Client Name: | ||||
Client Project Name: | BRAVO 2024-RPL1 | |||
Start - End Dates: | 2/21/2018 - 1/31/2020 | |||
Deal Loan Count: | 6 | |||
Conditions Report 2.0 | ||||
Loans in Report: | 6 | |||
Loans with Conditions: | 5 |
Loan Number | Original Principal Balance | State | Initial Lender ATR/QM Status | Loan Level ATR/QM Status | Initial Securitization Overall Loan Grade | Final Securitization Overall Loan Grade | Initial Securitization Credit Loan Grade | Final Securitization Credit Loan Grade | Initial Securitization Property Valuations Loan Grade | Final Securitization Property Valuations Loan Grade | Initial Securitization Compliance Loan Grade | Final Securitization Compliance Loan Grade | Initial S&P Overall Loan Grade | Final S&P Overall Loan Grade | Initial S&P Credit Loan Grade | Final S&P Credit Loan Grade | Initial S&P Property Valuations Loan Grade | Final S&P Property Valuations Loan Grade | Initial S&P Compliance Loan Grade | Final S&P Compliance Loan Grade | Condition Category | Condition Sub Category | Condition Status | Initial Securitization Condition Grade | Final Securitization Condition Grade | Initial S&P Condition Grade | Final S&P Condition Grade | Condition Code | Condition Description | Condition Material Indicator | Initial Comments | Client/Seller Response Comments | Conclusion Comments | TRID Error Type | Cure Method | Compensating Factors |
RPL1995 | XXXXXX | XXXXXX | ATR/QM: Exempt | ATR/QM: Exempt | D | B | A | A | A | A | D | B | D | B | A | A | A | A | D | B | Compliance | Federal Consumer Protection | Active | N/A | B | N/A | B | CMPFDCP3254 | TILA - Cannot determine if ARM Program Disclosure was provided in a timely manner | No | The Early Arm Statement was provided however, it is not dated so there is no way to determine if it was delivered to borrower within three days of the application date of XXX. | (No Data) | (No Data) | (No Data) | Not Applicable | CFCFS2860: Good credit history - Clayton Comments: Good credit history for both borrowers, with not late payments reporting CFCFS1741: Credit score exceeds guidelines - Clayton Comments: Mid fico: 708, minimum credit score allowed 620 |
RPL1995 | XXXXXX | XXXXXX | ATR/QM: Exempt | ATR/QM: Exempt | D | B | A | A | A | A | D | B | D | B | A | A | A | A | D | B | Compliance | Federal Consumer Protection | Satisfied | B | A | B | A | CMPFDCP849 | TILA - Required ARM Loan Program Disclosure missing | No | Required Early ARM Loan Program Disclosure missing in file | 7/3/2019: Lender provided the Early Arm Disclosure Statement. | 7/3/2019: Exception satisfied however, exception CMPFDCP3254 generated since the disclosure is not dated. | (No Data) | Not Applicable | CFCFS2860: Good credit history - Clayton Comments: Good credit history for both borrowers, with not late payments reporting CFCFS1741: Credit score exceeds guidelines - Clayton Comments: Mid fico: 708, minimum credit score allowed 620 |
RPL1995 | XXXXXX | XXXXXX | ATR/QM: Exempt | ATR/QM: Exempt | D | B | A | A | A | A | D | B | D | B | A | A | A | A | D | B | Compliance | TILA/RESPA Integrated Disclosure | Satisfied | B | B | B | B | CMPTRID4352 | TRID - CD: At least one section contains formatting that does not comply with the Regulation | No | Final CD XXX and Post CD XXX, section E., field Transfer Taxes - missing payee's name | 7/30/2019: Lender provided PCCD dated XXX with the Transfer Tax payee name included and a letter of explanation to borrower. | 7/30/2019: Exception satisfied. | Hybrid | Not Applicable | CFCFS2860: Good credit history - Clayton Comments: Good credit history for both borrowers, with not late payments reporting CFCFS1741: Credit score exceeds guidelines - Clayton Comments: Mid fico: 708, minimum credit score allowed 620 |
