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

 

Onslow Bay Funding LLC

 

Check the appropriate box to indicate the filing obligation 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)(l) ☐

 

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) ☐

 

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

 

Central Index Key Number of depositor: 0001658638

 

OBX 2022-NQM7 Trust

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

 

Central Index Key Number of issuing entity (if applicable): _______________

 

Central Index Key Number of underwriter (if applicable): ________________

 

Michael Fania, (212) 696-0100

Name and telephone number, including area code, of the person to contact in

connection with this filing

 

 

 

 

 

 

PART I: REPRESENTATION AND WARRANTY INFORMATION

 

Item 1.01Initial Filing of Rule l5Ga-1 Representations and Warranties Disclosure

 

Not Applicable

 

Item 1.02Periodic Filing of Rule l5Ga-1 Representations and Warranties Disclosure

 

Not Applicable

 

Item 1.03Notice of Termination of Duty to File Reports under Rule l5Ga-1

 

Not Applicable

 

 

 

 

PART II – FINDINGS AND CONCLUSIONS OF THIRD-PARTY DUE DILIGENCE

 

REPORTS

 

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.

 

 

 

 

EXHIBIT INDEX

 

99.01 AMC Diligence, LLC (“AMC”) Narrative
99.02 AMC Rating Agency Grades Report
99.03 AMC Exception Grades Report
99.04 AMC Valuation Summary Report
99.05 AMC Business Purpose Report
99.06 AMC Data Compare Report
99.07 AMC Delinquency Summary Report
99.08 AMC Servicing Pay History Report
99.09 AMC Title Diligence Summary
99.10 Consolidated Analytics, Inc (“CA”) Narrative
99.11 CA Annaly Standardized TPR Report
99.12 CA Due Diligence Standard Report
99.13 CA Grading Summary Report
99.14 CA Valuation Summary Report
99.15 CA Data Compare Report
99.16 Canopy Financial Technology Partners LLC (“Canopy”) Narrative
99.17 Canopy Rating Agency Grades Detail Report
99.18 Canopy Rating Agency Grades Summary Report
99.19 Canopy Valuation Report
99.20 Canopy ATR QM Report
99.21 Canopy Data Compare Report
99.22 Clayton Services LLC (“Clayton”) Narrative
99.23 Clayton Conditions Summary Report
99.24 Clayton Conditions Detail Report
99.25 Clayton Loan Grades Report
99.26 Clayton Loan Level Tape Compare Report
99.27 Clayton Rating Agency ATR QM Report
99.28 Clayton Valuations Summary Report
99.29 Clayton Non ATR QM Upload Report
99.30 Covius Real Estate Services, LLC (“Covius”) Narrative
99.31 Covius ATR QM Data Fields Report
99.32 Covius Rating Agency Business Purpose Report
99.33 Covius Rating Agency Exceptions Report
99.34 Covius Rating Agency Grades Report
99.35 Covius Rating Agency Tape Compare Securitization Report
99.36 Covius Rating Agency Valuation Report
99.37 Evolve Mortgage Services (“Evolve”) Narrative
99.38 Evolve Rating Agency Grades Report

 

 

 

 

99.39 Evolve Exception Detail Report
99.40 Evolve Valuation Report
99.41 Evolve Data Compare Report
99.42 Evolve QM ATR Data Report
99.43 Evolve Business Purpose Report
99.44 Inglet Blair, LLC (“IB”) Narrative
99.45 IB Loan Summary Report
99.46 IB Exception Report
99.47 IB Final Grading Summary Report
99.48 IB QM Summary Report
99.49 IB Data Comparison Report
99.50 IB Valuation Report

 

 

 

 

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.

 

ONSLOW BAY FUNDING LLC
   
Date: August 8, 2022 By: /s/ Michael Fania
Name:  Michael Fania
Title: Authorized Signatory

 

 

 


Exhibit 99.01

 

 

 

 

EXECUTIVE SUMMARY

 

DESCRIPTION OF SERVICES

(1) Type of assets that were reviewed.

