Exhibit 99.9
| Loan ID | Customer Loan ID | Seller Loan ID | Investor Loan Number | Loan Exception ID | Exception ID | Exception Date | Exception Type | Exception Category | Exception Subcategory | 15E Category | Exception | Exception Detail | Exception Information | Compensating Factors | Compensating Factor Information | Applying Party | Follow-up Comments | Cleared Date | Cured Date | Waived Date | Exception Level Grade | Exception Level Rating | Note Date | Property State | Occupancy | Purpose | Exception Remediation | Overall Initial Loan Grade |
Overall Final Loan Grade |
Credit Initial Loan Grade |
Credit Final Loan Grade |
Compliance Initial Loan Grade |
Compliance Final Loan Grade |
Property Initial Loan Grade |
Property Final Loan Grade |
Originator QM ATR Status | TPR QM ATR Status | Is Curable |
| 438820775 | Credit | Loan Package Documentation | Closing / Title | Missing Document | Missing Document: Rider - Other not provided | Verified Rider Other is missing | Reviewer Comment (2021-11-01): Clearing. Seller Comment (2021-11-01): Please see attached for the fully executed mortgage. Reviewer Comment (2021-11-01): We are looking for the Security Marked Other Rider with a note of Default Rate and Pre-Payment Penalty Addendum to Note and Mortgage. Buyer Comment (2021-11-01): Can you elaborate further on what rider is missing? |
11/01/2021 | 1 | A | VA | Investment | Purchase | D | B | C | A | B | B | D | A | N/A | N/A | No | ||||||||||||||
| 438820775 | Property | Property - Appraisal | Appraisal Documentation | Property - Appraisal | Loan is to be securitized. AVM supports value. Vendor/FSD do not meet Fitch criteria.; Sec ID: 10 | Verified AVM and appraisal in file for securitization | Reviewer Comment (2021-11-03): Clearing after re-review. Seller Comment (2021-11-02): AVM |
11/03/2021 | 1 | A | VA | Investment | Purchase | D | B | C | A | B | B | D | A | N/A | N/A | No | ||||||||||||||
| 438820775 | Credit | Asset | Asset Documentation | Asset | Guideline Issue:Insufficient asset documentation. | - | The file was missing required asset verification. Per guidelines, assets to be used for down payment, closing costs, debt payoff, and reserves must be seasoned for 60 days or sourced. | Reviewer Comment (2021-11-03): Clearing after re-review. Seller Comment (2021-11-02): verified: $[Redacted]= (balance: $[Redacted]and backed out $[Redacted]): total required: settlement statement: cash from bor: $[Redacted]+ [Redacted] month PITIA: $[Redacted]=total required $[Redacted]; sufficient assets |
11/03/2021 | 1 | A | VA | Investment | Purchase | D | B | C | A | B | B | D | A | N/A | N/A | No | |||||||||||||
| 438820775 | Credit | Title | Document Error | Title | There is no dollar amount noted on the title policy. | Verified missing page 1 of schedule A ( where the amount would be found). I searched for the missing page in "other" docs and didn't find it. Leave that field blank. | Reviewer Comment (2021-11-18): Received, clearing exception. Seller Comment (2021-11-18): see the uploaded Sch A with page 1 |
11/18/2021 | 1 | A | VA | Investment | Purchase | D | B | C | A | B | B | D | A | N/A | N/A | No | ||||||||||||||
| 438820775 | Compliance | Compliance | Federal Compliance | FACTA | Federal FACTA Disclosure Timing Test | FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score. | Verified FACTA disclosure dated [Redacted] | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | VA | Investment | Purchase | D | B | C | A | B | B | D | A | N/A | N/A | No | ||||||||||||||
| 438820775 | Compliance | Compliance | Federal Compliance | GSE | FNMA Points and Fees | FNMA Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of the greater of [Redacted]% of the Original Loan Amount and $[Redacted](2021). FNMA Finance Charge total $[Redacted]on a Original Loan Amount of $[Redacted]vs. an allowable total of $[Redacted]and $[Redacted]([Redacted]) (an overage of $[Redacted]or .[Redacted]%). | Verified tolerance fee is in excess | Reviewer Comment (2021-11-03): Clearing after re-review. |
11/03/2021 | 1 | A | VA | Investment | Purchase | D | B | C | A | B | B | D | A | N/A | N/A | Yes | |||||||||||||
| 438820775 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Verified PITIA months reserves according to guidelines | Reviewer Comment (2021-11-03): Clearing after re-review. Seller Comment (2021-11-02): verified: $[Redacted]= (balance: $[Redacted]and backed out $[Redacted]): total required: settlement statement: cash from bor: $[Redacted]+ [Redacted]month PITIA: $[Redacted]=total required $[Redacted]; sufficient assets |
11/03/2021 | 1 | A | VA | Investment | Purchase | D | B | C | A | B | B | D | A | N/A | N/A | No | ||||||||||||||
| 438820775 | Credit | Asset | Asset Calculation / Analysis | Asset | Guideline Requirement: Available for Reserves discrepancy. | Reviewer Comment (2021-11-03): Clearing after re-review. Seller Comment (2021-11-02): verified: $[Redacted]= (balance: $[Redacted]and backed out $[Redacted]): total required: settlement statement: cash from bor: $[Redacted]+ [Redacted]month PITIA: $[Redacted]=total required $[Redacted]; sufficient assets |
11/03/2021 | 1 | A | VA | Investment | Purchase | D | B | C | A | B | B | D | A | N/A | N/A | No | |||||||||||||||
| 438820777 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - ___ | Required income documentation is missing/needed; 2018, 2019 and 2020 4506T, balance sheet, business license, business returns and transcripts | Reviewer Comment (2021-12-08): Received, Clearing. Seller Comment (2021-12-07): P&L and business license are uploaded. for CDL loans, no 4506T/transcripts/tax returns/Balance Sheet are required |
12/08/2021 | 1 | A | PA | Investment | Purchase | D | B | C | A | C | B | D | A | N/A | N/A | No | |||||||||||||
| 438820777 | Property | Property - Appraisal | Appraisal Documentation | Property - Appraisal | Loan is to be securitized. Secondary valuation is missing.; Sec ID: 2 | Proof of secondary valuation is missing/needed | Reviewer Comment (2021-12-08): provided Seller Comment (2021-12-07): AVM valuation is within [Redacted]% variance and supports the value. |
12/08/2021 | 1 | A | PA | Investment | Purchase | D | B | C | A | C | B | D | A | N/A | N/A | No | ||||||||||||||
| 438820777 | Credit | Missing Document | General | Missing Document | Missing Document: COVID-19 Attestation not provided | Documentation not provided/missing | Reviewer Comment (2021-11-16): Received, clearing. Seller Comment (2021-11-16): Covid-19 Attestation |
11/16/2021 | 1 | A | PA | Investment | Purchase | D | B | C | A | C | B | D | A | N/A | N/A | No | ||||||||||||||
| 438820777 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | FEMA Disaster Issue: The most recent valuation inspection is dated prior to the most recent FEMA disaster. | Disaster happened after the valuation was completed | Reviewer Comment (2021-12-03): Clearing Seller Comment (2021-12-03): PCI Report |
12/03/2021 | 1 | A | PA | Investment | Purchase | D | B | C | A | C | B | D | A | N/A | N/A | No | ||||||||||||||
| 438820777 | Compliance | Compliance | Federal Compliance | GSE | FNMA Points and Fees | FNMA Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of the greater of [Redacted]% of the Original Loan Amount and [Redacted] (2021). FNMA Finance Charge total $[Redacted]on a Original Loan Amount of $[Redacted]vs. an allowable total of [Redacted]and $[Redacted](2021) (an overage of $[Redacted]or [Redacted]%). | Reviewer Comment (2021-11-16): Provided with trailing documents |
11/16/2021 | 1 | A | PA | Investment | Purchase | D | B | C | A | C | B | D | A | N/A | N/A | Yes | ||||||||||||||
| 438820777 | Compliance | Compliance | State Compliance | State Defect | Pennsylvania Prepayment Penalty First Lien | Pennsylvania Prepayment Penalty: A prepayment penalty not permissible on a first lien loan less than or equal to $[Redacted]. | Reviewer Comment (2022-01-19): Bank preemption Reviewer Comment (2021-12-27): Generally, a federally chartered entity can use federal preemption to preempt state restrictions on late charges and prepayment penalties. The OCC regulations implementing Section 85 of the National Bank Act provide that, "[a] national bank located in a state may charge interest at the maximum rate permitted to any state-chartered or licensed lending institution by the law of that state." This authority is commonly referred to as the "most favored lender doctrine." A national bank may elect to charge the most favorable interest rates under state law for a particular class of loans. However, the national bank must also adhere to the restrictions on the types of loans to which such rates apply, such as the applicable loan amounts or lien priorities. A national bank that elects not to use Section 85 may not avail itself of the rate permitted to the most favored lender in a state in which it is lending. If the bank elects not to use Section 85, it would be subject to the state's general usury laws. In the event, however, that such a federally chartered entity originates a loan that triggers the thresholds of a state law enacted to combat predatory lending acts and subsequently sells that loan in the secondary market to an entity that is not a federally chartered entity, there is some uncertainty whether the assignee, by virtue of contractual rights, would be able to assert the same preemption claim in litigation or a regulatory enforcement action involving the loan. The client should consult with its own counsel on these issues. In sum, state late charge and prepayment penalty exceptions (not related to APL regulations) can be downgraded to EV2 as a result of federal preemption or client can waive at their discretion. The client originating the review can make the determination of downgrading if they wish. Buyer Comment (2021-12-22): This is not applicable as we are a federal reserves bank. |
2 | B | PA | Investment | Purchase | D | B | C | A | C | B | D | A | N/A | N/A | No | |||||||||||||||
| 438820776 | Credit | Insurance | Insurance Analysis | Insurance | Flood Insurance Policy expires within 90 days of the Note Date. | Flood Insurance Policy Expiration Date ___; Note Date ___ | 2 | B | HI | Investment | Refinance - Rate/Term | D | B | B | B | B | B | D | A | N/A | N/A | No | ||||||||||||||||
| 438820776 | Property | Property - Appraisal | Appraisal Documentation | Property - Appraisal | Loan is to be securitized. AVM provided is invalid. The FSD is greater than 0.2.; Sec ID: 12 | Reviewer Comment (2021-11-30): Clearing after re-review. Buyer Comment (2021-11-30): We do not have any criteria for confidence score, nor is this on our guidelines. |
11/30/2021 | 1 | A | HI | Investment | Refinance - Rate/Term | D | B | B | B | B | B | D | A | N/A | N/A | No | |||||||||||||||
| 438820776 | Compliance | Compliance | Federal Compliance | GSE | FNMA Points and Fees | FNMA Points and Fees on subject loan of [Redacted ] is in excess of the allowable maximum of the greater of [Redacted ] of the Original Loan Amount and [Redacted ] (2021). FNMA Finance Charge total $[Redacted ] on a Original Loan Amount of [Redacted] vs. an allowable total of $[Redacted ] and $[Redacted ] (2021) (an overage of $[Redacted ] | Verified Points and Fees on subject loan of [Redacted ] is in excess of the allowable maximum of the greater of [Redacted ]% of the Original Loan Amount and $[Redacted ]2021). FNMA Finance Charge total [Redacted ] on a Original Loan Amount of $[Redacted ] vs. an allowable total of $[Redacted ]and $[Redacted ] | 2 | B | HI | Investment | Refinance - Rate/Term | D | B | B | B | B | B | D | A | N/A | N/A | Yes | |||||||||||||||
| 438820776 | Credit | Title | Document Error | Title | There is no dollar amount noted on the title policy. | The preliminary title report in file did not disclose the amount of title insurance coverage. Provide a copy of the final title policy or an addendum to the preliminary report verifying title insurance of at least the loan amount. | 2 | B | HI | Investment | Refinance - Rate/Term | D | B | B | B | B | B | D | A | N/A | N/A | No | ||||||||||||||||
| 438639114 | Compliance | Compliance | Federal Compliance | GSE | FNMA Points and Fees | FNMA Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of the greater of [Redacted]% of the Original Loan Amount and $[Redacted](2021). FNMA Finance Charge total $[Redacted]on a Original Loan Amount of $[Redacted]vs. an allowable total of $[Redacted]and $[Redacted](2021) (an overage of $[Redacted]or [Redacted]%). | Reviewer Comment (2021-12-07): Clearing |
12/07/2021 | 1 | A | FL | Investment | Purchase | C | A | C | A | B | A | A | A | N/A | N/A | Yes | ||||||||||||||
| 438639114 | Credit | Asset | Asset Documentation | Asset | Earnest Money Deposit is unsourced. Per guidelines EMD source is required. | Fully executed HUD shows $[Redacted] for EMD; however, only $[Redacted]in EMD is sourced. Please provide additional $[Redacted]for completion of $[Redacted]or revised HUD showing $[Redacted]additional conditions may be required upon receipt. | Reviewer Comment (2021-12-07): Received, Clearing. Seller Comment (2021-12-07): total $[Redacted]: see uploaded two documents. |
12/07/2021 | 1 | A | FL | Investment | Purchase | C | A | C | A | B | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639114 | Credit | Loan Package Documentation | Loan File | Missing Document | Missing Document: Hazard Insurance Policy not provided | Missing Master condo insurance policy | Reviewer Comment (2021-11-29): provided with trailing documents. Seller Comment (2021-11-29): condo master insurance |
11/29/2021 | 1 | A | FL | Investment | Purchase | C | A | C | A | B | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639116 | Credit | Missing Document | General | Missing Document | Missing Document: COVID-19 Attestation not provided | Reviewer Comment (2021-11-17): Received, clearing. Seller Comment (2021-11-17): COVID-19 Attestation |
11/17/2021 | 1 | A | GA | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | |||||||||||||||
| 438639117 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | FEMA Disaster Issue: The most recent valuation inspection is dated prior to the most recent FEMA disaster. | No post disaster inspection was in file. | Reviewer Comment (2021-11-22): Received, clearing. Seller Comment (2021-11-22): PCI Report |
11/22/2021 | 1 | A | NJ | Investment | Purchase | C | B | C | A | B | B | A | A | N/A | N/A | No | ||||||||||||||
| 438639117 | Compliance | Compliance | State Compliance | State Defect | New Jersey Prepayment Penalty | New Jersey Prepayment Penalty: No prepayment penalties are permissible in the state of New Jersey. Prepay language states prepay will not exceed maximum permitted by applicable law. | Loan involves prepayment penalty in state that does not allow prepayments. | 2 | B | NJ | Investment | Purchase | C | B | C | A | B | B | A | A | N/A | N/A | No | |||||||||||||||
| 438639115 | Property | Property - Appraisal | Appraisal Documentation | Property - Appraisal | Loan is to be securitized. Secondary valuation is missing.; Sec ID: 2 | Reviewer Comment (2021-12-15): Received, Clearing. Reviewer Comment (2021-12-08): CDA with 5 day SLA has been requested with XXXX approval. Buyer Comment (2021-12-08): UW pulled another AVM with no hit, please pull the 2nd valuation from your end |
12/15/2021 | 1 | A | GA | Investment | Purchase | D | A | A | A | A | A | D | A | N/A | N/A | No | |||||||||||||||
| 438639125 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Credit | Payment Shock exceeds credit guidelines. | Payment Shock: ___ | Verified payment shock exceed guidelines | The representative FICO score exceeds the guideline minimum by at least 40 points. The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-04-19): Pre funding exception. Seller Comment (2022-04-19): Approved Exception for High Payment Shock Reviewer Comment (2022-04-14): Exception Explanation Updated from: Payment Shock: [Redacted]% Reviewer Comment (2022-04-13): Reopened Reviewer Comment (2021-12-23): Exception provided. Seller Comment (2021-12-23): Agree - approved exception from [Redacted] |
04/19/2022 | 2 | B | FL | Primary | Refinance - Cash-out - Other | C | B | C | B | C | A | A | A | Non QM | Non QM | No | |||||||||||
| 438639125 | Compliance | Compliance | Federal Compliance | TILA | Federal Loan Originator Compensation - Individual LO Not NMLS Licensed at Time of Application | Truth in Lending Act (NMLSR Dodd- Frank 2014): Individual Loan Originator not NMLS licensed or registered at time of application. | The loan originator license date is [Redacted], the application date is [Redacted]. | Reviewer Comment (2022-01-18): Received, Clearing. Buyer Comment (2022-01-18): LO was granted a temp license by Florida - listed on the NMLS site Reviewer Comment (2021-12-23): Was the originator not licensed at the time? Seller Comment (2021-12-23): Agree - exception uploaded |
01/18/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | B | C | B | C | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438639125 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Interim Closing Disclosure Timing Test | TILA-RESPA Integrated Disclosure - Corrected Closing Disclosure provided on or after [Redacted] contains a change in APR and was not received by borrower at least three (3) business days prior to consummation | Reviewer Comment (2022-01-11): Received, Clearing. Seller Comment (2022-01-11): Final CD issued [Redacted] APR [Redacted]%, previously issued CD [Redacted] APR [Redacted]% - no new wait triggered. see referenced CDs attached |
01/11/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | TRID timing exception, no remediation available. | C | B | C | B | C | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438639125 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Appraisal Fee was last disclosed as $[Redacted]on LE but disclosed as $575 on Final Closing Disclosure. File does not contain a valid COC for this fee, cure provided at closing. | Reviewer Comment (2021-11-15): Sufficient Cure Provided At Closing |
11/15/2021 | 1 | A | FL | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | C | B | C | B | C | A | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438639125 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee. Fee Amount of $725.00 exceeds tolerance of $400.00. Sufficient or excess cure was provided to the borrower at Closing. | Second Appraisal Fee was last disclosed as $400 on LE but disclosed as $725 on Final Closing Disclosure. File does not contain a valid COC for this fee, cure provided at closing. | Reviewer Comment (2021-11-15): Sufficient Cure Provided At Closing |
11/15/2021 | 1 | A | FL | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | C | B | C | B | C | A | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438639125 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - ATR Risk | Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk. | Reviewer Comment (2021-12-23): Exception provided. Buyer Comment (2021-12-23): Agree - previously uploaded exception covers this |
12/23/2021 | 1 | A | FL | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM Loan Designation | C | B | C | B | C | A | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438639125 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines | Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of [Redacted]% moderately exceeds the guideline maximum of [Redacted]%. (DTI Exception is eligible to be regraded with compensating factors.) | The representative FICO score exceeds the guideline minimum by at least 40 points. The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-04-14): Received updated documents to clear the issue. Seller Comment (2022-04-14): Please find attached the tax statement from the county, which was in file. The use of the worst-case scenario is $[Redacted]which was the taxes used to qualify. Clarity report shows using an estimate from the title company on the prelim CD that is not correct. Loan closed correctly at DTI of [Redacted]%. Please clear finding with docs attached. Reviewer Comment (2022-04-13): Reopened Reviewer Comment (2021-12-23): Exception provided. Buyer Comment (2021-12-23): Agree - previously uploaded exception covers this |
04/14/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | B | C | B | C | A | A | A | Non QM | Non QM | No | ||||||||||||
| 438639125 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: Investor qualifying total debt ratio discrepancy. | DTI of [Redacted]% exceeds Guideline total debt ratio of [Redacted]%. | The representative FICO score exceeds the guideline minimum by at least 40 points. The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-04-14): Received updated documents to clear the issue. Seller Comment (2022-04-14): Please find attached the tax statement from the county, which was in file. The use of the worst-case scenario is $[Redacted]which was the taxes used to qualify. Clarity report shows using an estimate from the title company on the prelim CD that is not correct. Loan closed correctly at DTI of [Redacted]%. Please clear finding with docs attached. Reviewer Comment (2022-04-13): Reopened Reviewer Comment (2021-12-23): Exception provided. |
04/14/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | B | C | B | C | A | A | A | Non QM | Non QM | No | ||||||||||||
| 438639125 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General Ability To Repay Provision Investor Guidelines | Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk. | Ability to RePay was not provided due to total DTI above guidelines. | Reviewer Comment (2022-02-01): NonQM Reviewer Comment (2022-02-01): . Reviewer Comment (2021-12-23): Exception provided. Buyer Comment (2021-12-23): Agree - previously uploaded exception covers this |
02/01/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | B | C | B | C | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438639126 | Compliance | Compliance | State Compliance | State Defect | (TX50(a)(6)) Texas Cash-out Loan (Itemization of Points and Fees Not Provided At Least 1 Business Day Prior to Closing - No Waiver) | Texas Constitution Section 50(a)(6): Final itemized disclosure of fees, points, costs and charges not provided to borrower at least one (1) business day prior to closing without a waiver. | Reviewer Comment (2022-05-04): Received, Clearing. Seller Comment (2022-05-04): Borrower letter waiving need to receive [Redacted] hours before Reviewer Comment (2022-03-11): Texas owners Affidavit acknowledging lender's compliance disclosure reflects [Redacted] as borrower receipt of disclosure, which is less than [Redacted] business day from closing. Exception remains Buyer Comment (2022-03-11): Disagree - Final Closing package was sent to Borrower / Title company on [Redacted] for closing, loan did not sign until [Redacted] - this was provided well before the 1 business day |
05/04/2022 | 1 | A | TX | Primary | Refinance - Cash-out - Other | Refund or credit the borrower $1,000 and offer the borrower the right to refinance the extension of credit for the remaining term of the loan at no cost to the borrower on the same terms, including interest, as the original extension of credit with any modifications necessary to comply with this section or on terms on which the borrower and the lender or holder otherwise agree. | D | B | C | A | D | B | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438639126 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Policy Guarantee Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Title - Policy Guarantee Fee Fee was not disclosed on Loan Estimate. File does not contain a valid COC for this fee, cure provided at closing. | Reviewer Comment (2021-11-24): Sufficient Cure Provided At Closing |
11/24/2021 | 1 | A | TX | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | D | B | C | A | D | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438639126 | Compliance | Compliance | State Compliance | Misc. State Level | (TX50(a)(6)) Texas Cash-out Loan (T-42 Endorsement Not Obtained) | Texas Constitution Section 50(a)(6): Acceptable FNMA title insurance endorsements not obtained for home equity loan. The loan file does not evidence the Title Policy includes the Texas T-42 endorsement or the T-42.1 endorsement. (The loan is a Texas Section 50 (a)(6) home equity loan.) | 2 | B | TX | Primary | Refinance - Cash-out - Other | The endorsements would be required at the time of original title policy issuance, there is not an obvious remediation | D | B | C | A | D | B | A | A | Non QM | Non QM | No | |||||||||||||||
| 438639126 | Compliance | Compliance | State Compliance | State Defect | (TX50(a)(6)) Texas Cash-out Loan (Acknowledgment of Fair Market Value Disclosure Not Signed by the Lender) | Texas Constitution Section 50(a)(6): Acknowledgment of the Fair Market Value not properly executed by the Lender. | Reviewer Comment (2022-03-11): Received, cleared Seller Comment (2022-03-11): Disagree - TX fair market acknowledgement uploaded |
03/11/2022 | 1 | A | TX | Primary | Refinance - Cash-out - Other | To Remediate: the lender or holder may either: (1) Deliver to the borrower the required disclosure documents, (AFMV signed by the lender), and obtain an executed copy; OR (2) refund or credit the borrower $1,000 and offer the borrower the right to refinance the extension of credit for the remaining term of the loan at no cost to the borrower on the same terms, including interest, as the original extension of credit with any modifications necessary to comply with this section or on terms on which the borrower and the lender or holder otherwise agree. Letter of explanation and proof of delivery of cure documents required, and, if cured with refund or credit, copy of refund check or evidence of principal reduction also required. | D | B | C | A | D | B | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438639126 | Compliance | Compliance | State Compliance | State Defect | (TX50(a)(6)) Texas Cash-out Loan (Loan Not Closed At Office of Lender, Attorney, or Title Company) | Texas Constitution Section 50(a)(6): Unable to determine if loan was closed at an authorized location due to missing documentation. | 2 | B | TX | Primary | Refinance - Cash-out - Other | Refund or credit the borrower $1,000 and offer the borrower the right to refinance the extension of credit for the remaining term of the loan at no cost to the borrower on the same terms, including interest, as the original extension of credit with any modifications necessary to comply with this section or on terms on which the borrower and the lender or holder otherwise agree. | D | B | C | A | D | B | A | A | Non QM | Non QM | No | |||||||||||||||
| 438639126 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | The appraisal was provided electronically on [Redacted], the initial appraisal was effective on [Redacted] and signed and dated [Redacted]. The updated appraisal report effective date is [Redacted] while the report was signed and dated on [Redacted]. | 2 | B | TX | Primary | Refinance - Cash-out - Other | D | B | C | A | D | B | A | A | Non QM | Non QM | No | |||||||||||||||
| 438639126 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Non Escrowed Property Costs Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on [Redacted] not accurate. | The final CD disclosed the Amount of Non-Escrowed Property Costs over Year 1 as $[Redacted]on page 4; however the Flood Insurance the borrower has on the property which is not required should still be reported. The Flood Policy total $[Redacted]per year. Final CD reflects Estimated Taxes, Insurance & Assessments of $[Redacted]monthly, correct amount is $[Redacted]. Provide a post-close CD correcting the Escrow Account section on page 4 and Estimated Taxes, Insurance & Assessments on page 1; and a copy of the letter of explanation letter sent to the borrower disclosing the changes made. | Reviewer Comment (2022-01-26): Past [Redacted] day cure timeframe. Seller Comment (2022-01-26): Disagree - PCCD and LOX uploaded showing flood policy |
2 | B | TX | Primary | Refinance - Cash-out - Other | Letter of Explanation & Corrected Closing Disclosure | D | B | C | A | D | B | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438639126 | Credit | Hazard Insurance | Document Error | Hazard Insurance | Hazard Insurance policy does not list Lender or Servicer and its successors and assigns, per guideline requirements. | HOI policy provide reflects incorrect mortgagee clause. Lender to provide updated policy reflecting "Lender its successors and assigns" | Reviewer Comment (2021-12-20): servicer is acceptable Seller Comment (2021-12-20): Clause is acceptable |
12/20/2021 | 1 | A | TX | Primary | Refinance - Cash-out - Other | D | B | C | A | D | B | A | A | Non QM | Non QM | No | ||||||||||||||
| 438639126 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Reviewer Comment (2021-12-22): Received, Clearing. Seller Comment (2021-12-22): The finding is not valid. The asset statement in file expired on [Redacted] but there is an exception in file for this, see attached. Also we have assets just in borrower name (Redacted totaling over [Redacted], see attached statement page 5 highlighted, and the system shows PITIA of $[Redacted] which is $[Redacted] verified is more than sufficient |
12/22/2021 | 1 | A | TX | Primary | Refinance - Cash-out - Other | D | B | C | A | D | B | A | A | Non QM | Non QM | No | |||||||||||||||
| 438639126 | Credit | Guideline | Guideline Issue | Guideline | Aged document: Asset Account date is more than 90 days prior to Closing. | - | Reviewer Comment (2022-03-18): bank statement provided Seller Comment (2022-03-18): The updated statement from XXXX is attached to cure the finding below. |
03/18/2022 | 1 | A | TX | Primary | Refinance - Cash-out - Other | D | B | C | A | D | B | A | A | Non QM | Non QM | No | ||||||||||||||
| 438639126 | Compliance | Compliance | State Compliance | State Defect | (TX50(a)(6)) Texas Cash-out Loan (Itemization of Points and Fees Not Provided At Least 1 Business Day Prior to Closing - With Waiver) | Texas Constitution Section 50(a)(6): Final itemized disclosure of fees, points, costs and charges not provided to borrower at least one (1) business day prior to closing with waiver. | Reviewer Comment (2022-05-04): Received, Clearing. |
05/04/2022 | 1 | A | TX | Primary | Refinance - Cash-out - Other | Refund or credit the borrower $1,000 and offer the borrower the right to refinance the extension of credit for the remaining term of the loan at no cost to the borrower on the same terms, including interest, as the original extension of credit with any modifications necessary to comply with this section or on terms on which the borrower and the lender or holder otherwise agree. | D | B | C | A | D | B | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438639141 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Survey Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Survey fees increased from $[Redacted]to $[Redacted]without a valid change of circumstance. | Reviewer Comment (2022-03-18): [Redacted] received attestation that survey was borrower shopped provider requirement Seller Comment (2022-03-16): Disagree - Attestation uploaded confirming the Survey was required and outsourced by the borrower-chosen title provider. Reviewer Comment (2022-03-10): [Redacted]: Agreed Survey Fee was listed in Section C - borrower shopped. However as Survey fee was not disclosed in LE's unable to determine from the file whether the lender or title company required the survey. If the lender required the survey fee then a cure is due to the borrower. If the borrower-chosen service provider further outsourced the Survey Fee, an attestation on exception from the seller is needed. The attestation/letter should confirm that the service was outsourced by the borrower-chosen provider. This attestation would allow us to test the fee under the no tolerance category with the understanding that the new fee added on the CD was imposed by a provider through which the borrower indirectly selected. In case if the fee was not required by Lender or Title and it was opted by the borrower provide corrected PCCD moving the fee to Section H with LOE Seller Comment (2022-03-08): Disagree - Borrower shopped, Survey fee of $[Redacted]was listed in Section C of CD p2 to reflect, COC not required, uploaded Final CD and SSPL. |
03/18/2022 | 1 | A | NJ | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639141 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Service Charges. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Service Charge fees increased from $[Redacted]to $[Redacted]without a valid change of circumstance. | Reviewer Comment (2022-03-18): [Redacted] received Corrected CD issued [Redacted] and LOE to borrower updating fee name as a title fee. Seller Comment (2022-03-17): Disagree - clerical PCCD and LOX uploaded Reviewer Comment (2022-03-10): [Redacted]Service fee (Miscellaneous) is in sec C and paid to title services. Also, this fee is under the services borrower shopped. Provide corrected PCCD designated with title word in order to clear the exception or provide cure documents. Seller Comment (2022-03-08): Disagree - Borrower shopped, Miscellaneous fee of $[Redacted]was listed in Section C of CD p2 to reflect, COC not required, uploaded Final CD and SSPL. |
03/18/2022 | 1 | A | NJ | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639141 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien | TRID Final Closing Disclosure [Redacted] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) | The final Closing Disclosure did not list Seller-paid fees/charges on Page 2. | Reviewer Comment (2022-03-03): [Redacted] received seller's CD. Seller Comment (2022-03-01): Disagree - The Final Closing Disclosure for the borrower will not disclose seller paid fees. There is a Final Settlement Statement listing Buyer & Seller paid fees, as well as, a Seller CD listing seller paid fees |
03/03/2022 | 1 | A | NJ | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639141 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Credit | AUS Findings: PITIA months reserves discrepancy. | Reviewer Comment (2022-02-07): Received, Clearing. Seller Comment (2022-02-07): Invalid findings: System is correct and matches AUS, final 1008 was not correct. |
02/07/2022 | 1 | A | NJ | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||||
| 438639141 | Compliance | Compliance | State Compliance | State Defect | (State High Cost Disclosure) New Jersey High-Cost Loan (Borrower Notice Not Provided) | New Jersey High-Cost Loan: Notice to Borrower not provided to borrower. | Reviewer Comment (2022-04-01): Offset for U&O Escrow paid by Seller which brings NJ P&F under threshold. |
04/01/2022 | 1 | A | NJ | Primary | Purchase | Within 45 days of closing, provide: (1) Letter of Explanation; (2) refund of amount over the high-cost threshold maximum; and (3) proof of delivery. (Narrow Defense - CHD Approval Required) Within 365 days of closing, and prior to lender receiving any notice from borrower of the compliance failure, provide: (1) Lender Attestation to AMC attesting (i) the failure was not intentional and was a bona fide error notwithstanding procedures in place to prevent such loans from being made and (ii) the lender has not received any notice from borrower of the failure; (2) refund of amount over the high-cost threshold maximum; and (3) proof of delivery. |
C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||
| 438639141 | Compliance | Compliance | State Compliance | State Defect | (State High Cost) New Jersey High-Cost Loan (Points and Fees) | New Jersey Home Ownership Security Act: Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Total Loan Amount. Points and Fees total $[Redacted]on a Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or .[Redacted]%). Non-Compliant High Cost Loan. | Reviewer Comment (2022-04-01): Offset for U&O Escrow paid by Seller which brings NJ P&F under threshold. |
04/01/2022 | 1 | A | NJ | Primary | Purchase | Within 45 days of closing, provide: (1) Letter of Explanation; (2) refund of amount over the high-cost threshold maximum; and (3) proof of delivery. (Narrow Defense - CHD Approval Required) Within 365 days of closing, and prior to lender receiving any notice from borrower of the compliance failure, provide: (1) Lender Attestation to AMC attesting (i) the failure was not intentional and was a bona fide error notwithstanding procedures in place to prevent such loans from being made and (ii) the lender has not received any notice from borrower of the failure; (2) refund of amount over the high-cost threshold maximum; and (3) proof of delivery. |
C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | |||||||||||||
| 438639141 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Points and Fees | Reviewer Comment (2022-05-02): Restated. |
05/02/2022 | 1 | A | NJ | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639141 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or .[Redacted]%). | Reviewer Comment (2022-05-02): Restated. Buyer Comment (2022-05-02): Please restate to NQM Reviewer Comment (2022-04-29): Max allowed is $[Redacted]and the current total is $[Redacted] Seller Comment (2022-04-29): It's part of the finance charge but collapsed in the PDF uploaded previously. See attached breakout of the finance charge Reviewer Comment (2022-04-29): Not seeing broker compensation in DocMajic. Exception remains. Seller Comment (2022-04-29): We disagree with the fail. see attached passing test. undiscounted rate/price [Redacted] |
05/02/2022 | 1 | A | NJ | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||||
| 438639141 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - General Ability to Repay | Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not match. However, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. | Restated. | 2 | B | NJ | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||||
| 438639142 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-07-08): Accepted as is Reviewer Comment (2022-06-17): EV2-B |
2 | B | NC | Primary | Purchase | A | B | A | A | A | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639143 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Service Charges. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Title - Service Charge Fee amount of increased from $[Redacted]to $[Redacted]without a valid change of circumstance. | Reviewer Comment (2022-03-18): [Redacted] received Corrected CD updating title fee names Seller Comment (2022-03-17): Disagree - uploaded clerical PCCD and LOX Reviewer Comment (2022-02-25): Miscellaneous fee disclosed on closing disclosure is tested at a zero percent fee as it was not disclosed as a "Title -" fee even though the borrower shopped and it was paid to the same title provider. If applicable, please provide corrected PCCD which reflects the fee as Title - Miscellaneous with LOE or provide Cure. Cure consists of Corrected CD, LOE to borrower, proof of mailing and copy of refund check. Seller Comment (2022-02-24): Disagree - Borrower shopped, Miscellaneous Fee of $[Redacted]was listed in Section C of CD p2 to reflect, COC not required |
03/18/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639143 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on 24 months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-07-08): Accepted as is Reviewer Comment (2022-06-17): EV2-B |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639144 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Have Escrow - Monthly Escrow Payment Overdisclosed | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] disclosed the Monthly Escrow Payment that does not match the actual escrow payment for the loan. | Closing Disclosure Projected Escrow Amount $[Redacted]is less then Escrow Payment Amount $[Redacted]verified on the loan. Lender to provide corrected final CD. | Reviewer Comment (2022-01-27): Sufficient Cure Provided At Closing |
01/27/2022 | 1 | A | WA | Primary | Refinance - Cash-out - Other | Letter of Explanation & Corrected Closing Disclosure | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639144 | Compliance | Compliance | Federal Compliance | RESPA | RESPA - Initial Escrow Account statement Inaccurate | RESPA: Initial escrow account statement does not match charges on HUD-1/Final Closing Disclosure. | CD in file shows a hazard insurance policy amount that is less than what was verified in file. Lender to provide corrected escrow disclosure. | Reviewer Comment (2022-07-08): Accepted as is |
2 | B | WA | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||||
| 438639144 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on 24 months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-07-08): Accepted as is Reviewer Comment (2022-06-17): EV2-B |
2 | B | WA | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639145 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 Test | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of [Redacted] on Final Closing Disclosure provided on [Redacted] not accurate. | Final CD disclosed annual tax/insurance as $[Redacted], actual figure is $[Redacted]. Lender to provide corrected CD. | Reviewer Comment (2022-03-11): [Redacted] Received PCCD dated [Redacted] along with LOE. Seller Comment (2022-03-09): Disagree - PCCD uploaded with accurate figures and escrow selection |
03/11/2022 | 2 | B | CA | Primary | Refinance - Rate/Term | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639145 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Not Have Escrow - Reason | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether the loan will have an escrow account. | Final CD did not identify why there was no escrow account - lender to provide a corrected CD with the reason selected so this can be cleared (declined or not provided). | Reviewer Comment (2022-03-11): [Redacted] received Post CD and LOX. Seller Comment (2022-03-09): Disagree - PCCD and LOX uploaded |
03/11/2022 | 2 | B | CA | Primary | Refinance - Rate/Term | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639145 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Fee was out of tolerance with sufficient cure. | Reviewer Comment (2022-01-19): Sufficient Cure Provided At Closing |
01/19/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | Final CD evidences Cure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639145 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-07-08): Accepted as is Reviewer Comment (2022-06-17): EV2-B |
2 | B | CA | Primary | Refinance - Rate/Term | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639147 | Compliance | Compliance | Federal Compliance | TRID | TRID Appraisal Disclosure - ECOA Timing | ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date. | File has acknowledgement of receipt of appraisal on doc [Redacted] | Reviewer Comment (2022-03-18): [Redacted] received [Redacted] LE |
03/18/2022 | 1 | A | NJ | Second Home | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | |||||||||||||
| 438639147 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Homeownership counselling organizations disclosure not provided to borrower | 2 | B | NJ | Second Home | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||||