RPL1995 | XXXXXX | XXXXXX | ATR/QM: Exempt | ATR/QM: Exempt | D | B | A | A | A | A | D | B | D | B | A | A | A | A | D | B | Compliance | TILA/RESPA Integrated Disclosure | Satisfied | B | B | B | B | CMPTRID4463 | TRID - Assumption selection on the CD does not match the clause in the mortgage. | No | Per ARM Rider, loan is assumable under certain condition. Final CD indicates loan is not assumable. Values are not matching. Condition pending receiving corrected Post CD with LOE and proof of delivery to borrower | 7/30/2019: Lender provided a letter of explanation and a PCCD dated XXX with the assumption changed to assumable. | 7/30/2019: Exception satisfied. | Non-Numeric | Not Applicable | CFCFS2860: Good credit history - Clayton Comments: Good credit history for both borrowers, with not late payments reporting CFCFS1741: Credit score exceeds guidelines - Clayton Comments: Mid fico: 708, minimum credit score allowed 620 |
RPL1995 | XXXXXX | XXXXXX | ATR/QM: Exempt | ATR/QM: Exempt | D | B | A | A | A | A | D | B | D | B | A | A | A | A | D | B | Compliance | TILA/RESPA Integrated Disclosure | Satisfied | C | B | C | B | CMPTRID5051 | TRID - CD: Inconsistency between the amounts disclosed for the Homeowners' Insurance premium in one or more sections of the CD | No | Final CD XXX and Post CD XXX, section F. field HOI - incorrect value. Per HOI invoice in file, total amount due for HOI is $XXX | 7/12/2019: Lender provided a refund letter to the borrower from the HOI company stating a credit was applied to the account and that a refund check for the remaining credit on the account was enclosed. However, a re-disclosed CD from lender with the correct HOI amount, LOX and client's permission for 130(b) or (c) cure is still required to satisfy. Exception remains. 7/25/2019: Lender provided PCCD dated XXX with the correct HOI amount and a letter of explanation to borrower. | 7/25/2019: Exception satisfied. | Numeric | Not Applicable | CFCFS2860: Good credit history - Clayton Comments: Good credit history for both borrowers, with not late payments reporting CFCFS1741: Credit score exceeds guidelines - Clayton Comments: Mid fico: 708, minimum credit score allowed 620 |
RPL1995 | XXXXXX | XXXXXX | ATR/QM: Exempt | ATR/QM: Exempt | D | B | A | A | A | A | D | B | D | B | A | A | A | A | D | B | Compliance | TILA/RESPA Integrated Disclosure | Satisfied | D | A | D | A | CMPTRID3600 | TRID - CD delivered only via e-mail but there is no prior e-sign consent in file; by regulation, CD must be treated as not delivered | No | Initial CD XXX is e-signed by both borrowers however prior e-consent found in file is only for borrower 1. Missing e-consent for borrower 2. | 7/12/2019: Lender provided the borrower's e-consent. | 7/12/2019: Exception satisfied. | (No Data) | Not Applicable | CFCFS2860: Good credit history - Clayton Comments: Good credit history for both borrowers, with not late payments reporting CFCFS1741: Credit score exceeds guidelines - Clayton Comments: Mid fico: 708, minimum credit score allowed 620 |
RPL1995 | XXXXXX | XXXXXX | ATR/QM: Exempt | ATR/QM: Exempt | D | B | A | A | A | A | D | B | D | B | A | A | A | A | D | B | Compliance | TILA/RESPA Integrated Disclosure | Satisfied | D | A | D | A | CMPTRID5111 | TRID - LE delivered only via e-mail but there is no prior e-sign consent in file; by regulation, LE must be treated as not delivered | No | LE XXX is e-signed by second borrower however no prior e-consent found in file. Only first borrower e-consent is found in file dated XXX | 7/12/2019: Lender provided the borrower's e-consent. | 7/12/2019: Exception satisfied. | (No Data) | Not Applicable | CFCFS2860: Good credit history - Clayton Comments: Good credit history for both borrowers, with not late payments reporting CFCFS1741: Credit score exceeds guidelines - Clayton Comments: Mid fico: 708, minimum credit score allowed 620 |