AMC Diligence, LLC (“AMC”) performed the due diligence services described below (the “Review”) on residential mortgage loans originated by multiple correspondent lenders and acquired directly on a mini-bulk basis by Onslow Bay Financial LLC (the “Client”). AMC performed the Review either (i) directly for Client on mortgage loan files provided by Client to AMC, or (ii) for third parties on mortgage loan files provided by such parties to AMC with results of such Review conveyed to the Client via reliance letter. The Review (including the Review related to reliance letter loans) was conducted from June 2020 through June 2022 on mortgage loans with origination dates from June 2005 through June 2022.

 

(2) Sample size of the assets reviewed.

The total population of the Review covered 567 mortgage loans totaling an aggregate original principal balance of approximately $332.591 million.

 

(3) Determination of the sample size and computation.

The Review was conducted consistent with the criteria for the nationally recognized statistical rating organizations, NRSRO(s), identified above.

 

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

AMC compared data fields on the bid tape provided by the Client to the data found in the actual mortgage loan file as captured by AMC. This comparison, when data was available (please note that not all fields were available for all loans during the Review) and relevant for the Scope in question, included the following data fields:

 

# of Units Interest Only Period Original Interest Rate
Amortization Term Interest Rate Change Frequency Original Interest Rate Period
Amortization Type Interest Rate Initial Cap Original Loan Amount
Appraisal Date Interest Rate Initial Floor Original LTV
Appraised Value Interest Rate Life Max Original P&I
Borrower First Name Interest Rate Life Min Original Term
Borrower Last Name Interest Rate Periodic Cap Originator Loan Designation
Borrower SSN Interest Rate Periodic Floor PMI Coverage %
City Investor: Qualifying Total Debt Ratio Property Type
Coborrower First Name Lien Position Purpose
Coborrower Last Name LTV Valuation Value Refi Purpose
Coborrower SSN Margin Representative FICO
Contract Sales Price Maturity Date State
Current Maturity Date MERS Min Number Street
Doc Type Mortgage Type Subject Debt Service Coverage Ratio
First Payment Date Note Date Zip
Has FTHB Occupancy  
Index Type Original CLTV  

 

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

 

CREDIT SCOPE (394 Mortgage Loans):

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. When applicable, a review of the mortgage loan file to the Automated Underwriting System output within the mortgage loan file was also performed.

 

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 the 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, and (iii) gathered liabilities listed on the credit report to be included in the debt to income ratio as appropriate.

 

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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 the 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, (vi) IRS tax transcripts, and (vii) bank statements.

 

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 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 provided and appropriate, AMC verified that DU findings included an approved/ineligible decision where required by the guidelines. However, all mortgage loans are manually underwritten with documentation requirements determined by the guidelines and not 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 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.

 

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 review of the chain of title and the duration of ownership by the seller or borrower (whichever is applicable) satisfied the guidelines. Included in this review was 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 that was 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.

 

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(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 guideline requirements, and (viii) 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 the 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. 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.

 

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

 

COMPLIANCE SCOPE (395 Mortgage Loans):

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.

 

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 loan’s collateral that has been reviewed by AMC.

 

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

 

FOR APPLICATION DATES BEFORE JANUARY 10, 2014

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

a)Rescission (§1026.23):
i)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;
v)failure to provide the three (3) business day rescission period; and
vi)any material disclosure violation on a rescindable 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;
b)TIL Disclosure (§§1026.17, 18 and 19) as applicable for loans with application dates prior to October 3, 2015:
i)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);
c)Tolerances (§§1026.18, 22 and 23):
i)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;
d)High-cost Mortgage (§§1026.31, 32 and 33):
i)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;
e)Higher-priced Mortgage Loan (§1026.35):
i)APR threshold test; and
ii)compliance with the escrow account and appraisal requirements;

 

