwriting guidelines as specified by Client (the “Guidelines”) are met. Confirmation of the loan terms will be performed through recalculation and review of documentation contained in the loan file provided to the Consultant. The Credit Qualification review will consist of the following:

Guidelines: Determine whether each mortgage loan meets the requisite guideline requirements as specified by the Client. In lieu of specific requirements, Consultant should consider Regulation Z including Appendix Q if applicable. If the loan pre-dates the requirements of Regulation Z and Appendix Q, Consultant will consider Fannie Mae’s Single-Family guidelines.

l)	Employment: Review the file documentation for minimum required level of employment, income and asset verifications pursuant to Client provided underwriting guidelines.

m)	Income: Recalculate borrower(s) monthly gross income and verify calculations of income as used by the original loan underwriter at origination to determine compliance with the Client provided underwriting guidelines.

n)	Assets: Confirm the presence of adequate asset documentation to comply with the Client provided underwriting guideline requirements for closing funds, reserves and borrower liquidity.

o)	Debt Ratio: Recalculate the debt-to-income ratio and verify the ratio accuracy used by the loan underwriter at origination to determine compliance with Client provided underwriting guidelines and regulatory requirements.

Property Valuation: Analyze all appraisals and alternative value tools used to qualify the loan for integrity of comparable sales, completeness of data, eligibility of the appraiser and reasonableness of estimated value. Review the appraisal to determine the appraisal(s) meet the requirements of Client provided underwriting guidelines.

q)	Loan-to-Value Ratio: Recalculate and verify the loan-to-value ratio and combined loan-to-value ratio were accurate at origination and meet Client provided underwriting guideline and regulatory requirements.

r)	Credit History: Review the credit report to verify that the borrower(s) demonstrate adequate credit depth to comply with the Client provided underwriting guideline requirements.

s)	Credit Scores: Verify that borrower(s) meet minimum credit score requirements of the Client provided underwriting guidelines.

t)	Compensating Factors: Verify exceptions to the Client provided underwriting guidelines are documented and reasonable.

Document Review

a) Collateral Docs

•

Title Commitment / Policy: Verify the presence of the title commitment or final title policy. Confirm vested parties and the description of the property, liens and tax assessments.

•

Mortgage / Deed of Trust: Verify the presence of a copy Mortgage or Deed of Trust. Confirm that the documents have been executed by all required parties and that all riders, addendums and exhibits are present and duly executed. If the loan closed within 12 months of the review, Consultant will confirm the presence of a letter from the title company specifying the date the Mortgage / Deed Trust was sent for recording. If the closing did not occur within 12 months of the review and a copy of the recorded Mortgage /Deed of Trust is not contained in the loan file, the Client will submit a report from an independent document custodian verifying the presence of a recoded mortgage or a stamped / signed copy of the document stating the date the document was sent for recording.

•

Conveyance Deed: Verify as applicable that a proper conveyance deed is present in the loan file. Confirm the proper transfer of ownership interest of the subject parties is detailed on the deed.

b) Closing Docs

•

Final Truth-in-Lending Disclosure: If required, verify the presence of a final Truth-in-Lending Disclosure. Verify the completeness of required data and that all required signatures are present.

•

Notice of Right to Cancel: If required based on the specifics of the loan transaction, confirm the presence and required execution of the Notice of Right to Cancel.

•

Loan Estimate: If required verify the presence of the current Loan Estimate (LE) at the time of origination

•

Closing Disclosure: If required verify the presence of the current Closing Disclosure (CD) at the time of origination.

c) Credit Docs

•

Loan Application: Verify the presence and completeness of both the initial and final loan applications.

•

Underwriting Worksheet: Verify the presence of the relative underwriting worksheet i.e. form 1008, FHA MCAW and VA’s Loan Analysis.

•

Housing Payment History: In the absence of housing payment histories on the borrower(s) credit report(s), verify that that the file contains a verification of rent or a verification of mortgage form.

•

Letters of Explanation: When Letters of Explanation are required by the Client provided underwriting guidelines, verify the presence of any such letters exist in the loan file.

•

Gift Letters: When Gift Letters are required by the Client provided underwriting guidelines, verify the presence of any such letters exist in the loan file.

•

Income Documentation: Verify the presence of income and employment related documentation required by the Client provided underwriting guidelines for all borrowing parties contributing income to the debt ratio calculation.

•

Asset Documentation: Verify the presence of asset documentation required by the Client provided underwriting guidelines in the loan file.

•

Regulatory Compliance

For each Mortgage Loan, Consultant shall determine, to the extent possible and subject to caveats below, whether such Mortgage Loan at the time of origination complied with:

The “material”¹ disclosure requirements of the federal Truth-in-Lending Act (“TILA”), as amended by the Home Ownership and Equity Protection Act (“HOEPA”) and Dodd-Frank, 15 U.S.C. § 1601 et seq. and implemented by Regulation Z, 12 C.F.R. Part 1026, including the material provisions relating to Higher-Priced Mortgage Loans in Regulation Z, 12 C.F.R. §§ 1026.35, and the early TIL disclosure provisions of the Mortgage Disclosure Improvement Act (“MDIA”), as implemented by Regulation Z, 12 C.F.R. §§ 1026.17 et seq; and as amended by the TILA-RESPA Integrated Disclosure (“TRID”) Rule, as set forth below:

For Right of Rescission

A review of the Notice of Right to Cancel, including a verification of the transaction date and expiration date, ensuring proper execution of the Notice of Right to Cancel by all required parties, verifying the disbursement date and determining if a full three (3) day rescission period was adequately provided to the borrower(s).