| 438639147 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Loan Estimate Timing Electronically Provided | TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application. | LE not delivered within time of consummation | Reviewer Comment (2022-03-10): [Redacted] received document stating it was received within time frame. Seller Comment (2022-03-09): Disagree - The provided Broker Initial 1003 reflecting the LO sign date as [Redacted], Considering this as an Application date. The Initial package along with the Initial LE issued on [Redacted], It's within three (3) business days of the application date.; The previously provided Broker Initial 1003 reflecting the LO sign date as - the app date. Per the attached, the Initial package along with the Initial LE issued on [Redacted], - three (3) business days of the application date. Seller Comment (2022-03-08): Disagree - The provided Broker Initial 1003 reflecting the LO sign date as [Redacted], Considering this as an Application date. The Initial package along with the Initial LE issued on [Redacted], It's within three (3) business days of the application date. |
03/10/2022 | 1 | A | NJ | Second Home | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||
| 438639147 | Compliance | Compliance | Federal Compliance | TRID | TRID Settlement Service Provider Status | TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers. | Borrower did not receive a list of service providers disclosure | Reviewer Comment (2022-03-10): [Redacted] received Settlement service providers list. |
03/10/2022 | 1 | A | NJ | Second Home | Refinance - Cash-out - Other | No Defined Cure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||
| 438639147 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Miscellaneous. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Fee tolerance exceeded for the miscellaneous fee | Reviewer Comment (2022-03-18): [Redacted] received Corrected CD and LOE to borrower, over [Redacted]days from closing, correcting title fee names Seller Comment (2022-03-17): Disagree - uploaded PCCD and LOX attached for clerical adjustment to correct title fee names Reviewer Comment (2022-03-10): [Redacted]: On review Miscellaneous fee disclosed on closing disclosure is tested at a zero percent fee as it was not disclosed as a "Title -" fee even though the borrower shopped and it was paid to the same title provider. If applicable, please provide corrected PCCD which reflects the fee as Title - Miscellaneous with LOE or provide Cure. Cure consists of Corrected CD, LOE to borrower, proof of mailing and copy of refund check. Seller Comment (2022-03-08): Disagree - Borrower shopped, Miscellaneous Fee of $[Redacted]was listed in Section C of CD p2 to reflect, COC not required. See attached Final CD and SSPL |
03/18/2022 | 1 | A | NJ | Second Home | Refinance - Cash-out - Other | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639147 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Sales tax. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Fee tolerance exceeded for the sales tax fee | Reviewer Comment (2022-03-18): [Redacted] received Corrected CD and LOE to borrower revising fee names Seller Comment (2022-03-17): Disagree - uploaded PCCD and LOX attached for clerical adjustment to correct title fee names Reviewer Comment (2022-03-10): [Redacted]: On review Sales Tax fee disclosed on closing disclosure is tested at a zero percent fee as it was not disclosed as a "Title -" fee even though the borrower shopped and it was paid to the same title provider. If applicable, please provide corrected PCCD which reflects the fee as Title - Sales Tax with LOE or provide Cure. Cure consists of Corrected CD, LOE to borrower, proof of mailing and copy of refund check. Seller Comment (2022-03-08): Disagree - Borrower shopped, Sales Tax of [Redacted] was listed in Section C of CD p2 to reflect, COC not required, uploaded Final CD and SSPL |
03/18/2022 | 1 | A | NJ | Second Home | Refinance - Cash-out - Other | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639147 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Service Charges. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Fee tolerance exceeded for the title service charges fee | Reviewer Comment (2022-03-10): [Redacted] received Settlement service providers list. Seller Comment (2022-03-08): Disagree - Borrower shopped, Title - Transaction Mgmt Platform Fee of $[Redacted]was listed in Section C of CD p2 to reflect, COC not required, uploaded final cd and SSPL |
03/10/2022 | 1 | A | NJ | Second Home | Refinance - Cash-out - Other | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639147 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Wire /Funding/ Disbursement Fee. Fee Amount of $50.00 exceeds tolerance of $0.00. Insufficient or no cure was provided to the borrower. | Fee tolerance exceeded for the disbursement fee | Reviewer Comment (2022-03-10): [Redacted] received Settlement service providers list. Seller Comment (2022-03-08): Disagree - Borrower shopped, Title - Wire Transfer Fee of $[Redacted]was listed in Section C of CD p2 to reflect, COC not required, uploaded Final CD and SSPL |
03/10/2022 | 1 | A | NJ | Second Home | Refinance - Cash-out - Other | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639147 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Survey Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Fee tolerance exceeded for the survey fee | Reviewer Comment (2022-03-11): [Redacted] received Settlement service Providers List. Reviewer Comment (2022-03-10): [Redacted] received Settlement Service Providers List. However, we need cure for survey fee for $[Redacted]as it was not disclosed on LE's. Or provide attestation letter from seller which confirm that the service was outsourced by the borrower-chosen provider. This attestation would allow us to test the fee under the no tolerance category with the understanding that the new fee added on the CD was imposed by a provider through which the borrower indirectly selected. Seller Comment (2022-03-08): Disagree - Borrower shopped, Survey Fee of $[Redacted]was listed in Section C of CD p2 to reflect, COC not required, uploaded Final CD and SSPL |
03/11/2022 | 1 | A | NJ | Second Home | Refinance - Cash-out - Other | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639147 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Examination Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Fee tolerance exceeded for the title examination fee | Reviewer Comment (2022-03-10): [Redacted] received Settlement service providers list. Seller Comment (2022-03-08): Disagree - Borrower shopped, Title - Examination Fee of [Redacted] was listed in Section C of CD p2 to reflect, COC not required, uploaded Final CD and SSPL. |
03/10/2022 | 1 | A | NJ | Second Home | Refinance - Cash-out - Other | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639147 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Points and Fees | Reviewer Comment (2022-04-29): Restated. |
04/29/2022 | 1 | A | NJ | Second Home | Refinance - Cash-out - Other | Lender to provide updated ATR/QM status | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639147 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted] (an overage of $[Redacted]or .[Redacted]%). | Reviewer Comment (2022-04-29): Restated. Buyer Comment (2022-04-29): We agree the fail is valid. This will need to be restated as NQM |
04/29/2022 | 1 | A | NJ | Second Home | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||||
| 438639147 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - General Ability to Repay | Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not match. However, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. | [Redacted]. | 2 | B | NJ | Second Home | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||||
| 438639149 | Credit | Title | Document Error | Title | There is no dollar amount noted on the title policy. | Reviewer Comment (2022-03-16): Supplemental title with sufficient coverage on file |
03/16/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | B | B | B | A | A | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438639149 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-07-08): Accepted as is Reviewer Comment (2022-06-17): EV2-B |
2 | B | CA | Primary | Refinance - Cash-out - Other | B | B | B | A | A | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639150 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Lender Credit Tolerance Violation | TILA-RESPA Integrated Disclosure:[Redacted] Percent Tolerance exceeded for Lender Credits. Final Lender Credit of [Redacted] is less than amount of binding Lender Credit previously disclosed in the amount of [Redacted]. | No valid change in circumstance for this fee change. | Reviewer Comment (2022-02-25): [Redacted] received valid changed circumstance. Seller Comment (2022-02-24): Disagree - Lender Credit reflecting in Initial LE dated [Redacted] is [Redacted] from there it got decreased and increased in LE's issued between [Redacted] to [Redacted]. COC attached in LE's for the Increase and decrease in value of lender credit. In the Final LE dated [Redacted] the Lender credit value was [Redacted] (COC issued on [Redacted]. [Redacted] in CD dated [Redacted], COC provided on [Redacted] |
02/25/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639150 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing | RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to borrower. | Lender to provide document - only ABA in file was for the title company. | Reviewer Comment (2022-07-08): Accepted as is |
2 | B | CA | Primary | Refinance - Rate/Term | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639150 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted] | Reviewer Comment (2022-07-08): Accepted as is Reviewer Comment (2022-06-17): EV2-B |
2 | B | CA | Primary | Refinance - Rate/Term | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639151 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Hazard coverage of $[Redacted]is insufficient to cover the mortgage amount of $[Redacted]with an estimated cost new of $[Redacted]. Please provide a letter from the Insurer stating the maximum insurable amount and/or a replacement costs estimator from the insurer. | Reviewer Comment (2022-02-07): Received, Clearing. Seller Comment (2022-02-07): Exception disapproved. Invalid finding: In Florida RCE from Insurance Company is illegal. The coverage is at 100% Replacement cost as verified by LOE from Insurance Agent. See attached. |
02/07/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639151 | Compliance | Compliance | Federal Compliance | TRID | TRID Appraisal Disclosure - ECOA Timing | ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date. | Copy of appraisal disclosure not provided to borrower within time of consummation | Reviewer Comment (2022-03-29): Provided |
03/29/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | |||||||||||||
| 438639151 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Homeownership Counseling Organizations disclosure not provided to borrower. | Reviewer Comment (2022-07-08): Accepted as is |
2 | B | FL | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639151 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Non Escrowed Property Costs Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on [Redacted] not accurate. | Discrepancy in non escrowed property costs | Reviewer Comment (2022-03-14): SitusAMC Received PCCD and LOE. Seller Comment (2022-03-11): Disagree - PCCD and LOX uploaded |
03/14/2022 | 2 | B | FL | Primary | Refinance - Cash-out - Other | Letter of Explanation & Corrected Closing Disclosure | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639151 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Loan Estimate Timing Electronically Provided | TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application. | LE not provided within time of consummation | Reviewer Comment (2022-03-11): SitusAMC received document stating the initial disclosures were provided within time frame. Seller Comment (2022-03-10): Loan application date was [Redacted]; EConsent received from all parties; LE emailed [Redacted] (see attached) |
03/11/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639151 | Compliance | Compliance | Federal Compliance | TRID | TRID Settlement Service Provider Status | TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers. | List of service providers disclosure not provided to borrower | Reviewer Comment (2022-03-11): SitusAMC Received SSPL dated [Redacted] |
03/11/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | No Defined Cure | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438639151 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Abstract / Title Search. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Title search fee exceeded tolerable amount | Reviewer Comment (2022-03-11): SitusAMC Received SSPL dated [Redacted]. Upon further review, no tolerance breach was found. Exception cleared. Seller Comment (2022-03-10): Disagree - Borrower Shopped Title, which required Title Search fee, uploaded Initial CD, Final CD, Title Prelim CD and SSPL. |
03/11/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639151 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Bank Statement Loan | Reviewer Comment (2022-04-05): SHQM (APOR) |
04/05/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM status | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639151 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-07-08): Accepted as is Reviewer Comment (2022-06-17): EV2-B |
2 | B | FL | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639152 | Credit | Credit | Credit Documentation | Credit | Credit Report Error: Missing source document for credit/housing history. | Lender Exception Approval provided for housing history as it is free and clear and borrower provided [Redacted] month cancelled checks with comp factors: [Redacted]. reserves LTV FICO Residual Income |
The representative FICO score is above 680. The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%. The Loan to Value (LTV) on the loan is less than or equal to 70%. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-02-17): Exception from [Redacted] Seller Comment (2022-02-17): Attached exception approved [Redacted] |
02/17/2022 | 2 | B | CA | Primary | Purchase | C | B | C | B | A | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438639152 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of [Redacted] does not match Due Diligence Loan Designation of QM (APOR) Fail. | Bank Statement Loan | Reviewer Comment (2022-04-05): SHQM (APOR) |
04/05/2022 | 1 | A | CA | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | C | B | A | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639152 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted] months with a Fixed Expense Ratio of [Redacted] | Reviewer Comment (2022-07-08): Accepted as is Reviewer Comment (2022-06-17): EV2-B |
2 | B | CA | Primary | Purchase | C | B | C | B | A | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639153 | Compliance | Compliance | Federal Compliance | ATR/QM | NonQM ATR | Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied. | General Ability to Repay requirements not satisfied due to missing income documentation. | Reviewer Comment (2022-02-11): updated with receipt of TDs |
02/11/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639153 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - ATR | Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Fail. | Non-QM loan. | Reviewer Comment (2022-02-11): updated with receipt of TDs |
02/11/2022 | 1 | A | NY | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639153 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General Ability To Repay Provision Income and Assets - REO 25% Method | Ability to Repay (Dodd-Frank 2014): Unable to verify Real Estate Owned income (25% Method) using reasonably reliable third-party records. | The file is missing the lease confirming rental income. | Reviewer Comment (2022-02-11): REO income removed from calculation Seller Comment (2022-02-10): The borrowers were initially planning to retain the departure residence, but then they found a cash buyer and decided to sell it. It was sold on [Redacted]. NYC recording documents are attached |
02/11/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639153 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: Investor qualifying total debt ratio discrepancy. | 1003 - Current residence is now a rental property. application reflects $[Redacted]/mo rental income. File does not contain a lease. Lender rental income $[Redacted]. Loan file contain proof of HOA fee of $[Redacted]/mo. Lender did not calculate the rental loss of $[Redacted]into the DTI | Reviewer Comment (2022-02-23): removed REO Seller Comment (2022-02-23): see attached showing departing residence has been sold. |
02/23/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639153 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General Ability To Repay Provision Investor Guidelines | Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk. | 1003 - Current residence is now a rental property. application reflects $[Redacted]/mo rental income. File does not contain a lease. Lender rental income $[Redacted]. Loan file contain proof of HOA fee of $[Redacted]/mo. Lender did not calculate the rental loss of $[Redacted]into the DTI | Reviewer Comment (2022-02-25): Received, Clearing. Seller Comment (2022-02-25): The borrower sold the property and therefor there would not be a lease agreement to provide. Per guideline current principle residence payment can be omitted with an executed purchase contract. |
02/25/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639153 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines | Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and [Redacted](c)(5) of [Redacted]% significantly exceeds the guideline maximum of [Redacted]%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.) | 1003 - Current residence is now a rental property. application reflects $[Redacted]/mo rental income. File does not contain a lease. Lender rental income $[Redacted]. Loan file contain proof of HOA fee of $[Redacted]/mo. Lender did not calculate the rental loss of $[Redacted]into the DTI | Reviewer Comment (2022-02-25): Received, Clearing. Seller Comment (2022-02-25): The borrower sold the property and therefor there would not be a lease agreement to provide. Per guideline current principle residence payment can be omitted with an executed purchase contract. The dti is actually [Redacted] |
02/25/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639153 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - ATR Risk | Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk. | updated with receipt of TDs | Reviewer Comment (2022-02-25): Received, Clearing. |
02/25/2022 | 1 | A | NY | Primary | Purchase | Lender to provide updated ATR/QM Loan Designation | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639153 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Bank Statement Loan | Reviewer Comment (2022-04-05): SHQM (APOR) |
04/05/2022 | 1 | A | NY | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639153 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted] | Reviewer Comment (2022-07-08): Accepted as is Reviewer Comment (2022-06-17): EV2-B |
2 | B | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639157 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $[Redacted]exceeds tolerance of $[Redacted]plus [Redacted]% or $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-01-20): Sufficient Cure Provided At Closing |
01/20/2022 | 1 | A | AL | Primary | Purchase | Final CD evidences Cure | A | B | A | A | A | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | |||||||||||||
| 438639157 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Points and Fees | Reviewer Comment (2022-05-02): Restated. |
05/02/2022 | 1 | A | AL | Primary | Purchase | Lender to provide updated ATR/QM status | A | B | A | A | A | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639157 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted] (an overage of $[Redacted]or .[Redacted]%). | Reviewer Comment (2022-05-02): Restated. Buyer Comment (2022-05-02): Please restate to NQM Reviewer Comment (2022-04-29): Compliance test does not reflect any bona fide discount points. Seller Comment (2022-04-29): we disagree with the fail. see attached passing test. undiscounted rate/price: [Redacted] |
05/02/2022 | 1 | A | AL | Primary | Purchase | A | B | A | A | A | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||||
| 438639157 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - General Ability to Repay | Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not match. However, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. | Restated. | 2 | B | AL | Primary | Purchase | A | B | A | A | A | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||||
| 438639158 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Appraisal delivery date [Redacted] which is prior as the appraisal report is dated [Redacted] | Reviewer Comment (2022-07-08): Accepted as is |
2 | B | TX | Primary | Refinance - Rate/Term | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639158 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Lender Credit Tolerance Violation | TILA-RESPA Integrated Disclosure: [Redacted] Percent Tolerance exceeded for Lender Credits. Final Lender Credit of [Redacted] is less than amount of binding Lender Credit previously disclosed in the amount of [Redacted] | Credit was last disclosed as [Redacted] on the CD provided with an issue date of [Redacted], but disclosed as [Redacted] on the Final Closing Disclosure. File does not contain a valid COC for this fee, nor evidence of cure in file. | Reviewer Comment (2022-02-18): Received, Clearing. Seller Comment (2022-02-18): Disagree - Decrease of lender credit is due to rate lock extension. Pricing adjusted within APR threshold and accurately disclosed on final closing CD. |
02/18/2022 | 1 | A | TX | Primary | Refinance - Rate/Term | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639158 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted] months with a Fixed Expense Ratio of [Redacted] | Reviewer Comment (2022-07-08): Accepted as is Reviewer Comment (2022-06-17): EV2-B |
2 | B | TX | Primary | Refinance - Rate/Term | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639128 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on 24 months with a Fixed Expense Ratio of 0% (Wage Earner) | Reviewer Comment (2022-07-08): Accepted as is Reviewer Comment (2022-06-17): EV2-B |
2 | B | TX | Primary | Purchase | A | B | A | A | A | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639127 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Bank Statement Loan | Reviewer Comment (2022-07-12): Loan is SHQM (APOR). |
07/12/2022 | 1 | A | CT | Primary | Purchase | Lender to provide updated ATR/QM status | A | B | A | A | A | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639127 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-07-08): Accepted as is Reviewer Comment (2022-06-17): EV2-B |
2 | B | CT | Primary | Purchase | A | B | A | A | A | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639129 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Borrower was not provided with a COC | Reviewer Comment (2022-01-19): Sufficient Cure Provided At Closing |
01/19/2022 | 1 | A | FL | Primary | Purchase | Final CD evidences Cure | A | B | A | A | A | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639129 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-07-08): Accepted as is Reviewer Comment (2022-06-17): EV2-B |
2 | B | FL | Primary | Purchase | A | B | A | A | A | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639163 | Credit | Credit | Credit Documentation | Missing Document | Missing Document: Credit Report not provided | Missing credit report for XXXX. | Reviewer Comment (2022-06-01): Received, Clearing. Seller Comment (2022-06-01): The attached note is to clear the findings below. Please note, the non-borrowing spouse credit is not required as she is not on the loan. |
06/01/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | A | A | A | A | A | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438639170 | Compliance | Compliance | Federal Compliance | TRID Defect | TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File | TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s). The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing. Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $[Redacted]may be required. | The Loan Estimate for this purchase transaction is not in the file. | Reviewer Comment (2022-02-25): SitusAMC received LEs. Seller Comment (2022-02-24): Disagree - attached Initial LE and Re-Disclosed LE were located in the file. |
02/25/2022 | 1 | A | FL | Second Home | Purchase | No Defined Cure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438639170 | Compliance | Compliance | Federal Compliance | Flood | Flood Insurance Escrow - Flood not Escrowed for Property in Flood Zone | Loan originated post December 2015, the subject property is in a flood zone, flood insurance is not escrowed. | Flood Policy is paid by the HOA. | 2 | B | FL | Second Home | Purchase | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438639170 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | SitusAMC received LE and COC. The appraisal was completed [Redacted] however the VCC indicating the service fee increased due to complexity was not disclosed until [Redacted]. Please provide a corrected CD, LOE, refund check, and proof of mailing. | Reviewer Comment (2022-03-14): SitusAMC upon further review sufficient cure provided at closing Reviewer Comment (2022-03-03): SitusAMC received cure at closing for Appraisal fee however we also required a valid COC for verification of employment or cure for the same. Exception will be cleared once we receive cure or valid document for verification of employment fee. Exception remains. Seller Comment (2022-03-02): Disagree - uploaded final CD dated [Redacted] shows $[Redacted]tolerance cure on page 2 Section J Seller Comment (2022-03-02): Disagree - re-disclosed LE was provided on [Redacted], the closing date was [Redacted] |
03/14/2022 | 1 | A | FL | Second Home | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639170 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Verification Of Employment Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | SitusAMC received LE and COC. The COC indicates the fee is now required however a valid changed circumstance of why it is now required and was not initially is not indicated. Please provide VCC or please provide a corrected CD, LOE, refund check, and proof of mailing to cure. | Reviewer Comment (2022-03-14): SitusAMC received valid COC hence no further action required Seller Comment (2022-03-10): Agree - valid change of circumstance was not in the file. See attached COC which clarifies when the condition was received from the UW, when the $[Redacted]was redisclosed, and the re-disclosed LE. |
03/14/2022 | 1 | A | FL | Second Home | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639170 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Revised Loan Estimate Timing Before Closing | TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on [Redacted] not received by borrower at least four (4) business days prior to closing. | Please provide receipt for [Redacted] LE if available for review. | Reviewer Comment (2022-03-04): SitusAMC received documentation indicating the revised LE was received the same day issued. Seller Comment (2022-03-02): Disagree - re-disclosed LE was provided on [Redacted], the closing date was [Redacted] |
03/04/2022 | 1 | A | FL | Second Home | Purchase | No Defined Cure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438639170 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | SitusAMC upon further review sufficient cure provided at closing | Reviewer Comment (2022-03-14): Sufficient Cure Provided At Closing |
03/14/2022 | 1 | A | FL | Second Home | Purchase | Final CD evidences Cure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639172 | Credit | Missing Document | General | Missing Document | Missing Document: Verification of Non-US Citizen Status not provided | The file is missing a valid work visa and/or extension for the co-borrower. | Reviewer Comment (2022-03-02): Received, Clearing. Seller Comment (2022-03-02): Co-borrower is ITIN and DL and ITIN paperwork is all that is needed, see ITIN paperwork attached.; SM-AP email from [Redacted] |
03/02/2022 | 1 | A | CA | Primary | Purchase | C | A | C | A | A | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438639174 | Compliance | Legal / Regulatory / Compliance | Anti-Predatory Violation | Federal Defect | (Fed High Cost Provision) Federal High-Cost Mortgage Loan (Financed Points and Fees) | Truth in Lending Act (HOEPA): Mortgage loan financed Points and Fees. | Reviewer Comment (2022-03-23): Received, Clearing. |
03/23/2022 | 1 | A | NJ | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Non QM | Non QM | No | ||||||||||||||
| 438639174 | Compliance | Compliance | Federal Compliance | Federal Defect | (Fed High Cost) Federal High-Cost Mortgage Loan (Points and Fees) | Truth in Lending Act (High-Cost Mortgage): Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees of $[Redacted] on a Federal Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or .[Redacted]%). Non-Compliant High Cost Loan. | Reviewer Comment (2022-03-23): Received, Clearing. Reviewer Comment (2022-03-15): Based on undiscounted rate of [Redacted]and [Redacted]in discount non of the discount is bona fide so violation still exists. Buyer Comment (2022-03-15): from undiscounted to locked rate, it's [Redacted]in discount Reviewer Comment (2022-03-10): Undercount Rate of [Redacted] is understood, but the: B: Undiscounted/Starting Adjusted Interest Rate Price: The percentage of the total Discount Points that were paid to bring the rate to the Undiscounted/Par interest rate. This does NOT include the percentage of the Discount Points on the CD that were actually paid to buy down the Note rate from the Starting Adjusted Rate. doesn't make sense at [Redacted]. Should be a percentage. Buyer Comment (2022-03-10): Undiscounted rate/price for this loan is [Redacted] - this would allow us to exclude discount as bona fide |
04/25/2022 | 1 | A | NJ | Primary | Refinance - Cash-out - Other | (1) Signed letter from borrower indicating their choice to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (2) Assuming option (a) is selected, a copy of refund check and proof of mailing; (3) Assuming option (b) is selected, proof of cure for each of the prohibited practices violations noted. | C | B | C | A | C | B | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438639174 | Compliance | Compliance | State Compliance | State Defect | (State High Cost Provision) New Jersey High-Cost Loan (Financed Fees Exceeds Threshold) | New Jersey High-Cost Loan: Lender financed points and fees in excess of [Redacted]% of the total loan amount. | Reviewer Comment (2022-04-25): Cured to a non-high cost loan |
04/25/2022 | 1 | A | NJ | Primary | Refinance - Cash-out - Other | Within 45 days of closing, provide: (1) Letter of Explanation; (2) refund of amount over the high-cost threshold maximum; and (3) proof of delivery. (Narrow Defense - CHD Approval Required) Within 365 days of closing, and prior to lender receiving any notice from borrower of the compliance failure, provide: (1) Lender Attestation to AMC attesting (i) the failure was not intentional and was a bona fide error notwithstanding procedures in place to prevent such loans from being made and (ii) the lender has not received any notice from borrower of the failure; (2) refund of amount over the high-cost threshold maximum; and (3) proof of delivery. |
C | B | C | A | C | B | A | A | Non QM | Non QM | No | |||||||||||||
| 438639174 | Compliance | Compliance | State Compliance | State Defect | (State High Cost) New Jersey High-Cost Loan (Points and Fees) | New Jersey Home Ownership Security Act: Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Total Loan Amount. Points and Fees total $[Redacted]on a Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or .[Redacted]%). Non-Compliant High Cost Loan. | Reviewer Comment (2022-04-25): LOE, refund, proof of delivery, attestation and client approval to accept cure under bona fide error provision Seller Comment (2022-04-25): Attestation Letter Reviewer Comment (2022-04-22): Need Lender Attestation to AMC attesting (i) the failure was not intentional and was a bona fide error notwithstanding procedures in place to prevent such loans from being made and (ii) the lender has not received any notice from borrower of the failure. Seller Comment (2022-04-22): Agree - uploaded PCCD, LOX, check and shipping label Reviewer Comment (2022-03-31): New Jersey's definition of bona fide discount points are those which are: (1) knowingly paid by the borrower; (2) for the express purpose of reducing the interest rate; (3) reduces the interest rate from an interest rate which does not exceed the conventional mortgage rate for first lien mortgage by more than [Redacted]% and (4) recouped within the first five years of the scheduled loan payments. Loan discount points will be considered to be recouped within the first five years of the scheduled loan payments if the reduction in the interest rate that is achieved by the payment of the loan discount points reduces the interest charged on the scheduled payments such that the borrower's dollar amount of savings in interest over the first [Redacted] years is equal to or exceeds the dollar amount of loan discount points paid by the borrower. As it relates to "for the express purpose of reducing the rate", we have loan discounts paid in Section A of the CD of [Redacted]% but also have [Redacted]% in points paid as an Undiscounted Interest Rate Price. As a result, only [Redacted] points are eligible for the purpose of reducing the rate. A. Loan Discounts = [Redacted] B. Undiscounted Interest Rate Price = [Redacted] C. Eligible Bona Fide Discount Points = [Redacted](A - B) D. CD Loan Discounts = $[Redacted] E. Eligible Bona Fide Discount Points of [Redacted]* Loan Amount of $[Redacted]= $[Redacted](these points can be excluded) F. Points to remain included = $[Redacted](D - E) SitusAMC is excluding the $[Redacted]as bona fide, but points and fees still exceed the NJ P&F threshold by $[Redacted]. Buyer Comment (2022-03-31): This meets NJ requirements for 1 point of bona fide discount to be excluded. Please provide explanation why no discount is able to be excluded per last comment. Reviewer Comment (2022-03-23): Exception Detail Updated from: New Jersey Home Ownership Security Act: Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Total Loan Amount. Points and Fees total $[Redacted]on a Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or .[Redacted]%). Non-Compliant High Cost Loan. Reviewer Comment (2022-03-22): Exception Detail Updated from: New Jersey Home Ownership Security Act: Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Total Loan Amount. Points and Fees total $[Redacted]on a Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or [Redacted]%). Non-Compliant High Cost Loan. Reviewer Comment (2022-03-15): Based on undiscounted rate of [Redacted]and [Redacted]in discount non of the discount is bona fide so violation still exists. Buyer Comment (2022-03-15): from undiscounted to locked rate, it's [Redacted]in discount Reviewer Comment (2022-03-10): Undercount Rate of [Redacted]is understood, but the: B: Undiscounted/Starting Adjusted Interest Rate Price: The percentage of the total Discount Points that were paid to bring the rate to the Undiscounted/Par interest rate. This does NOT include the percentage of the Discount Points on the CD that were actually paid to buy down the Note rate from the Starting Adjusted Rate. doesn't make sense at [Redacted]. Should be a percentage. Buyer Comment (2022-03-10): Undiscounted rate/price for this loan is [Redacted] - this would allow us to exclude discount as bona fide |
04/25/2022 | 2 | B | NJ | Primary | Refinance - Cash-out - Other | Within 45 days of closing, provide: (1) Letter of Explanation; (2) refund of amount over the high-cost threshold maximum; and (3) proof of delivery. (Narrow Defense - CHD Approval Required) Within 365 days of closing, and prior to lender receiving any notice from borrower of the compliance failure, provide: (1) Lender Attestation to AMC attesting (i) the failure was not intentional and was a bona fide error notwithstanding procedures in place to prevent such loans from being made and (ii) the lender has not received any notice from borrower of the failure; (2) refund of amount over the high-cost threshold maximum; and (3) proof of delivery. |
C | B | C | A | C | B | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438639174 | Compliance | Legal / Regulatory / Compliance | Anti-Predatory Violation | Federal Defect | (Fed High Cost Provision) Federal High-Cost Mortgage Loan (2015 Counseling Requirement) | Truth in Lending Act (HOEPA): Pre-loan counseling requirements not met. | The Counseling Disclosure was provided on [Redacted], closing date. | Reviewer Comment (2022-03-23): Received, Clearing. |
03/23/2022 | 1 | A | NJ | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Non QM | Non QM | No | |||||||||||||
| 438639174 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - ___ | Business bank statements for March, May, and June of 2021 were missing to complete a full 12 months of bank statements provided. | Reviewer Comment (2022-03-04): Received, Clearing. Seller Comment (2022-03-04): Exception approved. |
03/04/2022 | 1 | A | NJ | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Non QM | Non QM | No | |||||||||||||
| 438639174 | Credit | Missing Document | General | Missing Document | Missing Document: Bank Statements - Business not provided | The borrower qualified using the [Redacted]month bank statement program, only [Redacted] months of bank statements were provided. | Reviewer Comment (2022-03-04): Received, Clearing. Seller Comment (2022-03-04): Attached all found in file [Redacted] Bank Statements that is required. |
03/04/2022 | 1 | A | NJ | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Non QM | Non QM | No | ||||||||||||||
| 438639159 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [redacted] is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total [redacted] on a Federal Total Loan Amount of [redacted] vs. an allowable total of [redacted] (an overage of [redacted] or .[Redacted]%). | Reviewer Comment (2022-04-08): Received new CD. Seller Comment (2022-04-08): See additional documents attached - the Settlement Statement and Final CD, the bottom line matched up to the penny no UW Fee. Reviewer Comment (2022-04-06): Originator Comp Fee and UW fee are both calculated in the QM fees and costs which total $[redacted]. Which is over allowable.. Seller Comment (2022-04-06): Disagree - Final Originator Compensation was [redacted], and the UW fee was removed from [redacted] CD, the total amount charge of [redacted] was less than the allowable Max. Reviewer Comment (2022-03-31): Provided documents do not show fees used to calculate. But Max allowed is $[redacted] and there is Loan Originator Compensation and UW Fee that total $[redacted] which is over the allowed. Seller Comment (2022-03-31): Disagree - uploaded passed compliance review along with undiscounted rate |
04/08/2022 | 1 | A | AZ | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639159 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of [redacted] exceeds tolerance of [redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-02-23): Sufficient Cure Provided At Closing |
02/23/2022 | 1 | A | AZ | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | |||||||||||||
| 438639159 | Compliance | Compliance | Federal Compliance | TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form | TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date | Truth in Lending Act: Subject loan transaction disbursed on [redacted], prior to three (3) business days from transaction date of [redacted]. | Reviewer Comment (2022-03-07): Received, Clearing. Seller Comment (2022-03-07): Disagree - Note signed on [redacted] with Disbursement Date of [redacted], uploaded Settlement Statement |
03/07/2022 | 1 | A | AZ | Primary | Refinance - Cash-out - Other | TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | |||||||||||||
| 438639159 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [redacted] | Reviewer Comment (2022-09-19): Accepted as is Reviewer Comment (2022-06-17): EV2-B |
2 | B | AZ | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639159 | Compliance | Compliance | Federal Compliance | TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form | TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Date | Truth in Lending Act: Actual Date(s) on Notice of Right to Cancel occurs prior to expected date(s). | Reviewer Comment (2022-04-15): Received signed final CD, clearing exception. Seller Comment (2022-04-15): Final CD Reviewer Comment (2022-04-14): Receipt of the [redacted] CD cause the issue to refire. We need the signed final CD to clear the RTC. The[redacted] CD was unsigned so we default to add 3 business days to the date. Seller Comment (2022-04-14): ROR dates are good |
04/15/2022 | 1 | A | AZ | Primary | Refinance - Cash-out - Other | TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | |||||||||||||
| 438639159 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points. Fee Amount of [redacted] exceeds tolerance of [redacted]. Insufficient or no cure was provided to the borrower. | . | Reviewer Comment (2022-04-12): SitusAMC received valid CD and COC no further action required. Seller Comment (2022-04-12): Review: Per borrower request, [redacted]COC CD was issued for Lender Fee Buyout at a cost of %[redacted], discount points and lender credit adjusted to reflect. See attached Lock Confirmation and COC CD. Seller Comment (2022-04-12): Review: Per borrower request,[redacted] COC CD was issued for Lender Fee Buyout at a cost of %[redacted], discount points and lender credit adjusted to reflect. See attached Lock Confirmation and COC CD. |
04/12/2022 | 1 | A | AZ | Primary | Refinance - Cash-out - Other | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639160 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - ___ | Reviewer Comment (2022-03-03): Received, Clearing. Seller Comment (2022-03-03): The attached documents were on file prior to closing. |
03/03/2022 | 1 | A | NJ | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639160 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Loan was originated as Safe Harbor QM (APOR). | Reviewer Comment (2022-04-06): SHQM (APOR) |