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

a)Good Faith Estimate (GFE) (§1024.7) as applicable for loans with application dates prior to October 3, 2015:
i)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 loan terms and/or fees on any revised GFEs over the applicable tolerance(s); and
v)confirm the presence of a settlement service provider list, as applicable.
b)Final HUD-1/A Settlement Statement (HUD) (§1024.8) as applicable for loans with application dates prior to October 3, 2015:
i)confirm current applicable HUD form was provided;
ii)determination that the 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.
c)GFE and Final HUD Comparison (§1024.7) as applicable for loans with application dates prior to October 3, 2015:
i)review changes disclosed on the last GFE provided to the borrower(s) to determine that such changes were within the allowed tolerances;
ii)confirm 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 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.
d)Additional RESPA/Regulation X Disclosures and Requirements (§1024.6, 15, 17, 20, and 33):
i)confirm the presence of the Servicing Disclosure Statement form in the 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 loan file or that the 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;
v)confirm the presence of the Affiliated Business Arrangement Disclosure in the 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 loan file and proper timing.

 

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

 

(IV) The disclosure requirements and prohibitions of state, county and municipal laws and ordinances with respect to “high-cost” loans, “covered” loans, “higher-priced” loans, “home” loans or any other similarly designated 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;

 

(V) Federal and state specific late charge and prepayment penalty provisions;

 

(VI) Document Review

AMC reviewed each mortgage loan file and verified if the following documents, if applicable, for the Review scope in question at the time of review, were included in the file and if the data on these documents was consistent:

§Initial application (1003);
 

§

Final application (1003);

 

§

Note;
 

§

Appraisal;

 

§

Sales contract;

 

§

Title/Preliminary Title;

 

§

Initial TIL;

 

§

Final TIL;

 

§

Final HUD-1;

 

§

Initial and final GFE’s;

§

Right of Rescission Disclosure;

 

§

Mortgage/Deed of Trust;

 

§

Mortgage Insurance;
 

§

Tangible Net Benefit Disclosure;

 

§

FACTA disclosures; and

§

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

 

FOR APPLICATION DATES ON OR AFTER JANUARY 10, 2014

For mortgage loans with application dates on or after January 10, 2014 additional compliance testing was applicable and conducted by AMC. Testing during this period included all items as referenced in the FOR APPLICATION DATES BEFORE JANUARY 10, 2014 section above plus:

 

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

a)With respect to brokered loans, the Prohibitions and Restrictions related to Loan Originator Compensation and Steering (§1026.36):
i)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 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 loan file and, as necessary, attempted to obtain the loan originator compensation agreement and/or governing policies and procedures of the loan originator. In the absence of the 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 loan originator, if any. These statements, for example, were in the form of a letter signed by the seller correspondent/loan originator or representations in the mortgage loan purchase agreement between the Client and seller correspondent;
b)Homeownership counseling (§1026.36):
i)determine if the creditor obtained proof of homeownership counseling in connection with a loan to a first time homebuyer that contains a negative amortization feature;
c)Mandatory Arbitration Clauses (§1026.36):
i)determine if the terms of the loan require arbitration or any other non-judicial procedure to resolve any controversy or settle any claims arising out of the transaction;
d)Prohibition on Financing Credit Insurance (§1026.36):
i)determine if the creditor financed, directly or indirectly, any premiums or fees for credit insurance; and
e)Nationwide Mortgage Licensing System (NMLS) & Registry ID on Loan Documents (§1026.36):
i)review for presence of loan originator organization and individual loan originator name and NMLSR ID, as applicable, on the credit application, note or loan contract, security instrument, Loan Estimate and Closing Disclosure; and
ii)verify the data against the NMLSR database, as available.

 

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

a)Additional RESPA/Regulation X Disclosures and Requirements (§1024.6, 15, 17, 20, and 33):
i)confirm that the creditor provided the borrower a list of homeownership counseling organizations within three (3) business days of application; and
ii)confirm that the list of homeownership counseling organizations was obtained no earlier than 30 days prior to when the list was provided to the loan applicant.

 

(IX) 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:

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

b)Refinancing of non-standard mortgages (12 C.F.R. 1026.43(d));
c)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
d)Balloon-payment qualified mortgages made by certain creditors (12 C.F.R. 1026.43(f)).