This review is also to be performed on transactions that are exempt from the rescission requirement but on which a Notice of Right to Cancel was provided.

A condition must be placed if the transaction is a refinance by the original creditor and the borrower was provided the Form H-8 rescission notice. Consultant will note in the condition whether there was a new advance that is subject to rescission per TILA/Regulation Z.

For TILs (Application Dates prior to 10/3/2015)

¹ These “material” disclosures include the required disclosures of the APR, the finance charge, the amount financed, the total number of payments, the payment schedule, and if the loan is subject to the Homeownership and Equity Protection Act (“HOEPA”), the disclosure requirements and prohibitions of that statute which are set forth in 12 C.F.R. §§ 1026.32(c) and (d).

Confirm the initial TIL disclosure and final TIL disclosures were provided.

ii.

Review and compare the initial and final TIL, and any re-disclosed TIL(s), with a reportoutlining any TILA violations, including a recalculation of disclosed finance charge,proper execution by all required parties, principal and interest calculations, proper completion of the interest rate and payment summary, recalculation of disclosed APR, and a review to determine disclosure differences were within the allowed tolerances and disclosures were provided within the required timeframes;

For TRID Disclosures (Application Dates on or after 10/3/2015)

Confirm the initial Loan Estimate (LE) was delivered within three (3) business days ofapplication and seven (7) business days prior to consummation in accordance withClient’s Underwriting Guidelines;

ii.

Review the required sections of each LE to ensure they were populated in accordancewith the TRID Rules. (If the file reflects more than one LE was provided, each revised LEmust have corresponding Change of Circumstance documentation. The 0% and 10% fee tolerance evaluations will be based on the fee amounts disclosed on the initial LE and any valid changes documented and disclosed after the initial LE;

iii.

Confirm the Closing Disclosure (CD) confirm the borrower received the initial CD at leastthree (3) business days prior to consummation;

iv.

Review the required sections of each CD to ensure they were populated in accordancewith the TRID Rules. (Any fee tolerance issues to be cured at closing or within 60 days ofloan consummation.)

2.	Section 4 of the Real Estate Settlement Procedures Act (“RESPA”), 12 U.S.C. §2603 and 2604, as implemented by Regulation X, 12 C.F.R. Part 1024, and as amended by the TRID Rule;

3.	The disclosure requirements and prohibitions of Section 50(a)(6), Article XVI of the Texas Constitution;

4.	Confirmation that one of the following are in the loan file, per the Fair Credit Reporting Act: Consumer Credit Score Disclosure, Your Credit Score and the Price You Pay for Credit, or Notice to Home Loan Applicant;

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: the general Ability to Repay underwriting standards (12 C.F.R. 1026.43(c)); refinancing of non-standard mortgages (12 C.F.R. 1026.43(d)); Qualified Mortgages (12 C.F.R. 1026.43(e) (including qualified mortgages as 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)) In accordance with “Ability to Repay and Qualified Mortgage Review” description below;

6.	The Loan Originator Compensation and Prohibitions on Steering provisions of TILA, as implemented by Regulation Z, 12 C.F.R 1026.36;

7.	The requirements for Higher-Price Mortgage Loans, as implemented by Regulation Z, 12 C.F.R. 1026.35;

8.	The appraisal and valuation requirements of TILA, as implemented by Regulation Z, 12 C.F.R. 1026.35;

9.	The counseling requirements of TILA, as implemented by Regulation Z, 12 C.F.R. 1026.36(k) and RESPA, as implemented by Regulation X, 12 C.F.R. 1024.20;

10.	The escrow requirements of RESPA, as implemented by Regulation X, 12 C.F.R 1024.17;

11.	The disclosure requirements and prohibitions of any applicable state, county and municipal laws and ordinances, as amended, that have been enacted to regulate so-called “predatory lending”:

12.	Consultant shall confirm that any mortgage property located in an area identified on a flood hazard map or flood insurance rate map issued by the Federal Emergency Management Agency as having special flood hazards is subject to a qualified flood insurance policy that appears to be is in effect.

13.	For any loans designated as TILA exemption, Consultant shall review the loan file for evidence that the primary purpose of the loan was for commercial or business purposes, including, but not limited to a business purpose certification.

14.	Documentation. Review of the following documents for regulatory compliance:

Final HUD-1 Settlement Statement (“HUD-1”), if applicable

If the loan is in an escrow state, the HUD-1 will be considered final as follows:

HUD-1 is marked Final;

If HUD-1 is not marked Final, it must be stamped certified by the closing agent.

ii.

There should be no markings indicating that the HUD-1 is estimated.

HUD-1 is signed by all parties (including closing agent) or stamped certified by the closing agent; and

If HUD-1 is stamped, the HUD-1 / stamp should be signed or initialed by the closing agent; if the stamp does not contain the signature or initials, it must identify the name of the closing agent.