04/06/2022 | 1 | A | NJ | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639160 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted] % | Reviewer Comment (2022-09-19): Accepted as is Reviewer Comment (2022-06-17): EV2-B |
2 | B | NJ | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639177 | Credit | Loan Package Documentation | Application / Processing | Insurance | Missing Document: Flood Certificate not provided | Lender to provide flood cert for subject transaction. | Reviewer Comment (2022-03-04): Received, Clearing. Seller Comment (2022-03-04): Exception approved. |
03/04/2022 | 1 | A | CA | Primary | Purchase | D | B | D | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639177 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Purchase Agreement / Sales Contract not provided | Lender to provide purchase contract for transaction. | Reviewer Comment (2022-03-04): Received, Clearing. Seller Comment (2022-03-04): Exception approved. |
03/04/2022 | 1 | A | CA | Primary | Purchase | D | B | D | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639177 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | Missing [Redacted] W2s and VVOE from United Airlines for B1. | Reviewer Comment (2022-03-04): Received, Clearing. Seller Comment (2022-03-04): Exception approved. |
03/04/2022 | 1 | A | CA | Primary | Purchase | D | B | D | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639177 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-09-19): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-04-07): Updated Seller Comment (2022-03-08): Proof of existence of borrower's company attached |
2 | B | CA | Primary | Purchase | D | B | D | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639177 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM Provision Income and Assets - Wages | General QM: Unable to verity income due to, missing W-2, Paystub, LES, ETS or WVOE. | Lender to provide all missing income docs to clear this. | Reviewer Comment (2022-03-04): Received, Clearing. |
03/04/2022 | 1 | A | CA | Primary | Purchase | D | B | D | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639177 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | . | Reviewer Comment (2022-03-30): SHQM (APOR) Loan Buyer Comment (2022-03-07): Need more information |
03/30/2022 | 1 | A | CA | Primary | Purchase | Lender to provide updated ATR/QM status | D | B | D | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639177 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Have Escrow Account | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXX incorrectly disclosed whether the loan will have an escrow account. | Loan has no escrow account but final CD discloses one - lender to provide a corrected CD. | Reviewer Comment (2022-03-10): SitusAMC Received PCCD and LOE. Seller Comment (2022-03-08): Disagree - PCCD and LOX uploaded |
03/10/2022 | 2 | B | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | D | B | D | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639177 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Not Have Escrow Account | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXX incorrectly disclosed whether the loan will have an escrow account. | Loan has no escrow account but final CD discloses one - lender to provide a corrected CD. | Reviewer Comment (2022-03-10): SitusAMC Received PCCD and LOE. Seller Comment (2022-03-08): Disagree - PCCD and LOX uploaded |
03/10/2022 | 2 | B | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | D | B | D | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639177 | Credit | Income / Employment | Income Documentation | Income / Employment | The verification of employment is required and was not found in file. | - | Lender to provide VVOEs for [Redacted]and [Redacted]. | Reviewer Comment (2022-03-04): Received, Clearing. Seller Comment (2022-03-04): Exception approved. |
03/04/2022 | 1 | A | CA | Primary | Purchase | D | B | D | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639177 | Credit | Income / Employment | Income Documentation | Income / Employment | Verification(s) of employment is not within 10 calendar days of the Note. | - | Lender to provide VVOEs for [Redacted]and [Redacted]. | Reviewer Comment (2022-03-04): Received, Clearing. Seller Comment (2022-03-04): Exception approved. |
03/04/2022 | 1 | A | CA | Primary | Purchase | D | B | D | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639177 | Credit | Income / Employment | Income Documentation | Income / Employment | Verification(s) of employment is not within 10 calendar days of the Note. | - | Lender to provide VVOEs for [Redacted]and [Redacted]. | Reviewer Comment (2022-03-04): Received, Clearing. Seller Comment (2022-03-04): Exception approved. |
03/04/2022 | 1 | A | CA | Primary | Purchase | D | B | D | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639177 | Credit | Income / Employment | Income Documentation | Income / Employment | Verification(s) of employment is not within 10 calendar days of the Note. | - | Lender to provide VVOEs for [Redacted]and [Redacted]. | Reviewer Comment (2022-03-04): Received, Clearing. Seller Comment (2022-03-04): Exception approved. |
03/04/2022 | 1 | A | CA | Primary | Purchase | D | B | D | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639177 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - ___ ___ |
Lender to provide: 1) for [Redacted], current tax cert; 2) for [Redacted], HOA cert; 3) for [Redacted], HOA cert; 4) for [Redacted], tax cert. | Reviewer Comment (2022-03-04): Received, Clearing. Seller Comment (2022-03-04): Exception approved. |
03/04/2022 | 1 | A | CA | Primary | Purchase | D | B | D | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639177 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - ___ | Missing [Redacted] W2s and VVOE from XXXX for B1. | Reviewer Comment (2022-03-04): Received, Clearing. Seller Comment (2022-03-04): Exception approved. |
03/04/2022 | 1 | A | CA | Primary | Purchase | D | B | D | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639177 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | Lender to provide [Redacted] W2s and VVOE from XXXX XXXX. | Reviewer Comment (2022-03-04): Received, Clearing. Seller Comment (2022-03-04): Exception approved. |
03/04/2022 | 1 | A | CA | Primary | Purchase | D | B | D | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639178 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted] months with a Fixed Expense Ratio of [Redacted] (Wage Earner) Verified Third party verification of Bank Statement missing in file. |
Reviewer Comment (2022-07-19): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-04-07): Updated Seller Comment (2022-03-22): The attached VOE's/business searches verify XXXX[Redacted], Inc [Redacted], Inc. are to cure the finding below. The income used was verified by the XXXX account statements.; Seller Comment (2022-03-08): The attached VOE's/business searches verify XXXX,[Redacted], Inc DBA [Redacted], Inc. are to cure the finding below. The income used was verified by the XXXX account statements. |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639178 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM Provision Investor and QM DTIs match and both significantly exceed Guidelines | General QM: The DTI calculated in accordance with the Lenders Guidelines and 1026.43(e) of [Redacted] significantly exceeds the guideline maximum of [Redacted]. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.) | DTI updated per guidelines requirements. | Reviewer Comment (2022-03-04): Received, Clearing. |
03/04/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639178 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Loan was originated as Safe Harbor QM(APOR) | Reviewer Comment (2022-04-05): SHQM (APOR) Loan |
04/05/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM status | C | B | C | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639178 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure:[Redacted] Percent Fee Tolerance exceeded for Credit Report Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | Credit Report Fee Amount of [Redacted] exceeds tolerance of [Redacted]. COC in the file for this change was not dated, however the invoice shows the fee increased on [Redacted]. The change in fee was not disclosed to the borrower until closing on [Redacted]. Insufficient or no cure was provided to the borrower | Reviewer Comment (2022-04-04): [Redacted] received LOX stating about the credit report requirement as per UW and processor repulling new reports. Seller Comment (2022-04-01): Disagree - uploaded Lender Attestation Letter, Invoice, and COC CD Reviewer Comment (2022-03-22): [Redacted] upon further review please provide updated COC or detailed LOE specifying the reason as mentioned in comment or please provide cure documents. Buyer Comment (2022-03-21): Review: Per UW and Processor original credit reports expired, repulled new credit reports required and borrower worked on improving credit score thus [Redacted] fee was added. Reviewer Comment (2022-03-15): Situs AMC upon further review in provided COC dated [Redacted] stating as "Credit Report Fee for Loan Amount Changes" which is not a valid reason for fee increases to [Redacted] on CD dated [Redacted](#2). So kindly provide a valid COC with additional information why the fee increases on CD dated [Redacted](#2) or provide Cure. Seller Comment (2022-03-14): Disagree, [Redacted] COC CD was issued for credit report fee increased, uploaded COC CD and Invoices Reviewer Comment (2022-03-10): [Redacted] upon further review COC dated [Redacted](D0344) is applied for CD sequence 1 (D0211) dated [Redacted].COC dated [Redacted] mentioned loan amount changed but did not specify any reason for credit report fee and CD sequence 1 also not reflected credit report fee change. CD sequence 2 (D0345)reflected credit report fee change but COC (D0289) is not dated to apply for CD sequence 2. Kindly provide additional information for COC dated [Redacted] to justify the reason or need date of change on COC (D0289) or need valid COC for CD sequence 2 or need cure. Seller Comment (2022-03-08): Disagree- COC CD issued with increase to credit fee based on credit report invoice received showing increased fee. Invoice received [Redacted] and COC CD issued [Redacted]. |
04/04/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639178 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: Investor qualifying total debt ratio discrepancy. | Total DTI of [Redacted] exceeds Guideline total debt ratio of [Redacted] due to the addition of a missed liability payment not included on teh final 1003 and variances in rental income on the investment properties. | Reviewer Comment (2022-03-04): Received, Clearing. |
03/04/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639178 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM Provision Investor Guidelines Violation | General QM: Based on the loan failing one or more guideline components, the loan is at QM risk. | Loan is failing QM testing due to missing income documentation stated in other exceptions. | Reviewer Comment (2022-04-05): Exception Resolved |
04/05/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639178 | Property | Property - Appraisal | Appraisal Reconciliation | Property - Appraisal | Appraisal is required to be in name of Lender | - | The appraisal was not in the name of the lender. HPML/Safe Harbor requires correct lender to be identified. Provide a revised appraisal correcting the client. | 2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438639178 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | The file is missing copies of current lease(s) to support monthly gross rents received totalling [Redacted]. | Reviewer Comment (2022-03-04): Received, Clearing. Seller Comment (2022-03-04): Leases go month to month after initial term - tenant is still paying on a month to month basis |
03/04/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639178 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | The file is missing copies of current lease(s) to support monthly gross rents received totalling [Redacted]. | Reviewer Comment (2022-03-04): Received, Clearing. Seller Comment (2022-03-04): Leases go month to month after initial term |
03/04/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639179 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | 1003/Declarations: F. Are you a co-signer or guarantor on any debt or loan that is not disclosed on this application? reflects Yes. Missing documented and/or does not meet guideline requirements. | - | Reviewer Comment (2022-03-14): Received, Clearing. Seller Comment (2022-03-14): Disagree - uploaded 1003 with both borrower's signatures |
03/14/2022 | 1 | A | CA | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639179 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted] months with a Fixed Expense Ratio of [Redacted] | Reviewer Comment (2022-07-19): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-04-07): Updated Seller Comment (2022-03-22): The attached google search and business licenses attached are to clear the finding below. The file contains the bank statements and the attached google search verifies the bank's existence. Seller Comment (2022-03-08): The attached google search is to clear the finding below. The file contains the bank statements and the attached google search verifies the bank's existence. |
2 | B | CA | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639161 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - ___ ___ |
The file was missing HOA verification and Tax verification [Redacted] and [Redacted] addresses | Reviewer Comment (2022-03-09): Received, Clearing. Seller Comment (2022-03-09): See attached documents; For the tax documents please see the attached property profiles to match the APN number since the tax docs do not have an address listed. |
03/09/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639161 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Valuation provision timing discrepancy | Reviewer Comment (2022-06-07): Accepted as is per client request |
2 | B | CA | Primary | Refinance - Rate/Term | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639161 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Loan designation mismatch between originator and due diligence | Reviewer Comment (2022-04-05): SHQM (APOR) |
04/05/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | Lender to provide updated ATR/QM status | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639161 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-07): Accepted as is per client request Reviewer Comment (2022-04-07): Updated Seller Comment (2022-03-25): The findings are invalid. File is a Non-Agency Alternative Elite Alternative Income program. Program allows borrower to use business banks statements for qualifying income. Borrower provided bank statement for [Redacted]months along with business license to confirm ownership of business. Documents were not "Protected" and may not have been previously visible.; • [Redacted] months bank statement and business verifications are in the file along with the borrowers business license to confirm income and ownership.; Third party verification attached. Certificate of Business Operation letter. Business website search. CA business entity search Seller Comment (2022-03-18): The findings are invalid. File is a Non-Agency Alternative Elite Alternative Income program. Program allows borrower to use business banks statements for qualifying income. Borrower provided bank statement for [Redacted]months along with business license to confirm ownership of business. Documents were not "Protected" and may not have been previously visible.; • [Redacted]months bank statement and business verifications are in the file along with the borrowers business license to confirm income and ownership.; Third party verification attached. Certificate of Business Operation letter. Business website search. CA business entity search Seller Comment (2022-03-14): The findings are invalid. File is a Non-Agency Alternative Elite Alternative Income program. Program allows borrower to use business banks statements for qualifying income. Borrower provided bank statement for [Redacted]months along with business license to confirm ownership of business. Documents were not "Protected" and may not have been previously visible.; • [Redacted] months bank statement and business verifications are in the file along with the borrowers business license to confirm income and ownership. Buyer Comment (2022-03-08): The findings are invalid. File is a Non-Agency Alternative Elite Alternative Income program. Program allows borrower to use business banks statements for qualifying income. Borrower provided bank statement for [Redacted] months along with business license to confirm ownership of business. Documents were not "Protected" and may not have been previously visible. |
2 | B | CA | Primary | Refinance - Rate/Term | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639161 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Appraisal fee exceeded fee tolerance | Reviewer Comment (2022-03-18): SitusAMC upon further review sufficient cure provided at closing Seller Comment (2022-03-16): Disagree - Appraisal Fee increased from Final LE $[Redacted]to Initial CD $[Redacted]without valid COC - the $[Redacted]credit for increase in Closing Costs above legal limit was included in the Lender Credit in the amount of $[Redacted]on Initial CD & $[Redacted]remained included on Final CD with Lender Credit amount of $[Redacted]on Page 2, Section J of the CD. The cure was issued - there is no additional cure due to the borrower Reviewer Comment (2022-03-11): SitusAMC upon further as cure for appraisal fee provided at closing will be cleared once the [Redacted]% tolerance exception resolution will be received. Seller Comment (2022-03-09): Disagree - Appraisal Fee increased from $[Redacted]on Final LE to $[Redacted]on Initial CD through Final CD. Cure is included in Lender Credit listed on Page 2, Section J of CD. No additional cure is due |
03/18/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639161 | Compliance | Compliance | Federal Compliance | TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form | TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date | Truth in Lending Act: Subject loan transaction disbursed on [Redacted], prior to three (3) business days from transaction date of [Redacted]. | Rescission not disbursed within time of consummation | Reviewer Comment (2022-03-04): Received, Clearing. Seller Comment (2022-03-04): Disagree - Notice of Right to Cancel has the correct Date of [Redacted] |
03/04/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639161 | Compliance | Compliance | Federal Compliance | TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form | TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Date | Truth in Lending Act: Actual Date(s) on Notice of Right to Cancel occurs prior to expected date(s). | Right to cancel disclosure timing is off | Reviewer Comment (2022-03-04): Received, Clearing. Seller Comment (2022-03-04): Disagree - Notice of Right to Cancel has correct Date of [Redacted] |
03/04/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639161 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | SitusAMC received sufficient cure at closing. | Reviewer Comment (2022-04-04): Sufficient Cure Provided At Closing |
04/04/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | Final CD evidences Cure | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639162 | Compliance | Compliance | Federal Compliance | FACTA | FACTA Disclosure Missing | FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. | FACTA disclosure not provided or missing | 2 | B | FL | Primary | Purchase | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438639162 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Have Escrow Account | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether the loan will have an escrow account. | Discrepancy regarding whether there is an escrow account or not | Reviewer Comment (2022-03-16): [Redacted] Received PCCD and LOX. Seller Comment (2022-03-15): Disagree - corrected PCCD uploaded Reviewer Comment (2022-03-09): [Redacted] received CD and LOX which states escrow account is not established whereas we required Post CD to reflect will not have an escrow account box to be checked on page 4 along with LOX in order to cure the exception. Seller Comment (2022-03-07): Disagree - PCCD and LOX uploaded |
03/16/2022 | 2 | B | FL | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639162 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Not Have Escrow Account | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether the loan will have an escrow account. | Discrepancy regarding whether there is an escrow account or not | Reviewer Comment (2022-03-16): [Redacted] Received PCCD and LOX. Seller Comment (2022-03-15): Disagree - corrected PCCD uploaded Reviewer Comment (2022-03-09): [Redacted] received CD and LOX which states escrow account is not established whereas we required Post CD to reflect will not have an escrow account box to be checked on page 4 along with LOX in order to cure the exception. Seller Comment (2022-03-07): Disagree - PCCD and LOX uploaded |
03/16/2022 | 2 | B | FL | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639162 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: [Redacted] Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-03-09): Sufficient Cure Provided At Closing |
03/09/2022 | 1 | A | FL | Primary | Purchase | Final CD evidences Cure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | |||||||||||||
| 438639165 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $[Redacted]exceeds tolerance of $[Redacted]plus [Redacted]% or $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-02-23): Sufficient Cure Provided At Closing |
02/23/2022 | 1 | A | MA | Primary | Purchase | Final CD evidences Cure | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | |||||||||||||
| 438639165 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-09-19): Accepted as is Reviewer Comment (2022-06-17): EV2-B |
2 | B | MA | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639165 | Credit | Loan Package Documentation | Loan File | Missing Document | Missing Document: Hazard Insurance Policy not provided | The hazard insurance policy in the file is blank with no premium information. | Reviewer Comment (2022-03-02): Received, Clearing. Seller Comment (2022-03-02): The policies for both REO's show an annual premium and there were on file prior to the loan closing. Address [Redacted] =$[Redacted]annual Address [Redacted]. =$[Redacted]annual |
03/02/2022 | 1 | A | MA | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639166 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% CPA letter, third party listing and business license in the file. |
Reviewer Comment (2022-09-19): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-04-07): Updated Seller Comment (2022-04-04): Business verification/license/bank statements/business narrative attached Seller Comment (2022-03-07): Business verification/license/bank statements/business narrative attached |
2 | B | NY | Primary | Purchase | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639173 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Contact Information - Lender | TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on [Redacted] did not disclose the required Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). | Lender Contact Name is not disclosed on page 5 of the final CD provided on [Redacted] | Reviewer Comment (2022-03-14): SitusAMC received Letter of Explanation & Corrected Closing Disclosure. Seller Comment (2022-03-10): Agree - attached is the post consummation CD and letter of explanation to the borrower |
03/14/2022 | 2 | B | TX | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639173 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% The file contains a CPA letter, third party business listing and a business license. |
Reviewer Comment (2022-09-19): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-04-07): Updated Seller Comment (2022-03-29): Disagree - CPA letter reflects [Redacted] Bank statements reflect [Redacted] Business License reflects [Redacted] Business verification (internet search) reflects [Redacted] The CPA letter ties both businesses as one and the same and all documents reflects the same address Seller Comment (2022-03-23): Disagree - CPA letter reflects The [Redacted] Bank statements reflect [Redacted] Business License reflects [Redacted] Business verification (internet search) reflects [Redacted] The CPA letter ties both businesses as one and the same and all documents reflects the same address Seller Comment (2022-03-08): Disagree - CPA letter reflects [Redacted] Bank statements reflect [Redacted] Business license reflects [Redacted] Business verification (internet search) reflects [Redacted] The CPA letter ties both businesses as one and the same and all documents reflect the same address Reviewer Comment (2022-03-04): The QM Bank Statement exceptions are firing due to the lack of additional third-party documentation that evidences the deposits into the bank account were actually income. Bank statement loans without supporting documentation to evidence the deposits into the bank accounts are income would not be considered QM based on concerns that the loan would not meet the consider and verify standard. Note this was previously communicated in the last Client Bulletin that was sent out in March of last year. The Bulletin can be accessed on the Resources tab under [Redacted]Compliance Bulletin [Redacted]. See Section 1.3 on page 3. Buyer Comment (2022-03-03): Cleared - Exception set in error Reviewer Comment (2022-03-03): reopen |
2 | B | TX | Primary | Purchase | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639175 | Property | Property - Appraisal | Appraisal Reconciliation | Property - Appraisal | Appraisal is required to be in name of Lender | - | The appraisal lists the broker and not the lender. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | AZ | Primary | Refinance - Rate/Term | C | B | C | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639175 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Loan designation mismatch with due diligence | Reviewer Comment (2022-04-05): SHQM (APOR) Buyer Comment (2022-03-21): Notes from system for safe harbor: [Redacted] -This loan QM Points and Fees test Not available QM Result is Safe Harbor QM Liability Protection Determination: Safe Harbor. Loan APR of [Redacted]does not exceed the Average Prime Offer Rate (APOR) Threshold of [Redacted]. Loan passing QM with Rate [Redacted]% |
04/05/2022 | 1 | A | AZ | Primary | Refinance - Rate/Term | Lender to provide updated ATR/QM status | C | B | C | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639175 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% A third party verification was provided for the 24 month bank statements, the entity search is dated from [Redacted]. |
Reviewer Comment (2022-09-19): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-04-07): Updated Seller Comment (2022-03-21): [Redacted] month bank statements attached and income calc worksheet with analytics |
2 | B | AZ | Primary | Refinance - Rate/Term | C | B | C | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639175 | Credit | Missing Document | General | Missing Document | Missing Document: Bank Statements - Business not provided | The J[Redacted] bank statement for [Redacted]of [Redacted]was missing. | Reviewer Comment (2022-03-15): Received, Clearing. Seller Comment (2022-03-15): Findings are valid. File is a rate & term refi on the Elite Alternative Income program. 24 months bank statements are required. Attached is the missing statement for a complete 24 months. |
03/15/2022 | 1 | A | AZ | Primary | Refinance - Rate/Term | C | B | C | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639175 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - ___ | [Redacted]months of bank statements are required only [Redacted]months were provided, with [Redacted][Redacted]not found in the file. | Reviewer Comment (2022-03-15): Received, Clearing. Seller Comment (2022-03-15): Findings are valid. File is a rate & term refi on the Elite Alternative Income program. 24 months bank statements are required. Attached is the missing statement for a complete 24 months. Reviewer Comment (2022-03-08): 24 months of bank statements are required only 23 months were provided, with July 2021 not found in the file. Buyer Comment (2022-03-08): The findings are invalid. File is a Non-Agency Alternative program. Program allows borrower to use business banks statements for qualifying income. Borrower provided bank statement for 24 months along with business articles of organization to confirm ownership of business. |
03/15/2022 | 1 | A | AZ | Primary | Refinance - Rate/Term | C | B | C | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639175 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File) | ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing. | The appraisal acknowledgement was not found in the file. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | AZ | Primary | Refinance - Rate/Term | C | B | C | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639148 | Compliance | Compliance | Federal Compliance | Missing Disclosure | Notice of Special Flood Hazard Disclosure Not Provided Timely | FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing. | Notice of Special Flood Hazard Disclosure was provided to, and signed by Borrower on [Redacted] | 2 | B | FL | Second Home | Purchase | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438639148 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Appraisal fee increased from $[Redacted]to $[Redacted]. A cure of $[Redacted]was provided. | Reviewer Comment (2022-02-24): Sufficient Cure Provided At Closing |
02/24/2022 | 1 | A | FL | Second Home | Purchase | Final CD evidences Cure | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639148 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Second Appraisal fee increased from $[Redacted]to $[Redacted]. A cure of $[Redacted]was provided. | Reviewer Comment (2022-02-24): Sufficient Cure Provided At Closing |
02/24/2022 | 1 | A | FL | Second Home | Purchase | Final CD evidences Cure | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639148 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Transfer Tax increased from $[Redacted]to $[Redacted]. A cure of $[Redacted] was provided. The LE listed the county tax as Transfer Tax. | Reviewer Comment (2022-02-24): Sufficient Cure Provided At Closing |
02/24/2022 | 1 | A | FL | Second Home | Purchase | Final CD evidences Cure | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639186 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | AUS Findings: All conditions were not met | The application indicates the borrower is an irrevocable trust and this is not allowed per guidelines. The borrowers are listed as individuals and the security instrument shows the title vested as only the trustees. | The representative FICO score exceeds the guideline minimum by at least 40 points. The qualifying DTI on the loan is at least 10% less than the guideline maximum. The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-06-22): Post funding exception approval, waived with compensating factors Reviewer Comment (2022-06-21): Post Closing Exceptions need to come from the buyer [Redacted]. Seller Comment (2022-06-21): Please see attached exceptional approval for this loan. |
06/22/2022 | 2 | B | FL | Investment | Purchase | C | B | C | B | A | A | C | A | N/A | N/A | No | ||||||||||||
| 438639186 | Property | Appraisal Reconciliation | Value Discrepancy | Appraisal Reconciliation | Loan is to be securitized. Highest level secondary valuation does not support the value used to qualify.; Sec ID: 7 | The AVM provided shows an estimated value of $[Redacted] and the 1004 shows an appraised value of $[Redacted]. | Reviewer Comment (2022-03-29): Received, Clearing. |
03/29/2022 | 1 | A | FL | Investment | Purchase | C | B | C | B | A | A | C | A | N/A | N/A | No | ||||||||||||||
| 438639186 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - ___ | The mortgage statement and HOA verification were not provided for the borrowers primary. | Reviewer Comment (2022-03-17): Not required, cleared Seller Comment (2022-03-17): [Redacted] is borrower's primary property. Per attached guideline in yellow highlighted, borrower must fully complete all sections of schedule of real estate owned on 1003 are completed. No supporting document will be required, like mortgage statement and HOA. |
03/17/2022 | 1 | A | FL | Investment | Purchase | C | B | C | B | A | A | C | A | N/A | N/A | No | |||||||||||||
| 438639196 | Credit | Credit | Credit Documentation | Guideline | Missing Document: Asset not provided | As noted per lending guidelines, verification from business's Accountant/CPA/Tax Preparer must verify that business will not be adversely impacted by borrower's withdraw from business account when funds are used. Missing this letter confirmation. | Reviewer Comment (2022-03-10): Received, Clearing. Seller Comment (2022-03-10): [Redacted] Letter attached |
03/10/2022 | 1 | A | FL | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639195 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - | The statement for the HELOC and HOA verification on the borrowers primary was not provided | Reviewer Comment (2022-03-21): Received, Clearing. Seller Comment (2022-03-21): Per attached guideline in yellow highlighted, no supporting documentation will be required (like mortgage statement and HOA bill) for REO. |
03/21/2022 | 1 | A | MI | Investment | Refinance - Cash-out - Home Improvement | C | A | C | A | A | A | A | A | N/A | N/A | No | |||||||||||||
| 438639200 | Property | Property - Appraisal | Appraisal Documentation | Property - Appraisal | Loan is to be securitized. Appraisal is missing.; Sec ID: 1 | The file is missing a copy of the fuil appraisal. | Reviewer Comment (2022-03-17): Appraisal received Seller Comment (2022-03-17): Appraisal attached |
03/17/2022 | 1 | A | NY | Investment | Purchase | D | D | C | A | A | A | D | D | N/A | N/A | No | ||||||||||||||
| 438639200 | Credit | Loan Package Documentation | Closing / Title | Loan Package Documentation | Taxes: Subject property taxes not documented | The file is missing verification of the annual school tax used to qualify in the amount of $[Redacted]. | Reviewer Comment (2022-03-10): Received, Clearing. Seller Comment (2022-03-10): Tax Cert attached |
03/10/2022 | 1 | A | NY | Investment | Purchase | D | D | C | A | A | A | D | D | N/A | N/A | No | ||||||||||||||
| 438639200 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected. | The file does not contain a full appraisal report but does contain a 442 Completion report. | Reviewer Comment (2022-03-17): Appraisal received, cleared Seller Comment (2022-03-17): Appraisal attached |
03/17/2022 | 1 | A | NY | Investment | Purchase | D | D | C | A | A | A | D | D | N/A | N/A | No | ||||||||||||||
| 438639200 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - | The file is missing either a copy of the lease agreements or an Aperating Expense report to verify rents used to qualify. | Reviewer Comment (2022-03-18): Received, Clearing. Seller Comment (2022-03-18): Attached Appraisal page #[Redacted] shows the operating income statement. Per attached1003 and 1008, they reflect rental of[Redacted]/month qualifying rent. |
03/18/2022 | 1 | A | NY | Investment | Purchase | D | D | C | A | A | A | D | D | N/A | N/A | No | |||||||||||||
| 438639200 | Property | Property - Appraisal | Appraisal Documentation | Property - Appraisal | Loan is to be securitized. AVM supports value. Vendor/FSD do not meet Fitch criteria.; Sec ID: 10 | Note Date: ___; Lien Position: ___ | 2 | D | NY | Investment | Purchase | D | D | C | A | A | A | D | D | N/A | N/A | No | ||||||||||||||||
| 438639189 | Compliance | Loan Package Documentation | Closing / Title | Missing, Incorrect, or Incomplete HUD-1 | Missing Document: HUD-1 Addendum not provided | The Hud addendum was not provided and the fee totals for section [Redacted]are missing. The closing statement section [Redacted]totals do not match the HUD-1. | Reviewer Comment (2022-03-09): [Redacted] addendum received Seller Comment (2022-03-09): See attached. Addendum provided along with its itemized break-down for the [Redacted] total value. |
03/09/2022 | 1 | A | CA | Investment | Purchase | D | A | A | A | D | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639188 | Credit | Legal / Regulatory / Compliance | Title / Lien Defect | Title | Title Policy is Preliminary or Commitment, and not a Final Title Policy. | Lender to provide a copy of the final title policy. | Reviewer Comment (2022-03-11): Received, Clearing. |
03/11/2022 | 1 | A | CA | Investment | Purchase | D | B | D | A | C | B | D | A | N/A | N/A | No | ||||||||||||||
| 438639188 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Mismatch of data related to Occupancy. | - | The borrower is a foreign national and states on the application that they will occupy the property and owner occupancy is not allowed by the guidelines. The occupancy certificate states that the property is for investment purposes. The lender to provide a copy of the CPA letter providing detail of non-United States REO. | Reviewer Comment (2022-03-14): Received, Clearing. Reviewer Comment (2022-03-11): Corrected 1003 with declaration section 5 indicating property is not for [Redacted] occupancy and section 4 stating it is an [Redacted] purpose must be fully executed by the borrower and originator. Seller Comment (2022-03-11): Correct as a [Redacted] type property. Updated 1003 attached. |
03/14/2022 | 1 | A | CA | Investment | Purchase | D | B | D | A | C | B | D | A | N/A | N/A | No | |||||||||||||
| 438639188 | Credit | Loan Package Documentation | Application / Processing | Missing Document | Missing Document: Fraud Report not provided | Lender to provide a copy of the fraud report. | Reviewer Comment (2022-03-11): Received, Clearing. Seller Comment (2022-03-10): Fraud report and [Redacted] comments. |
03/11/2022 | 1 | A | CA | Investment | Purchase | D | B | D | A | C | B | D | A | N/A | N/A | No | ||||||||||||||
| 438639188 | Compliance | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Missing Lender's Initial 1003 | Lender to provide a copy of the initial application. | Reviewer Comment (2022-03-11): Received, Clearing. Seller Comment (2022-03-11): Initial 1003 attached |
03/11/2022 | 1 | A | CA | Investment | Purchase | D | B | D | A | C | B | D | A | N/A | N/A | No | ||||||||||||||
| 438639188 | Credit | Credit | Credit Documentation | Credit | No evidence of fraud report in file | - | Lender to provide a copy of the fraud report. | Reviewer Comment (2022-03-11): Received, Clearing. Seller Comment (2022-03-11): Fraud Report attached |
03/11/2022 | 1 | A | CA | Investment | Purchase | D | B | D | A | C | B | D | A | N/A | N/A | No | |||||||||||||
| 438639188 | Property | Property - Appraisal | Appraisal Documentation | Property - Appraisal | Loan is to be securitized. Secondary valuation is missing.; Sec ID: 2 | Lender to provide a copy of the secondary valuation. | Reviewer Comment (2022-03-29): Received, Clearing. |
03/29/2022 | 1 | A | CA | Investment | Purchase | D | B | D | A | C | B | D | A | N/A | N/A | No | ||||||||||||||
| 438639188 | Credit | Title | Document Error | Title | There is no dollar amount noted on the title policy. | Lender to provide a copy of the final title policy. | Reviewer Comment (2022-03-11): Received, Clearing. Seller Comment (2022-03-11): ALTA attached |
03/11/2022 | 1 | A | CA | Investment | Purchase | D | B | D | A | C | B | D | A | N/A | N/A | No | ||||||||||||||
| 438639188 | Credit | Missing Document | General | Missing Document | Missing Document: Official Check not provided | Lender to provide evidence of the earnest money deposit. | Reviewer Comment (2022-03-11): Received, Clearing. Seller Comment (2022-03-11): EMD attached |
03/11/2022 | 1 | A | CA | Investment | Purchase | D | B | D | A | C | B | D | A | N/A | N/A | No | ||||||||||||||
| 438639188 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Missing | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Receive a Copy" appraisal disclosure to consumer. | Lender to provide a copy of the Right to Receive Appraisal disclosure. | 2 | B | CA | Investment | Purchase | D | B | D | A | C | B | D | A | N/A | N/A | No | |||||||||||||||
| 438639188 | Credit | Insurance | Insurance Documentation | Insurance | Missing Document: Hazard Dec Page not provided | Lender to provide master insurance policy for project - not in file. | Reviewer Comment (2022-03-11): Received, Clearing. Seller Comment (2022-03-11): Master Policy attached |
03/11/2022 | 1 | A | CA | Investment | Purchase | D | B | D | A | C | B | D | A | N/A | N/A | No | ||||||||||||||
| 438639188 | Credit | Missing Document | General | Missing Document | Missing Document: Bank Statements - Personal not provided | Per guides all funds have to be transferred to US depository account - bank statements were all from Citibank in XXXX. Lender to provide proof of transfer to US depository account prior to closing. | Reviewer Comment (2022-03-15): Received, Clearing. Seller Comment (2022-03-15): Bank Statement, Conversion to [Redacted], and [Redacted] letter for verification attached. |
03/15/2022 | 1 | A | CA | Investment | Purchase | D | B | D | A | C | B | D | A | N/A | N/A | No | ||||||||||||||
| 438639188 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | Lender to provide source of $785876.96 deposit to title on 12/2/21 (D0055) reflected as credit on HUD - bank account in XXXX never showed sufficient funds to support the transfer of this amount. Lender to also source deposits of $116250 on 10/29/21 and $30000 on 11/24/21 - source bank statements are in a foreign language and no translation was in file. | Reviewer Comment (2022-03-14): Received, Clearing. Seller Comment (2022-03-14): Per wire notice and Title company notice, funds was transferred from [Redacted]. And Borrower is the [Redacted] of this company as per letter from[Redacted]. First page of Borrower's [Redacted] account statement shows current balance in [Redacted] |
03/14/2022 | 1 | A | CA | Investment | Purchase | D | B | D | A | C | B | D | A | N/A | N/A | No | ||||||||||||||
| 438639188 | Credit | Loan Package Documentation | Application / Processing | Missing Document | Missing Document: Other not provided | Borrower Statement of Business Purpose is missing from the file | Reviewer Comment (2022-03-11): Received, Clearing. Seller Comment (2022-03-11): Attached. |
03/11/2022 | 1 | A | CA | Investment | Purchase | D | B | D | A | C | B | D | A | N/A | N/A | No | ||||||||||||||