 

AMC reviews applicable loans for compliance with the ATR and QM rule requirements based upon each loan’s originator designation (Safe Harbor QM, Higher-priced QM, Temporary SHQM, Temporary HPQM, Non-QM, Exempt from ATR). AMC determines the loan’s status under the ATR or QM rule requirements and assigns a due diligence loan designation. Generally, AMC notes as a material exception if the due diligence findings do not confirm the originator’s loan designation. Additionally, AMC notes if an originator loan designation was not provided.

 

Qualified Mortgage

With respect to QM (Safe Harbor and Higher-priced) designated loans, AMC 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, (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) 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.

 

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, AMC reviews the loan to determine whether, based on available information in the loan file the loan satisfied (i), (ii) and (iii) in the preceding paragraph and reviews the Automated Underwriting System output within the file to confirm agency eligibility.

 

For each QM designated loan that satisfied the applicable requirements enumerated above, AMC 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 applicable percentage.

 

The Review also includes determining, as applicable, whether a loan is a qualified mortgage 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.).

 

For each QM designated loan that does not satisfy the applicable requirements enumerated above, AMC then determines whether the 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 loan to determine whether, based on available information in the 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.

 

Note: for loans designated as QM – agency eligible, AMC will not review for compliance with the requirements of Appendix Q or General Ability to Repay.

 

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AMC reviews 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 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 loans constitute all of the factors and/or criteria that Authorities may consider in determining the status of a loan. AMC’s review is based on information contained in the loan file at the time it is provided to AMC to review, and only reflects information as of that point in time.

 

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

a)Providing Appraisals and Other Valuations (12 C.F.R. 1002.14):
i)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;
iv)with respect to a borrower that has waived the three (3) business day disclosure requirement, confirm that the borrower has signed the waiver or other acknowledgment at least three (3) business days prior to consummation; and (2) confirm that the lender has provided copies of appraisals and other written valuations at or prior to consummation.

 

(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 comparables and adjustments were reasonable and that pictures were provided and were accurate. 

 

FOR APPLICATION DATES ON OR AFTER OCTOBER 3, 2015

For mortgage loans with application dates on or after October 3, 2015 additional compliance testing was applicable and conducted by AMC. Testing during this period included all items as referenced in the FOR APPLICATION DATES BEFORE JANUARY 10, 2014 and FOR APPLICATION DATES ON OR AFTER JANUARY 10. 2014 sections above plus:

 

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 Industry Group (the "SFIG 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 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.

 

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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:

 

(XII) 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):

a)Loan Estimate (LE) (§§1026.19 and 37):
i)confirm the presence of LE for applications on or after October 3, 2015;
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 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;
v)confirm that any written estimate of terms or costs provided prior to receipt of a LE contained the required disclosures;
vi)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;
vii)confirm the presence and timely provision of a settlement service provider list (when consumer is given the opportunity to shop for services);
viii)confirm borrower received LE not later than four (4) business days prior to consummation; and
ix)confirm LE was not provided to the borrower on or after the date of the CD.
b)Closing Disclosure (CD) (§§1026.19 and 38):
i)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 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;
v)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 Industry Group (“SFIG”) 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 SFIG Compliance Review Scope.)
c)Your Home Loan Toolkit (§1026.19):
i)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.

 

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(XIII) 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):

§Loan Estimates;
§Closing Disclosures; and
§Certain other disclosures related to the enumerated tests set forth herein.

 

DEBT SERVICE COVERAGE RATIO (DSCR) REVIEW (172 Mortgage Loans)

 

DOCUMENT REVIEW

For each Loan, AMC will review the Loan File and verify whether the following documents, if applicable, are included in the file and if the data on these documents is consistent and logical: (a) initial application (1003), (b) credit report, (c) employment documentation, (d) asset documentation, (e) sales contract, (f) hazard and/or flood insurance policies, (g) appraisal, (h) title/preliminary title, (i) mortgage/deed of trust, (j) note, (k) certificate of business purpose / non-owner occupancy, (l) articles of incorporation, if applicable, (m) operating agreement, and (n) background check.