Final Truth in Lending Disclosure (“TIL”), if applicable

Loan Estimate, if applicable

The Loan Estimate in will be considered delivered based on the date issued, subject to the three-day mailing rule unless the file contains documentation indicating earlier receipt. The loan file may contain one or more Loan Estimates with the latest one provided up until three business days prior to the issuance of an initial Closing Disclosure.

Closing Disclosure, if applicable

The Closing Disclosure in the loan file will be considered delivered based on the date issued, subject to the three-day mailing rule unless the file contains documentation indicating earlier receipt. The loan file may contain one or more Closing Disclosures with the latest one provided up until the consummation date being considered the Final with any delivered post consummation considered as a corrected Closing Disclosure.

Notice of Right to Cancel (if applicable)

Initial TIL, if applicable

Good Faith Estimate (“GFE”), if applicable

Note

Mortgage/Deed of Trust

FACTA disclosures

Third Party Fees

Third party fees on the HUD-1 or Closing Disclosure if applicable referred to as HUD-1/Closing Disclosure, must be shown as paid to the third-party provider. A condition must be set if a third-party fee is paid to the lender, investor, etc. or the payee is blank.

ii.

CONSULTANT will condition for evidence in the file indicating that a charge on the HUD-1/Closing Disclosure exceeds the actual cost to the borrower (i.e. cost printed / stamped on the face of the document showing an amount less than the charge on the HUD-1/Closing Disclosure). Variations of less than $1 are deemed to be within reasonable limits and are not to be reported.

iii.

Any refunds that are provided to the borrower must be accompanied by a revised HUD-1/Closing Disclosure to show the final, accurate charges to the borrower.

Each loan reviewed will be assigned a Compliance condition grade in accordance with the Rating Agency Criteria as more fully described in Section 2(f).

Consultant will not make a determination as to whether the loans comply with federal, state or local laws, constitutional provisions, regulations or ordinances that are not expressly enumerated above. Furthermore, the findings reached by Consultant are dependent upon its receipt of complete and accurate data regarding the loans from loan originators and other third parties upon which Consultant is relying in reaching such findings.

Ability to Repay and Qualified Mortgage Review

For Agency Eligible Loans Only: Consultant reviews applicable loans for compliance with the Qualified Mortgage (QM) rule requirements set forth in Regulation Z (12 C.F.R. 1026.43 et seq.) based upon the loan’s designation (Safe Harbor QM, Rebuttable Presumption QM, Exempt). Consultant determines the loan’s status under the QM rule requirements and assigns a due diligence loan designation. Consultant notes as a material exception if the due diligence findings do not confirm the same loan designation. Additionally, Consultant notes if a loan designation was not provided. Consultant will verify if each loan meets the requirements for a QM under § 1026.43(e)(2)—whether the loan is a safe harbor QM under § 1026.43(e)(1)(i) or a rebuttable presumption QM under § 1026.43(e)(1)(ii). Consultant will verify the presence of documentation for lender determination of QM and indicating factors in its ability-to-repay determination, including how the originator applied its policies and procedures in verification. For loans applications taken on or after June 1, 2021, Consultant will verify whether the loan meets the requirements of the revised general QM definition effective March 1, 2021.

2.	For loans for which applications were received prior to July 1, 2021, if a 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, Consultant reviews the loan to determine whether, based on available information in the loan file the loan satisfied (i), (ii) and (iii) in the paragraph (3)(a)(i) below and reviews the Automated Underwriting System output within the file to confirm agency eligibility.

3.	For Non-Agency Eligible Loans: Consultant reviews applicable loans for compliance with the Ability to Repay (ATR) but not Qualified Mortgage (QM) rule requirements set forth in Regulation Z (12 C.F.R. 1026.43 et seq.).

a. Qualified Mortgage:

For QM (Safe Harbor or HPCT) designated loans, Consultant reviews the loan to determine whether, based on available information in the loan file: (i) the loan contains risky 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. Consultant reviews to the applicable consider and verify requirements under the QM rule depending on whether the QM was originated under the original general QM definition or the revised general QM definition effective March 1, 2021.

ii.

For each QM designated loan that satisfied the applicable requirements enumerated above, Consultant then determines whether the loan is a Safe Harbor QM or Higher Priced QM by comparing the loan’s actual annual percentage rate, as recalculated, to the applicable average prime offer rate plus a certain percentage. For QM designated loans originated under the revised general QM definition effective March 1, 2021, Consultant also determines whether the loan exceeds the pricing thresholds for QM loans.

b. Ability to Repay:

The ability to repay portion of the review for non-agency eligible loans only will focus on the eight factors detailed in the ATR Rule as detailed below for non-agency eligible loans. The Consultant will review the loan file to determine if the creditor verified and considered each of the eight factors utilizing reasonably reliable third-party documentation at or before consummation.

Current or reasonably expected income or assets that the consumer will rely on to repay the loan.

Current employment status

Monthly mortgage payment for subject loan using the introductory or fully indexed rate, whichever is higher, and monthly, fully amortizing payments that are substantially equal.

Monthly payment on any simultaneous loans secured by the subject property.

Monthly payments for property taxes and hazard/flood insurance and certain other costs related to the property such as homeowner’s association fees or ground rent.

Debts, alimony, and child support obligations

Monthly debt-to-income ratio or residual income

Credit history

ii.