| 438639188 | Compliance | Compliance | Federal Compliance | Missing Required Data (other than HUD-1 or Note) | Disparity in Occupancy - High Cost as Primary | The mortgage loan file contains documenting evidence the consumer intends to occupy the subject property as their primary residence. (Compliance testing performed based on the Occupancy Type of Investment). If tested as primary residence, loan exceeds one or more high cost thresholds. | Reviewer Comment (2022-03-11): Received, Clearing. Seller Comment (2022-03-11): Updated 1003 provided, borrower's certification of business purpose of [Redacted] property, and disclosure notices provided. Correct as an [Redacted]. |
03/11/2022 | 1 | A | CA | Investment | Purchase | D | B | D | A | C | B | D | A | N/A | N/A | No | ||||||||||||||
| 438639197 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - ___ ___ ___ ___ ___ ___ |
Lender to provide: 1) [Redacted], proof of HOI; 2) for [Redacted], proof of HOI; 3) for [Redacted], proof of HOI; 4) for [Redacted], proof of HOI; 5) for [Redacted], proof of HOI; 6) for [Redacted], proof of HOI. | Reviewer Comment (2022-03-22): Received, Clearing. Seller Comment (2022-03-22): Per attached guideline in yellow highlighted, no supporting documentation will be required (like mortgage statement, real estate taxes, Insurance and HOA bills) for REO. |
03/22/2022 | 1 | A | FL | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | A | A | N/A | N/A | No | |||||||||||||
| 438639203 | Credit | Missing Document | General | Missing Document | Missing Document: Cancelled Check(s) not provided | Earnest money deposit in the amount of $[Redacted]was not sourced | Reviewer Comment (2022-03-10): Received, Clearing. Seller Comment (2022-03-10): EMD attached |
03/10/2022 | 1 | A | CA | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639199 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - ___ ___ ___ |
Lender to provide: 1) for [redacted] proof of HOI payment and lease agreement; 2) for [redacted], proof of HOI and lease agreement; 3) for [redacted], proof of HOI. | Reviewer Comment (2022-03-14): HOI provided Seller Comment (2022-03-14): Per attached guideline in highlight, borrower must fully complete all sections of schedule of Real Estate Owned on 1003. No supporting documentation will be required, like, mortgage statements, insurance. The information stated on signed 1003 will serve as verification of income and expenses of properties. To evidence the property [redacted] is no mortgagee, please see attached. |
03/14/2022 | 1 | A | NY | Investment | Purchase | D | A | D | A | A | A | D | A | N/A | N/A | No | |||||||||||||
| 438639199 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Guarantor Agreement not provided | Per documents in file the LLC has two managers. No guarantor agreement was in file. | Reviewer Comment (2022-03-14): Received, Clearing. Seller Comment (2022-03-14): Guaranty of Payment attached. [Redacted] Letter reflecting borrower as [Redacted] owner attached. |
03/14/2022 | 1 | A | NY | Investment | Purchase | D | A | D | A | A | A | D | A | N/A | N/A | No | ||||||||||||||
| 438639199 | Property | Property - Appraisal | Appraisal Documentation | Property - Appraisal | Loan is to be securitized. Secondary valuation is missing.; Sec ID: 2 | Lender to provide secondary valuation. | Reviewer Comment (2022-03-29): Received, Clearing. |
03/29/2022 | 1 | A | NY | Investment | Purchase | D | A | D | A | A | A | D | A | N/A | N/A | No | ||||||||||||||
| 438639199 | Credit | Insurance | Insurance Documentation | Insurance | Missing Document: Hazard Dec Page not provided | Missing blanket cert for condominium complex - lender to provide. | Reviewer Comment (2022-03-11): Received, Clearing. Seller Comment (2022-03-11): Master Policy attached |
03/11/2022 | 1 | A | NY | Investment | Purchase | D | A | D | A | A | A | D | A | N/A | N/A | No | ||||||||||||||
| 438639190 | Compliance | Compliance | State Compliance | State Defect | New Jersey Prepayment Penalty | New Jersey Prepayment Penalty: No prepayment penalties are permissible in the state of New Jersey. Prepay language states prepay will not exceed maximum permitted by applicable law. | Loan has prepayment penalty. | 2 | B | NJ | Investment | Refinance - Rate/Term | C | B | C | A | B | B | A | A | N/A | N/A | No | |||||||||||||||
| 438639190 | Credit | Loan Package Documentation | Application / Processing | Insurance | Missing Document: Flood Certificate not provided | Lender to provide flood certificate. | Reviewer Comment (2022-03-10): Flood Cert received as trailing Seller Comment (2022-03-10): Flood Cert attached |
03/10/2022 | 1 | A | NJ | Investment | Refinance - Rate/Term | C | B | C | A | B | B | A | A | N/A | N/A | No | ||||||||||||||
| 438639190 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - ___ | Provide proof borrower owns the property free-and-clear | Reviewer Comment (2022-03-21): Received, Clearing. Seller Comment (2022-03-21): Per fraud report page#[Redacted], it's [Redacted] loan amount for the property [Redacted]. |
03/21/2022 | 1 | A | NJ | Investment | Refinance - Rate/Term | C | B | C | A | B | B | A | A | N/A | N/A | No | |||||||||||||
| 438639202 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - ___ | Lender to provide proof of taxes/insurance on [Redacted] property (not in file). | Reviewer Comment (2022-03-21): requirements met Seller Comment (2022-03-21): Per attached guideline in yellow highlighted, no supporting documentation will be required (like mortgage statement, real estate taxes and HOA bills) for REO. |
03/21/2022 | 1 | A | NY | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | |||||||||||||
| 438639202 | Credit | Hazard Insurance | Document Error | Hazard Insurance | Hazard Insurance policy does not list Lender or Servicer and its successors and assigns, per guideline requirements. | HOI cert does not show the ISAOA/ATIMA for the lender. Lender to provide corrected HOI cert. | Reviewer Comment (2022-03-15): Received, Clearing. Seller Comment (2022-03-15): HOI attached |
03/15/2022 | 1 | A | NY | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639194 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | HOI coverage is insufficient by $[Redacted]. Provide verification of policy with sufficient coverage OR provide copy of insurer's replacement cost estimate supporting current coverage amount. | Reviewer Comment (2022-04-21): Received, Clearing. Seller Comment (2022-04-21): RCE attached Reviewer Comment (2022-03-10): Exception from buyer is required if anything less than stated below. Seller Comment (2022-03-10): Please see attached guideline. As long as the verbiage is listed, we accept this. Reviewer Comment (2022-03-10): We require coverage up to replacement cost which is currently from appraisal up to the loan amount. Without [Redacted] or increased [Redacted] exception will remain. Seller Comment (2022-03-10): HOI listed [Redacted]. As long as HOI has [Redacted] verbiage listed, we accept this. |
04/21/2022 | 1 | A | NY | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639194 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | The file is missing verification of insurance for the additional financed investment property owned by the borrower. | Reviewer Comment (2022-03-21): meets guidelines Seller Comment (2022-03-21): Per attached guidelines in yellow highlighted, no supporting documentation will be required (like mortgage statement, real estate taxes, Insurance & HOA bills) for REO. Per fraud report, the [Redacted] is owned by borrower with [Redacted] loan amount. |
03/21/2022 | 1 | A | NY | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639182 | Compliance | Compliance | Federal Compliance | Flood | Flood Insurance Policy Missing | The subject property is in a flood zone, evidence of flood insurance was not provided/obtained. Failure to obtain and disclose required insurance may result in additional federal and/or state compliance violations. | Flood Insurance policy missing in file. | Reviewer Comment (2022-03-10): Received, Clearing. Seller Comment (2022-03-10): Master Policy includes [Redacted] |
03/10/2022 | 1 | A | FL | Investment | Purchase | C | A | C | A | C | A | A | A | N/A | N/A | No | |||||||||||||
| 438639182 | Credit | Insurance | Insurance Documentation | Insurance | Missing Document: Flood Insurance Policy not provided | Reviewer Comment (2022-03-09): Received, Clearing. Seller Comment (2022-03-09): Flood included in the master insurance provided here. |
03/09/2022 | 1 | A | FL | Investment | Purchase | C | A | C | A | C | A | A | A | N/A | N/A | No | |||||||||||||||
| 438639181 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | Lender to provide CPA letter for business. Noting borrower appears to run a tax preparation service. | Reviewer Comment (2022-03-25): Received, Clearing. Seller Comment (2022-03-25): CPA letter attached |
03/25/2022 | 1 | A | FL | Investment | Refinance - Rate/Term | C | A | C | A | A | A | A | A | N/A | N/A | No | |||||||||||||
| 438639181 | Credit | Property - Appraisal | General Appraisal Requirements | Property - Appraisal | Subject is a refinance and property is listed for sale. | - | Per appraisal the subject is under contract for $[Redacted]. | Reviewer Comment (2022-04-04): Received, Clearing. Seller Comment (2022-04-04): Attached revised appraisal and lease agreement. |
04/04/2022 | 1 | A | FL | Investment | Refinance - Rate/Term | C | A | C | A | A | A | A | A | N/A | N/A | No | |||||||||||||
| 438639181 | Credit | Property - Appraisal | Property Eligibility - Site and Utilities | Property - Appraisal | Subject property has environmental problems noted by appraiser or visible in the photos | - | [Redacted] Bedrooms in the garage without emergency exit. Use of property appears to be commercial, not residential. | Reviewer Comment (2022-04-04): Received, Clearing. Seller Comment (2022-04-04): Attached are the revised appraisal and lease agreement, and something regarding the use of a home for elder care. It is NOT considered [Redacted]. |
04/04/2022 | 1 | A | FL | Investment | Refinance - Rate/Term | C | A | C | A | A | A | A | A | N/A | N/A | No | |||||||||||||
| 438639181 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Loan originated with subject property as residential rental but the lease is to "Century Assisted Living Facility," which is listed as a for-profit company with Florida Secretary of State, and shows as owned by the borrower. Several online listings for the company appear through Google search. Appraisal shows property is being used as an assisted living facility as well, but appraiser states subject is owner occupied. Unclear if county zoning laws would allow the business to be run out of the subject. Based on review, subject is being utilized as a commercial property, not a residential rental. |
Reviewer Comment (2022-04-04): Received, Clearing. Seller Comment (2022-04-04): Attached are the revised appraisal and lease agreement, And something found regarding the use of a home for elder care. It is NOT considered [Redacted]. |
04/04/2022 | 1 | A | FL | Investment | Refinance - Rate/Term | C | A | C | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639181 | Credit | Borrower and Mortgage Eligibility | Mortgage / Program Eligibility | Borrower and Mortgage Eligibility | Questionable Occupancy: Valuation occupancy differs from occupancy on loan approval. | Appraisal shows subject as owner occupied, but loan was originated as investment. | Reviewer Comment (2022-04-04): Received, Clearing. Seller Comment (2022-04-04): Please see revised appraisal and lease agreement. |
04/04/2022 | 1 | A | FL | Investment | Refinance - Rate/Term | C | A | C | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639193 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Mismatch of data related to Occupancy. | - | Final 1003 indicated borrower will occupy subject as primary residence - lender to provide corrected final 1003. | Reviewer Comment (2022-03-11): Received, Clearing. Seller Comment (2022-03-11): The loan was underwritten and closed as an [Redacted]. Please see updated 1003. |
03/11/2022 | 1 | A | WA | Investment | Purchase | C | A | C | A | C | A | A | A | N/A | N/A | No | |||||||||||||
| 438639193 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - ___ | Missing evidence primary residence is owned free-and-clear | Reviewer Comment (2022-03-21): Received, Clearing. Seller Comment (2022-03-21): per fraud report page #[Redacted], it is [Redacted] loan amount for the property [Redacted]. |
03/21/2022 | 1 | A | WA | Investment | Purchase | C | A | C | A | C | A | A | A | N/A | N/A | No | |||||||||||||
| 438639193 | Compliance | Compliance | Federal Compliance | Missing Required Data (other than HUD-1 or Note) | Disparity in Occupancy - High Cost and Higher Priced as Primary | The mortgage loan file contains documenting evidence the consumer intends to occupy the subject property as their primary residence. (Compliance testing performed based on the Occupancy Type of Investment). If tested as primary residence, loan exceeds one or more high cost and one or more HPML thresholds. Additional compliance testing required to determine if loan would be a compliant or non-compliant HPML. | Reviewer Comment (2022-03-11): Received, Clearing. Seller Comment (2022-03-11): Updated 1003 provided, borrower's certification of business purpose of [Redacted], and disclosure notices provided. Correct as an [Redacted]. |
03/11/2022 | 1 | A | WA | Investment | Purchase | C | A | C | A | C | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639193 | Compliance | Compliance | Federal Compliance | Missing Required Data (other than HUD-1 or Note) | Disparity in Occupancy - High Cost and Higher Priced as Primary | The mortgage loan file contains documenting evidence the consumer intends to occupy the subject property as their primary residence. (Compliance testing performed based on the Occupancy Type of Investment). If tested as primary residence, loan exceeds one or more high cost and one or more HPML thresholds. Additional compliance testing required to determine if loan would be a compliant or non-compliant HPML. | Reviewer Comment (2022-03-22): Received, Clearing. |
03/22/2022 | 1 | A | WA | Investment | Purchase | C | A | C | A | C | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639192 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - ___ | Missing evidence S[Redacted] property is owned free-and-clear | Reviewer Comment (2022-03-09): Received, Clearing. Seller Comment (2022-03-09): Attached insurance indicates no mortgagee clause. On page #[Redacted], there is no mortgagee on it. Additional, per processing cert, confirmed with [Redacted], there is is no mortgagee clause for the property located at [Redacted]. |
03/09/2022 | 1 | A | WA | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | |||||||||||||
| 438639204 | Credit | Hazard Insurance | Insufficient Coverage | Hazard Insurance | The Hazard Insurance Policy Effective Date is after closing. | Hazard Insurance Policy Effective Date ___, Disbursement Date: ___ | The homeowner's insurance declarations page in the file verified an effective date of [Redacted], which is after the consummation date of [Redacted]. Provide a revised homeowner's insurance declaration page or policy verifying coverage in effect at or prior to consummation. | Reviewer Comment (2022-03-14): Received, Clearing. Seller Comment (2022-03-14): It's [Redacted]. Borrower has insurance effective date from [Redacted] and renew insurance effective from [Redacted]. So the insurance covers the note date of [Redacted]. Reviewer Comment (2022-03-11): The homeowner's insurance declarations page in the file verified an effective date of [Redacted], which is after the consummation date of [Redacted]. Seller Comment (2022-03-10): HOI effective date covers the closing date. |
03/14/2022 | 1 | A | NY | Investment | Refinance - Cash-out - Other | C | B | C | A | A | A | B | B | N/A | N/A | No | |||||||||||||
| 438639204 | Property | Appraisal Reconciliation | Value Discrepancy | Appraisal Reconciliation | Loan is to be securitized. Highest level secondary valuation supports the value. There is a lower level tertiary product that does not support the qualifying value.; Sec ID: 22 | Note Date: ___; Lien Position: ___ | Tertiary product ClearAVM doc ID 0094 has an estimated value of XXXX, which does not support the appraised value. | 2 | B | NY | Investment | Refinance - Cash-out - Other | C | B | C | A | A | A | B | B | N/A | N/A | No | |||||||||||||||
| 438639204 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Verified assets in the file [Redacted]months are insufficient to meet reserves requirement [Redacted]months for the subject and primary residence. Final 1003 reflects $39,905.28 verified, however, the final 1008 is stating required reserves to be $[Redacted]. | Reviewer Comment (2022-03-14): Received, Clearing. Seller Comment (2022-03-14): It's [Redacted]. Per attached settlement statement, total [Redacted] disbursement to borrower, which is sufficient to cover [Redacted] months reserves [Redacted]. |
03/14/2022 | 1 | A | NY | Investment | Refinance - Cash-out - Other | C | B | C | A | A | A | B | B | N/A | N/A | No | ||||||||||||||
| 438639204 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | Mortgage statement showing PITI, tax and insurance verification is not in the file. | Reviewer Comment (2022-03-14): Received, Clearing. Seller Comment (2022-03-14): Per attached guideline, no supporting documentation will be required, like real estate taxes and insurance. The information stated on signed 1003 will serve as verification of income and expense of the properties. |
03/14/2022 | 1 | A | NY | Investment | Refinance - Cash-out - Other | C | B | C | A | A | A | B | B | N/A | N/A | No | ||||||||||||||
| 438639201 | Credit | Loan Package Documentation | Application / Processing | Insurance | Missing Document: Flood Certificate not provided | Reviewer Comment (2022-03-10): Received, Clearing. Seller Comment (2022-03-10): Flood Cert attached |
03/10/2022 | 1 | A | CA | Investment | Refinance - Cash-out - Other | C | B | C | A | B | B | A | A | N/A | N/A | No | |||||||||||||||
| 438639201 | Credit | Loan Package Documentation | Application / Processing | Missing Document | Missing Document: Fraud Report not provided | Reviewer Comment (2022-03-10): [Redacted] Seller Comment (2022-03-10): Fraud Report attached |
03/10/2022 | 1 | A | CA | Investment | Refinance - Cash-out - Other | C | B | C | A | B | B | A | A | N/A | N/A | No | |||||||||||||||
| 438639201 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - ___ ___ |
Reviewer Comment (2022-03-21): Received, Clearing. Seller Comment (2022-03-21): Per attached guideline in yellow highlighted, no supporting documentation will be required for REO. The information stated on signed 1003 will serve verification of income and expense of properties. |
03/21/2022 | 1 | A | CA | Investment | Refinance - Cash-out - Other | C | B | C | A | B | B | A | A | N/A | N/A | No | ||||||||||||||
| 438639201 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | Unable to determine if the borrower signed a valuation receipt acknowledgment due to missing information. | Unable to determine if the borrower signed a valuation receipt acknowledgment due to missing information. | 2 | B | CA | Investment | Refinance - Cash-out - Other | C | B | C | A | B | B | A | A | N/A | N/A | No | |||||||||||||||
| 438639206 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | Lender to provide Social Security award letters for B1/B2. | Reviewer Comment (2022-03-18): Received, Clearing. Reviewer Comment (2022-03-18): Were still at [Redacted] for DTI based on the income and debts provided. Seller Comment (2022-03-18): We didn't use the [Redacted] to qualify the borrowers. The DTI is still within guidelines at [Redacted]. Please see attached updated 1003. |
03/18/2022 | 1 | A | NY | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | A | A | N/A | N/A | No | |||||||||||||
| 438639206 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: Investor qualifying total debt ratio discrepancy. | . | Reviewer Comment (2022-04-06): Received updated income, Clearing exception. Seller Comment (2022-04-06): Please see attached revised 1003 , 1008 and Social Security award letters for both borrowers. |
04/06/2022 | 1 | A | NY | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639191 | Credit | Credit | Credit Documentation | Guideline | Missing Document: Asset not provided | Lender to provide closing disclosure for primary residence refinance reflecting funds to close per final 1003 and approval. | Reviewer Comment (2022-03-15): Received, Clearing. Seller Comment (2022-03-15): Final CD attached. |
03/15/2022 | 1 | A | NV | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639191 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - ___ | Lender to provide: 1) for [Redacted], proof of PITI after refi; 2) for[Redacted], proof of HOI; 3) for [Redacted]Rainbow, proof of HOI and HOA, and lease agreement, and lease agreement; 4) for [Redacted], proof of HOI/HOA and lease agreement; 5) for [Redacted], proof of HOI/HOA; 6) for [Redacted], proof of PITI and lease agreement for $[Redacted]/mo. | Reviewer Comment (2022-03-22): Received, Clearing. Seller Comment (2022-03-22): Per attached guideline in yellow highlighted, no supporting documentation will be required (like mortgage statement, real estate taxes, Insurance & HOA bills) for REO. |
03/22/2022 | 1 | A | NV | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | |||||||||||||
| 438639205 | Property | Property - Appraisal | Appraisal Documentation | Property - Appraisal | Loan is to be securitized. AVM supports value. Vendor/FSD do not meet Fitch criteria.; Sec ID: 10 | Reviewer Comment (2022-05-02): CDA received, Clearing. |
05/02/2022 | 1 | A | NY | Investment | Purchase | D | A | C | A | A | A | D | A | N/A | N/A | No | |||||||||||||||
| 438639205 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Mismatch of data related to Occupancy. | - Occupancy: ___; Declarations/Will borrower occupy: ___ | The 1004 provided shows the subject property is owner occupied, the occupancy certification shows the property as an investment. | Reviewer Comment (2022-03-24): Received, Clearing. Seller Comment (2022-03-24): It's [Redacted] transaction. The occupancy on appraisal is reflecting the current occupancy status from seller. Our borrower/buyer is purchasing this subject property as [Redacted] residence from [Redacted] primary property. there is no issue or purpose of this loan at all. |
03/24/2022 | 1 | A | NY | Investment | Purchase | D | A | C | A | A | A | D | A | N/A | N/A | No | |||||||||||||
| 438639205 | Credit | Guideline | Guideline Issue | Guideline | Borrower does not have the minimum active tradelines per guidelines. | The guidelines require [Redacted]active tradelines, the borrower and co-borrower have [Redacted] active tradeline each and their primary mortgage tradeline. | Reviewer Comment (2022-03-11): Received, Clearing. Seller Comment (2022-03-11): We accept active, inactive, or closed tradelines as long as they reflect a [Redacted] month period. |
03/11/2022 | 1 | A | NY | Investment | Purchase | D | A | C | A | A | A | D | A | N/A | N/A | No | ||||||||||||||
| 438639207 | Credit | Credit | Credit Eligibility | Credit | Active Tradelines is less than 3 | - ___ open Tradelines which is less than the minimum required by guidelines. | The borrower has [Redacted] active tradelines and only 1 tradeline has a [Redacted]month history, [Redacted] active tradelines are required per the guidelines if a [Redacted]month active history was not provided for [Redacted] tradelines. | The Debt Service Coverage Ratio (DSCR) is greater than the guideline requirement by .50. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. |
SitusAMC SitusAMC |
Reviewer Comment (2022-03-16): Pre funding exception provided. Seller Comment (2022-03-16): Disagree - exception approved |
03/16/2022 | 2 | B | TX | Investment | Refinance - Cash-out - Other | C | B | C | B | A | A | N/A | No | ||||||||||||||
| 438639210 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Borrower was not provided with a COC | Reviewer Comment (2022-04-01): SitusAMC received valid COC and CD dated [Redacted]. Seller Comment (2022-03-30): Review: [Redacted] COC CD was issued for Loan Amount increased, thus Discount Points adjusted to reflect. See attached COC CD and [Redacted]. |
04/01/2022 | 1 | A | CA | Primary | Refinance - Limited Cash-out GSE | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | A | A | A | C | A | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438639210 | Compliance | Compliance | Federal Compliance | TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form | TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date | Truth in Lending Act: Subject loan transaction disbursed on [Redacted], prior to three (3) business days from transaction date of [Redacted]. | Loan was disbursed prior to midnight of third business day after consummation. Lender to re-open recession, provide copy of new right to cancel form, copy of letter of explanation sent to borrower, and proof of delivery. Note: This exception will not be cleared until expiration of new rescission period. | Reviewer Comment (2022-04-20): Received, cleared Seller Comment (2022-04-20): Final CD and final SS Seller Comment (2022-04-20): signed final SS Reviewer Comment (2022-03-31): Received estimated statement statement. Provide final signed settlement statement verifying loan disbursed on [Redacted] in order to cure. Seller Comment (2022-03-31): Disagree - uploaded Settlement Statement and PCCD provided from closing agent has the correct Disbursement Date of [Redacted] |
04/20/2022 | 1 | A | CA | Primary | Refinance - Limited Cash-out GSE | TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form | C | A | A | A | C | A | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438639210 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Loan Estimate Timing Electronically Provided | TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated [Redacted] was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations. | LE was electronically provided to the borrower on [Redacted] without E-Consent | Reviewer Comment (2022-04-06): [Redacted] received document stating it was send within time frame. Seller Comment (2022-04-04): Disagree - uploaded [Redacted] Reviewer Comment (2022-04-01): [Redacted] The loan application date was [Redacted]. The consumer went through the E-Consent process on [Redacted] and acknowledged the receipt of the LE on [Redacted]. In the event the consumer had not provided E-Consent by [Redacted], then the lender should have sent the consumer the Loan Estimate through another means to comply with the [Redacted] day [Redacted] timing requirement. Proof of the [Redacted] being sent alternative method is required to Clear. Seller Comment (2022-03-30): Review: Initial Disclosure Package was manually fulfilled on [Redacted] which was within [Redacted] days of application date. See attached signed Initial [Redacted] and [Redacted]. |
04/06/2022 | 1 | A | CA | Primary | Refinance - Limited Cash-out GSE | C | A | A | A | C | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438639209 | Property | Property - Appraisal | Appraisal Documentation | Property - Appraisal | Loan is to be securitized. AVM provided is invalid. The FSD is greater than 0.2.; Sec ID: 12 | Need secondary qualifying valuation. | Reviewer Comment (2022-06-20): Received, Clearing. |
06/20/2022 | 1 | A | MD | Primary | Refinance - Cash-out - Other | A | A | A | A | A | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438639208 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Originator Compensation. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | No valid change in circumstance in file. | Reviewer Comment (2022-03-22): "[Redacted]" received valid COC in order to clear this exception. Seller Comment (2022-03-21): Disagree - uploaded [Redacted] email requested [Redacted] to flip from [Redacted] along with COC CD and [Redacted] cert |
03/22/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | A | C | A | C | A | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438639208 | Credit | Income / Employment | Income Documentation | Income / Employment | The verification of employment is required and was not found in file. | - | Reviewer Comment (2022-03-24): Received, Clearing. Seller Comment (2022-03-24): We have attached the prior [Redacted] to cure the finding below. |
03/24/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | A | C | A | C | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438639211 | Credit | Hazard Insurance | Document Error | Hazard Insurance | Hazard Insurance policy does not list Lender or Servicer and its successors and assigns, per guideline requirements. | HOI policy provide reflects incorrect mortgagee clause. Lender reflected is not lender on Note. Lender to provide updated policy reflecting correct lender. | Reviewer Comment (2022-03-16): Received, Clearing. Seller Comment (2022-03-16): Exception approved. |
03/16/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | A | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639211 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Bank Statement Loan | Reviewer Comment (2022-04-06): [Redacted] |
04/06/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM status | C | B | C | A | A | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639211 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or [Redacted]%). | Reviewer Comment (2022-03-29): Bonafide points |
03/29/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | A | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639211 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-07-08): Accepted as is Reviewer Comment (2022-06-17): EV2-B |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | A | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639212 | Credit | System | General | Appraisal Reconciliation | Valuation address does not match Note address. | - | The appraisal lists an additional N for North at the end of the street address which is not listed on the note. | Reviewer Comment (2022-04-20): Updated Note received Seller Comment (2022-04-20): Attached is updated Note with Correct address including N behind. Reviewer Comment (2022-04-15): This exception is for appraisal lists an additional N for North at the end of the street address which is not listed on the note. Seller Comment (2022-04-15): Rebut: [Redacted] letter was in file. Purpose to buy out another on Deed. |
04/20/2022 | 1 | A | NY | Primary | Purchase | C | A | C | A | A | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438639212 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Reviewer Comment (2022-04-08): Clearing after re-review. Seller Comment (2022-04-08): Rebut: PITI [Redacted] Verified Assets:[Redacted] Closing Cost: [Redacted] Remaining [Redacted] |
04/08/2022 | 1 | A | NY | Primary | Purchase | C | A | C | A | A | A | A | A | Non QM | Non QM | No | |||||||||||||||
| 438639212 | Credit | System | General | System | Security Instrument address does not match Note address. | Security agreement address does not match note address | Reviewer Comment (2022-04-27): Received, Clearing. Buyer Comment (2022-04-27): The Note is what needed to be fixed not the Security Instrument. Corrected Note was provided. Reviewer Comment (2022-04-25): Looking for updated Security Agreement. Seller Comment (2022-04-25): Updated note uploaded |
04/27/2022 | 1 | A | NY | Primary | Purchase | C | A | C | A | A | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438639212 | Credit | Title | General | Title | Final Title Policy Coverage is less than Original Loan Amount. | Amended title policy dated [Redacted] reflects a policy amount of [Redacted]which is less than loan amount | Reviewer Comment (2022-06-03): Received, Clearing. Seller Comment (2022-06-03): Uploaded corrected [Redacted] |
06/03/2022 | 1 | A | NY | Primary | Purchase | C | A | C | A | A | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438639213 | Credit | Insurance | Insurance Analysis | Insurance | Insurance address does not match Note address. | Title shows city as "[Redacted]," appraisal shows "[Redacted]," insurance/flood cert shows "[Redacted]," note / security instrument show as "[Redacted]." | Reviewer Comment (2022-04-14): Received updated policy with corrected city, Clearing. Seller Comment (2022-04-14): Disagree - uploaded updated [Redacted]; Property is assessed in the [Redacted]. |
04/14/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | A | C | A | A | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438639213 | Credit | System | General | Appraisal Reconciliation | Valuation address does not match Note address. | - | Title shows city as "[Redacted]," appraisal shows "[Redacted]," insurance/flood cert shows "[Redacted]," note / security instrument show as "[Redacted]." | Reviewer Comment (2022-05-06): Received, Clearing. Seller Comment (2022-05-06): Disagree - letter from the title company showing that [Redacted] is part of [Redacted] so it is not inaccurate to call the town [Redacted] as well as [Redacted] since [Redacted] is part of [Redacted] Reviewer Comment (2022-04-19): In order to clear, please update appraisal city to match the city on the note. Seller Comment (2022-04-19): The [Redacted] is in [Redacted] so they are interchangeable. The appraisal does not have to be changed to read [Redacted]. The Zip code and the APN number are correct for the property. Reviewer Comment (2022-04-18): In order to clear, please update appraisal city to match the city on the note. Seller Comment (2022-04-15): [Redacted] is the neighborhood of the city of [Redacted] that the property is located in. See attached Zillow screenshot confirming the same Reviewer Comment (2022-04-14): Appraisal shows "[Redacted]," note / security instrument show as "[Redacted]" Seller Comment (2022-04-14): Property is assessed in the [Redacted]. |
05/06/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | A | C | A | A | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438639213 | Credit | System | General | System | Flood Certificate Subject Address does not match Note address. | Title shows city as "[Redacted]," appraisal shows "[Redacted]," insurance/flood cert shows "[Redacted]," note / security instrument show as "[Redacted]." | Reviewer Comment (2022-04-14): Received, Clearing. Seller Comment (2022-04-14): Property is assessed in the [Redacted]. |
04/14/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | A | C | A | A | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438639221 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or .[Redacted]%). | Reviewer Comment (2022-04-26): Restated by [Redacted]. Buyer Comment (2022-04-26): We agree this fail is valid. What do we need to do to restate as [Redacted]? |
04/26/2022 | 1 | A | FL | Second Home | Refinance - Rate/Term | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||||
| 438639221 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Non Escrowed Property Costs Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on [Redacted] not accurate. | Property expenses calculated as follows: Taxes = $[Redacted]monthly, Hazard insurance = $[Redacted], HOA = $[Redacted]monthly. The annual disbursements based upon the file documentation over [Redacted]months is [Redacted], however page 4 of the final CD reflects $[Redacted]. | 2 | B | FL | Second Home | Refinance - Rate/Term | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||||
| 438639221 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | QM (APOR) fail due to exceeding points and fees threshold. Provide evidence of undiscounted interest rate and price. | Reviewer Comment (2022-04-26): Restated by [Redacted]. |
04/26/2022 | 1 | A | FL | Second Home | Refinance - Rate/Term | Lender to provide updated ATR/QM status | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639221 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Have Escrow Account | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether the loan will have an escrow account. | The final CD on page 1 and 2 does not indicate an escrow account page 4 has the box checked that there will be an escrow account. | Reviewer Comment (2022-04-11): [Redacted] Received PCCD AND and LOE. Seller Comment (2022-04-08): Disagree - PCCD and LOX uploaded |
04/11/2022 | 2 | B | FL | Second Home | Refinance - Rate/Term | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639221 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Not Have Escrow Account | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether the loan will have an escrow account. | The final CD on page 1 and 2 does not indicate an escrow account page 4 has the box checked that there will be an escrow account. | Reviewer Comment (2022-04-11): [Redacted] Received PCCD AND and LOE. Seller Comment (2022-04-08): Disagree - PCCD and LOX uploaded |
04/11/2022 | 2 | B | FL | Second Home | Refinance - Rate/Term | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639221 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | The loan discount fee increased from $[Redacted]on the initial Loan Estimate to $[Redacted] on the final CD. A change in circumstance was not provided for the increase and the $[Redacted]lender credit does not cover the increase. | Reviewer Comment (2022-04-11): [Redacted] Received LE dated [Redacted] along with valid COC therefore no cure required. Seller Comment (2022-04-08): Disagree - uploaded Initial LE was [Redacted], please see COC [Redacted] for the rate lock which includes fee change for discount points. |
04/11/2022 | 1 | A | FL | Second Home | Refinance - Rate/Term | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639221 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | The lender provided a $[Redacted]credit that covers the increase of the appraisal fee from $[Redacted]to $[Redacted]. | Reviewer Comment (2022-04-18): [Redacted] received Sufficient cure at closing for the Appraisal fee increased. Reviewer Comment (2022-04-11): [Redacted] We agree and understand that the cure was given at closing for [Redacted] for the Appraisal fee. The exception will be cleared once we receive the cure/resolution for the [Redacted]. Exception Remains. Buyer Comment (2022-04-08): Disagree - Final CD shows cure of [Redacted] for the increase in appraisal fee and is correct. |
04/18/2022 | 1 | A | FL | Second Home | Refinance - Rate/Term | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639221 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Compliance Report dated [Redacted] Doc#68 stated TRID warning of 0% tolerance violation of $[Redacted]and [Redacted]% tolerance violation of $[Redacted] | Reviewer Comment (2022-04-18): [Redacted] received Corrected PCCD, Letter of Explanation, Proof of Delivery and Copy of Refund Check. Seller Comment (2022-04-15): Uploaded check and shipping label for transfer tax as other cure was accounted for at closing Reviewer Comment (2022-04-13): "[Redacted] received PCCD and LOE but proof of mailing and copy of refund check is missing. Please provided Copy of refund check and proof of mailing in order to cure this exception. Seller Comment (2022-04-12): Disagree - uploaded LOX with fee name for the cure. Reviewer Comment (2022-04-11): [Redacted] Received PCCD dated [Redacted] with cure however Please provide Corrected LOE which states about the cure provided along with copy of check and proof of mailing to cure this Exception. Seller Comment (2022-04-08): Disagree - Cure for transfer tax of [Redacted] is required, PCCD and LOX uploaded. COC CD [Redacted] for transfer tax fee increase is not valid. Initial LE [Redacted], final CD is [Redacted]. (Cure shown on PCCD: [Redacted] + [Redacted]= [Redacted] total cure) |
04/18/2022 | 2 | B | FL | Second Home | Refinance - Rate/Term | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639221 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - General Ability to Repay | Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not match. However, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. | Restated by XXXX. | 2 | B | FL | Second Home | Refinance - Rate/Term | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||||
| 438639222 | Compliance | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Missing Lender's Initial 1003 | 2 | B | CA | Primary | Purchase | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||||
| 438639222 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Lender to provide copy of this disclosure and proof of when it was provided to borrower. | 2 | B | CA | Primary | Purchase | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438639222 | Compliance | Compliance | Federal Compliance | TRID | TRID Settlement Service Provider Status | TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers. | Lender to provide Settlement Service Provider list. | Reviewer Comment (2022-04-11): [Redacted] Received Settlement Service Provider List. |
04/11/2022 | 1 | A | CA | Primary | Purchase | No Defined Cure | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438639222 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Lender to provide settlement service provider list to remove the title fee violations. | Reviewer Comment (2022-04-12): [Redacted] On further review as per rate lock available in the file no cure required. Seller Comment (2022-04-11): Disagree - Loan Discount Points decreased from on CD dated [Redacted] to [Redacted] on CD with COC dated [Redacted] due to Concession applied - [Redacted] per Rate Lock Confirmation dated [Redacted] reason showing on Rate Lock History. There is no tolerance cure due - fee decreased due to concession applied, it did not increase. |
04/12/2022 | 1 | A | CA | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639222 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Lender to provide settlement service provider list to remove the title fee violations. | Reviewer Comment (2022-04-12): [Redacted] Sufficient cure provided at closing. Seller Comment (2022-04-11): Disagree - Appraisal Re-Inspection Fee was added to Intermediate CD dated [Redacted], Lender Credit issued in Section [Redacted], Page [Redacted] for increase in Closing Costs above legal limit. Final Executed CD dated [Redacted] still shows Lender Credit [Redacted] for increase in Closing Cots above legal limit for addition of Appraisal Inspection Fee since there was no valid COC for the change. There is no additional cure due for this fee. |
04/12/2022 | 1 | A | CA | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639222 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Abstract / Title Search. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Lender to provide settlement service provider list to remove the title fee violations. | Reviewer Comment (2022-04-11): [Redacted] Received Settlement Service Provider List therefore no cure required. Seller Comment (2022-04-11): Disagree - Borrower did not choose Settlement Agent listed - fees are not subject to tolerance - remain in Section [Redacted] of CD, uploaded SSPL |