RPL2008 | XXXXXX | XXXXXX | Non-QM: Lender documented all ATR UW factors | Non-QM: Lender documented all ATR UW factors | A | A | A | A | A | A | A | A | A | A | A | A | A | A | A | A | CFCFS1744: DTI below guideline requirement - Clayton Comments: DTI of 18.67 is below lender's guide lines max of 50%. CFCFS2854: Significant time in profession - Clayton Comments: Borrower has been in the same line of work for 14 years. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments: Verified cash reserves of 6.58 months PITI exceed guide lines. | |||||||||||||||
RPL1515 | XXXXXX | XXXXXX | (No Data) | ATR/QM: Not Applicable | C | B | N/A | N/A | N/A | N/A | C | B | C | B | N/A | N/A | N/A | N/A | C | B | Compliance | Federal Consumer Protection | Active | B | B | B | B | CMPFDCP314 | TILA - Final TIL not dated, unable to confirm timely delivery | No | Final TIL is not hand dated by the borrower, unable to confirm timely delivery. | (No Data) | (No Data) | (No Data) | (No Data) | (No Data) |
RPL1515 | XXXXXX | XXXXXX | (No Data) | ATR/QM: Not Applicable | C | B | N/A | N/A | N/A | N/A | C | B | C | B | N/A | N/A | N/A | N/A | C | B | Compliance | State Prepayment Penalty | Active | C | B | C | B | CMPSTPP106 | PPP - Prepayment penalty exceeds maximum allowed (%) | No | Maximum prepayment penalty is 1% of amount repaid. Prepayment penalty per note is 6 months interest of OPB. Prepayment penalty expired XXX in 60 months. | (No Data) | Prepayment penalty has expired | (No Data) | Not Applicable | (No Data) |
RPL1515 | XXXXXX | XXXXXX | (No Data) | ATR/QM: Not Applicable | C | B | N/A | N/A | N/A | N/A | C | B | C | B | N/A | N/A | N/A | N/A | C | B | Compliance | State Prepayment Penalty | Active | C | B | C | B | CMPSTPP108 | PPP - Prepayment penalty type exceeds maximum allowed | No | Prepayment penalty type exceeds maximum allowed. Prepayment penalty expired XXX in 60 months. | (No Data) | Prepayment penalty has expired | (No Data) | Not Applicable | (No Data) |
RPL1515 | XXXXXX | XXXXXX | (No Data) | ATR/QM: Not Applicable | C | B | N/A | N/A | N/A | N/A | C | B | C | B | N/A | N/A | N/A | N/A | C | B | Compliance | State Prepayment Penalty | Active | C | B | C | B | CMPSTPP1535 | PPP - Prepayment penalty term exceeds state maximum | No | Maximum prepayment penalty is 1% of amount prepaid. Prepayment penalty per note is 6 months interest of OPB. Prepayment penalty expired XXX in 60 months. | (No Data) | Prepayment penalty has expired | (No Data) | Not Applicable | (No Data) |
RPL1542 | XXXXXX | XXXXXX | (No Data) | ATR/QM: Not Applicable | D | B | N/A | N/A | N/A | N/A | D | B | D | B | N/A | N/A | N/A | N/A | D | B | Compliance | Documentation | Active | D | B | D | B | CMPDOC155 | Application Missing | No | Missing Application. | (No Data) | Applicable Statute of Limitations has expired - Final grade EV2 | (No Data) | Not Applicable | (No Data) |
RPL1542 | XXXXXX | XXXXXX | (No Data) | ATR/QM: Not Applicable | D | B | N/A | N/A | N/A | N/A | D | B | D | B | N/A | N/A | N/A | N/A | D | B | Compliance | Federal Consumer Protection | Active | B | B | B | B | CMPFDCP300 | HMDA Rate Spread greater than threshold | No | Test APR of 11.759% with HMDA Benchmark Rate of 4.540% causing variance of 7.219% which exceeds HMDA Rate spread Trigger of 3.000. | (No Data) | (No Data) | (No Data) | (No Data) | (No Data) |
RPL1542 | XXXXXX | XXXXXX | (No Data) | ATR/QM: Not Applicable | D | B | N/A | N/A | N/A | N/A | D | B | D | B | N/A | N/A | N/A | N/A | D | B | Compliance | Right of Rescission | Active | B | B | B | B | CMPROR118 | ROR - Disbursement date is on/before disclosed "midnight of" date | No | Disbursement date of XXX is before disclosed midnight of date of XXX. | (No Data) | (No Data) | (No Data) | (No Data) | (No Data) |