For loans designated as agency eligible, Consultant will not review for compliance with the requirements of Appendix Q or General Ability to Repay.

iii.

Consultant reviews loans to determine their conformity with the ATR/QM factors above and is not rendering an independent assessment or analysis. Consultant’s review is based on information contained in the loan file at the time it is provided to Consultant, and only reflects information as of that point in time and does not mean any regulator, judicial or agency will agree with the Consultant’s conclusion.

Regulatory Compliance Disclaimer

other agreed upon party, acknowledges and agrees that the scoring models applied by Consultant 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.

Seasoning And Certain Compliance Exceptions

Additional Disclosures and Requirements:

Consultant will not review for compliance with current documentation and timing requirements in effect at origination of the Mortgage Loan including:

•

Servicing Transfer Disclosure (for applications prior to 10/03/2015):

•

Special Information Booklet (for applications prior to 10/03/2015)/ Home Loan Tool Kit (for applications on or after 10/03/2015):

•

Affiliated Business Disclosure

•

Initial Escrow Disclosure Statement

•

Fair Credit Report Act (Regulation V)

High-Cost, State & Local Anti-Predatory Regulations

•

Arkansas Home Loan Protection Act, Ark. Stat. Ann. § 23-53-101 et seq.

•

California Anti-Predatory Lending Statute, Cal. Fin. Code § 4970 et seq.

•

California Higher-Priced Mortgage Loan Statute, Cal. Fin. Code §4995 et seq.

•

Colorado Consumer Equity Protection Act, Colo, Rev. Stat. § 5-3.5-101 et seq..

•

Connecticut Abusive Home Loan Lending Practices Act, Conn. Stat. Ann. §36a- 746 et seq., as amended from time to time.

•

Connecticut Nonprime Home Loans Statute, Conn. Gen. Stat. §§ 36a-760 et seq. (as originally enacted and as amended by Senate Bill 949).

•

District of Columbia Home Loan Protection Act, D.C. Official Code § 26-1151.01 et seq., as implemented by 20 D.C. Municipal Reg § 2000.1 et seq.

•

Florida Fair Lending Act, Fla. Stat. Ann. § 494.0078 et seq. (for loans closed before July 1, 2014).

•

Georgia Fair Lending Act, Ga. Stat. Ann. § 7-6A-1 et seq. (as originally enacted by House Bill 02-1361 and as modified by Senate Bill 03-53).

•

Idaho Residential Mortgage Practices Act, Idaho Code § 26-3101 et seq.

•

Illinois High Risk Home Loan Regulations, 38 Ill. Admin. Code §345.10 et seq.

•

Illinois High Risk Home Loan Act, Public Act. 93-0561 (2003) codified at 815, ILCS §§ 137/5 et seq., and as amended by SB 1692 (2012), effective January 10, 2014.

•

Illinois Predatory Lending Database Program, Public Act 95-0691 (SB 1167).

•

City of Chicago, Illinois, Anti-Predatory Lending Ordinance, Chicago Municipal Code, §§ 2-32-440; 2-32-455; 2-92-325; 4-4-155; 8-4-325.

•

Cook County, Illinois, Anti-Predatory Lending Ordinance, Cook County Code of Ordinances § 34-341.

•

Cook County, Illinois, Anti-Predatory Lending Pilot Program, Illinois House Bill 4050 (2005).

•

Indiana Home Loan Practices Act, as amended by HB 1179 (2005), Ind. Code §24-9-1 et seq.

•

Section 16a-3-308a of the Kansas Consumer Credit Code, Kan. Stat. Ann. §16a.101 et seq.

•

Kentucky Anti-Predatory Lending Statute, Ky. Rev. Stat. § 360.100 et seq.

•

Maine, An Act to Enhance Consumer Protections in Relation to Certain Mortgages (for loans closed prior to September 27, 2011), Me. Rev. Stat. Ann. Tit. 9-A, §§ 8-103(1); 8-206(8);8-206A, as amended by Legislative Documents 1869 (2007), 2125 (2008) and 1439 (2009).

•

Maine Consumer Credit Code - Truth-in-Lending, (for loans closed on or after September 27, 2011), Me. Rev. Stat. Ann. tit. 9-A, §§ 8-501 et seq., as amended from time to time.

•

Maryland Commercial Law, Md. Code Ann., Com. Law §§ 12-124.1; 12-127; 12- 409.1; 12-1029.

•

Maryland Regulations for Higher Priced Mortgage Loans, as promulgated under the Maryland Mortgage Lender Law, Md. Code Ann., Fin. Instit. Code §§ 11-501 et seq.; Md. Code Regs. §§ 09.03.06.01 et seq.

•

Massachusetts High-Cost Mortgage Regulations, 209 CMR Parts 32 and 40, as amended from time to time.

•

Massachusetts Predatory Home Loan Practices Act, M.G.L. Chapter 183C, §§ 1 et seq.

•

Massachusetts “Borrower’s Interest” Standard, M.G.L. Chapter 183, §28C.

•

Massachusetts Mortgage Lender and Broker Regulations, 940 CMR §800 (15-17).

•

Massachusetts Regulations for Higher Priced Mortgage Loans, 209 CMR §§ 32.00 et.seq., as amended from time to time.