04/11/2022 | 1 | A | CA | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639222 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Loan Tie-In Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Lender to provide settlement service provider list to remove the title fee violations. | Reviewer Comment (2022-04-11): [Redacted] Received Settlement Service Provider List therefore no cure required. Seller Comment (2022-04-11): Disagree - Borrower did not choose Settlement Agent listed - fees are not subject to tolerance - remain in Section [Redacted] of CD, uploaded SSPL |
04/11/2022 | 1 | A | CA | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639222 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - SubEscrow Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Lender to provide settlement service provider list to remove the title fee violations. | Reviewer Comment (2022-04-11): [Redacted] Received Settlement Service Provider List therefore no cure required. Seller Comment (2022-04-11): Disagree - Borrower did not choose Settlement Agent listed - fees are not subject to tolerance - remain in Section [Redacted] of CD, uploaded SSPL |
04/11/2022 | 1 | A | CA | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639222 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Wire /Funding/ Disbursement Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Lender to provide settlement service provider list to remove the title fee violations. | Reviewer Comment (2022-04-11): [Redacted] Received Settlement Service Provider List therefore no cure required. Seller Comment (2022-04-11): Disagree - Borrower did not choose Settlement Agent listed - fees are not subject to tolerance - remain in Section [Redacted] of CD, uploaded SSPL |
04/11/2022 | 1 | A | CA | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639222 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee. Fee Amount of $[Redacted] exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Lender to provide settlement service provider list to remove the title fee violations. | Reviewer Comment (2022-04-11): [Redacted] Received Settlement Service Provider List therefore no cure required. Seller Comment (2022-04-11): Disagree - Borrower did not choose Settlement Agent listed - fees are not subject to tolerance - remain in Section [Redacted] of CD, uploaded SSPL |
04/11/2022 | 1 | A | CA | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639222 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Minimum [Redacted]months of housing history required for the current/primary residence not verified | The representative FICO score exceeds the guideline minimum by at least 40 points. The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has verified disposable income of at least $2500.00. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-04-05): Client elects to waive with comp factors |
04/05/2022 | 2 | B | CA | Primary | Purchase | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438639222 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee. Fee Amount of $[Redacted] exceeds tolerance of $0.00. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-04-12): Sufficient Cure Provided At Closing |
04/12/2022 | 1 | A | CA | Primary | Purchase | Final CD evidences Cure | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | |||||||||||||
| 438639242 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or .[Redacted]%). | Reviewer Comment (2022-05-04): Restated. Buyer Comment (2022-05-04): Agree on the fail - please restate to NQM |
05/04/2022 | 1 | A | NJ | Primary | Purchase | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||||
| 438639242 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Designation mismatch due to excessive points and fees | Reviewer Comment (2022-05-04): Restated. Buyer Comment (2022-05-04): Agree on the fail - please restate to NQM |
05/04/2022 | 1 | A | NJ | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639242 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Survey Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Fee was not disclosed on prior Loan Estimates or Closing Disclosures and no cure was provided | Reviewer Comment (2022-05-04): Restated. Reviewer Comment (2022-05-02): "[Redacted] received PCCD dated [Redacted] along with LOE however [Redacted] page of PCCD is missing. Please provided updated PCCD in order to clear this exception. Seller Comment (2022-04-29): Disagree - [Redacted] - the fee name has been corrected to "[Redacted]" uploaded PCCD and LOX |
05/04/2022 | 1 | A | NJ | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639242 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Sales Tax. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | No cure or valid COC on file | Reviewer Comment (2022-05-04): Restated. Reviewer Comment (2022-05-02): "[Redacted] received PCCD dated [Redacted] along with LOE however [Redacted] page of PCCD is missing. Please provided updated PCCD in order to clear this exception. Seller Comment (2022-04-29): Disagree - The fee name is incorrect on the Final CD and has been corrected on the PCCD to "[Redacted]" per [Redacted]. The borrower did not choose the settlement company listed on the [Redacted], therefore, the title fees are not subject to tolerance and are disclosed in Section [Redacted] of the CD. There is no cure due for this fee |
05/04/2022 | 1 | A | NJ | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639242 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - General Ability to Repay | Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not match. However, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. | Restated. | 2 | B | NJ | Primary | Purchase | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||||
| 438639226 | Compliance | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Missing Lender's Initial 1003 | Lender to provide initial 1003 for transaction (not in file). | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438639226 | Credit | Title | General | Title | Title Policy Coverage is less than Original Loan Amount. | The Title Policy Amount of ___ is less than the note amount of ___ based on the ___ in file. | Lender to provide final title cert for transaction (not in file). | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639226 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | B1 company less than two years old at time of approval - lender to provide proof exception was made. | The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has owned the subject property for at least 5 years. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-04-12): Client elects to waive with compensating factors Seller Comment (2022-04-12): Agree - exception approved |
04/12/2022 | 2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||
| 438639226 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Loan designation is Safe Harbor QM (APOR) | Reviewer Comment (2022-04-12): [Redacted] |
04/12/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM status | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639226 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639226 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted] months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639226 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Lender to provide homeownership counseling document (not in file). | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639226 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Loan Estimate Timing Electronically Provided | TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application. | Lender to provide initial LE dated within 3 days of application (not in file). | Reviewer Comment (2022-04-12): LE Received Reviewer Comment (2022-04-11): [Redacted] Received Initial LE dated [Redacted]. The loan application date was [Redacted]. The consumer went through the E-Consent process on [Redacted] and acknowledged the receipt of the LE on [Redacted]. In the event the consumer had not provided E-Consent by [Redacted], then the lender should have sent the consumer the Loan Estimate through another means to comply with the [Redacted] day LE timing requirement. Proof of the LE being sent alternative method is required to Clear. Seller Comment (2022-04-08): Disagree - uploaded intital LE dated [Redacted] |
04/12/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639226 | Compliance | Compliance | Federal Compliance | TRID | TRID Appraisal Disclosure - ECOA Timing | ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date. | Lender to provide right to appraisal disclosure or initial LE dated within 3 days of application (not in file). | Reviewer Comment (2022-04-12): LE Received |
04/12/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | |||||||||||||
| 438639226 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Loan Estimate Timing Electronically Provided | TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated [Redacted] was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations. | LE was E-signed on [Redacted] however e-consent was signed on [Redacted]. | Reviewer Comment (2022-04-20): [Redacted] Received Earliest [Redacted]. Seller Comment (2022-04-19): Disagree - e-consent received by all parties on [Redacted]. Initial Disclosure issued [Redacted], consented and signed same day. |
04/20/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639228 | Compliance | Compliance | Federal Compliance | Missing Disclosure | Notice of Special Flood Hazard Disclosure Not Provided Timely | FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing. | Special Flood Hazard Disclosure was provided to to the Borrower on Note date. | 2 | B | CA | Primary | Refinance - Cash-out - Home Improvement | B | B | A | A | B | B | A | A | Non QM | Non QM | No | |||||||||||||||
| 438639238 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Originator Compensation. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | The lender on the initial [Redacted] and [Redacted] CDs, Loan Originator Compensation YSP is shown as lender paid to broker. On the[Redacted] CD the fee changed to borrower paid Loan Origination Compensation and a valid change in circumstance or lender credit was not provided. | Reviewer Comment (2022-04-15): [Redacted] received [Redacted] and CD dated [Redacted] for change in compensation plan. Seller Comment (2022-04-15): Disagree - Due to compliance fail for [Redacted] and ineligible to close as [Redacted] does not make or purchase federal or state high-cost loans. Originator Compensation Fee flipped from [Redacted] was required to bring to compliance; Discount Points adjusted to reflect |
04/15/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | A | A | A | C | A | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438639241 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Not Have Escrow - Reason | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted]incorrectly disclosed whether the loan will have an escrow account. | Lender did not disclose the reason why borrower will not have an Escrow account. | Reviewer Comment (2022-04-13): [Redacted] Received PCCD and LOE. Seller Comment (2022-04-13): Please see attached Attestation Letter & PCCD correcting Escrow Account Section, Page [Redacted] to borrower declined. |
04/13/2022 | 2 | B | TX | Primary | Refinance - Cash-out - Other | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438639241 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - ATR | Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Fail. | Loan was originated as Non QM Third Party verification on income missing in file. Triggering the exception. | Reviewer Comment (2022-04-28): Received, Clearing. |
04/28/2022 | 1 | A | TX | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM status | C | B | A | A | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438639241 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General Ability To Repay Provision Employment - Bank Statements | Ability-to-Repay (Dodd-Frank 2014): Unable to verify current employment status using reasonably reliable third-party records. | Third Party verification on income missing in file. | Reviewer Comment (2022-04-28): Received, Clearing. Seller Comment (2022-04-28): 3rd Party Verification |
04/28/2022 | 1 | A | TX | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Non QM | Non QM | No | |||||||||||||
| 438639241 | Compliance | Compliance | Federal Compliance | ATR/QM | NonQM ATR | Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied. | Third Party verification on income missing in file | Reviewer Comment (2022-04-28): Received, Clearing. |
04/28/2022 | 1 | A | TX | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Non QM | Non QM | No | |||||||||||||
| 438639241 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $[Redacted]exceeds tolerance of $[Redacted]plus [Redacted]% or $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Recording fees amount of were disclosed on LE as $[Redacted], fees was disclosed on Final CD as $[Redacted]a cure as provided to the borrower of $[Redacted] | Reviewer Comment (2022-04-07): Sufficient Cure Provided At Closing |
04/07/2022 | 1 | A | TX | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | C | B | A | A | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438639244 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien | TRID Final Closing Disclosure 03/09/2022 on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) | Lender to provide seller CD and corrected final borrower's CD disclosing all seller paid fees. | Reviewer Comment (2022-04-19): Received Seller CD. Seller Comment (2022-04-15): Disagree - uploaded seller CD |
04/19/2022 | 1 | A | AZ | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | C | A | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438639244 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Non Escrowed Property Costs Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of 0.00 on Final Closing Disclosure provided on 03/09/2022 not accurate. | HOA dues are $[Redacted]/mo but are not disclosed on borrower's CD. Lender to provide corrected CD. | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | AZ | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | C | A | C | B | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438639244 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | FTHB reserve requirement for LTV >85% is [Redacted]months. Lender to provide proof of sufficient reserves or proof that an exception was made. | Reviewer Comment (2022-05-03): Received, Clearing. Seller Comment (2022-05-03): Additional verified assets on the file from the co-borrowers commission from the subject transaction CD, see attached documents and screen shots. . The co borrower was also the real estate agent in this purchase, on the settlement statement she was paid real estate commission on subject transaction. |
05/03/2022 | 1 | A | AZ | Primary | Purchase | C | B | C | A | C | B | A | A | Non QM | Non QM | No | ||||||||||||||
| 438639255 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien | TRID Final Closing Disclosure [Redacted] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) | The seller paid closing costs in the amount of $[Redacted]were not reflected on the borrower's CD. | Reviewer Comment (2022-05-04): [Redacted] received seller's CD. Seller Comment (2022-05-02): Final SS - seller paid fees are not disclosed by us on the borrower's CDs Seller Comment (2022-04-12): Disagree - uploaded seller CD and [Redacted] |
05/04/2022 | 1 | A | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639255 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Borrower was not provided with a COC | Reviewer Comment (2022-04-07): Sufficient Cure Provided At Closing |
04/07/2022 | 1 | A | CA | Primary | Purchase | Final CD evidences Cure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639255 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | 2 | B | CA | Primary | Purchase | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||||
| 438639255 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Not Have Escrow - Reason | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXX incorrectly disclosed whether the loan will have an escrow account. | Final CD shows there will be no escrow account | Reviewer Comment (2022-04-14): [Redacted] received PCCD and Letter of Explanation with reflecting changes in the Will Not have escrow Seller Comment (2022-04-13): PCCD and LOX to borrower regarding the escrow selection |
04/14/2022 | 2 | B | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639257 | Credit | Title | Document Error | Title | There is no dollar amount noted on the title policy. | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | C | B | C | B | A | A | Non QM | Non QM | No | ||||||||||||||||
| 438639257 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Fee was out of tolerance with sufficient cure given. | Reviewer Comment (2022-04-20): Sufficient Cure Provided At Closing |
04/20/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | C | B | C | B | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438639257 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Have Escrow Account | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether the loan will have an escrow account. | Loan has no escrow account but pg 3 of the final CD shows it does. Lender to provide corrected CD. | Reviewer Comment (2022-04-25): [Redacted] received Post CD and LOX. Seller Comment (2022-04-22): Disagree - uploaded PCCD and LOX |
04/25/2022 | 2 | B | CA | Primary | Refinance - Cash-out - Other | Letter of Explanation & Corrected Closing Disclosure | C | B | C | B | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438639257 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Not Have Escrow Account | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[Redacted] incorrectly disclosed whether the loan will have an escrow account. | Loan has no escrow account but pg 3 of the final CD shows it does. Lender to provide corrected CD. | Reviewer Comment (2022-04-25): [Redacted] received Post CD and LOX. Seller Comment (2022-04-22): Disagree - uploaded PCCD and LOX |
04/25/2022 | 2 | B | CA | Primary | Refinance - Cash-out - Other | Letter of Explanation & Corrected Closing Disclosure | C | B | C | B | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438639257 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Lender provided two CDs from day of closing, both signed by borrower, each with different cash to close figure. Lender to advise which document is correct for testing purposes. | Reviewer Comment (2022-05-03): Received, Clearing. Seller Comment (2022-05-03): Disagree - uploaded correct CD's |
05/03/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | C | B | C | B | A | A | Non QM | Non QM | No | ||||||||||||||
| 438639258 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - | Lender to provide proof of P/I for [Redacted]. | Reviewer Comment (2022-04-18): Received, Clearing. Seller Comment (2022-04-18): The finding is erroneous. The documents to clear the exception was in the file previously. Sending another copy for review. |
04/18/2022 | 1 | A | CA | Investment | Refinance - Limited Cash-out GSE | C | A | C | A | A | A | A | A | N/A | N/A | No | |||||||||||||
| 438639265 | Property | Property - Appraisal | Appraisal Reconciliation | Property - Appraisal | Appraisal is required to be in name of Lender | - | The final 1004 provided lists the broker as the client/lender. | 2 | B | NJ | Primary | Refinance - Cash-out - Other | B | B | A | A | A | A | B | B | Non QM | Non QM | No | |||||||||||||||
| 438639271 | Property | Property - Appraisal | Appraisal Reconciliation | Property - Appraisal | Appraisal is required to be in name of Lender | - | The appraisal shows [Redacted] as the lender/client and the note shows [Redacted]. An appraisal transfer letter was not provided. | 2 | B | CA | Primary | Refinance - Cash-out - Other | B | B | A | A | A | A | B | B | Non QM | Non QM | No | |||||||||||||||
| 438639216 | Credit | Credit | Credit Documentation | Credit | There is no lease in place for the subject property and the absence of this document casts doubt on business purpose of loan. | The file is missing a copy of the lease agreement for the subject property but does include a letter of explanation explaining the cash out is to have reserves on hand. | Reviewer Comment (2022-04-08): Lease received Seller Comment (2022-04-08): See the attached Lease Agreement |
04/08/2022 | 1 | A | TX | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | |||||||||||||||||
| 438639224 | Credit | Borrower and Mortgage Eligibility | Mortgage / Program Eligibility | Borrower and Mortgage Eligibility | Guideline Requirement: Debt Service Coverage Ratio (Subject DSCR) discrepancy. | Reviewer Comment (2022-04-12): Clearing after re-review. Seller Comment (2022-04-12): This is a [Redacted], Loan amount [Redacted], SFR, [Redacted], CBR Score of [Redacted]. |
04/12/2022 | 1 | A | CA | Investment | Refinance - Rate/Term | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438639240 | Credit | Insurance | Insurance Documentation | Insurance | Missing Document: Flood Insurance Policy not provided | The flood policy was not found in the file. | Reviewer Comment (2022-04-21): Not found in the prior file, clearing with receipt now. Seller Comment (2022-04-21): Please find attached the same flood policy that was sent with file but actually showing that it is [Redacted]. |
04/21/2022 | 1 | A | CA | Investment | Purchase | C | A | C | A | A | A | N/A | No | |||||||||||||||||
| 438639250 | Credit | Hazard Insurance | Document Error | Hazard Insurance | Hazard Insurance policy does not list Lender or Servicer and its successors and assigns, per guideline requirements. | Lender to provide HOI cert showing servicer as the mortgagee - mortgagee on HOI cert does not have ISAOA/ATIMA designation. | Reviewer Comment (2022-04-27): Received, Clearing. Seller Comment (2022-04-27): [Redacted] has been added to the HOI policy |
04/27/2022 | 1 | A | CT | Investment | Refinance - Rate/Term | C | B | C | B | A | A | N/A | No | |||||||||||||||||
| 438639250 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | XXXX mortgage statement on [Redacted] reflects $[Redacted]in deferred principal, however evidence of deferral agreement was not provided | The representative FICO score exceeds the guideline minimum by at least 40 points. The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%. The Debt Service Coverage Ratio (DSCR) is greater than the guideline requirement by .50. Seasoned Borrower/Investor whose experience exceeds 10 completed projects. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-04-11): Client elects to waive with compensating factors |
04/11/2022 | 2 | B | CT | Investment | Refinance - Rate/Term | C | B | C | B | A | A | N/A | No | |||||||||||||||
| 438639263 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Loan fails QM testing due to points and fees. | Reviewer Comment (2022-04-26): Loan is [Redacted]. |
04/26/2022 | 1 | A | IN | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639263 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or [Redacted]%). | Loan fails QM testing due to points and fees. | Reviewer Comment (2022-04-26): Received, Clearing. Seller Comment (2022-04-26): undiscounted rate/price: [Redacted]. Passing compliance test attached |
04/26/2022 | 1 | A | IN | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639263 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Fee was out of tolerance with sufficient cure given. | Reviewer Comment (2022-04-14): Sufficient Cure Provided At Closing |
04/14/2022 | 1 | A | IN | Primary | Purchase | Final CD evidences Cure | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639263 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | The Business Narrative on file is blank with no signature or date. Borrowers must provide a comprehensive business narrative per credit guidelines. | Reviewer Comment (2022-04-21): Received, Clearing. Seller Comment (2022-04-21): The attached fully executed e-signed business narrative form is to clear the finding below. |
04/21/2022 | 1 | A | IN | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639263 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on [Redacted]months with a Fixed expense ratio of [Redacted]% | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | IN | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639276 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or .[Redacted]%). | Points and fees exceed maximum. Missing evidence of undiscounted interest rate and price. | Reviewer Comment (2022-04-25): Received, Clearing. Seller Comment (2022-04-25): See passing DocMagic test. Undiscounted rate [Redacted], final price of [Redacted] |
04/25/2022 | 1 | A | AZ | Second Home | Purchase | C | A | A | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639276 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Designation mismatch due to points and fees. | Reviewer Comment (2022-04-25): Received, Clearing. |
04/25/2022 | 1 | A | AZ | Second Home | Purchase | Lender to provide updated ATR/QM status | C | A | A | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639272 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted] months with a Fixed Expense Ratio of [Redacted]% for both businesses. | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B Reviewer Comment (2022-04-26): The Bank Statement income was based on [Redacted] months with a Fixed Expense Ratio of [Redacted]. |
2 | B | TX | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639272 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on 24[Redacted] months with a Fixed Expense Ratio of [Redacted]% for both businesses. | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B Reviewer Comment (2022-04-26): The Bank Statement income was based on [Redacted] months with a Fixed Expense Ratio of [Redacted]. |
2 | B | TX | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639272 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% for both businesses. | Reviewer Comment (2022-04-26): Loan is [Redacted]. |
04/26/2022 | 1 | A | TX | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639272 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | The third party business verification within [Redacted]business days of the note and the internet/telephone listings are required per the guidelines and were not provided for either entity. | Reviewer Comment (2022-04-26): Received, Clearing. Seller Comment (2022-04-26): The attached Internet search on the processor cert. is used to cure the finding below. |
04/26/2022 | 1 | A | TX | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639234 | Property | Valuation | Valuation Issue | Valuation | The desk review has a effective date that is other than what the appraisal effective date is. The desk review should have the same effective date as the appraisal | The CDA provided shows an effective date of [Redacted] and the [Redacted] provided shows an effective date of [Redacted]. | The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower's monthly mortgage payment has decreased by at least 20%. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): See attached CDA Reviewer Comment (2022-06-14): reopened Reviewer Comment (2022-05-09): Exception Provided. Seller Comment (2022-05-09): Agree - exception approved Reviewer Comment (2022-04-27): Exception stands Buyer Comment (2022-04-27): Response: The CDA report date is based on when it was submitted by the review appraiser, which is [Redacted] and cannot be changed. |
07/20/2022 | 1 | A | FL | Primary | Purchase | C | B | A | A | C | B | C | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438639234 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Loan was originated as Safe Harbor QM (APOR) but the high points and fees are triggering the Loan designation fail. | Reviewer Comment (2022-04-26): Loan is [Redacted]. |
04/26/2022 | 1 | A | FL | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | A | A | C | B | C | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639234 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of [Redacted] of the Federal Total Loan Amount. Points and Fees total [Redacted] on a Federal Total Loan Amount of [Redacted] vs. an allowable total of [Redacted] (an overage of [Redacted] or [Redacted]). | Verified Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of [Redacted] of the Federal Total Loan Amount. Points and Fees total [Redacted] on a Federal Total Loan Amount of [Redacted] vs. an allowable total of [Redacted] (an overage of [Redacted] or [Redacted]). | Reviewer Comment (2022-04-26): Received, Clearing. Seller Comment (2022-04-26): undiscounted rate/ price: [Redacted]. Passing compliance test attached with points excluded as bona fide |
04/26/2022 | 1 | A | FL | Primary | Purchase | C | B | A | A | C | B | C | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639234 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | . | Reviewer Comment (2022-07-19): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B Reviewer Comment (2022-04-26): Bank Statement income was based on [Redacted] months with a Fixed expense ratio of [Redacted] |
2 | B | FL | Primary | Purchase | C | B | A | A | C | B | C | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639229 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or .[Redacted]%). | Points and fees exceed maximum. Missing evidence of undiscounted interest rate and price. | Reviewer Comment (2022-05-02): Restated. Buyer Comment (2022-05-02): Valid finding - we'd like to restate as NQM |
05/02/2022 | 1 | A | NY | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||
| 438639229 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | The Bank Statement income was based on 24 months with a Fixed/CPA Expense Ratios for both borrowers of [Redacted]%. | Reviewer Comment (2022-05-02): Restated. Buyer Comment (2022-05-02): Loan is being restated to NQM due to Points/Fees fail |
05/02/2022 | 1 | A | NY | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM status | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639229 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - General Ability to Repay | Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not match. However, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. | Restated. | 2 | B | NY | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||||
| 438639219 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Rate/Term | B | B | B | B | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639219 | Credit | Title | Document Error | Title | There is no dollar amount noted on the title policy. | Lender to provide final title cert. | 2 | B | CA | Primary | Refinance - Rate/Term | B | B | B | B | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||||
| 438820778 | Credit | 1003 | Document Error | 1003 | Borrower(s) is not a U.S. Citizen, and the guideline required documentation was not provided. | - | The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-05-04): Pre funding exception. Seller Comment (2022-05-04): Disagree - exception approved prior to funding |
05/04/2022 | 2 | B | PA | Investment | Purchase | C | B | C | B | A | A | A | A | N/A | N/A | No | ||||||||||||
| 438820778 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - | Reviewer Comment (2022-04-29): Received trailing document, cleared Seller Comment (2022-04-29): Disagree - uploaded REO docs |
04/29/2022 | 1 | A | PA | Investment | Purchase | C | B | C | B | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438820778 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - | Reviewer Comment (2022-06-22): Received, Clearing. Seller Comment (2022-06-22): Uploaded REO docs Reviewer Comment (2022-05-05): This will require a buyer exception. Buyer Comment (2022-05-05): The borrower is not responsible to pay for an HO6 policy. This is a tenant occupied property therefore it was his option not to obtain. We have spoken to the customer today and we have confirmed that the borrower is not responsible to have an HO6 policy therefore he does not have one. Please waive this condition. |
06/22/2022 | 1 | A | PA | Investment | Purchase | C | B | C | B | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639231 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted] with a Fixed Expense Ratio of [Redacted] | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | FL | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639231 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted] with a Fixed Expense Ratio of [Redacted] | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | FL | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639231 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Lender Credit Tolerance Violation | TILA-RESPA Integrated Disclosure: [Redacted] Percent Tolerance exceeded for Lender Credits. Final Lender Credit of [Redacted] is less than amount of binding Lender Credit previously disclosed in the amount of [Redacted]. | No valid change in circumstance for this fee change. | Reviewer Comment (2022-04-25): [Redacted] received additional information on valid changed circumstance. Seller Comment (2022-04-21): Review: [Redacted] COC CD was issued for [Redacted] lock extension at additional cost of [Redacted] to borrower, lender credit adjusted to reflect. See attached COC CD and Lock Confirmation. |
04/25/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639232 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on [Redacted]months with a fixed expense ratio of [Redacted]% | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639232 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Due to bank statement income and missing lease on rental property. | Reviewer Comment (2022-04-29): Loan is [Redacted]. |
04/29/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM status | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639232 | Credit | Title | Document Error | Title | There is no dollar amount noted on the title policy. | Lender to provide final title cert. | 2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||||
| 438639274 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM Provision Income and Assets - REO 25% Method | General QM: Unable to verify Real Estate Owned income ([Redacted]) using reasonably reliable third-party records. | Due to missing lease agreement. | Reviewer Comment (2022-05-02): Received, Clearing. Seller Comment (2022-05-02): Updated 1003, 1008 and rental calc, rental income was not calculated correctly, loan still qualifies with DTI at [Redacted] instead of [Redacted] at funding. |
05/02/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639274 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 Test | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over [Redacted] of [Redacted] on Final Closing Disclosure provided on [Redacted] not accurate. | Flood insurance was not included in estimated property costs. | 2 | B | CA | Primary | Refinance - Rate/Term | Letter of Explanation & Corrected Closing Disclosure | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||||
| 438639274 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Due to missing lease agreement. | Reviewer Comment (2022-05-02): Received, Clearing. |
05/02/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | Lender to provide updated ATR/QM status | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639274 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Not Have Escrow - Reason | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether the loan will have an escrow account. | File has no escrow account but lender marked there will be one on page [Redacted]. Lender to provide corrected CD. | Reviewer Comment (2022-04-25): [Redacted] received Post CD and LOX. Seller Comment (2022-04-22): Disagree - uploaded PCCD and LOX provided clerical adjustment to correct page 4, marked box for no escrow account reason |
04/25/2022 | 2 | B | CA | Primary | Refinance - Rate/Term | Letter of Explanation & Corrected Closing Disclosure | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639274 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - | Lender to provide lease for [Redacted] (no lease was in file and borrowers will not qualify without this income). | Reviewer Comment (2022-04-28): Received, Clearing. Seller Comment (2022-04-28): See lease attached. |
04/28/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639262 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Second Home | Refinance - Cash-out - Home Improvement | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639269 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CO | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639275 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on [Redacted]months with a Fixed expense ratio of [Redacted]%. | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639248 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___. | The qualifying DTI on the loan is at least 10% less than the guideline maximum. The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%. Borrower's monthly mortgage payment has decreased by at least 20%. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-05-05): Prefunding exception. Seller Comment (2022-05-05): Exception approved. |
05/05/2022 | 2 | B | NY | Second Home | Refinance - Rate/Term | C | B | C | B | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438639248 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Loan Qualified using [Redacted]months bank statement income with a [Redacted]% expense ratio. | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | NY | Second Home | Refinance - Rate/Term | C | B | C | B | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639260 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]%. | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Rate/Term | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639230 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien | TRID Final Closing Disclosure XXXX on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) | TRID Final Closing Disclosure [Redacted] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page [Redacted]. (Points and Fees testing limited to Borrower paid fees.) (Final[Redacted]) | Reviewer Comment (2022-04-25): [Redacted] received seller cd Seller Comment (2022-04-21): Disagree - uploaded seller CD |
04/25/2022 | 1 | A | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | B | B | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639230 | Credit | Credit | Credit Documentation | Guideline | The Verification of Rent (VOR) / Verification of Mortgage (VOM) is required and was not found in file. | The guidelines required a current VOM/VOR; however the borrower's previous mortgage was paid off in XXXX and current housing was not provided. The loan file contained a Lender Excpetion. | The representative FICO score exceeds the guideline minimum by at least 40 points. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-04-19): Client elects to waive with compensating factors |
04/19/2022 | 2 | B | CA | Primary | Purchase | C | B | B | B | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438639259 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on [Redacted] months with a Fixed expense ratio of [Redacted] | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Rate/Term | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639259 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: [Redacted] Percent Fee Tolerance exceeded for Loan Originator Compensation. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | Loan Discount Points was last disclosed as [Redacted] on LE but disclosed as [Redacted] on Final CD file does not contain any Change of circumstance for this fee nor a cure. Provide a post close CD disclosing the tolerance cure to include [Redacted] a copy of refund check ,proof of delivery and a copy of the letter of explanation sent tot he Borrower disclosing the changes made. | Reviewer Comment (2022-04-22): [Redacted] received valid COC dated [Redacted] with reason why the fee was increased on the CD dated [Redacted] hence after review the exception was cleared. Seller Comment (2022-04-22): Disagree - uploaded lock confirmation and coc cd's |
04/22/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639259 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Have Escrow Account | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether the loan will have an escrow account. | Closing disclosure disclosed that loan will have an escrow but no fees were disclosed in section G of closing disclosure and Estimated Escrow is fees is [Redacted]. | Reviewer Comment (2022-04-22): [Redacted] Received PCCD and LOE. Seller Comment (2022-04-22): Disagree - uploaded PCCD and LOX |
04/22/2022 | 2 | B | CA | Primary | Refinance - Rate/Term | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639259 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Not Have Escrow Account | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether the loan will have an escrow account. | Closing disclosure disclosed that loan will have an escrow but no fees were disclosed in section G of closing disclosure and Estimated Escrow is fees is [Redacted]. | Reviewer Comment (2022-04-22): [Redacted] Received PCCD and LOE. Seller Comment (2022-04-22): Disagree - uploaded PCCD and LOX |
04/22/2022 | 2 | B | CA | Primary | Refinance - Rate/Term | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639259 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Acknowledgment of receipt of Appraisal was signed by the borrower on [Redacted]. Appraisal was competed on [Redacted]. | 2 | B | CA | Primary | Refinance - Rate/Term | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438639249 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639249 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Non Escrowed Property Costs Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on[Redacted] not accurate. | The Escrow Account box is checked off on page [Redacted] of the final CD, however the loan has no escrow account based on the page 1 of the final CD. | Reviewer Comment (2022-04-25): [Redacted] Received PCCD and LOE with correct escrow section on page 04. |
04/25/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639249 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Have Escrow Account | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether the loan will have an escrow account. | The Escrow Account box is checked off on page [Redacted]of the final CD, however the loan has no escrow account based on the page [Redacted] of the final CD. | Reviewer Comment (2022-04-25): [Redacted] Received PCCD and LOE. Seller Comment (2022-04-22): Page 4 - Escrow Account Section incorrect - sent PCCD with LOX showing will not have an escrow account because borrower declined. |