RPL1542 | XXXXXX | XXXXXX | (No Data) | ATR/QM: Not Applicable | D | B | N/A | N/A | N/A | N/A | D | B | D | B | N/A | N/A | N/A | N/A | D | B | Compliance | Right of Rescission | Active | C | B | C | B | CMPROR2330 | ROR - Disbursement date is before end of statutory rescission period | No | Disbursement date of XXX is prior to end of rescission period date of XXX based on transaction date of XXX. | (No Data) | Applicable Statute of Limitations has expired - EV2 | (No Data) | Not Applicable | (No Data) |
RPL1326 | XXXXXX | XXXXXX | QM: GSE Temporary - QM/RP | QM: GSE Temporary - QM/RP | D | B | A | A | D | A | B | B | D | B | A | A | D | A | B | B | Compliance | TILA/RESPA Integrated Disclosure | Satisfied | B | B | B | B | CMPTRID4352 | TRID - CD: At least one section contains formatting that does not comply with the Regulation | No | Final CD XXX Transaction Information section is missing seller address. | 5.30.19 - Lender provided LOX and corrected with CD with sellers address. | 5.30.19 - Exception satisfied | Hybrid | Not Applicable | CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments: 70 months PITI reserves verified, max per guidelines is 6 months |
RPL1326 | XXXXXX | XXXXXX | QM: GSE Temporary - QM/RP | QM: GSE Temporary - QM/RP | D | B | A | A | D | A | B | B | D | B | A | A | D | A | B | B | Property Valuations | Appraisal | Satisfied | D | A | D | A | PRVAAPPR3116 | Missing updated valuation | No | Missing updated property valuation supporting the appraised value of $XXX. | 5/23/2019 Desk Review provided supports value with a 0% variance. | 5/23/2019 Exception satisfied. | (No Data) | Not Applicable | CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments: 70 months PITI reserves verified, max per guidelines is 6 months |
RPL1994 | XXXXXX | XXXXXX | ATR/QM: Exempt | ATR/QM: Exempt | C | B | C | A | A | A | B | B | C | B | C | A | A | A | B | B | Compliance | Right of Rescission | Active | B | B | B | B | CMPROR1909 | Incorrect ROR Form Used - H8 Form Used in Refinance With Original Creditor | No | Regulation Z designates the H9 rescission form as the form designed for same lender refinance transactions; for this loan the lender is using the H8 form. Regulation Z has language allowing the use of a substantially similar notice. Claytons view has been that an H8 protects the lender and assignee to at least the same extent as an H9, but Clayton recognized that one could think that the mere existence of the H9 takes away the substantially similar notice argument. The majority of U.S. Circuit Courts that have opined on the issue have upheld the use of an H8 in a same-lender refinance; therefore, Clayton grades the use of an H8 form in a same-lender refinance as a level 2/B- Non Material exception in those Circuits that have not decided on this issue. | (No Data) | (No Data) | (No Data) | Not Applicable | CFCFS1736: Significant time at current residence - Clayton Comments: Borrower has owned his home 7 years and 10 months. CFCFS1741: Credit score exceeds guidelines - Clayton Comments: Credit score of 739 exceeds the minimum of 620, 109 points. |
RPL1994 | XXXXXX | XXXXXX | ATR/QM: Exempt | ATR/QM: Exempt | C | B | C | A | A | A | B | B | C | B | C | A | A | A | B | B | Compliance | TILA/RESPA Integrated Disclosure | Satisfied | B | B | B | B | CMPTRID3716 | TRID - Curable issue related to the Closing Disclosure in file | No | Lender name is missing the LLC in the Transaction Information section of CD XXX. Corrected on PCCD XXX. | (No Data) | Exception satisfied since corrected on PCCD. | (No Data) | Not Applicable | CFCFS1736: Significant time at current residence - Clayton Comments: Borrower has owned his home 7 years and 10 months. CFCFS1741: Credit score exceeds guidelines - Clayton Comments: Credit score of 739 exceeds the minimum of 620, 109 points. |