•

Massachusetts Subprime ARMs to First Time Homebuyers, M.G.L. Chapter 184, §17B.5.

•

Michigan Consumer Mortgage Protection Act, Mich. Stat. Ann. § 445-1631 et seq.

•

Minnesota Mortgage Originator and Service Licensing Act, § 58.137 et seq. (S.F. 2988 (2002)), as amended by House File 1004 (2007) and Senate File 988 (2007).

•

Nebraska Mortgage Bankers Registration and Licensing Act, Neb. Stat § 45-702 et seq.

•

Nevada Anti-Predatory Lending Law, Assembly Bill No. 284 (2003) and Amended by Assembly Bill No. 440 (2007), codified as NRS § 598D.010 et seq.

•

New Jersey Home Ownership Security Act of 2002, NJ Stat. Ann. § C:46:10B-22 et seq., as amended from time to time.

•

New Mexico Home Loan Protection Act, Senate Bill 449 (Regular Session 2003), codified at NM Rev. Stat. § 58-21A-1 et seq. and as amended from time to time.

•

New York High-Cost Home Loan Regulations, 3 NYCCR Part 41 (2001).

•

New York High-Cost Home Loan Act, N.Y. Bank. L. Ch. 626., as codified in NY Bank. Law § 6-l, and as implemented by 3 NYCCR Part 41 as amended from time to time.

•

New York Subprime Home Loans Statute, NY Bank. Law § 6-m.

•

North Carolina Anti-Predatory Lending Law, N.C. Gen. Stat. §§ 24-1.1A to 24- 10.2 and North Carolina Amendments to Anti-Predatory Lending Law, N.C. Gen. Stat. §§ 24-9; 24-1.1(E)(a); 24-10.2(a), as amended from time to time.

•

Ohio Anti-Predatory Lending Statute, HB 386 as amended by Senate Bill 185 (2006), and as codified in various sections of the Ohio Code.

•

Ohio Consumer Sales Practices Act, Ohio Rev. Code Ann. § 1345.01, as implemented by Ohio Admin. Rules § 109 4-3-01 et seq.

•

City of Cleveland Heights, Ohio, Anti-Predatory Lending Ordinance, Ordinance No. 72-2003 (PSH), Mun. Code §§ 757.01 et seq.

•

Summit County, Ohio, Anti-Predatory Lending Ordinance, Ordinance No. 2004- 618, Muni. Code §§ 201.01 et seq.

•

Oklahoma Anti-Predatory Lending Law, House Bill No. 1574 (2003), as codified in various sections of Title 14A of the Oklahoma Consumer Credit Code.

•

Oklahoma Higher-Priced Mortgage Loans Law, Okla. Admin. Code §§ 160:45-9- 1 et seq.

•

Pennsylvania Consumer Equity Protection Act, 63 Pa. Cons. Stat. Ann. § 456.501 et seq.

•

Rhode Island Home Loan Protection Act, R.I. Gen. L. 34-25.1-2 et seq, as implemented by Emergency Banking Regulation 3 (2006) and Final Banking Regulation 3 (2007) and amended by Senate Bill 371 (2007).

•

City of Providence, Rhode Island, Anti-Predatory Lending Ordinance, Chapter 2006-33, Ordinance No. 245.

•

South Carolina High-Cost and Consumer Home Loans Act, S.C. Code § 37-23-10 et seq.

•

Tennessee Home Loan Protection Act, Tenn. H.R. 3597 (2006), as codified at Tenn. Code Ann. §§ 45-20-101 et seq.

•

Texas High-Cost Home Loan Statute, Tx. Fin. Code Ann. § 343.201 et seq.

•

Section 50(a)(6), Article XVI of the Texas Constitution

•

Section 50(f)(2), Article XVI of the Texas Constitution

•

Utah Residential Mortgage Practices Amendments, Utah Code Ann. § 61-2c-102 et seq.

•

Utah High-Cost Home Loan Act, Utah Code § 61-2d-101 et seq.

•

Vermont Interest Act, 9 V.S.A. § 104, implemented by Regulation B-98-2.

•

Virginia Mortgage Lender and Broker Act (for loans originated prior to July 1, 2003), Va. Code Ann. §§ 6.1-413; 6.1-422; 6.1-428.

•

Virginia Mortgage Lender and Broker Act (for loans originated on or after July 1, 2003 to September 30, 2010, as amended), Va. Code Ann. §§ 6.1-411, 6.1-422.1, 6.1-425.1 and 6.1-425.2.

•

Virginia Mortgage Lender and Broker Act (for loans originated on or after October 1, 2010), Va. Code Ann. §§ 6.2-1600 et seq., as amended from time to time.

•

Virginia Senate Bill 797 (2008), effective July 1, 2008 (uncodified).

•

West Virginia Residential Mortgage Lender, Broker and Servicer Act, W.Va. Code § 31-17 et seq.

•

Wisconsin Responsible High-Cost Mortgage Lending Act, Wis. Stat. § 428.202, as implemented by Wis. Admin. Code DFI-Bkg 46.01 et seq.

Misrepresentation and Third-Party Review

Validate that fraud reports and independent third-party property valuations reports are in the file. The review will consist of the following:

1) Misrepresentation Review and Valuation Review

•

Alerts: Assess credit report alerts for accuracy and potential issues.