04/25/2022 | 2 | B | CA | Primary | Refinance - Cash-out - Other | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639249 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Not Have Escrow Account | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether the loan will have an escrow account. | The Escrow Account box is checked off on page [Redacted] of the final CD, however the loan has no escrow account based on the page [Redacted] of the final CD. | Reviewer Comment (2022-04-25): [Redacted] Received PCCD and LOE. Seller Comment (2022-04-22): Page 4 - Escrow Account Section incorrect - sent PCCD with LOX showing will not have an escrow account because borrower declined. |
04/25/2022 | 2 | B | CA | Primary | Refinance - Cash-out - Other | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639247 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted] with a Fixed Expense Ratio of [Redacted]. | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | FL | Primary | Refinance - Rate/Term | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639246 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted] months with a Fixed Expense Ratio of [Redacted] | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | NY | Primary | Refinance - Rate/Term | C | B | C | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639246 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: [Redacted] Percent Fee Tolerance exceeded. Total amount of [Redacted] exceeds tolerance of [Redacted] plus [Redacted] or [Redacted]. Insufficient or no cure was provided to the borrower. | [Redacted] tolerance was exceeded by [Redacted] due to increase of Recording Fee Total. No valid COC provided, nor evidence of cure in file. Provide a post-close CD disclosing the tolerance cure to include [Redacted], a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made. | Reviewer Comment (2022-04-20): [Redacted] received clarification, cure provided at closing. Seller Comment (2022-04-19): Review: Cure in the amount of [Redacted] was applied to the Final CD in section J. See attached Final CD. |
04/20/2022 | 1 | A | NY | Primary | Refinance - Rate/Term | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639246 | Credit | Hazard Insurance | Insufficient Coverage | Hazard Insurance | The Hazard Insurance Policy Effective Date is after closing. | Hazard insurance policy effective date is on [Redacted], which is after the [Redacted] date. | Reviewer Comment (2022-04-20): Received current policy Seller Comment (2022-04-20): Attached HOI from [Redacted] to [Redacted]. |
04/20/2022 | 1 | A | NY | Primary | Refinance - Rate/Term | C | B | C | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639246 | Property | Property - Appraisal | Appraisal Reconciliation | Property - Appraisal | Appraisal is required to be in name of Lender | - | Lender to provide appraisal transfer letter from [Redacted] for both appraisals | 2 | B | NY | Primary | Refinance - Rate/Term | C | B | C | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438639266 | Credit | Title | Document Error | Title | There is no dollar amount noted on the title policy. | 2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | B | B | C | B | A | A | Non QM | Non QM | No | |||||||||||||||||
| 438639266 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 Test | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on [Redacted] not accurate. | The final CD shows estimated property costs over year 1 as $[Redacted]and the tax verification and HOI documentation show a total of $[Redacted]. | 2 | B | CA | Primary | Refinance - Cash-out - Other | Letter of Explanation & Corrected Closing Disclosure | C | B | B | B | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||||
| 438639266 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Not Have Escrow - Reason | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether the loan will have an escrow account. | The final CD does not have the box check for the reason of not having an escrow account. | Reviewer Comment (2022-04-26): [Redacted] received Post CD and LOX. Seller Comment (2022-04-26): Disagree - uploaded PCCD and LOX |
04/26/2022 | 2 | B | CA | Primary | Refinance - Cash-out - Other | Letter of Explanation & Corrected Closing Disclosure | C | B | B | B | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438639261 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-04-19): . |
2 | B | CA | Primary | Refinance - Rate/Term | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639261 | Compliance | Compliance | Federal Compliance | TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form | TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date | Truth in Lending Act: Subject loan transaction disbursed on [Redacted], prior to three (3) business days from transaction date of [Redacted]. | Final CD and Right to Cancel form signed on [Redacted], causing the dates to vary from what was pre-filled as the closing date on the documents. | Reviewer Comment (2022-04-19): Received, Clearing. Seller Comment (2022-04-19): Review: See screenshot below and attached Notice of Right to Cancel and Settlement Statement with closing date adjusted accordingly. |
04/19/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639233 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or .[Redacted]%). | Reviewer Comment (2022-05-16): Restated Buyer Comment (2022-05-16): Agree with the finding - please restate as NQM |
05/16/2022 | 1 | A | NY | Primary | Refinance - Rate/Term | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||||
| 438639233 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | QM APOR fail due to exceeding points and fees threshold | Reviewer Comment (2022-05-16): Restated |
05/16/2022 | 1 | A | NY | Primary | Refinance - Rate/Term | Lender to provide updated ATR/QM status | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639233 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Have Escrow Account | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether the loan will have an escrow account. | Loan Disclosures: Final Closing Disclosure provided on XXXX incorrectly disclosed whether the loan will have an escrow account. (Final[Redacted]) | Reviewer Comment (2022-05-24): SitusAMC received Post CD and LOX. Seller Comment (2022-05-23): See attached PCCD - no escrow account was established |
05/24/2022 | 2 | B | NY | Primary | Refinance - Rate/Term | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639233 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Not Have Escrow Account | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether the loan will have an escrow account. | Loan Disclosures: Final Closing Disclosure provided on XXXX incorrectly disclosed whether the loan will have an escrow account. (Final[Redacted]) | Reviewer Comment (2022-05-24): SitusAMC received Post Cd and LOX. Buyer Comment (2022-05-23): PCCD and LOX were uploaded to the other condition. No escrow account was established, clerical error |
05/24/2022 | 2 | B | NY | Primary | Refinance - Rate/Term | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639233 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - General Ability to Repay | Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not match. However, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. | Restated | 2 | B | NY | Primary | Refinance - Rate/Term | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||||
| 438639273 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639273 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-04-27): Loan is [Redacted]. |
04/27/2022 | 1 | A | CA | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639273 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien | TRID Final Closing Disclosure[Redacted] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) | No seller paid fees disclosed on page 2 | Reviewer Comment (2022-05-04): [Redacted] received Seller CD Seller Comment (2022-05-02): Disagree - uploaded seller doc |
05/04/2022 | 1 | A | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639273 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Not Have Escrow - Reason | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[Redacted] incorrectly disclosed whether the loan will have an escrow account. | Reason for not having an escrow not provided. | Reviewer Comment (2022-05-03): [Redacted] Received PCCD and LOE. Seller Comment (2022-05-02): Disagree - uploaded PCCD and LOX |
05/03/2022 | 2 | B | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639273 | Credit | Credit | Credit Documentation | Guideline | Missing Document: Verification of Rent (VOR) / Verification of Mortgage (VOM) not provided | [Redacted] months housing history was not provided | The representative FICO score exceeds the guideline minimum by at least 40 points. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-04-20): Client elects to waive with compensating factors |
04/20/2022 | 2 | B | CA | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438639273 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Business Narrative provided indicates number of employees is 5+. Unable to determine expense factor. Per expense ratio table, ratio is determined based on 0, 1-10 or 10+ employees. | Reviewer Comment (2022-04-27): Received, Clearing. Seller Comment (2022-04-27): Rebut: Business Narrative states [Redacted] .Ratio table states [Redacted] NOT 10+ Ratio id [Redacted]% See Below |
04/27/2022 | 1 | A | CA | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639220 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Originator Loan Designation of Safe Harbor QM (APOR) is due to high points and fees. | Reviewer Comment (2022-04-29): Undiscounted interest rate [Redacted]. Cleared |
04/29/2022 | 1 | A | NJ | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM status | C | A | A | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639220 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted] vs. an allowable total of $[Redacted] (an overage of $[Redacted]or [Redacted]%). | Verified Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted] on a Federal Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or [Redacted]%). | Reviewer Comment (2022-04-29): Undiscounted interest rate [Redacted]. Cleared Reviewer Comment (2022-04-29): Per compliance report, pre-discounted rate is [Redacted] Exception remains. Seller Comment (2022-04-29): Undiscounted rate/price should have actually been [Redacted] points can be excluded as bona fide which results in a passing test Reviewer Comment (2022-04-26): Based on undiscounted rate/price: [Redacted] @ [Redacted] loan still fails QM Points and Fees. Seller Comment (2022-04-26): undiscounted rate/price: [Redacted]. Passing compliance test attached |
04/29/2022 | 1 | A | NJ | Primary | Refinance - Cash-out - Other | C | A | A | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639220 | Compliance | Compliance | State Compliance | State Defect | (State High Cost) New Jersey High-Cost Loan (Points and Fees) | New Jersey Home Ownership Security Act: Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Total Loan Amount. Points and Fees total $[Redacted]on a Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or .[Redacted]%). Non-Compliant High Cost Loan. | Verified Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Total Loan Amount. Points and Fees total $[Redacted]on a Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted] (an overage of $[Redacted]or .[Redacted]%). Non-Compliant High Cost Loan. | Reviewer Comment (2022-04-29): Undiscounted interest rate [Redacted]. Cleared Reviewer Comment (2022-04-29): Per compliance report, pre-discounted rate is [Redacted] Exception remains. Seller Comment (2022-04-29): undiscounted rate [Redacted] points can be excluded as bona fide, will pass NJ High Cost - test attached |
04/29/2022 | 1 | A | NJ | Primary | Refinance - Cash-out - Other | Within 45 days of closing, provide: (1) Letter of Explanation; (2) refund of amount over the high-cost threshold maximum; and (3) proof of delivery. (Narrow Defense - CHD Approval Required) Within 365 days of closing, and prior to lender receiving any notice from borrower of the compliance failure, provide: (1) Lender Attestation to AMC attesting (i) the failure was not intentional and was a bona fide error notwithstanding procedures in place to prevent such loans from being made and (ii) the lender has not received any notice from borrower of the failure; (2) refund of amount over the high-cost threshold maximum; and (3) proof of delivery. |
C | A | A | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639220 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Fee was disclosed on LE as $[Redacted]and fee was disclosed on CD as $[Redacted]and no cure was provided to the Borrower. Provide a post -close CD disclosing the tolerance cure to include $[Redacted],a copy of refund check proof of delivery and a copy of the explanation sent to the Borrower disclosing the the changes made. | Reviewer Comment (2022-04-20): SitusAMC received valid COC dated [Redacted] and rate lock confirmation with reason why the fee was increased on the CD dated [Redacted] hence after review the exception was cleared. Seller Comment (2022-04-20): : Due to closing delay lock extended at a total cost of [Redacted] to borrower, discount points adjusted to reflect. See attached Lock Confirmation, COC CD, [Redacted]Cert, and signed Final CD. No cure is required |
04/20/2022 | 1 | A | NJ | Primary | Refinance - Cash-out - Other | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | A | A | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639220 | Compliance | Compliance | State Compliance | State Defect | (State High Cost Provision) New Jersey High-Cost Loan (Financed Fees Exceeds Threshold) | New Jersey High-Cost Loan: Lender financed points and fees in excess of [Redacted]% of the total loan amount. | Verified Lender financed points and fees in excess of [Redacted]% of the total loan amount. | Reviewer Comment (2022-04-29): Undiscounted interest rate [Redacted]. Cleared |
04/29/2022 | 1 | A | NJ | Primary | Refinance - Cash-out - Other | Within 45 days of closing, provide: (1) Letter of Explanation; (2) refund of amount over the high-cost threshold maximum; and (3) proof of delivery. (Narrow Defense - CHD Approval Required) Within 365 days of closing, and prior to lender receiving any notice from borrower of the compliance failure, provide: (1) Lender Attestation to AMC attesting (i) the failure was not intentional and was a bona fide error notwithstanding procedures in place to prevent such loans from being made and (ii) the lender has not received any notice from borrower of the failure; (2) refund of amount over the high-cost threshold maximum; and (3) proof of delivery. |
C | A | A | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438639220 | Compliance | Compliance | State Compliance | State Defect | (State High Cost Provision) New Jersey High-Cost Loan (Counseling Requirement) | New Jersey High-Cost Loan: Proof of counseling from HUD-approved nonprofit credit counselor not obtained. | Proof of Notice of Counseling missing in file. | Reviewer Comment (2022-04-29): Undiscounted interest rate [Redacted]. Cleared |
04/29/2022 | 1 | A | NJ | Primary | Refinance - Cash-out - Other | Within 45 days of closing, provide: (1) Letter of Explanation; (2) refund of amount over the high-cost threshold maximum; and (3) proof of delivery. (Narrow Defense - CHD Approval Required) Within 365 days of closing, and prior to lender receiving any notice from borrower of the compliance failure, provide: (1) Lender Attestation to AMC attesting (i) the failure was not intentional and was a bona fide error notwithstanding procedures in place to prevent such loans from being made and (ii) the lender has not received any notice from borrower of the failure; (2) refund of amount over the high-cost threshold maximum; and (3) proof of delivery. |
C | A | A | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438639220 | Compliance | Compliance | State Compliance | State Defect | (State High Cost Disclosure) New Jersey High-Cost Loan (Borrower Notice Not Provided Timely) | New Jersey High-Cost Loan: Notice to Borrower not provided to borrower at least three (3) business days prior to closing. | New Jersey High-Cost Loan: Notice to Borrower not provided to borrower at least three (3) business days prior to closing. | Reviewer Comment (2022-04-29): Undiscounted interest rate [Redacted]. Cleared |
04/29/2022 | 1 | A | NJ | Primary | Refinance - Cash-out - Other | Within 45 days of closing, provide: (1) Letter of Explanation; (2) refund of amount over the high-cost threshold maximum; and (3) proof of delivery. (Narrow Defense - CHD Approval Required) Within 365 days of closing, and prior to lender receiving any notice from borrower of the compliance failure, provide: (1) Lender Attestation to AMC attesting (i) the failure was not intentional and was a bona fide error notwithstanding procedures in place to prevent such loans from being made and (ii) the lender has not received any notice from borrower of the failure; (2) refund of amount over the high-cost threshold maximum; and (3) proof of delivery. |
C | A | A | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438639218 | Credit | Missing Document | General | Missing Document | Missing Document: Account Statements - Business not provided | Reviewer Comment (2022-04-26): Received, Clearing. |
04/26/2022 | 1 | A | CA | Second Home | Refinance - Rate/Term | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438639218 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | The file is missing the business bank statement dated [Redacted]. | Reviewer Comment (2022-04-26): Not found in the file prior, Clearing exception. Seller Comment (2022-04-26): Disagree - uploaded Jan bank stmt |
04/26/2022 | 1 | A | CA | Second Home | Refinance - Rate/Term | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639218 | Compliance | Compliance | Federal Compliance | Missing Required Data (other than HUD-1 or Note) | Disparity in Occupancy - Not Tested As Primary | The mortgage loan file contains documenting evidence the consumer intends to occupy the subject property as their primary residence. (Compliance testing performed based on the Occupancy Type of Second Home). Determination has not been made as to whether the loan would be High Cost and/or HPML if ran as a Primary Residence. | Documents show the subject property as both a second home and also a primary residence. Both borrowers have separate primary housing. Home was underwritten using second home guidelines. | Reviewer Comment (2022-05-10): Clearing for updated. Seller Comment (2022-05-10): Disagree - uploaded updated 1003 Reviewer Comment (2022-04-28): Provide updated/signed 1003 reflecting subject property is a second home Seller Comment (2022-04-28): Disagree - LOE from borrower stating property is 2nd home. |
05/10/2022 | 1 | A | CA | Second Home | Refinance - Rate/Term | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639218 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Loan Qualified using [Redacted]months bank statement income with an expense ratio of [Redacted]%. | Reviewer Comment (2022-05-11): Loan is [Redacted]. Seller Comment (2022-05-11): Disagree - uploaded updated 1003, 1008, income calc and written VOE on B2 showing overtime and bonus is likely to continue and more income available. Loan still qualifies with [Redacted]with correction to income rental payment of co-signer |
05/11/2022 | 1 | A | CA | Second Home | Refinance - Rate/Term | Lender to provide updated ATR/QM status | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639218 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on [Redacted] months with a fixed expense ratio of [Redacted]%. | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Second Home | Refinance - Rate/Term | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639218 | Compliance | Compliance | Federal Compliance | Missing Required Data (other than HUD-1 or Note) | Disparity in Occupancy - Not High Cost and Not Higher Priced | The mortgage loan file contains documenting evidence the consumer intends to occupy the subject property as their primary residence. (Compliance testing performed based on the Occupancy Type of Second Home). | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | CA | Second Home | Refinance - Rate/Term | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438639288 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines | Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of [Redacted]% moderately exceeds the guideline maximum of [Redacted]%. (DTI Exception is eligible to be regraded with compensating factors.) | Exception for the DTI is approved. Evidenced on document [Redacted]. | The representative FICO score exceeds the guideline minimum by at least 40 points. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-04-25): Client elects to waive with comp factors |
04/25/2022 | 2 | B | NY | Primary | Purchase | B | B | B | B | B | B | A | A | Non QM | Non QM | No | |||||||||||
| 438639288 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $[Redacted]exceeds tolerance of $[Redacted]plus [Redacted]% or $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Fee disclosed at $[Redacted]. Final amount was $[Redacted]. A cure for $[Redacted]is required. | Reviewer Comment (2022-04-22): Sufficient Cure Provided At Closing |
04/22/2022 | 1 | A | NY | Primary | Purchase | Final CD evidences Cure | B | B | B | B | B | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438639288 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: Investor qualifying total debt ratio discrepancy. | Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___. | Exception for the DTI has been approved. See document [Redacted]. | The representative FICO score exceeds the guideline minimum by at least 40 points. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-04-22): Client elects to waive with compensating factors |
04/22/2022 | 2 | B | NY | Primary | Purchase | B | B | B | B | B | B | A | A | Non QM | Non QM | No | |||||||||||
| 438639280 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on [Redacted]months with a Fixed expense ratio of [Redacted]%. | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B Reviewer Comment (2022-05-03): Already regraded to a EV2. Seller Comment (2022-05-03): Disagree - uploaded income calc wksht Reviewer Comment (2022-05-02): Updated Seller Comment (2022-05-02): Disagree - Income calc worksheet in file showing [Redacted] ratio showing income of [Redacted], however, initial 1003 stated income of [Redacted]used to qualify, in visionnet page 1002 |
2 | B | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639280 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Appraisal Fee was last disclosed as $[Redacted]on LE but disclosed as $[Redacted]on Final Closing Disclosure. File does not contain a valid COC for this fee, cure provided at closing. | Reviewer Comment (2022-04-22): Sufficient Cure Provided At Closing |
04/22/2022 | 1 | A | NY | Primary | Purchase | Final CD evidences Cure | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639280 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | The loan was qualified using [Redacted]months bank statement income with a [Redacted]% expense ratio. | Reviewer Comment (2022-05-02): [Redacted] |
05/02/2022 | 1 | A | NY | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639280 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - | The file does not contain a copy of the mortgage statement, taxes, insurance or other payments verification. | Reviewer Comment (2022-05-02): Received, Clearing. Seller Comment (2022-05-02): See Final CD Attached, for [Redacted] |
05/02/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639301 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Lender provided two final CDs from day of closing, both signed by borrower. Lender to advise which one is the actual final CD. | Reviewer Comment (2022-05-03): Received, Clearing. Seller Comment (2022-05-03): Disagree - uploaded final CD |
05/03/2022 | 1 | A | CA | Primary | Purchase | C | B | C | B | A | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639301 | Credit | Title | Document Error | Title | There is no dollar amount noted on the title policy. | Lender to provide final title cert. | 2 | B | CA | Primary | Purchase | C | B | C | B | A | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||||
| 438639282 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]%. | Reviewer Comment (2022-04-29): QM |
04/29/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM status | C | C | C | A | C | B | C | C | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639282 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]%. | Reviewer Comment (2022-07-19): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B Reviewer Comment (2022-05-18): Exception will remain EV2 for QM bank statement income Seller Comment (2022-04-29): CPA Letter for [Redacted] Real Estate for the borrower. |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | C | C | A | C | B | C | C | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639282 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 Test | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on [Redacted] not accurate. | The final CD disclosed the Amount of Total Property Costs over Year [Redacted] as $[Redacted]on page [Redacted]; however the annual taxes ($[Redacted]) and homeowners insurance ($[Redacted]) total are $[Redacted]per year. Final CD reflects Estimated Taxes, Insurance & Assessments of $[Redacted]monthly, correct amount is $[Redacted]. Provide a post-close CD correcting on page [Redacted] and Estimated Taxes, Insurance & Assessments on page [Redacted]; and a copy of the letter of explanation letter sent to the borrower disclosing the changes made. | 2 | B | CA | Primary | Refinance - Cash-out - Other | Letter of Explanation & Corrected Closing Disclosure | C | C | C | A | C | B | C | C | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||||
| 438639282 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Not Have Escrow - Reason | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether the loan will have an escrow account. | Page [Redacted] of the final CD does not disclose reason borrower will not have an escrow account | Reviewer Comment (2022-04-29): [Redacted] received Post CD and LOX. Seller Comment (2022-04-28): Disagree - uploaded PCCD and LOX |
04/29/2022 | 2 | B | CA | Primary | Refinance - Cash-out - Other | Letter of Explanation & Corrected Closing Disclosure | C | C | C | A | C | B | C | C | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639282 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted] exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Appraisal Fee was last disclosed as $[Redacted]on LE but disclosed as $[Redacted]on Final Closing Disclosure. File does not contain a valid COC for this fee, a $[Redacted]credit was provided. | Reviewer Comment (2022-04-25): Sufficient Cure Provided At Closing |
04/25/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | C | C | C | A | C | B | C | C | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639282 | Property | Appraisal Reconciliation | Value Discrepancy | Appraisal Reconciliation | Loan is to be securitized. Highest level secondary valuation supports the qualifying value. There are 2 or more lower level tertiary products that do not support the value.; Sec ID: 23 | Reviewer Comment (2022-07-19): this is due to highest level secondary valuation supports the qualifying value, but there are 2 or more lower level tertiary products that do not support the value. Seller Comment (2022-07-19): The appraisal was completed on [Redacted], the CDA on[Redacted] and the fields review was completed on [Redacted], field review is being used per guidelines Reviewer Comment (2022-05-18): This issue is the conflicting secondary values. The file contains a Desk Review and an AVM, that are not only out of tolerance of the appraisal, but of the LTV value as well. Exception remains Seller Comment (2022-05-18): The system is using the field review per our guidelines that I have attached. The appraisal and CDA have a variance, but we are using the field review per our guidelines. Reviewer Comment (2022-05-02): Exception is due to appraisal and CDA are a greater variance than allowed. The use of the field report value doesn't overcome issue. Seller Comment (2022-05-02): The Field Review is the Final value per guidelines. The system is using is using the [Redacted]Field Review not the [Redacted]Appraisal. |
3 | C | CA | Primary | Refinance - Cash-out - Other | C | C | C | A | C | B | C | C | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||||
| 438639282 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - | Tax Verification is not in the file for all three REOs | Reviewer Comment (2022-04-29): Received, Clearing. Seller Comment (2022-04-29): Disagree - uploaded REO docs |
04/29/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | C | C | A | C | B | C | C | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639282 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | Missing business narrative | Reviewer Comment (2022-04-28): Received in trailing docs Seller Comment (2022-04-28): Business Narrative has been attached. SM-email from CD on [Redacted] at [Redacted] PM. |
04/28/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | C | C | A | C | B | C | C | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639282 | Property | Appraisal Reconciliation | Value Discrepancy | Appraisal Reconciliation | Loan is to be securitized. Highest level secondary valuation supports the qualifying value. There are 2 or more lower level tertiary products that do not support the value.; Sec ID: 23 | Note Date: ___; Lien Position: ___ | 3 | C | CA | Primary | Refinance - Cash-out - Other | C | C | C | A | C | B | C | C | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||||
| 438639298 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed/CPA Expense Ratio of Redacted%. | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B Reviewer Comment (2022-05-02): Need Cash to Borrower: ; Total Cash Out: [Redacted]; Refi Purpose: Rate/Term issue addressed. Seller Comment (2022-05-02): Disagree - Income Calc worksheet in file showing [Redacted] expense ratio and [Redacted] ownership, in [Redacted]page 1300 Seller Comment (2022-04-29): Verification of Professional Bank |
2 | B | FL | Primary | Refinance - Rate/Term | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639298 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Non Escrowed Property Costs Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of Redactedon Final Closing Disclosure provided on Redacted not accurate. | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | FL | Primary | Refinance - Rate/Term | Letter of Explanation & Corrected Closing Disclosure | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||||
| 438639298 | Credit | System | General | System | Flood Certificate Subject Address does not match Note address. | Flood cert shows address as [Redacted]. Lender to provide corrected flood cert that matches note/deed/appraisal/title. | Reviewer Comment (2022-05-03): Received, Clearing. Seller Comment (2022-05-03): Disagree - uploaded flood cert Reviewer Comment (2022-04-29): Document provided still reflects wrong address. Seller Comment (2022-04-29): Exception approved. |
05/03/2022 | 1 | A | FL | Primary | Refinance - Rate/Term | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639298 | Compliance | Compliance | Federal Compliance | Missing Disclosure | Acknowledgement of Borrower Receipt of Notice of Special Flood Hazard Disclosure Missing | FDPA Notification Rule: Creditor did not retain record of borrower's receipt of Notice of Special Flood Hazard Disclosure. | Earliest copy found of flood disclosure was not signed or dated. Lender to provide signed/dated copy. | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | FL | Primary | Refinance - Rate/Term | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639298 | Compliance | Compliance | Federal Compliance | Missing Disclosure | Notice of Special Flood Hazard Disclosure Missing | Unable to determine compliance of Notice of Special Flood Hazard Disclosure due to missing information. | Earliest copy found of flood disclosure was not signed or dated. Lender to provide signed/dated copy. | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | FL | Primary | Refinance - Rate/Term | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639298 | Credit | Guideline | Guideline Issue | Guideline | Refi Purpose reflects Rate/Term and cash out greater than the lesser of 2% of the loan amount or $2000. | Loan originated as rate/term but final CD indicates payoff of non purchase money second and several revolving and installment debts. | Reviewer Comment (2022-05-05): Received, Clearing. Seller Comment (2022-05-05): Disagree - uploaded FNMA and financing estimate disclosure |
05/05/2022 | 1 | A | FL | Primary | Refinance - Rate/Term | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639284 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on Redactedmonths with a Fixed Expense Ratio of Redacted%. | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | PA | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639283 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on Redactedmonths with a Fixed Expense Ratio of Redacted% | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639283 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Finance Charge | TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on Redacted disclosed an inaccurate Finance Charge on page [Redacted]that does not match the actual Finance Charge for the loan (fee amounts included in Finance Charge calculation are based on Closing Disclosure dated [Redacted]). | Finance Charge variance due to fee labeled Assoc-Admin Fee. Lender to provide documentation detailing fee to determine if this should be included in the finance charge. | Reviewer Comment (2022-05-12): [Redacted] received updated fee name. Seller Comment (2022-05-11): Disagree - uploaded PCCD and LOX |
05/12/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission if Applicable | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639303 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Not Have Escrow Account | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether the loan will have an escrow account. | Loan has no escrow account but lender indicated there is one on page Redacted of CD. Lender to provide corrected CD. | Reviewer Comment (2022-05-02): [Redacted] Received PCCD and LOE. Seller Comment (2022-04-29): Disagree - uploaded PCCD and LOX |
05/02/2022 | 2 | B | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639303 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on 24 months of personal bank statements with a Fixed expense ratio of [Redacted]%. | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Purchase | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639303 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Have Escrow Account | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether the loan will have an escrow account. | Loan has no escrow account but lender indicated there is one on page [Redacted] of CD. Lender to provide corrected CD. | Reviewer Comment (2022-05-02): [Redacted] Received PCCD and LOE. Seller Comment (2022-04-29): Disagree - uploaded PCCD and LOX |
05/02/2022 | 2 | B | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639303 | Credit | Credit | Credit Documentation | Guideline | Missing Document: Verification of Rent (VOR) / Verification of Mortgage (VOM) not provided | The representative FICO score exceeds the guideline minimum by at least 40 points. The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-04-26): Client elects to waive with compensating factors |
04/26/2022 | 2 | B | CA | Primary | Purchase | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639302 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM Provision Employment - Schedule C | General QM: Unable to verify current Sole Proprietorship status using reasonably reliable third-party records. | Missing third party verification of business | Reviewer Comment (2022-05-06): Received, Clearing. Seller Comment (2022-05-06): 3rd Party verification for business |
05/06/2022 | 1 | A | CA | Second Home | Purchase | C | A | C | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639302 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM Provision Investor and QM DTIs match and both moderately exceed Guidelines | General QM: The DTI calculated in accordance with the Lenders Guidelines and 1026.43(e) of [Redacted]% moderately exceeds the guideline maximum of [Redacted]%. (DTI Exception is eligible to be regraded with compensating factors.) | DTI of [Redacted]% moderately exceeds the guideline maximum of [Redacted]% due to a variance in qualifying income from sole proprietorship. | Reviewer Comment (2022-05-02): Received, Clearing. Seller Comment (2022-05-02): The DTI is within tolerance and not over [Redacted]% |
05/02/2022 | 1 | A | CA | Second Home | Purchase | C | A | C | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639302 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: Investor qualifying total debt ratio discrepancy. | The file was approved as a non-agency loan. | Reviewer Comment (2022-05-02): Received, Clearing. |
05/02/2022 | 1 | A | CA | Second Home | Purchase | C | A | C | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639302 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Verification of Safe Harbor QM (APOR) not proven. | Reviewer Comment (2022-05-06): Received, Clearing. |
05/06/2022 | 1 | A | CA | Second Home | Purchase | Lender to provide updated ATR/QM status | C | A | C | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639302 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM Provision Investor Guidelines Violation | General QM: Based on the loan failing one or more guideline components, the loan is at QM risk. | Verification of Safe Harbor QM (APOR) due to missing income documentation and increased DTI. | Reviewer Comment (2022-05-02): Received, Clearing. |
05/02/2022 | 1 | A | CA | Second Home | Purchase | C | A | C | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639299 | Credit | Title | General | Title | Title Policy Coverage is less than Original Loan Amount. | The Title Policy Amount of ___ is less than the note amount of ___ based on the ___ in file. | Lender to provide final title policy. | 2 | B | CA | Second Home | Refinance - Rate/Term | B | B | B | B | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438639299 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B Reviewer Comment (2022-04-26): Bank Statement income was based on [Redacted]months with a Fixed expense ratio of [Redacted]%. |
2 | B | CA | Second Home | Refinance - Rate/Term | B | B | B | B | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639297 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on 24 months with a Fixed Expense Ratio of 40%. | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B Reviewer Comment (2022-04-25): Bank Statement income was based on [Redacted] months with a fixed expense ratio of [Redacted]%. |
2 | B | CA | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639278 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-04-29): QM |
04/29/2022 | 1 | A | NY | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639278 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B Reviewer Comment (2022-05-19): Bank statement income loan, will remain EV2 Seller Comment (2022-04-29): CPA Letter for Sai Baba Consulting Services Inc for the Borrower. |
2 | B | NY | Primary | Purchase | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639278 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Verification of [Redacted]months housing history is missing | The representative FICO score exceeds the guideline minimum by at least 40 points. The qualifying DTI on the loan is at least 10% less than the guideline maximum. The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-04-25): Client elects to waive with compensating factors |
04/25/2022 | 2 | B | NY | Primary | Purchase | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438639281 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B Reviewer Comment (2022-04-26): The Bank Statement income was based on [Redacted] months with a Fixed Expense Ratio of [Redacted]%. |
2 | B | FL | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639281 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Non Escrowed Property Costs Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year [Redacted] of [Redacted]on Final Closing Disclosure provided on [Redacted] not accurate. | Non-escrowed property costs of $[Redacted]or $[Redacted]monthly were not verified in the file. | 2 | B | FL | Primary | Refinance - Cash-out - Other | Letter of Explanation & Corrected Closing Disclosure | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||||
| 438639300 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank statement income was based on [Redacted]months with a Fixed expense ratio of [Redacted]%. | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | FL | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639300 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Appraisal was sent to the borrower per Appraisal notice in file on [Redacted]. | 2 | B | FL | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438639300 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Creditor did not provide valuation for all Appraisal except for primary. valuation. | 2 | B | FL | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438639296 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Band Statement income was based on [Redacted] moths with an expense ratio of [Redacted]%. | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-05-06): . Seller Comment (2022-05-03): Please find attached income calc that shows [Redacted]% expense ratio. [Redacted] page 1467 |
2 | B | CA | Primary | Purchase | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639296 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $[Redacted]exceeds tolerance of $[Redacted]plus [Redacted]% or $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | [Redacted]% tolerance was exceeded by $[Redacted]due to an increase in recording fees. No valid COC provided, cure provided at closing. | Reviewer Comment (2022-04-27): Sufficient Cure Provided At Closing |
04/27/2022 | 1 | A | CA | Primary | Purchase | Final CD evidences Cure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639304 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Appraisal fee increased from $[Redacted]to $[Redacted]without a valid change of circumstance. A Credit of $[Redacted]was issued on the final Closing Disclosure. | Reviewer Comment (2022-04-26): Sufficient Cure Provided At Closing |