 

CREDIT REVIEW

The credit review focuses on the borrower’s experience in property management, credit profile and adherence to guidelines. The borrower’s assets are analyzed to determine there are sufficient funds for the required equity in the project. Conformity to applicable guidelines will all be assessed during the review. An income calculation will not be performed though the presence of income documentation if required by the guidelines will be noted.

 

Credit Application: For the Credit Application, AMC will verify whether (a) the application is signed by all listed borrowers, (b) the application is substantially filled out, (c) all known borrower-owned properties are disclosed on the Real Estate Owned section or attachments, and (d) borrower’s property management/landlord experience.

 

Credit Report: AMC will verify (a) a credit report is present for each borrower, (b) note and research the Real Estate Owned and fraud alerts, (c) and gather data including (i) representative FICO, (ii) scores from Equifax, Experian, and Transunion (if available), (iii) verify that the public records listed are disclosed on the application and adequately explained and in compliance with guidelines, and (iv) the number and length of trade lines.

 

Employment and Income: AMC will determine whether applicable supporting employment and income documentation required by the guidelines, was present in the mortgage loan file and where possible, wasn’t fraudulent.

 

Borrowing Entity: AMC will verify the borrowing entity, if not an individual, is properly documented. In addition, AMC will verify if the business entity is a US or foreign entity and if the individual signing the loan documentation has the appropriate authority. Distinction will be made between guarantors and principals, individuals and business entities.

 

Property income: AMC will determine whether all applicable supporting documentation as required by the guidelines is present in the file. No traditional borrower DTI ratios will be calculated but instead a “Property DTI” will be calculated per guidelines using the lease or expected lease amount and the property expenses. Documentation verifying property income may include: (a) leases and monthly rental income, (b) property vacancy, (c) balance sheets / financial statements, and (d) an appraisal analysis of market rents.

 

Valuation Review: AMC’s review will include 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 will include verifying the appraisal report was (i) materially complete, (ii) in conformity with the guideline requirements for the property type in question, (iii) completed by an appraiser that was actively licensed to perform the valuation, (iv) 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, (iv) 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 will (i) review the relative comparable data (gross and net adjustments, sale dates and distance from subject property) and ensure that such comparable properties are within standard appraisal guidelines; (ii) confirm the property value and square footage of the subject property was bracketed by comparable properties, (iii) verify that comparable properties used are similar in size, style, and location to the subject, and (iv) check for the reasonableness of adjustments when reconciling value between the subject property and comparable properties.

 

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Other aspects of AMC’s review include (i) verifying that the address matched the mortgage note, (ii) 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 (iii) confirming the appraiser noted an estimated lease amount to be used in instances where there is no lease in place.

 

Asset Review: AMC will assess whether the asset documentation required by the guidelines is present in the file. AMC will verify that assets presented support the required reserves. Documentation reviewed may include: (a) depository account statements, (b) stock or security account statements, (c) settlement statements or other evidence of conveyance and transfer of funds if a sale of assets was involved, and (d) operating accounts from other properties.

 

Insurance: AMC will (a) look for the presence of rent loss insurance as required by the guidelines, (b) verify that hazard insurance meets the minimum required amount of coverage in the guidelines, (c) confirm that the flood cert is for the correct borrower, property, lender and loan number, and (d) for properties in a flood zone per the flood cert, confirm that flood insurance meets guideline requirements in the file and meets the minimum required amount of coverage.

 

Title: AMC will verify whether the appropriate vestee is on the title document: if a purchase, the seller; if a refinance, the borrower. AMC will also review the Title Commitment for the disclosure 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; and environmental liens. Review for instances of delinquent taxes (non-liens). In addition, AMC will review for Oil, Gas, Water or Mineral rights.

 

Fraud / Criminal Background: To the extent potentially fraudulent activity is identified as part of the document review, such information will be reported to Client. In addition, AMC will look for an independent, third party fraud report and background check in each file and will review the results of the fraud report in conjunction with source documents found in the file to assess the likelihood of any misrepresentations associated with the origination of the loan.