•

Social Security Numbers: Compare SSN(s) across all file documents.

•

Data Consistency: Review the documents contained in the loan file for consistency of data.

•

Third Party Fraud Tools: To the extent a third party fraud tool is contained in the loan file, the Consultant will ensure high level or critical warnings are reviewed and addressed.

Independent Third-Party Values

Review each loan to determine whether a third party valuation product was required and if required, that the third party product value was compared to the original appraised value to identify a value variance and apply the appropriate rating agency grade after reviewing the required valuation products. i) Consultant will perform the following steps.

•

Property is complete

•

Property is described in average or better condition

•

No apparent appraiser independence violation statements

•

Appraisal addresses any adverse comments

•

Appraisal is completed on appropriate GSE Forms

•

Appraisal contains required attachments.

•

Appraiser was appropriately licensed at the time the appraisal was signed

If the valuation Consultant des not supply the updated valuation product directly to the Consultant, the Client will authorize the valuation Consultant to issue an attestation with sufficient information for the Consultant to determine the correct valuation product was utilized to verify the accuracy of the origination appraisal.

Value Review Disclaimer

•

Opus makes no representation or warranty as to the value of the mortgaged property, notwithstanding that Opus may have reviewed the valuation information for reasonableness.

•

Opus is not an Appraisal Management Company (“AMC”) and therefore does not opine on the actual value of the underlying property.

•

Properties in FEMA declared disaster zones.

If a FEMA declared disaster occurs after the inspection date on the appraisal, Consultant will review the file to determine if an exterior inspection to ensure:

•

No apparent damage to the property

•

Property appears to be occupied

I. Data Compare

Client will provide a data tape with the following data fields and Consultant will compare the field to the applicable source document and report any variance

•

Appraised Value

•

CLTV

•

DTI

•

FICO

•

Interest Only

•

Interest Rate

•

Loan Term

•

Loan Purpose

•

LTV

•

Occupancy

•

Original Balance

•

Property Address

•

Property City

•

Property State

•

Property Type

•

Sales Price

•

Second Mortgage Lien Amount

•

Self Employed

•

Units

•

Zip Code

•

Loan Type

•

QM Status

II. Rating Agency Grading Criteria

Fitch Ratings Grading Criteria

Grading shall be provided for each exception, each exception category and holistically for each loan. The methodology for the application of the RMBS grading as defined by Fitch in their current industry publications as updated from time to time.

Moody’s Investor Services Grading Criteria

Grading shall be provided for each exception, each exception category and holistically for each loan. The methodology for the application of the RMBS grading as defined by Moody’s in their current industry publications as updated from time to time.

Kroll Bond Rating Agency LLC Grading Criteria

Grading shall be provided for each exception, each exception category and holistically for each loan. The methodology for the application of the RMBS grading as defined by Kroll in their current industry publications as updated from time to time.

S&P Global Ratings Grading Criteria

Grading shall be provided for each exception, each exception category and holistically for each loan. The methodology for the application of the RMBS grading as defined by Standard & Poor’s in their current industry publications and updated from time to time.

DBRS Morningstar Grading Criteria

Grading shall be provided for each exception, each exception category and holistically for each loan. The methodology for the application of the RMBS grading as defined by DBRS in their current industry publications and updated from time to time.

III. Opus Grading Criteria

1) Opus Grading Criteria

Grading shall be provided for each exception, each exception category and holistically for each loan. The following grading is not intended for securitization reviews and Opus will not issue a Rating Agency Narrative, Reliance or Form ABS Due Diligence 15E if Client elects to utilize the following grading criteria. The methodology for the application of grading is defined by Opus and updated from time to time shall be determined as follows:

Opus Credit Grades

•

Level 1 Credit Grade Definition: Loan was originated in accordance with the mortgage loan originator underwriting guidelines without exception.

•

Level 2 Credit Grade Definition: Loan was originated in substantial compliance with the originator's underwriting guidelines and there are sufficient compensating factors for any exceptions.

•

Level 3 Credit Grade Definition: Loan was not originated in substantial compliance with the originator's underwriting guidelines and there are insufficient compensating factors for the exceptions or is missing material documentation.

Opus Property Grades

•

Level 1 Property Grade Definition: Property value appears to be within 10% of original appraised amount and there are no material deficiencies in the appraisal process.

•

Level 2 Property Grade Definition: Property value appears to be within 10% of original appraised amount, but minor issues in the appraisal process were identified.

•

Level 3 Property Grade Definition: Property value does not appear to fall within 10% of the original appraised value and/or material deficiencies exist with respect to the appraisal process or the file is missing material documentation.

Opus Compliance Grades

•

Level 1 Compliance Grade Definition: Loan complies with all applicable laws and regulations reviewed under the applicable scope of work.

•

Level 2 Compliance Grade Definition: There are minor issues regarding legal and/or regulatory compliance but such issues do not represent risks to the enforceability of the borrower's obligation under the loan documents and will not result in assignee liability to the investor.

•

Level 3 Compliance Grade Definition: Loan is not in compliance with laws and regulations reviewed under the applicable scope of work or the loan is missing material documentation.