04/26/2022 | 1 | A | AZ | Second Home | Purchase | Final CD evidences Cure | A | A | A | A | A | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639294 | Credit | Borrower and Mortgage Eligibility | Mortgage / Program Eligibility | Borrower and Mortgage Eligibility | Guideline Requirement: Debt Service Coverage Ratio (Subject DSCR) discrepancy. | Calculated Debt Service Coverage Ratio (Subject DSCR) of ___ does not meet Guideline Debt Service Coverage Ratio (Subject DSCR) ___. | Comparable rents per appraisal is $[Redacted]. $[Redacted]was used to qualify at origination per approval | The representative FICO score exceeds the guideline minimum by at least 40 points. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. |
SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-07-14): Post funding exception received. Seller Comment (2022-07-14): XX agreed to purchase with the [Redacted] DSCR - was sold in our last trade Reviewer Comment (2022-05-02): Interest only payment is $[Redacted], Hazard insurance $[Redacted], Taxes $[Redacted], and HOA $[Redacted]monthly. [Redacted]/ [Redacted]= .[Redacted]DSCR. Exception remains Seller Comment (2022-05-02): Disagree - DSCR based on subject qualifying on an interest only Note |
07/14/2022 | 2 | B | CA | Investment | Purchase | C | B | C | B | A | A | N/A | No | ||||||||||||||
| 438639311 | Credit | Loan Package Documentation | Application / Processing | Insurance | Missing Document: Flood Certificate not provided | Reviewer Comment (2022-05-23): Received, Clearing. Seller Comment (2022-05-23): The attached flood cert is to cure the finding. |
05/23/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438639311 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | The file is missing a copy of the List of Homeownership Counseling Organizations. | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | CA | Primary | Refinance - Rate/Term | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639311 | Compliance | Compliance | Federal Compliance | TRID | TRID Settlement Service Provider Status | TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers. | The file is missing a copy of the Settlement Service Providers List. | Reviewer Comment (2022-05-23): [Redacted] Received Settlement service Provider List. |
05/23/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | No Defined Cure | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438639311 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Loan designation due to bank statements. | Reviewer Comment (2022-05-25): Loan is [Redacted]. |
05/25/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | Lender to provide updated ATR/QM status | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639311 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on [Redacted]months with a Fixed expense ratio of [Redacted]% | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B Reviewer Comment (2022-05-25): Regraded. Seller Comment (2022-05-25): Disagree - uploaded CA SOS |
2 | B | CA | Primary | Refinance - Rate/Term | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639311 | Credit | Title | General | Title | Title Policy Coverage is less than Original Loan Amount. | The Title Policy Amount of ___ is less than the note amount of ___ based on the ___ in file. | Lender to provide final title with a policy amount of $[Redacted]. | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | CA | Primary | Refinance - Rate/Term | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639311 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | The file is missing a copy of the phone listing and/or business address using directory assistance or internet search. | Reviewer Comment (2022-05-25): Received, Clearing. Seller Comment (2022-05-25): Disagree - uploaded secretary of state |
05/25/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639311 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Service Charges. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Title - Ucc Termination Advance (Service Charges) was not disclosed on Loan Estimate. The loan is missing a copy of the settlement servicer provider list. | Reviewer Comment (2022-05-23): [Redacted] Received Settlement Service Provider List therefore no cure required. Seller Comment (2022-05-20): Disagree - Borrower shopped, Title - Ucc Termination Fee Advance and was listed in Section C of CD p2 to reflect, no cure required. Attached is the Settlement Provider List disclosed and signed at the time of initial disclosures on [Redacted]. |
05/23/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639311 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $376.00 exceeds tolerance of $249.00 plus 10% or $273.90. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-05-25): Sufficient Cure Provided At Closing |
05/25/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | Final CD evidences Cure | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | |||||||||||||
| 438639312 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Not Have Escrow - Reason | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether the loan will have an [Redacted] account. | Final Closing Disclosure provided on [Redacted] did not disclose why the borrower will not have an [Redacted] account | Reviewer Comment (2022-05-05): [Redacted] Received PCCD and LOE. Seller Comment (2022-05-04): Disagree - uploaded PCCD and LOX |
05/05/2022 | 2 | B | CA | Primary | Refinance - Cash-out - Other | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639306 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - ATR | Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Fail. | Bank statements used to verify asset depletion income were expired at time of closing. Lender to provide updated statements. | Reviewer Comment (2022-06-03): Received, Clearing. Seller Comment (2022-06-03): Uploaded asset docs |
06/03/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | Lender to provide updated ATR/QM status | C | B | B | B | C | A | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438639306 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General Ability To Repay Provision Income and Assets - Asset Depletion Income | Ability to Repay (Dodd-Frank 2014): Unable to verity asset depletion income due to, bank statement provided was dated more than [Redacted]days prior to closing. | Bank statements used to verify asset depletion income were expired at time of closing. Lender to provide updated statements. | Reviewer Comment (2022-06-03): Received, Clearing. Seller Comment (2022-06-03): Uploaded balance stmt on account used for income dated [Redacted] within acceptable expiration date guidelines. |
06/03/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | C | B | B | B | C | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438639306 | Compliance | Compliance | Federal Compliance | ATR/QM | NonQM ATR | Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied. | Bank statements used to verify asset depletion income were expired at time of closing. Lender to provide updated statements. | Reviewer Comment (2022-06-03): Received, Clearing. |
06/03/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | C | B | B | B | C | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438639306 | Credit | Insurance | Insurance Analysis | Insurance | Hazard Insurance Policy expires within 90 days of the Note Date. | Hazard Insurance Policy Expiration Date ___, Note Date ___ | HOI expires [Redacted] - lender to provide proof the policy is active for at least [Redacted]days after closing. | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | CA | Primary | Refinance - Rate/Term | C | B | B | B | C | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438639313 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-05-19): [Redacted] Seller Comment (2022-05-19): See XXXX Statements from XXXX Acct with 140k [Redacted]Not used in loan. Added account. Attached are Bank Statements, 1003, & 1008. Reviewer Comment (2022-05-06): Bank statement income exception will be revisited once all guideline exceptions have been addressed Seller Comment (2022-05-06): Disagree - uploaded Income calc shows using [Redacted]% expense ration and narrative shows the reason for that, both are in the file, visionnet page [Redacted]-[Redacted]and [Redacted] |
05/19/2022 | 1 | A | CA | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639313 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B Reviewer Comment (2022-05-19): Downgraded. Seller Comment (2022-05-19): See XXXX Statements from XXXX Acct with 140k [Redacted] Not used in loan. Added account. Attached are Bank Statements, 1003, & 1008. Reviewer Comment (2022-05-06): Bank statement income exception will be revisited once all guideline exceptions have been addressed Seller Comment (2022-05-06): Disagree - uploaded Income calc shows using [Redacted]% expense ration and narrative shows the reason for that, both are in the file, visionnet page [Redacted]-[Redacted]and [Redacted] |
2 | B | CA | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639313 | Credit | Title | Document Error | Title | The Preliminary title policy is within CA or NV and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropiate coverage is provided. | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | CA | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||||
| 438639313 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Reviewer Comment (2022-05-19): Received, Clearing. Reviewer Comment (2022-05-19): Assets provided ending 4288 is not seasoned 60 days from the note date. Unable to use these assets. Exception remains Seller Comment (2022-05-19): See XXXX Statements from XXXX Acct with 140k [Redacted] Not used in loan. Added account. Attached are Bank Statements, 1003, & 1008. Reviewer Comment (2022-05-06): Calculated cash to close is [Redacted]. Breakdown : Total Closing costs - [Redacted], Down Payment [Redacted], - Seller Credits [Redacted] - adjustments and other credits [Redacted] + [Redacted] Gift. Verified [Redacted]in total gift, [Redacted]in EMD and [Redacted] from checking.[Redacted] - [Redacted] = [Redacted] remaining / [Redacted] required Seller Comment (2022-05-06): Rebut: Verified Assets: [Redacted] Closing Cost: [Redacted] Reserves: [Redacted]*[Redacted]=[Redacted] [Redacted] [Redacted] Seller Comment (2022-05-06): Disagree - uploaded DU showing : Verified Assets: [Redacted] Closing Cost: [Redacted] Reserves: [Redacted]*[Redacted]=[Redacted] [Redacted]-[Redacted]= [Redacted] [Redacted]-[Redacted]=[Redacted] |
05/19/2022 | 1 | A | CA | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438820779 | Credit | Compliance | Miscellaneous Compliance | Compliance | Transaction Error: Total Cash-out on a purchase transaction. | Gift of Equity of $[Redacted] plus seller credits of $[Redacted]result in cashback to borrower on CD of (-$[Redacted]), although a purchase transaction. | Reviewer Comment (2022-07-29): Received, Clearing. Seller Comment (2022-07-29): Disagree - overage was returned to the seller as shown on the wire and updated settlement statement |
07/29/2022 | 1 | A | AZ | Second Home | Purchase | C | B | C | B | A | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820779 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | First Time Home Buyer buying a second home. | The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-08-08): Exception in the loan file. |
08/08/2022 | 2 | B | AZ | Second Home | Purchase | C | B | C | B | A | A | A | A | Non QM | Non QM | No | ||||||||||||
| 438639285 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on [Redacted]months with a fixed expense ratio of [Redacted]%. | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | WA | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639317 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Loan Estimate Timing Electronically Provided | TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated [Redacted] was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations. | App date was [Redacted], LE provided [Redacted], E sign consent date was [Redacted]. | Reviewer Comment (2022-05-09): [Redacted] Received earliest [Redacted]. Seller Comment (2022-05-06): Disagree - Initial LE was issued and manually fulfilled on [Redacted]; Borrower has consented and viewed on the same date which is within the 3 business days of the application date of [Redacted], uploaded screenshots and DM Cert |
05/09/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Non QM | Non QM | No | |||||||||||||
| 438639317 | Compliance | Compliance | Federal Compliance | Missing Disclosure | Notice of Special Flood Hazard Disclosure Not Provided Timely | FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing. | Disclosure was signed on [Redacted] at closing. | Reviewer Comment (2022-06-14): Accepted as is per client |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Non QM | Non QM | No | ||||||||||||||
| 438639317 | Credit | Asset | Asset Calculation / Analysis | Asset | Available for Closing is insufficient to cover Cash From Borrower. | IRA on file is not in the borrower's name. Provide sufficient assets to close. | Reviewer Comment (2022-05-13): Received, Clearing. Seller Comment (2022-05-13): Received Signed [Redacted]/Full Access letter from wife. See Attached |
05/13/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Non QM | Non QM | No | ||||||||||||||
| 438639317 | Credit | Asset | Asset Calculation / Analysis | Asset | Available for Closing is insufficient to cover Cash From Borrower. | Access letter received for IRA account is insufficient as borrower is not on the account. There is a business account on file however, we would need a CPA letter stating withdrawal would not negatively impact the business. Funds to close are still insufficient. | Reviewer Comment (2022-06-14): Access letter from wife sufficient in community property state |
06/14/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Non QM | Non QM | No | ||||||||||||||
| 438639314 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or .[Redacted]%). | Reviewer Comment (2022-05-09): Received, Clearing. Seller Comment (2022-05-09): undiscounted rate/price: [Redacted]. Compliance test showing a pass with bona fide points |
05/09/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639314 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B Reviewer Comment (2022-05-09): Bank Statement income was based on 24 months with a fixed expense ratio of [Redacted]. |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438639308 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Lender Credit Tolerance Violation | TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-[Redacted]is less than amount of binding Lender Credit previously disclosed in the amount of $-[Redacted]. | No valid change in circumstance for this fee change | Reviewer Comment (2022-05-12): [Redacted] received Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD. Seller Comment (2022-05-10): Agree - uploaded PCCD, LOX, shipping label and check |
05/12/2022 | 2 | B | CA | Second Home | Refinance - Cash-out - Home Improvement | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639308 | Credit | Property - Appraisal | Appraisal Reconciliation | Property - Appraisal | Status of property as second home is in question due to distance from primary residence. | Subject is approx [Redacted] miles from borrower's primary residence in non resort area. Occupancy as second home needs additional documentation / comments from lender. | The representative FICO score exceeds the guideline minimum by at least 40 points. The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-08-01): Client exception. Reviewer Comment (2022-07-12): Due to how close the primary and secondary house are to each other a exception from AG will be required to resolve this exception. Seller Comment (2022-07-12): See LOX from borrower, verified via Google the property is not listed for rent Reviewer Comment (2022-06-15): Re-opened. Explanation regarding subject property distance from primary residence not received Reviewer Comment (2022-05-11): Received, Clearing. Seller Comment (2022-05-11): Disagree - uploaded LOE for address variations |
08/01/2022 | 2 | B | CA | Second Home | Refinance - Cash-out - Home Improvement | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438639308 | Credit | Income / Employment | Income Eligibility | Income / Employment | Employment/Income Error: Employment or Income source is unlikely to continue. | Income from sole proprietorship was used to qualify, borrower receives 1099s. WVOE from the company providing the 1099s shows income as "unlikely to continue." Based on file documents, the stability of the income questionable. | Reviewer Comment (2022-05-11): Received, Clearing. Seller Comment (2022-05-11): Disagree - uploaded LOE for employment |
05/11/2022 | 1 | A | CA | Second Home | Refinance - Cash-out - Home Improvement | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639308 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM Provision Investor Guidelines Violation | General QM: Based on the loan failing one or more guideline components, the loan is at QM risk. | Due to income concerns - see income exceptions. | Reviewer Comment (2022-05-12): Received, Cleared Buyer Comment (2022-05-12): The income exception appears to have been cleared - this should clear with it, correct? |
05/12/2022 | 1 | A | CA | Second Home | Refinance - Cash-out - Home Improvement | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639308 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Risk. | Due to income concerns - see income exceptions. | Reviewer Comment (2022-05-12): Received, Cleared Buyer Comment (2022-05-12): The income exception appears to have been cleared - this should clear with it, correct? |
05/12/2022 | 1 | A | CA | Second Home | Refinance - Cash-out - Home Improvement | Lender to provide updated ATR/QM status | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639308 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - | Lender to provide tax cert for borrower's primary residence. | Reviewer Comment (2022-05-31): Tax cert received Seller Comment (2022-05-31): Exception approved. Reviewer Comment (2022-05-27): Reopen as doesn't resolve mileage issue. Reviewer Comment (2022-05-11): Received, Clearing. Seller Comment (2022-05-11): Taxes for [Redacted] |
05/31/2022 | 1 | A | CA | Second Home | Refinance - Cash-out - Home Improvement | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639316 | Credit | Title | Document Error | Title | The Preliminary title policy is within CA or NV and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropiate coverage is provided. | Lender to provide final title cert. | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | CA | Primary | Refinance - Cash-out - Other | B | B | B | B | A | A | A | A | Non QM | Non QM | No | |||||||||||||||
| 438639315 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - | Tax Verification is not in the file. | Reviewer Comment (2022-05-16): Received, cleared Seller Comment (2022-05-16): Disagree - uploaded tax documentation |
05/16/2022 | 1 | A | CA | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | A | A | N/A | N/A | No | |||||||||||||
| 438639325 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank statement income based on 24 months' statements with fixed expense factor of 20%. | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639325 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Loan Estimate Timing Electronically Provided | TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations. | Borrower consented to electronic disclosures on [Redacted], LE sent [Redacted]. | Reviewer Comment (2022-05-19): [Redacted] received comment that the fulfilment means that they have send hard copy through mail. Seller Comment (2022-05-17): Disagree - Unless requested otherwise, initial disclosure packages are issued electronically, which requires an applicant to first authorize consent to receive electronic disclosures, prior to accessing the application & disclosure package. This 2 step process is compliant with the provisions of the E-Sign Act. To further ensure timing compliance, XXXX utilizes the DocMagic manual fulfillment process. Manual fulfillment automatically mails out a hard copy disclosure package when the applicant has not picked up the electronic message Reviewer Comment (2022-05-16): [Redacted] Provide Attestation what does Fulfillment date means and method of delivery for Initial Disclosures. Seller Comment (2022-05-13): Review: The Initial Disclosure Package was manually fulfilled on [Redacted] which was within the 3 business days of the application dated [Redacted]. Borrower's prior consent to receive electronic disclosures is not required. See attached screen shots of [Redacted] Section 6: Acknowledgement and Agreement. |
05/19/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639325 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Bank statement income based on [Redacted]months' statements with expense factor of [Redacted]%. | Reviewer Comment (2022-06-02): Loan is SHQM(APOR). |
06/02/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM status | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639325 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Provide 3rd party verification borrower has been self employed for at least [Redacted] years. | Reviewer Comment (2022-06-02): Received, Clearing. Seller Comment (2022-06-02): Uploaded 3rd party verification |
06/02/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639293 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or .[Redacted]%). | Reviewer Comment (2022-06-02): Restated to NonQM Buyer Comment (2022-05-31): Loan was intended to be originated as NQM, please restate |
06/02/2022 | 1 | A | NM | Primary | Refinance - Cash-out - Home Improvement | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||||
| 438639293 | Compliance | Compliance | Federal Compliance | RESPA | RESPA - Initial Escrow Account statement Inaccurate | RESPA: Initial escrow account statement does not match charges on HUD-1/Final Closing Disclosure. | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | NM | Primary | Refinance - Cash-out - Home Improvement | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | |||||||||||||||
| 438639293 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Verified Loan Designation as Safe Harbor QM | Reviewer Comment (2022-06-02): Restated to NonQM |
06/02/2022 | 1 | A | NM | Primary | Refinance - Cash-out - Home Improvement | Lender to provide updated ATR/QM status | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639293 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $[Redacted]exceeds tolerance of $[Redacted]plus [Redacted]% or $[Redacted]. Insufficient or no cure was provided to the borrower. | Verified no sufficient cure was provided to Borrower | Reviewer Comment (2022-06-01): Sufficient cure on file Reviewer Comment (2022-05-27): [Redacted] upon further review received PCCD moving the fee to sec C however the PCCD also shows cure for [Redacted] was provided please provide copy of refund check, proof of mailing & LOE for cure amount and also provide detailed LOE specifying the fees moved from sec B to sec C. Seller Comment (2022-05-27): Clerical error, no Cure required. Uploaded PCCD provided to show Borrower shopped Title Company thus associated fees moved to Section C. |
06/01/2022 | 1 | A | NM | Primary | Refinance - Cash-out - Home Improvement | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639293 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure - 1026.19(f)(2) Cure | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $[Redacted] exceeds tolerance of $[Redacted]plus 1[Redacted]% or $[Redacted]. Sufficient or excess cure was provided to the borrower. | Sufficient cure on file | Reviewer Comment (2022-06-01): Sufficient Cure Provided within [Redacted] of Closing |
06/01/2022 | 1 | A | NM | Primary | Refinance - Cash-out - Home Improvement | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | |||||||||||||
| 438639293 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - General Ability to Repay | Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not match. However, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. | Restated to NonQM | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | NM | Primary | Refinance - Cash-out - Home Improvement | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||||
| 438639295 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CT | Primary | Purchase | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639295 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Closing Disclosure Timing without Waiver | TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. | Evidence of earlier receipt is missing from the file | Reviewer Comment (2022-05-26): [Redacted] received lender attestation that 3-28 CD not disclosed to borrower. Seller Comment (2022-05-24): Disagree - [Redacted], the loan officer requested XXXX to generate the initial CD and uploaded Prelim CD dated [Redacted] for title info along with Credit invoice. [Redacted] CD not provided to borrower by XXXX, uploaded disclosure & audit history showing Initial CD disclosed [Redacted] and signed by both borrowers same day Reviewer Comment (2022-05-20): The initial CD in file is dated [Redacted]. Please provide receipt if available. Buyer Comment (2022-05-18): Disagree - Initial CD was edisclosed on Tuesday, [Redacted] which both borrowers viewed and signed same day, Final CD and closing executed on Friday, [Redacted] is in compliance with the timing requirement. |
05/26/2022 | 1 | A | CT | Primary | Purchase | No Defined Cure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438639292 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted] on a Federal Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted] (an overage of $[Redacted]or .[Redacted]%). | Loan fails QM due due points and fees. | Reviewer Comment (2022-06-01): Received, Clearing. Buyer Comment (2022-06-01): undiscounted rate price: [Redacted]. Loan passes compliance testing with bona fide discount |
06/01/2022 | 1 | A | NY | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639292 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 Test | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of [Redacted] on Final Closing Disclosure provided on [Redacted] not accurate. | Verified $[Redacted]quarterly taxes and $[Redacted]in monthly HOI, which equals $[Redacted]. The final CD reflects property costs of $[Redacted] | Reviewer Comment (2022-08-31): Accepted as is. |
2 | B | NY | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | |||||||||||||
| 438639292 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Reviewer Comment (2022-08-31): SHQM(APOR) Reviewer Comment (2022-06-03): This will be addressed when Open (Grade 3): Missing Document/GeneralMissing Document: VISA not provided is fixed. Buyer Comment (2022-06-03): points/fees condition cleared - this should as well |
08/31/2022 | 1 | A | NY | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639292 | Credit | Credit | Credit Documentation | Guideline | Missing Document: Verification of Rent (VOR) / Verification of Mortgage (VOM) not provided | VOR in the form of cancelled checks or bank statements was not provided | The representative FICO score exceeds the guideline minimum by at least 40 points. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-05-13): Client elects to waive with compensating factors |
05/13/2022 | 2 | B | NY | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438639292 | Credit | Missing Document | General | Missing Document | Missing Document: VISA not provided | Missing valid Visa documentation. Per employment authorization cards for both borrower's on file, visa category is CO8, which is an invalid [Redacted]type. | The representative FICO score exceeds the guideline minimum by at least 40 points. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-08-31): Client approved exception. Seller Comment (2022-08-30): Document attached. |
08/31/2022 | 2 | B | NY | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438639292 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on [Redacted] months with a Fixed expense ratio of [Redacted]% | Reviewer Comment (2022-08-31): Accepted as is. Reviewer Comment (2022-06-24): Bank statement compliance exception cannot be downgraded until guideline exceptions are addressed Seller Comment (2022-06-24): The bank statements are from [Redacted] Bank, third-party records should be obtainable. The VISA Finding is not related to this finding and is Incurable and this finding regarding the third party records should be should be removed. Reviewer Comment (2022-06-22): Guideline exceptions should be addressed before bank statements income exception is downgraded Seller Comment (2022-06-22): The bank statements are from [Redacted] Bank, third-party records should be obtainable. This isn't part of the VISA Finding and should be cleared. Reviewer Comment (2022-06-07): General QM bank statement exception will be revisited once all other open guideline exceptions are addressed Seller Comment (2022-06-07): The bank statements are from [Redacted] Bank; SM-Email from [Redacted] on [Redacted] at [Redacted] PM; |
2 | B | NY | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639319 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or .[Redacted]%). | Loan fails QM due to points and fees. | Reviewer Comment (2022-06-06): Received, Clearing. Buyer Comment (2022-06-06): undiscounted rate/price: [Redacted] - loan passes with bona fide points |
06/06/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639319 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on [Redacted]months with a Fixed expense ratio of [Redacted]% | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639330 | Credit | Missing Document | General | Missing Document | Missing Document: Account Statements - Business not provided | Missing copy of [Redacted] bank statement | Reviewer Comment (2022-05-24): Unable to find in the original file, clearing with receipt. Seller Comment (2022-05-24): Disagree - uploaded Business statement [Redacted] was found on the Visionet file page 843 of 938. |
05/24/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||||
| 438639330 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or .[Redacted]%). | Points and fees total of $[Redacted]exceeds maximum of $[Redacted] | Reviewer Comment (2022-06-06): Restated. Buyer Comment (2022-06-06): Please restate as NonQM |
06/06/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||
| 438639330 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Points and fees total of $[Redacted]exceeds maximum of $[Redacted]. Provide documentation of undiscounted interest rate price. | Reviewer Comment (2022-06-06): Restated. |
06/06/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM status | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438639330 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Closing Disclosure Timing without Waiver | TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. | Evidence of earlier receipt was not found in file | Reviewer Comment (2022-05-25): [Redacted] received [Redacted] CD electronically signed earlier. Seller Comment (2022-05-23): Disagree - There was an Initial CD disclosed on [Redacted], which is 3 business days prior to the closing date of [Redacted].[Redacted] is attached showing Created Date, receipt & signature date of [Redacted], which allowed the required 3 business days for first eligible closing date. Executed [Redacted] dated [Redacted] is attached. Both CD's are attached. The [Redacted] dated [Redacted] is located on Pages 491-495 - see attached. |
05/25/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | No Defined Cure | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||
| 438639330 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - General Ability to Repay | Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not match. However, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. | Restated. | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||||
| 438639322 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Loan qualified using [Redacted]month bank statement income with a [Redacted]% fixed expense ratio. | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Purchase | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639322 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $[Redacted]exceeds tolerance of $[Redacted]plus [Redacted]% or $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | [Redacted]% tolerance was exceeded by $[Redacted]due to an increase in recording fees. No valid COC provided, cure provided at closing. | Reviewer Comment (2022-05-16): Sufficient Cure Provided At Closing |
05/16/2022 | 1 | A | CA | Primary | Purchase | Final CD evidences Cure | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639322 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Not Have Escrow - Reason | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether the loan will have an escrow account. | Final CD provided on [Redacted] did not disclose reason for the borrower note establishing an escrow account on page 4. | Reviewer Comment (2022-05-23): [Redacted] received post Cd and LOX, Seller Comment (2022-05-20): Disagree - uploaded PCCD and LOX |
05/23/2022 | 2 | B | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639322 | Credit | Title | Document Error | Title | The Preliminary title policy is within CA or NV and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropiate coverage is provided. | Lender to provide final title with a policy amount of $[Redacted]. | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | CA | Primary | Purchase | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438639331 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or .[Redacted]%). | Reviewer Comment (2022-06-06): Received, Clearing. Buyer Comment (2022-06-06): undiscounted rate price [Redacted] - loan passes with bona fide points |
06/06/2022 | 1 | A | NJ | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639331 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-05-13): Sufficient Cure Provided At Closing |
05/13/2022 | 1 | A | NJ | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | |||||||||||||
| 438639331 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on [Redacted]months with a Fixed expense ratio of [Redacted]% | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | NJ | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639323 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Loan qualified with each borrower using [Redacted]month bank statement income each with a [Redacted]% fixed expense ratio. | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Rate/Term | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639323 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Loan qualified with each borrower using [Redacted]month bank statement income each with a [Redacted]% fixed expense ratio. | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Rate/Term | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639329 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | [Redacted]upon further review sufficient cure provided at closing. | Reviewer Comment (2022-05-31): Sufficient Cure Provided At Closing |
05/31/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | A | A | A | A | A | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639320 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639318 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank statement income based on [Redacted]months' statements and [Redacted]% fixed expense factor. | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Cash-out - Other | B | B | B | B | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639318 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___. | The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%. Borrower has worked in the same position for more than 3 years. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-05-16): Client elects to waive with compensating factors |
05/16/2022 | 2 | B | CA | Primary | Refinance - Cash-out - Other | B | B | B | B | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438639321 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Rate/Term | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639328 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable (redacted)records. | The Bank Statement income was based on (redacted) with a Fixed Expense Ratio of(redacted) | Reviewer Comment (2022-07-19): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Rate/Term | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639327 | Credit | Loan Package Documentation | Application / Processing | Insurance | Missing Document: Flood Certificate not provided | Lender to provide flood cert for transaction. | Reviewer Comment (2022-05-23): Received, cleared Seller Comment (2022-05-23): Flood Certification is attached. |
05/23/2022 | 1 | A | PA | Second Home | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Higher Priced QM (APOR) | No | ||||||||||||||
| 438639327 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM Provision Income and Assets - Wages | General QM: Unable to verity income due to, missing W-2, Paystub, LES, ETS or WVOE. | Lender to provide WVOE or most current paystub and [Redacted]for borrower - no documents were in file. | Reviewer Comment (2022-06-07): Received, Clearing. Seller Comment (2022-06-07): The Work # used for income and verification. |
06/07/2022 | 1 | A | PA | Second Home | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Higher Priced QM (APOR) | No | |||||||||||||
| 438639327 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Lender to provide proof homeownership counseling disclosure was provided. | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | PA | Second Home | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Higher Priced QM (APOR) | No | ||||||||||||||
| 438639327 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Lender to provide WVOE or most current paystub and W2 for borrower - no documents were in file. | Reviewer Comment (2022-06-07): Received, Clearing. Seller Comment (2022-06-07): The Work # used for income and verification. |
06/07/2022 | 1 | A | PA | Second Home | Purchase | Lender to provide updated ATR/QM status | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Higher Priced QM (APOR) | Yes | ||||||||||||
| 438639327 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - QM / ATR | Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Higher Priced QM (APOR) matches the Due Diligence Loan Designation of Higher Priced QM (APOR). | . | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | PA | Second Home | Purchase | Lender to provide updated ATR/QM status | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Higher Priced QM (APOR) | No | |||||||||||||
| 438639332 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Lender Credit Tolerance Violation | TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-[Redacted]is less than amount of binding Lender Credit previously disclosed in the amount of $-[Redacted]. | Lender to provide proof of undiscounted rate to clear this. | Reviewer Comment (2022-05-27): [Redacted] received additional information on pricing updates for changed circumstance. Seller Comment (2022-05-25): Disagree - uploaded Front End Rate Lock showing lock suspended due to LTV and corresponding rate lock certificate Reviewer Comment (2022-05-24): [Redacted] received changed circumstance reflecting loan amount decrease. However, the lender credit did not change proportionately with the loan amount decrease and is not the valid reason for the lender credit decrease. Provide additional information for and reason for the decrease in the lender credit or cure would be due borrower. Seller Comment (2022-05-20): Disagree - uploaded COC [Redacted] for change in loan amount. Loan amount decreased causing lender credit to decrease as well. |
05/27/2022 | 1 | A | AZ | Second Home | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639332 | Credit | Insurance | Insurance Documentation | Insurance | Missing Document: Mortgage Insurance Certificate (MIC) not provided | Lender to provide MI cert for transaction. | Reviewer Comment (2022-05-23): Received, Clearing. Seller Comment (2022-05-23): There is No PMI on this product at [Redacted] LTV, mortgage insurance is not required. The DU is a FNMA product that we use as guidelines along with our XXXX guidelines allow [Redacted]. so the DU can not be changed. |
05/23/2022 | 1 | A | AZ | Second Home | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639332 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Escrowed Property Costs Year 1 - October 2018 Test | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on[Redacted] not accurate. | Lender to provide corrected CD. | Reviewer Comment (2022-05-24): [Redacted] received [Redacted] Corrected CD and LOE to borrower. Seller Comment (2022-05-20): Disagree - The amount disclosed on Final CD page 4, Escrowed Property Costs over Year one is correct. However, [Redacted] does not require MI and this amount has been removed from Estimated Total Monthly Payments on page 1 of the CD which was the cause for the variance, uploaded PCCD, LOX and Final SS. |
05/24/2022 | 1 | A | AZ | Second Home | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639332 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Mortgage Insurance Payment | TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [Redacted] disclosed a mortgage insurance payment for payment stream 1 that does not match the actual payment for the loan. | [Redacted]received [Redacted] Corrected CD and LOE to borrower. Revised for actual regulation failure that was cured with this PCCD | Reviewer Comment (2022-05-24): [Redacted] received Letter of Explanation & Corrected Closing Disclosure. |
05/24/2022 | 2 | B | AZ | Second Home | Purchase | TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639332 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Projected P&I Min Payment Fixed Rate Subsequent Payments | TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [Redacted] disclosed a periodic principal and interest payment for payment stream 2 that does not match the actual payment for the loan. | [Redacted]received [Redacted] Corrected CD and LOE to borrower. Revised for actual regulation failure that was cured with this PCCD | Reviewer Comment (2022-05-24): [Redacted] received Corrected CD and LOE to borrower. |
05/24/2022 | 1 | A | AZ | Second Home | Purchase | TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639339 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien | TRID Final Closing Disclosure [Redacted] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page [Redacted]. (Points and Fees testing limited to Borrower paid fees.) | Seller CD not provided and no seller paid fees disclosed on Final Closing Disclosure | Reviewer Comment (2022-05-27): [Redacted] received Seller CD Seller Comment (2022-05-25): Disagree - uploaded seller CD |