 

DATA COLLECTION

AMC will compare data fields on the bid tape provided by the client to the data found in the actual file as captured by AMC. All material discrepancies will be noted.

 

(8) Other: review and methodology.

 

Data Integrity Review: AMC compared data fields on the securitization tape provided by the Client to the data found in the actual file as captured by AMC.

 

Payment History Review: AMC performed a review utilizing individual mortgage loan payment history reports provided by the servicer. Using the MBA methodology, AMC created a payment string using a look back period for each mortgage loan within the payment history population for 12 and 24 months.

 

Title Review

AMC’s review included a review of the chain of title and the duration of ownership by the seller or borrower (whichever is applicable) satisfied the guidelines. Included in this review was 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.

 

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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.

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, 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.

 

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.

 

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SUMMARY OF FINDINGS & CONCLUSIONS OF REVIEW

The NRSRO criteria referenced for this report and utilized for grading descriptions is based upon the NRSROs listed in the Form ABS Due Diligence-15E.

 

COMPLIANCE RESULTS SUMMARY

All 395 mortgage loans reviewed by AMC have a Compliance grade of “B” or higher and 78.23% of the mortgage loans have a Compliance grade of “A”. Please note that 172 loans are DSCR loans that were not subjected to a Compliance review and did not receive a Compliance grade.

 

Compliance Loan Grades
RA Grade # of Loans % of Loans
A 309 78.23%
B 86 21.77%
C 0 0.00%
D 0 0.00%
Total 395 100.00%

 

CREDIT RESULTS SUMMARY

All 566 mortgage loans reviewed by AMC have a Credit grade of “B” or higher and 86.40% of the loans have a Credit grade of “A”. Please note that 1 Loan received a Compliance Only review and was not subject to a Credit review and did not receive a Credit grade

 

Credit Loan Grades
RA Grade # of Loans % of Loans
A 489 86.40%
B 77 13.60%
C 0 0.00%
D 0 0.00%
Total 566 100.00%

 

PROPERTY/VALUATION RESULTS SUMMARY

All 566 mortgage loans reviewed by AMC have a Property grade of “B” or higher and 99.82% of the loans have a Property grade of “A”. Please note that 1 Loan received a Compliance Only review and was not subject to a Property review and did not receive a Property grade

 

Property Loan Grades
RA Grade # of Loans % of Loans
A 565 99.82%
B 1 0.18%
C 0 0.00%
D 0 0.00%
Total 566 100.00%

 

OVERALL REVIEW RESULTS SUMMARY

All 567 mortgage loans reviewed by AMC have an Overall grade of “B” or higher and 74.78% of the mortgage loans have an Overall grade of “A”.

 

Overall Loan Grades
RA Grade # of Loans % of Loans
A 424 74.78%
B 143 25.22%
C 0 0.00%
D 0 0.00%
Total 567 100.00%

 

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EXCEPTION CATEGORY SUMMARY

The table below summarizes the individual exceptions which carried an associated “B”, “C”, or “D” level exception grade. One loan may have carried more than one exception. In such cases, the exception with the lowest grade would drive the loan grade for that particular area of the review. The overall loan grade is the lowest grade for any one particular review scope (ex. a loan with a Compliance Grade of “B”, a Credit Grade of “A”, and a Property Grade of “A” would receive an overall Loan Grade of “B”).

 

Exception Type Final Exception Rating Exception Category Total
Compliance B TRID Defect 47
State HPML 27
ATR/QM 14
Missing, Incorrect, or Incomplete HUD-1 13
ECOA 9
Federal HPML 8
RESPA 5
ATR/QM Defect 4
State Late Charge 3
Misc. State Level 3
Federal Defect 2
Missing Non-Required Data 2
FACTA 2
TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 1
Missing Application Date 1
TILA 1
TRID 1
Total Compliance Grade (B) Exceptions: 143
Total Compliance Exceptions: 143
Credit B Guideline 75
Credit 11
Loan Package Documentation 5
Income / Employment 4
Borrower and Mortgage Eligibility 4
Insurance 3
Investment Product 2
Missing Document 2
Business Purpose 1
Title 1
Hazard Insurance 1
Total Credit Grade (B) Exceptions: 109
Total Credit Exceptions: 109
Property B Guideline 1
Total Property Grade (B) Exceptions: 1
Total Property Exceptions: 1
Grand Total: 253