RPL1994 | XXXXXX | XXXXXX | ATR/QM: Exempt | ATR/QM: Exempt | C | B | C | A | A | A | B | B | C | B | C | A | A | A | B | B | Compliance | TILA/RESPA Integrated Disclosure | Satisfied | B | B | B | B | CMPTRID4214 | TRID - Loan Estimate: An LE is missing at least one required data point | No | The Lender contact information is in the Broker section of NMLS on LE. Corrected on CD. | (No Data) | 5/07/2019: Exception satisfied since corrected on CD. | Hybrid | Not Applicable | CFCFS1736: Significant time at current residence - Clayton Comments: Borrower has owned his home 7 years and 10 months. CFCFS1741: Credit score exceeds guidelines - Clayton Comments: Credit score of 739 exceeds the minimum of 620, 109 points. |
RPL1994 | XXXXXX | XXXXXX | ATR/QM: Exempt | ATR/QM: Exempt | C | B | C | A | A | A | B | B | C | B | C | A | A | A | B | B | Compliance | TILA/RESPA Integrated Disclosure | Satisfied | B | B | B | B | CMPTRID4285 | TRID - CD: The value for Loan Amount in the LE column of the CD's Calculating Cash to Close table (Alt Version) is different from the value disclosed on the last LE | No | The Loan Amount of $XXX disclosed in the LE column of the Calculating Cash To Close table on CD XXX and PCCD XXX do not match the Loan Amount of $XXX on the LE. | 6/20/2019: Lender provided the PCCD dated XXX however the calculating cash to close values in the LE column still do not match the LE values. Exception remains. 6/21/2019: Lender provided LE dated XXX which has the matching values of the CD's Calculating Cash to Close table LE column. | 6/21/2019: Exception satisfied. | Non-Numeric | Not Applicable | CFCFS1736: Significant time at current residence - Clayton Comments: Borrower has owned his home XXX years and XXX months. CFCFS1741: Credit score exceeds guidelines - Clayton Comments: Credit score of 739 exceeds the minimum of 620, 109 points. |
RPL1994 | XXXXXX | XXXXXX | ATR/QM: Exempt | ATR/QM: Exempt | C | B | C | A | A | A | B | B | C | B | C | A | A | A | B | B | Compliance | TILA/RESPA Integrated Disclosure | Satisfied | B | B | B | B | CMPTRID4299 | TRID - CD: The value for Total Closing Costs in the LE column of the CD's Calculating Cash to Close table is different from the value disclosed on the last LE | No | The Total Closing Costs (J) value of -$XXX disclosed in the LE column of the Calculating Cash To Close table on CD XXX and PCCD XXX do not match the Total Closing Costs (J) value of -$XXX on the LE. | 6/20/2019: Lender provided the PCCD dated XXX however the calculating cash to close values in the LE column still do not match the LE values. Exception remains.6/21/2019: Lender provided LE dated XXX which has the matching values of the CD's Calculating Cash to Close table LE column. | 6/21/2019: Exception satisfied. | Non-Numeric | Not Applicable | CFCFS1736: Significant time at current residence - Clayton Comments: Borrower has owned his home XXX years and XXX months. CFCFS1741: Credit score exceeds guidelines - Clayton Comments: Credit score of 739 exceeds the minimum of 620, 109 points. |