IV. REDACTED INFORMATION

•

Borrower Name

•

Co-Borrower Name

•

SSNs

•

Property Address, City, County, MSA, Zip

•

Mailing Address

•

Account Number, including Originator and Servicer Loan Number

•

Origination Date

•

Names of Borrowers or any other Individuals

•

Company and Entity Names

•

Financial Institution Names

•

Job Position Titles

•

Any Address

•

Any Location Information (other than state), including City, County, MSA and Zip

•

Account Numbers of any type

•

Insurance Claim Numbers

•

Insurance Policy Numbers

•

Foreclosure Action dates and Case Numbers

•

Bankruptcy Action dates and Case Numbers

•

Any reference that would allow the identification of the location of a property (e.g. neighborhood, body of water, schools, major highways)

Pool Details

Loan Type
Type	Count	% of Pool
Non-Conforming	115	100.00%
Conforming-GSE Eligible	0	0.00%
Total	115	100.00%

Interest Rate
Type	Count	% of Pool
7.500 - 7.999	11	9.57%
8.000 - 8.499	24	20.87%
8.500 - 8.999	21	18.26%
9.000 - 9.499	19	16.52%
9.500 - 9.999	17	14.78%
10.000 - 10.499	5	4.35%
10.500 - 10.999	8	6.96%
11.000 - 11.499	1	0.87%
11.500 - 11.999+	9	7.83%
Total	115	100.00%

Purpose
Type	Count	% of Pool
Cash out Refi	114	99.13%
Purchase	0	0.00%
Rate / Term Refi	1	0.87%
Total	115	100.00%

DTI
Type	Count	% of Pool
0.00-20.00	5	4.35%
20.01-30.00	11	9.57%
30.01-40.00	24	20.87%
40.01-45.00	29	25.22%
45.01-50.00	46	40.00%
Total	115	100.00%

Product Type
Type	Count		% of Pool
Fixed		0		0.00%
ARM		115		100.00%
Total		115		100.00%

Occupancy
Type	Count	% of Pool
Primary Residence	95	82.61%
Second Home	3	2.61%
Investment Property	17	14.78%
Total	115	100.00%

Property Type
Type	Count	% of Pool
Single Family Detached	76	66.09%
Co-op	0	0.00%
Condo, Low Rise	6	5.22%
Condo, High Rise	0	0.00%
PUD	30	26.09%
1 Family Attached	2	1.74%
2 Family	0	0.00%
3 Family	1	0.87%
4 Family	0	0.00%
Total	115	100.00%

LTV
Type	Count	% of Pool
0.00-30.00	99	86.09%
30.01-40.00	8	6.96%
40.01-50.00	5	4.35%
50.01-60.00	0	0.00%
60.01-70.00	2	1.74%
70.01-80.00	1	0.87%
80.01-90.00	0	0.00%
Total	115	100.00%

QM Type
Type	Count	% of Pool
QM/Non-HPML	0	0.00%
QM/Agency Safe Harbor	0	0.00%
QM/HPML	0	0.00%
ATR/QM: Not Applicable	115	100.00%
Total	115	100.00%

Multiple Loans to One Borrower: TPR firm reviewed common identifiers for all loans in the population and confirmed there was one obligor with multiple loans in the pool.

Tape Discrepancies

Data Element	Count	Accuracy
Final Qualifying Property Value	2	98.26%
Note Type	3	97.39%
Property Address	2	98.26%
Property City	1	99.13%
Property Type	2	98.26%
Qualifying CLTV	12	89.57%
Qualifying Interest Rate	4	96.52%
Qualifying Total Debt Income Ratio	111	3.48%
Total Loan Population	115

Loan Grading Definitions

Credit

S&P	Moody’s	Fitch	Kroll	DBRS	Definition
A	A	A	A	A	Loan conforms to all applicable guidelines, no conditions noted
B	B	B	B	B	Loan does not meet every applicable credit guideline. However, most of the loan characteristics are within the guidelines and there are documented and significant compensating factors
C	C	C	C	C	The loan does not meet every applicable credit guideline, and most of the loan characteristics are outside of guidelines; or there are weak or no compensating factors
D	D	D	D	D	The loan file is missing critical documentation required to perform the review

Compliance

S&P	Moody’s	Kroll	DBRS	Definition
A	A	A	A	The loan was originated in compliance with applicable federal, state, and local predatory and high cost, TILA, and Regulation Z laws and regulations
B	B	B	B	The loan was originated in compliance with applicable federal, state, and local predatory and high cost, TILA, and Regulation Z laws and regulations; however, minor evidentiary issue(s) exist
C	C	C	C	The includes material violation(s) with applicable federal, state, and local predatory and high cost, TILA, and Regulation Z laws and regulations
D	D	D	D	The loan file is missing critical documentation required to perform the review

Fitch	Definition
A	The loan was originated in compliance with applicable federal, state, and local predatory and high cost, TILA, and Regulation Z laws and regulations
B	The loan is in compliance with all applicable laws and regulations and a benefit to the borrower is present and documented
C	The includes material violation(s) with applicable federal, state, and local predatory and high cost, TILA, and Regulation Z laws and regulations
D	The loan file is missing critical documentation required to perform the review