 

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TAPE INTEGRITY REVIEW RESULTS SUMMARY

Of the 567 mortgage loans reviewed, 493 mortgage loans had 1,234 different tape discrepancies across 39 data fields (some mortgage loans had more than one data delta). The largest variances were found on Investor: Qualifying Total Debt Ratio, Property Type and Mortgage Type.

 

Field Label Loans With Discrepancy Total Times Compared % Variance # Of
Loans
# of Units 1 549 0.18% 567
Amortization Term 0 16 0.00% 567
Amortization Type 1 394 0.25% 567
Appraisal Date 1 1 100.00% 567
Appraised Value 2 13 15.38% 567
Borrower First Name 47 447 10.51% 567
Borrower Last Name 60 451 13.30% 567
Borrower SSN 12 319 3.76% 567
City 17 565 3.01% 567
Coborrower First Name 9 75 12.00% 567
Coborrower Last Name 9 76 11.84% 567
Coborrower SSN 5 69 7.25% 567
Contract Sales Price 55 410 13.41% 567
Current Maturity Date 13 15 86.67% 567
Doc Type 53 69 76.81% 567
First Payment Date 1 62 1.61% 567
Has FTHB 76 393 19.34% 567
Index Type 0 1 0.00% 567
Interest Only Period 0 1 0.00% 567
Interest Rate Change Frequency 0 1 0.00% 567
Interest Rate Initial Cap 0 1 0.00% 567
Interest Rate Initial Floor 1 1 100.00% 567
Interest Rate Life Max 0 1 0.00% 567
Interest Rate Life Min 0 1 0.00% 567
Interest Rate Periodic Cap 0 1 0.00% 567
Interest Rate Periodic Floor 0 1 0.00% 567
Investor: Qualifying Total Debt Ratio 182 409 44.50% 567
Lien Position 0 437 0.00% 567
LTV Valuation Value 52 551 9.44% 567
Margin 73 93 78.49% 567
Maturity Date 0 41 0.00% 567
MERS Min Number 3 5 60.00% 567
Mortgage Type 103 308 33.44% 567
Note Date 3 56 5.36% 567
Occupancy 38 537 7.08% 567
Original CLTV 19 429 4.43% 567
Original Interest Rate 41 563 7.28% 567
Original Interest Rate Period 0 1 0.00% 567
Original Loan Amount 23 547 4.20% 567
Original LTV 17 551 3.09% 567
Original P&I 1 47 2.13% 567
Original Term 6 551 1.09% 567
Originator Loan Designation 3 29 10.34% 567
PMI Coverage % 50 170 29.41% 567
Property Type 128 551 23.23% 567
Purpose 1 560 0.18% 567
Refi Purpose 15 188 7.98% 567
Representative FICO 45 562 8.01% 567
State 0 561 0.00% 567
Street 34 473 7.19% 567
Subject Debt Service Coverage Ratio 24 40 60.00% 567
Zip 10 473 2.11% 567
Total 1,234 12,666 9.74% 567

 

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PAYMENT HISTORY REVIEW SUMMARY

A Payment History Review was completed on 3 mortgage loans of which 3 had complete pay history strings (100.00%). Of these mortgage loans, all 3 mortgage loans (100.00%) had no delinquencies during the lookback period and no missing pay history data.