RPL1994 | XXXXXX | XXXXXX | ATR/QM: Exempt | ATR/QM: Exempt | C | B | C | A | A | A | B | B | C | B | C | A | A | A | B | B | Compliance | TILA/RESPA Integrated Disclosure | Satisfied | B | B | B | B | CMPTRID4309 | TRID - CD: The value for Cash to Close in the LE column of the CD's Calculating Cash to Close table is different from the value disclosed on the last LE | No | The Cash to Close value of $XXX disclosed in the LE column of the Calculating Cash To Close table on CD XXX and PCCD XXX do not match the Estimated Cash to Close value of $XXX on the LE. | 6/20/2019: Lender provided the PCCD dated XXX however the calculating cash to close values in the LE column still do not match the LE values. Exception remains.6/21/2019: Lender provided LE dated XXX which has the matching values of the CD's Calculating Cash to Close table LE column. | 6/21/2019: Exception satisfied. | Non-Numeric | Not Applicable | CFCFS1736: Significant time at current residence - Clayton Comments: Borrower has owned his home XXX years and XXX months. CFCFS1741: Credit score exceeds guidelines - Clayton Comments: Credit score of 739 exceeds the minimum of 620, 109 points. |
RPL1994 | XXXXXX | XXXXXX | ATR/QM: Exempt | ATR/QM: Exempt | C | B | C | A | A | A | B | B | C | B | C | A | A | A | B | B | Compliance | TILA/RESPA Integrated Disclosure | Satisfied | B | B | B | B | CMPTRID4312 | TRID - CD: The value for Total Payoffs and Payments in the LE column of the CD's Calculating Cash to Close table is different from the value disclosed on the last LE | No | The Total Payoffs and Payments value of -$XXX disclosed in the LE column of the Calculating Cash To Close table on CD XXX and PCCD XXX do not match the Estimated Total Payoffs and Payments value of -$XXX on the LE. | 6/20/2019: Lender provided the PCCD dated XXX however the calculating cash to close values in the LE column still do not match the LE values. Exception remains.6/21/2019: Lender provided LE dated XXX which has the matching values of the CD's Calculating Cash to Close table LE column. | 6/21/2019: Exception satisfied. | Non-Numeric | Not Applicable | CFCFS1736: Significant time at current residence - Clayton Comments: Borrower has owned his home XXX years and XXX months. CFCFS1741: Credit score exceeds guidelines - Clayton Comments: Credit score of 739 exceeds the minimum of 620, 109 points. |
RPL1994 | XXXXXX | XXXXXX | ATR/QM: Exempt | ATR/QM: Exempt | C | B | C | A | A | A | B | B | C | B | C | A | A | A | B | B | Compliance | TILA/RESPA Integrated Disclosure | Satisfied | B | B | B | B | CMPTRID4463 | TRID - Assumption selection on the CD does not match the clause in the mortgage. | No | Assumption selection on the CD does not match the clause in the mortgage. Per ARM Rider loan is assumable upon approval after initial fixed period. | 6/20/2019: Lender provided the PCCD dated XXX correcting the Assumption statement and a letter of explanation to the borrower. | 6/20/2019: Exception satisfied. | Non-Numeric | Not Applicable | CFCFS1736: Significant time at current residence - Clayton Comments: Borrower has owned his home XXX years and XXX months. CFCFS1741: Credit score exceeds guidelines - Clayton Comments: Credit score of 739 exceeds the minimum of 620, 109 points. |
RPL1994 | XXXXXX | XXXXXX | ATR/QM: Exempt | ATR/QM: Exempt | C | B | C | A | A | A | B | B | C | B | C | A | A | A | B | B | Credit | Credit/Mtg History | Satisfied | C | A | C | A | CRDCRMH1805 | Debts/obligations not disclosed/accounted for at origination | No | LOX regarding XXX. Advise what property this is tied to as well as applicable documentation for taxes and insurance. | 5/15/2019 - Lender provided an updated final 1003 to show that the HELOC belongs to a REO XXX and to include another REO. In addition, included property profiles on both properties. | 5/15/2019 - Exception satisfied. | (No Data) | Not Applicable | CFCFS1736: Significant time at current residence - Clayton Comments: Borrower has owned his home XXX years and XXX months. CFCFS1741: Credit score exceeds guidelines - Clayton Comments: Credit score of 739 exceeds the minimum of 620, 109 points. |