Property Valuation

Moody’s	Fitch	Kroll	DBRS	Definition
A	A	A	A	Value is within a 10% variance of third party product. Appraisal meets lender guidelines. Subject property is 100% complete. Property condition is average or better. Standard GSE form was utilized. Appraiser is licensed. Appraisal is complete.
B	B	B	B	Meets all terms for an A, but property requires cosmetic or minor repairs that do not affect value or habitability
C	C	C	C	Any of the following items: Origination value and third party valuation product value has a variance of 10% or greater, cannot validate value, property is incomplete, property condition is less than average, GSE form was not utilized, and/or the appraisal and/or does not meet guidelines
D	D	D	D	The loan file was missing the appraisal and/or other valuations products needed to complete the review

S&P	Definition
A	First Level Review Value is within a 10% variance to the original appraisal. Appraisal meets lender guidelines. Subject property is 100% complete. Property condition is average or better. Standard GSE form was utilized. Appraiser is licensed. Appraisal is complete.
B	First Level Review Value is greater than a 10% variance to the original appraisal but the second level review value is within 10% variance of the original appraised value. In addition, property requires cosmetic or minor repairs that do not affect value or habitability
C	Any of the following items: Second Level Review Value is greater than a 10% variance to the original appraisal, cannot validate value, property is incomplete, property condition is less than average, GSE form was not utilized, and/or the appraisal and/or does not meet guidelines
D	The loan file was missing the appraisal and/or other valuations products needed to complete the review

Loan Review Findings

The following summarizes Consultant’s initial and final loan securitization and event grades assigned to the final reviewed loan pool and reported in the Agency Grading Report dated June 17, 2025.

Overall Grade Summary

DBRS, Kroll, and Moody’s NRSRO Grade	# of Loans	% of Loans
A	95	82.61%
B	20	17.39%
C	0	0.00%
D	0	0.00%

Compliance Grade Summary

DBRS, Kroll, and Moody’s NRSRO Grade	# of Loans	% of Loans
A	101	87.83%
B	14	12.17%
C	0	0.00%
D	0	0.00%

Credit Grade Summary

DBRS, Kroll, and Moody’s NRSRO Grade	# of Loans	% of Loans
A	105	91.30%
B	10	8.70%
C	0	0.00%
D	0	0.00%

Property Grade Summary

DBRS, Kroll, and Moody’s NRSRO Grade	# of Loans	% of Loans
A	12	10.43%
B	0	0.00%
C	0	0.00%
D	0	0.00%
N/A	103	89.57%

Overall Grade Summary

S&P NRSRO Grade	# of Loans	% of Loans
A	12	10.43%
B	3	2.61%
C	100	86.96%
D	0	0.00%

Compliance Grade Summary

S&P NRSRO Grade	# of Loans	% of Loans
A	101	87.83%
B	14	12.17%
C	0	0.00%
D	0	0.00%

Credit Grade Summary

S&P NRSRO Grade	# of Loans	% of Loans
A	105	91.30%
B	10	8.70%
C	0	0.00%
D	0	0.00%

Property Grade Summary

S&P NRSRO Grade	# of Loans	% of Loans
A	12	10.43%
B	0	0.00%
C	103	89.57%
D	0	0.00%

Overall Grade Summary

Fitch NRSRO Grade	# of Loans	% of Loans
A	95	82.61%
B	20	17.39%
C	0	0.00%
D	0	0.00%

Compliance Grade Summary

Fitch NRSRO Grade	# of Loans	% of Loans
A	101	87.83%
B	14	12.17%
C	0	0.00%
D	0	0.00%

Credit Grade Summary

Fitch NRSRO Grade	# of Loans	% of Loans
A	105	91.30%
B	10	8.70%
C	0	0.00%
D	0	0.00%

Property Grade Summary

Fitch NRSRO Grade	# of Loans	% of Loans
A	115	100.00%
B	0	0.00%
C	0	0.00%
D	0	0.00%

Loans Reviewed (115)

1000431143	1001302456	1001302485	1001302510	1001302535	1001302561
1000503903	1001302457	1001302486	1001302511	1001302537	1001302562
1000504097	1001302458	1001302487	1001302512	1001302538	1001302563
1000582758	1001302459	1001302488	1001302513	1001302540	1001302564
1000882920	1001302460	1001302490	1001302514	1001302541	1001302565
1001182503	1001302462	1001302492	1001302517	1001302543	1000882875
1001182556	1001302463	1001302493	1001302518	1001302544	1001182514
1001302442	1001302464	1001302494	1001302519	1001302545	1001182559
1001302443	1001302466	1001302495	1001302521	1001302546	1001302441
1001302445	1001302467	1001302496	1001302522	1001302548	1001302468
1001302446	1001302469	1001302497	1001302524	1001302549	1001302473
1001302447	1001302471	1001302499	1001302525	1001302551	1001302481
1001302448	1001302474	1001302500	1001302527	1001302552	1001302503
1001302449	1001302476	1001302501	1001302528	1001302553	1001302520
1001302450	1001302478	1001302504	1001302529	1001302554	1001302542
1001302451	1001302479	1001302505	1001302530	1001302555
1001302452	1001302480	1001302506	1001302531	1001302556
1001302453	1001302482	1001302507	1001302532	1001302557
1001302454	1001302483	1001302508	1001302533	1001302558
1001302455	1001302484	1001302509	1001302534	1001302559

If you have any questions, please contact Uriah Clavier at Uriah.Clavier@opuscmc.com.