 

Category # of Mortgage Loans % of Mortgage Loans
No Delinquency, No Missing Data 3 100.00 %
Delinquency, No Missing Data 0 0.00 %
No Delinquency, At Least One Month Missing 0 0.00 %
Delinquency, At Least One Month Missing 0 0.00 %
Total 3 100.00 %
     
Lookback # of Mortgage Loans % of Mortgage Loans
12 Months 1 33.33 %
24 Months 2 66.67 %
Total 3 100.00 %

 

TITLE REVIEW SUMMARY (2 Mortgage Loans)

As part of the due diligence services, the Client provided SitusAMC with identifying data on 2 mortgage loans. Based on the scope of review set forth herein, the critical findings are summarized as follows:

 

·No unresolved Super Position HOA Liens recorded after the subject mortgage which were entitled to limited or full lien priority over the subject mortgage were identified.
·No unresolved Municipal Liens which had limited or full lien priority over the subject mortgage were located.
·No unresolved Property Tax Liens which had limited or full lien priority over the subject mortgage were located.
·All Prior Liens identified in our review have been resolved.
·All Prior Mortgages identified in our review have been resolved.
·As to any Miscellaneous Items of substance, the items in this category typically defy standard categorization or summarization and are individually detailed.

 

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ADDITIONAL LOAN POPULATION SUMMARY (some totals may not add due to rounding)

Amortization Type Loan Count % of Loans Original Balance % of Balance
Fixed 547 96.47% $315,289,831.00 94.80%
Adjustable 20 3.53% $17,302,000.00 5.20%
Total 567 100.00% $332,591,831.00 100.00%
         
Lien Position Loan Count % of Loans Original Balance % of Balance
1 567 100.00% $332,591,831.00 100.00%
Total 567 100.00% $332,591,831.00 100.00%
         
Loan Purpose Loan Count % of Loans Original Balance % of Balance
Cash Out: Debt Consolidation 1 0.18% $680,000.00 0.20%
Cash Out: Home Improvement/Renovation 2 0.35% $1,540,000.00 0.46%
Cash Out: Other/Multi-purpose/Unknown Purpose 161 28.40% $77,041,946.00 23.16%
Limited Cash-Out 1 0.18% $161,081.00 0.05%
First Time Home Purchase 98 17.28% $63,753,370.00 19.17%
Other-than-first-time Home Purchase 265 46.74% $164,833,100.00 49.56%
Rate/Term Refinance - Lender Initiated 2 0.35% $520,736.00 0.16%
Rate/Term Refinance - Borrower Initiated 37 6.53% $24,061,598.00 7.23%
Total 567 100.00% $332,591,831.00 100.00%
         
Original Term Loan Count % of Loans Original Balance % of Balance
241-360 Months 526 92.77% $297,177,896.00 89.35%
361+ Months 41 7.23% $35,413,935.00 10.65%
Total 567 100.00% $332,591,831.00 100.00%
         
Property Type Loan Count % of Loans Original Balance % of Balance
Single Family Detached 308 54.32% $188,433,497.00 56.66%
Co-op 1 0.18% $206,500.00 0.06%
Condo, Low Rise 50 8.82% $25,257,317.00 7.59%
Condo, High Rise 12 2.12% $6,485,550.00 1.95%
PUD 135 23.81% $82,136,147.00 24.70%
1 Family Attached 7 1.23% $1,476,600.00 0.44%
2 Family 39 6.88% $17,261,020.00 5.19%
3 Family 10 1.76% $7,459,950.00 2.24%
4 Family 5 0.88% $3,875,250.00 1.17%
Total 567 100.00% $332,591,831.00 100.00%
         
Occupancy Loan Count % of Loans Original Balance % of Balance
Primary 301 53.09% $213,901,496.00 64.31%
Investment 248 43.74% $110,287,398.00 33.16%
Second Home 18 3.17% $8,402,937.00 2.53%
Total 567 100.00% $332,591,831.00 100.00%
         
Review Type Loan Count % of Loans Original Balance % of Balance
Full Credit/Compliance 394 69.49% $264,321,418.00 79.47%
Compliance-Only 1 0.18% $680,000.00 0.20%
Leases 172 30.34% $67,590,413.00 20.32%
Total 567 100.00% $332,591,831.00 100.00%

 

17 | P a g e

 


Exhibit 99.02

 

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 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
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