05/27/2022 | 1 | A | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639339 | Credit | Asset | Asset Documentation | Asset | Guideline Issue:Insufficient asset documentation. | - | Missing [Redacted]months statements for accounts ending [Redacted]and [Redacted]. | Reviewer Comment (2022-06-03): Received, Clearing. Seller Comment (2022-06-03): Uploaded verification of sale showing Funds for closing were from a sale of REO. The bank statements were only included to show deposit to borrower. No additional funds were used so 2 months full statements are not required. |
06/03/2022 | 1 | A | CA | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639339 | Credit | Missing Document | General | Missing Document | Missing Document: Donor Check not provided | Missing evidence of receipt and donor check for $[Redacted] gift | Reviewer Comment (2022-05-26): Received, Clearing. Seller Comment (2022-05-26): Disagree - uploaded proof receipt of gift funds sent directly to title |
05/26/2022 | 1 | A | CA | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639339 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on [Redacted]months with a Fixed expense ratio of [Redacted]%. | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | CA | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639339 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on [Redacted]months with a Fixed expense ratio of [Redacted]%. | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | CA | Primary | Purchase | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639339 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | . | Reviewer Comment (2022-06-23): Loan is SHQM(APOR). |
06/23/2022 | 1 | A | CA | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438820780 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Credit | Guideline Requirement: Maximum Loan Amount discrepancy. | Note loan amount of ___ is greater than Guideline maximum loan amount of ___. | The representative FICO score exceeds the guideline minimum by at least 40 points. The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-05-27): Pre-funding exception approved, waived with compensating factors. |
05/27/2022 | 2 | B | NY | Primary | Refinance - Rate/Term | B | B | B | B | A | A | A | A | Non QM | Non QM | No | ||||||||||||
| 438639337 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Loan approved using [Redacted]mont bank statement income with a [Redacted]% expense ratio. | Reviewer Comment (2022-05-24): Loan is SHQM(APOR). |
05/24/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM status | D | B | D | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639337 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on [Redacted]months with a Fixed expense ratio of [Redacted]%. | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Cash-out - Other | D | B | D | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639337 | Credit | Loan Package Documentation | Application / Processing | Missing Document | Missing Document: Other not provided | The AUS report in the file is DU approve/eligible, the signed UW Certificate of Agency Ineligibility (D0037) was signed and dated but missing any indication of eligibility or ineligibility selected. | Reviewer Comment (2022-05-24): Received, Clearing. Seller Comment (2022-05-24): Exception approved. |
05/24/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | D | B | D | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639341 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Transaction is delayed financing. Missing The sources of funds for the purchase transaction (such as bank statements, personal loan documents, or a HELOC on another property). | Reviewer Comment (2022-06-02): Received, Clearing. Seller Comment (2022-06-02): Borrower used the cash out on the refi to replenish his investment account. Source of funds - [Redacted] Bank account Reviewer Comment (2022-05-31): Received bank statements for account ending [Redacted]. Missing evidence funds used to pur[Redacted] the subject property came all from borrower funds. If the source of funds used to acquire the property was an unsecured loan or a loan secured by an asset other than the subject property (such as a HELOC secured by another property), the settlement statement for the refinance transaction must reflect that all cash-out proceeds be used to pay off or pay down, as applicable, the loan used to pur[Redacted] the property. Any payments on the balance remaining from the original loan must be included in the debt-to-income ratio calculation for the refinance transaction. Seller Comment (2022-05-31): Uploaded source of funds Reviewer Comment (2022-05-25): Exception approval received is for asset seasoning. Exception for source of funds remains Seller Comment (2022-05-25): This exception has been approved. |
06/02/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | C | B | A | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639341 | Credit | Asset | Asset Documentation | Asset | Asset documentation requirements not met. | Assets seasoning requirements for asset utilization not met | The representative FICO score exceeds the guideline minimum by at least 40 points. The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has verified disposable income of at least $2500.00. |
SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-05-17): Client elects to waive with compensating factors |
05/17/2022 | 2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | C | B | A | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438639338 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Purchase | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639333 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank statement income based on [Redacted]months' statements and an expense factor of [Redacted]% based on CPA's letter. | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | TN | Primary | Purchase | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639340 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of 3.05089% is in excess of the allowable maximum of 3.00000% of the Federal Total Loan Amount. Points and Fees total XXXX on a Federal Total Loan Amount of XXXX vs. an allowable total of XXXX (an overage of $545.44 or .05089%). | Loan fails QM due to points and fees. | Reviewer Comment (2022-06-06): Received, Clearing. Buyer Comment (2022-06-06): undiscounted rate/price: [Redacted]. Loan passes with bona fide points excluded |
06/06/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639340 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $[Redacted]exceeds tolerance of $[Redacted]plus [Redacted]% or $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Fee was out of tolerance with cure given. | Reviewer Comment (2022-05-17): Sufficient Cure Provided At Closing |
05/17/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639340 | Compliance | Compliance | Federal Compliance | Missing Disclosure | Notice of Special Flood Hazard Disclosure Not Provided Timely | FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing. | Notice was signed at closing | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639340 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B Reviewer Comment (2022-06-06): Bank Statement income was based on [Redacted] months with a Fixed expense ratio of [Redacted] |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438639334 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Non Escrowed Property Costs Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on[Redacted] not accurate. | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | CA | Primary | Refinance - Cash-out - Other | Letter of Explanation & Corrected Closing Disclosure | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||||
| 438639336 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B Reviewer Comment (2022-05-17): Bank Statement income was based on [Redacted] months with a fixed expense ratio of [Redacted]. |
2 | B | CA | Primary | Refinance - Cash-out - Other | A | B | A | A | A | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438639343 | Credit | Title | Document Error | Title | The Preliminary title policy is within CA or NV and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropiate coverage is provided. | Reviewer Comment (2022-07-28): Accepted as is |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||||
| 438639343 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or .[Redacted]%). | Points and fees total of $[Redacted]exceeds Federal allowable total of $[Redacted] (overage of $[Redacted]) | Reviewer Comment (2022-06-06): Loan passes with undiscounted rate and price provided Buyer Comment (2022-06-06): undiscounted rate/price: [Redacted] - loan passes with bona fide discount points |
06/06/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639343 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Loan Estimate Timing Electronically Provided | TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated [Redacted] was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations. | Reviewer Comment (2022-05-25): [Redacted] received initial LE and also we have e-consent which is within time frame. Seller Comment (2022-05-24): Disagree - Application Date of [Redacted] and Initial Disclosure Package was issued on [Redacted]. Borrower has received/consented/esigned the Initial Disclosure Package on [Redacted], which is within 3 business days of application |
05/25/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639343 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B Reviewer Comment (2022-06-06): Bank Statement income was based on [Redacted]24 months with a Fixed expense ratio of [Redacted] |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639342 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank statement based on [Redacted]months' statements and fixed expense factor of [Redacted]%. | Reviewer Comment (2022-07-28): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639342 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Fee out of tolerance with cure provided. | Reviewer Comment (2022-05-18): Sufficient Cure Provided At Closing |
05/18/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639350 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank statement income was based on [Redacted]months' statement and fixed expense factor of [Redacted]%. | Reviewer Comment (2022-08-17): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B Reviewer Comment (2022-06-03): Regraded. Seller Comment (2022-06-03): uploaded all docs on both businesses were in file |
2 | B | FL | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639350 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank statement income was based on [Redacted]months' statement and a fixed expense factor of [Redacted]%. | Reviewer Comment (2022-08-17): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B Reviewer Comment (2022-06-03): Regraded. Seller Comment (2022-06-03): Uploaded all docs on both businesses were in file |
2 | B | FL | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639350 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank statement income was based on [Redacted]months' statement and a fixed expense factor of [Redacted]%. | Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B Reviewer Comment (2022-06-03): Regraded. Seller Comment (2022-06-03): Uploaded all docs on both businesses were in file |
06/03/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639350 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Fee was out of tolerance with sufficient cure. | Reviewer Comment (2022-06-01): Sufficient Cure Provided At Closing |
06/01/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639350 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Originator Loan Designation of Safe Harbor QMBank statement income was based on [Redacted]months' statement and expense factor of [Redacted]%. (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Reviewer Comment (2022-06-03): Loan is SHQM(APOR). |
06/03/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM status | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639350 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Missing a letter from the CPA or tax-preparer must stating that the withdrawal will not negatively impact the business in order to use business funds | Reviewer Comment (2022-06-03): Received, Clearing. Seller Comment (2022-06-03): Uploaded LOX |
06/03/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639351 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on [Redacted]months with a fixed expense ratio of [Redacted]%. | Reviewer Comment (2022-08-17): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | TX | Second Home | Purchase | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639351 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Other Includes Insurance Costs | TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [Redacted] disclosed whether Homeowners insurance is included in escrow in incorrect section. Creditor disclosed insurance to consumer in "Other" section where regulation requires disclosure under "Homeowner's Insurance" section of Projected Payments table. Disclosure requirement met, non-material exception for incorrect format/placement. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | TX | Second Home | Purchase | Good Faith Redisclosure | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||||
| 438639355 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-08-17): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Rate/Term | B | B | B | B | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639355 | Credit | Title | Document Error | Title | The Preliminary title policy is within CA or NV and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropiate coverage is provided. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | CA | Primary | Refinance - Rate/Term | B | B | B | B | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||||
| 438639352 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on [Redacted]months with a Fixed expense ratio of [Redacted]% | Reviewer Comment (2022-08-17): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Rate/Term | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639352 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on [Redacted]months with a Fixed expense ratio of [Redacted]% | Reviewer Comment (2022-08-17): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Rate/Term | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639352 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on [Redacted]months with a Fixed expense ratio of [Redacted]% | Reviewer Comment (2022-08-17): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Rate/Term | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639352 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on [Redacted]months with a Fixed expense ratio of [Redacted]% | Reviewer Comment (2022-08-17): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Rate/Term | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639352 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on [Redacted]months with a Fixed expense ratio of [Redacted]% | Reviewer Comment (2022-08-17): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Rate/Term | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639352 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Non Escrowed Property Costs Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on [Redacted] not accurate. | Appraisal shows HOA dues at [Redacted]a month, the other appraiser shows [Redacted]a month and [Redacted]is what is being used as the HOA amount. provide proof off actual HOA dues to correct property cost per year. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | CA | Primary | Refinance - Rate/Term | Letter of Explanation & Corrected Closing Disclosure | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | |||||||||||||
| 438820783 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR [Redacted], or [Redacted]. Non-Compliant Higher Priced Mortgage Loan. | Higher priced loan. | Reviewer Comment (2022-07-16): Received, Clearing. |
07/16/2022 | 1 | A | TX | Primary | Purchase | C | A | A | A | C | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438820783 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Flipped Property - Did Not Obtain 2 Appraisals) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Flipped Property - Creditor did not obtain two (2) written appraisals. | Property sold to seller in [Redacted] for [Redacted] per appraisal - lender to provide satisfactory documentation to prove transaction meets flip guides, | Reviewer Comment (2022-07-16): Received, Clearing. Reviewer Comment (2022-07-06): This will be discussed during call tomorrow as [Redacted] has provided there stance in email prior. Seller Comment (2022-07-06): Settlement statement for the sale to Opendoor Reviewer Comment (2022-06-30): The appraisal is showing as [Redacted] on [Redacted] which is what we have entered. Please confirm if there is any further information on the prior sale to ensure we have that information accurate. This requirement is under the TILA HPML rules. Please see full regulatory text below. • In general. Except as provided in paragraphs (c)(2) and (c)(4)(vii) of this section, a creditor shall not extend a higher-priced mortgage loan to a consumer to finance the acquisition of the consumer's principal dwelling without obtaining, prior to consummation, two written appraisals, if: • * (A)The seller acquired the property [Redacted] or fewer days *prior to the date of the consumer's agreement to acquire the property and the price in the consumer's agreement to acquire the property exceeds the seller's acquisition price by more than [Redacted] percent; or • * (B)The *seller acquired the property [Redacted] to [Redacted] days prior to the date of the consumer's agreement to acquire the property and the price in the consumer's agreement to acquire the property exceeds the seller's acquisition price by more than [Redacted] percent. The Contract Date on this file of [Redacted] is [Redacted] days from the Last Sale Date of [Redacted], and the price increased from [Redacted] to [Redacted], which is clearly above the [Redacted]. Based on our current data, this exception is valid based on the last sale date and our current contract date, which are the required dates to use per the regulation provided above. Seller Comment (2022-06-29): The Date of Prior Sale/Transfer is [Redacted] the[Redacted] is the effective date of the source, on page 3 of PDF for the CORRECT appraisal. Reviewer Comment (2022-06-29): The appraisal provided is not for the subject borrower or property. Seller Comment (2022-06-29): The property had a quit claim deed done on, and has had 1 purchase in [Redacted] months per the appraisal which is the purchase on [Redacted]. It explains it on page 4 of the PDF. This is not a flip. Reviewer Comment (2022-06-29): Per appraisal the last transfer was [Redacted] for [Redacted] and fraud report provided doesn't reflects the same. Seller Comment (2022-06-29): This property is not a true flip situation, the prior purchase closed on [Redacted] for [Redacted], which is over [Redacted] months and [Redacted] days ago. A flip is when you buy a home from a seller who bought that home less than [Redacted] months ago and paid over [Redacted] percent more if within [Redacted] days or [Redacted] percent more within [Redacted] to [Redacted] days. In this case we are over [Redacted] days since the prior purchase as our loan closed and funded on [Redacted]. We attached the drive report for further review of prior sale that was cleared for any flipping issues. |
07/16/2022 | 1 | A | TX | Primary | Purchase | C | A | A | A | C | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438639345 | Compliance | Compliance | State Compliance | State Defect | (State High Cost Provision) New York High-Cost Loan (Ability to Repay not Verified) | New York High-Cost Loan: Borrower's ability to repay not verified with reliable documentation. | Reviewer Comment (2022-06-10): Excluded Borrower's Attorney fee per New York Consolidated Laws, Banking Law - BNK § 6-l. High-cost home loans 1(f)(i). |
06/10/2022 | 1 | A | NY | Primary | Purchase | No obvious cure | C | B | B | B | C | B | A | A | Non QM | Non QM | No | |||||||||||||
| 438639345 | Compliance | Compliance | State Compliance | State Defect | (State High Cost Disclosure) New York High-Cost Loan (High Cost Legend Not on Mortgage) | New York High-Cost Loan: Mortgage does not contain legend advising loan is high-cost. | Reviewer Comment (2022-06-10): Excluded Borrower's Attorney fee per New York Consolidated Laws, Banking Law - BNK § 6-l. High-cost home loans 1(f)(i). |
06/10/2022 | 1 | A | NY | Primary | Purchase | Within 30 days of closing, provide: (1) Signed letter from borrower indicating their choice to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (2) Assuming option (a) is selected, a copy of refund check and proof of mailing; (3) Assuming option (b) is selected, proof of cure for each of the prohibited practice violations noted. (Narrow Defense - CHD Approval Required) Within 60 days of discovery, and prior to lender receiving any notice from borrower of the compliance failure, provide: (1) Lender Attestation to AMC confirming (a) no action or receipt of written notice of failure has been received; and (b) the failure was not intentional and was a bona fide error notwithstanding procedures in place to prevent such loans from being made (specific explanation about high-cost loan was made despite controls is required); (2) Signed letter from borrower indicating their choice to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (3) Assuming option 2(a) is selected, a copy of refund check and proof of mailing; (3) Assuming option 2(b) is selected, proof of cure for each of the prohibited practice violations noted. |
C | B | B | B | C | B | A | A | Non QM | Non QM | No | |||||||||||||
| 438639345 | Compliance | Compliance | State Compliance | State Defect | (State High Cost Disclosure) New York High-Cost Loan (Shop Around Notice Not on Loan Application) | New York High-Cost Loan: Mandatory "Shop Around" Notice not included on loan application to applicant. | Reviewer Comment (2022-06-10): Excluded Borrower's Attorney fee per New York Consolidated Laws, Banking Law - BNK § 6-l. High-cost home loans 1(f)(i). |
06/10/2022 | 1 | A | NY | Primary | Purchase | No obvious cure | C | B | B | B | C | B | A | A | Non QM | Non QM | No | |||||||||||||
| 438639345 | Compliance | Compliance | State Compliance | State Defect | (State High Cost Disclosure) New York High-Cost Loan (Disclosure of Taxes and Insurance Not Provided) | New York High-Cost Loan: Disclosure of Taxes and Insurance not provided to borrower. | Reviewer Comment (2022-06-10): Excluded Borrower's Attorney fee per New York Consolidated Laws, Banking Law - BNK § 6-l. High-cost home loans 1(f)(i). |
06/10/2022 | 1 | A | NY | Primary | Purchase | Within 30 days of closing, provide: (1) Signed letter from borrower indicating their choice to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (2) Assuming option (a) is selected, a copy of refund check and proof of mailing; (3) Assuming option (b) is selected, proof of cure for each of the prohibited practice violations noted. (Narrow Defense - CHD Approval Required) Within 60 days of discovery, and prior to lender receiving any notice from borrower of the compliance failure, provide: (1) Lender Attestation to AMC confirming (a) no action or receipt of written notice of failure has been received; and (b) the failure was not intentional and was a bona fide error notwithstanding procedures in place to prevent such loans from being made (specific explanation about high-cost loan was made despite controls is required); (2) Signed letter from borrower indicating their choice to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (3) Assuming option 2(a) is selected, a copy of refund check and proof of mailing; (3) Assuming option 2(b) is selected, proof of cure for each of the prohibited practice violations noted. |
C | B | B | B | C | B | A | A | Non QM | Non QM | No | |||||||||||||
| 438639345 | Compliance | Compliance | State Compliance | State Defect | (State High Cost) New York High-Cost Loan (Points and Fees) | New York Anti-Predatory Lending Statute: Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Total Loan Amount. Points and Fees total $[Redacted]on a Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or .[Redacted]%). Non-Compliant High Cost Loan. | Reviewer Comment (2022-06-10): Excluded Borrower's Attorney fee per New York Consolidated Laws, Banking Law - BNK § 6-l. High-cost home loans 1(f)(i). |
06/10/2022 | 1 | A | NY | Primary | Purchase | C | B | B | B | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||||
| 438639345 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Non Escrowed Property Costs Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on [Redacted] not accurate. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | B | B | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||||
| 438639345 | Compliance | Compliance | State Compliance | State Defect | (State High Cost Disclosure) New York High-Cost Loan (Consumer Caution and Home Ownership Counseling Notice Not Provided Timely) | New York High-Cost Loan: Borrower not provided with Consumer Caution and Home Ownership Counseling Notice within three (3) business days of high-cost application and at least ten (10) business days before closing. | Borrower not provided with Consumer Caution and Home Ownership Counseling Notice within three (3) business days of high-cost application and at least ten (10) business days before closing. | Reviewer Comment (2022-06-10): Excluded Borrower's Attorney fee per New York Consolidated Laws, Banking Law - BNK § 6-l. High-cost home loans 1(f)(i). |
06/10/2022 | 1 | A | NY | Primary | Purchase | No obvious cure | C | B | B | B | C | B | A | A | Non QM | Non QM | No | ||||||||||||
| 438639345 | Compliance | Compliance | State Compliance | State Defect | (State High Cost Disclosure) New York High-Cost Loan (Counseling Disclosure Not Provided Timely) | New York High-Cost Loan: Counseling Disclosure not provided to borrower at time of application. | Counseling Disclosure not provided to borrower at time of application. | Reviewer Comment (2022-06-10): Excluded Borrower's Attorney fee per New York Consolidated Laws, Banking Law - BNK § 6-l. High-cost home loans 1(f)(i). |
06/10/2022 | 1 | A | NY | Primary | Purchase | No obvious cure | C | B | B | B | C | B | A | A | Non QM | Non QM | No | ||||||||||||
| 438639345 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | First-time Homebuyers require 12 months of recent rental payment history reflecting 0x30 must be documented with cancelled checks and / or bank statement activity. | The representative FICO score exceeds the guideline minimum by at least 40 points. The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-06-06): Prefunding exception. Waived with compensating factors |
06/06/2022 | 2 | B | NY | Primary | Purchase | C | B | B | B | C | B | A | A | Non QM | Non QM | No | ||||||||||||
| 438639345 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Non-warrantable condo does not meet guidelines. The project documents do not provide that amendments of a material adverse nature to mortgagees be agreed to by mortgagees that represent at least [Redacted]% of the votes of unit estates that are subject to mortgages. | The representative FICO score exceeds the guideline minimum by at least 40 points. The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-06-06): Prefunding exception. Waived with compensating factors |
06/06/2022 | 2 | B | NY | Primary | Purchase | C | B | B | B | C | B | A | A | Non QM | Non QM | No | ||||||||||||
| 438639345 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-06-06): Sufficient Cure Provided At Closing |
06/06/2022 | 1 | A | NY | Primary | Purchase | Final CD evidences Cure | C | B | B | B | C | B | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438639345 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-06-06): Sufficient Cure Provided At Closing |
06/06/2022 | 1 | A | NY | Primary | Purchase | Final CD evidences Cure | C | B | B | B | C | B | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438639354 | Credit | Credit | Credit Documentation | Guideline | Aged document: Credit Report is more than 90 days prior to the note date. | - | Reviewer Comment (2022-06-09): Clearing. Buyer Comment (2022-06-09): Please update the status to cleared. Reviewer Comment (2022-06-07): Not found in original file, clearing exception. Seller Comment (2022-06-07): Uploaded credit report which was already in file |
06/09/2022 | 1 | A | CO | Primary | Purchase | C | B | C | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639354 | Compliance | Compliance | State Compliance | Misc. State Level | Colorado Home Loan (Ability to Repay not Verified) | Colorado Home Loan (HB1322): Borrower's ability to repay not verified with reliable documentation. | Assets depletion loan. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | CO | Primary | Purchase | C | B | C | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639346 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Loan qualified using [Redacted]month bank statement income with a [Redacted]% fixed expense ratio. | Reviewer Comment (2022-08-17): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639353 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Loan qualified using [Redacted]month bank statement income with a [Redacted]% fixed expense ratio. | Reviewer Comment (2022-08-17): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Purchase | C | B | A | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639353 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Have Escrow Account | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether the loan will have an escrow account. | The box on the final Closing Disclosure was checked indicating that borrower will have an escrow account; however, Borrower signed an Escrow Waiver [Redacted]. | Reviewer Comment (2022-06-09): [Redacted] received Post CD and LOX. Seller Comment (2022-06-08): Uploaded PCCD and LOX |
06/09/2022 | 2 | B | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639353 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Not Have Escrow Account | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted]incorrectly disclosed whether the loan will have an escrow account. | Borrower signed an Escrow Waiver [Redacted]; however, the box indicating Borrower will not have an escrow account is unchecked. | Reviewer Comment (2022-06-09): [Redacted] received Post CD and LOX. Seller Comment (2022-06-08): Uploaded PCCD and LOX showing no escrows |
06/09/2022 | 2 | B | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639353 | Property | Appraisal Reconciliation | Value Discrepancy | Appraisal Reconciliation | Loan is to be securitized. Highest level secondary valuation supports the value. There is a lower level tertiary product that does not support the qualifying value.; Sec ID: 22 | Note Date: ___; Lien Position: ___ | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | CA | Primary | Purchase | C | B | A | A | C | B | B | B | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438639349 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of [Redacted]% | Reviewer Comment (2022-08-17): Accepted as is Reviewer Comment (2022-06-17): EV2-B Reviewer Comment (2022-06-17): Initial grade regrade to EV2B Reviewer Comment (2022-06-17): Intiial Grade Regrade to EV2-B |
2 | B | CA | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438820784 | Credit | Loan Package Documentation | Closing / Title | Loan Package Documentation | (Missing Doc) Missing Note Addendum: Note P&I does not match calculated P&I | Reviewer Comment (2022-07-06): Received, Clearing. Seller Comment (2022-07-06): Note Addendum has been attached. |
07/06/2022 | 1 | A | NY | Investment | Purchase | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438820785 | Credit | Borrower and Mortgage Eligibility | Mortgage / Program Eligibility | Borrower and Mortgage Eligibility | Guideline Requirement: Debt Service Coverage Ratio (Subject DSCR) discrepancy. | Calculated Debt Service Coverage Ratio (Subject DSCR) of ___ does not meet Guideline Debt Service Coverage Ratio (Subject DSCR) ___. | The qualifying DSCR on the loan is greater than the guideline minimum. Borrower's Experience/Track Record Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. |
DSCR is within range. Good Track Record |
Originator Originator SitusAMC |
Reviewer Comment (2022-07-27): Post funding exception approval, waived with compensating factors Reviewer Comment (2022-07-27): . Reviewer Comment (2022-07-25): Post funding exception approval, waived with compensating factors Seller Comment (2022-07-25): exception approved by [Redacted] to purchased with the .[Redacted] DSCR |
07/27/2022 | 2 | B | OR | Investment | Purchase | C | B | C | B | A | A | N/A | No | ||||||||||||||
| 438820785 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___. | The qualifying DSCR on the loan is greater than the guideline minimum. Borrower's Experience/Track Record |
DSCR is within range. Good Track Record |
Originator Originator |
Reviewer Comment (2022-07-27): Clearing for updated exception. Reviewer Comment (2022-07-27): . Reviewer Comment (2022-07-25): Prefunding exception approval, waived with compensating factors Reviewer Comment (2022-06-06): Pre close exception. Seller Comment (2022-06-06): Uploaded updated 1008 and pre-funding approved exception in file for short[Redacted] month reserves |
07/27/2022 | 1 | A | OR | Investment | Purchase | C | B | C | B | A | A | N/A | No | ||||||||||||||
| 438820785 | Credit | Asset | Asset Calculation / Analysis | Asset | Guideline Requirement: Available for Reserves discrepancy. | Calculated Available for Reserves of ___ is less than Guideline Available for Reserves of ___. | Calculated PITIA months reserves of [Redacted] is less than Guideline PITIA months reserves of [Redacted]. | The qualifying DSCR on the loan is greater than the guideline minimum. Borrower's Experience/Track Record Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. |
DSCR is within range. Good Track Record |
Originator Originator SitusAMC |
Reviewer Comment (2022-07-27): Prefunding exception approval, waived with compensating factors |
07/27/2022 | 2 | B | OR | Investment | Purchase | C | B | C | B | A | A | N/A | No | |||||||||||||
| 438639361 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Bank statement income based on [Redacted]mos' statements and expense factor of [Redacted]%. | Reviewer Comment (2022-06-21): SHQM(APOR) Seller Comment (2022-06-21): Please find attached income calc wkst showing [Redacted]% expense ration and 1008 showing income used |
06/21/2022 | 1 | A | CA | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438639361 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on [Redacted]months with a Fixed expense ratio of [Redacted]% | Reviewer Comment (2022-08-17): Accepted as is Reviewer Comment (2022-06-21): Regraded. Seller Comment (2022-06-21): Please find attached income calc wkst showing[Redacted]% expense ration and 1008 showing income used |
2 | B | CA | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639361 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Non Escrowed Property Costs Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on [Redacted] not accurate. | Lender to provide final CD correctly disclosing non escrowed property costs. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | |||||||||||||
| 438639361 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | Earnest money deposit of $[Redacted]was made on [Redacted], after closing date of all bank statements in file. Lender to provide paper trail for funds. | Reviewer Comment (2022-06-20): Received, Clearing. Seller Comment (2022-06-16): Valid, however, Funds were not additional EMD, as not listed on PA, and were actually closing costs from the borrower. Assets in file show available funds for the transfer, lowered the assets by the $[Redacted] sent to title after statements but before closing and reserves are still sufficient. See attached updated 1003 and 1008. |
06/20/2022 | 1 | A | CA | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639361 | Credit | Borrower and Mortgage Eligibility | Mortgage / Program Eligibility | Borrower and Mortgage Eligibility | Guideline Requirement: Combined High loan to value discrepancy. | Calculated high loan to value percentage of ___ exceeds Guideline high loan to value percentage of ___ | Lender made exception to [Redacted]%. | The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-06-21): Waived with comp factors already. Buyer Comment (2022-06-21): There is a PTF exception in file, this should be waived Reviewer Comment (2022-06-15): Prefunding credit exception approval, waived with compensating factors Reviewer Comment (2022-06-15): reopened Reviewer Comment (2022-06-15): Lender made exception to [Redacted]% LTV. |
06/21/2022 | 2 | B | CA | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||
| 438639361 | Credit | Borrower and Mortgage Eligibility | Mortgage / Program Eligibility | Borrower and Mortgage Eligibility | Guideline Requirement: High loan to value discrepancy. | Calculated high loan to value percentage of ___ exceeds Guideline high loan to value percentage of ___ | Lender made exception to [Redacted]%. | The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-06-21): Waived with comp factors already. Buyer Comment (2022-06-21): There is a PTF exception in file, this should be waived. Reviewer Comment (2022-06-15): Prefunding credit exception approval, waived with compensating factors Reviewer Comment (2022-06-15): reopened Reviewer Comment (2022-06-15): Lender made exception to [Redacted]% LTV. |
06/21/2022 | 2 | B | CA | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||
| 438639361 | Credit | Borrower and Mortgage Eligibility | Mortgage / Program Eligibility | Borrower and Mortgage Eligibility | Guideline Requirement: Loan to value discrepancy. | Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___. | Lender made exception to [Redacted]%. | The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-06-21): Waived with comp factors already. Buyer Comment (2022-06-21): There is a PTF exception in file, this should be waived. Reviewer Comment (2022-06-15): Prefunding credit exception approval, waived with compensating factors Reviewer Comment (2022-06-15): Lender made exception to [Redacted]% LTV. |
06/21/2022 | 2 | B | CA | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||
| 438639361 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM Provision Income and Assets - Assets | General QM: Unable to verify assets using reasonably reliable third-party records. | Lender to provide paper trail for $[Redacted]earnest money deposit made on [Redacted]. | Reviewer Comment (2022-06-21): Received, Clearing. Buyer Comment (2022-06-21): This was provided under credit finding |
06/21/2022 | 1 | A | CA | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438820788 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of $[Redacted]or .[Redacted]%). | Provide evidence of undiscounted rate and price in order to determine if any part of discount parts are bona fide | Reviewer Comment (2022-07-07): Restated Seller Comment (2022-07-07): correct rate per the rate stack provided is [Redacted]/[Redacted] |
07/07/2022 | 1 | A | FL | Primary | Purchase | C | B | B | B | C | B | A | A | Higher Priced QM (APOR) | Non QM | No | |||||||||||||
| 438820788 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Provide evidence of undiscounted rate and price in order to determine if any part of discount parts are bona fide | Reviewer Comment (2022-07-07): Restated Buyer Comment (2022-07-07): Please reinstate to NQM |
07/07/2022 | 1 | A | FL | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | B | B | C | B | A | A | Higher Priced QM (APOR) | Non QM | Yes | ||||||||||||
| 438820788 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Lender Exception approval provided for rent free on housing history for primary and HPML with increase in sales price within [Redacted]days increase by more than [Redacted]%. Comp factors: reserves exceed minimum requirement; Time on current job; Residual Income |
The representative FICO score exceeds the guideline minimum by at least 40 points. The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-06-16): Prefunding exception approval, waived with compensating factors |
06/16/2022 | 2 | B | FL | Primary | Purchase | C | B | B | B | C | B | A | A | Higher Priced QM (APOR) | Non QM | No | ||||||||||||
| 438820788 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - General Ability to Repay | Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not match. However, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. | Restated | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | FL | Primary | Purchase | C | B | B | B | C | B | A | A | Higher Priced QM (APOR) | Non QM | No | ||||||||||||||
| 438639356 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - | [Redacted] & [Redacted] (Closing Disclosure or Mtg Statement from recent refinance not provided, lender to provide copy to cure) | Reviewer Comment (2022-06-20): Received, cleared Seller Comment (2022-06-16): Final CDs for both properties |
06/20/2022 | 1 | A | CO | Investment | Refinance - Rate/Term | C | A | C | A | A | A | A | A | N/A | N/A | No | |||||||||||||
| 438639357 | Compliance | Compliance | State Compliance | Misc. State Level | Colorado Consumer Credit Code (First Lien Refinance Notice Not Provided) | Colorado Consumer Credit Code: Borrower not provided First Lien Refinance Notice. | Colorado CCC First Lien Disclosure missing in file. | 2 | B | CO | Investment | Refinance - Rate/Term | C | B | C | B | B | B | A | A | N/A | N/A | No | |||||||||||||||
| 438639357 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - ___ | Missing HOA documentation to support the letter provided for [Redacted]. | Reviewer Comment (2022-06-20): Received, Clearing. Seller Comment (2022-06-17): Valid, please see attached documentation verifying HOAs |
06/20/2022 | 1 | A | CO | Investment | Refinance - Rate/Term | C | B | C | B | B | B | A | A | N/A | N/A | No | |||||||||||||
| 438639357 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: Investor qualifying total debt ratio discrepancy. | [Redacted] was qualified with PITI of $[Redacted]based on a refinance amount for the property, however, only received documentation in the amount of $[Redacted](currently used to qualify), missing documentation to support lower payment used to qualify. Letter of explanation informs of HOA dues for [Redacted]and [Redacted]and also included the monthly payment as part of the DTI. Need documentation to support the monthly HOA dues. All information is subject to review and additional requirement(s) may apply. Cal: Debt: Subject $[Redacted]+ Combined REO: $[Redacted]= $[Redacted]plus credit liabilities of $[Redacted]= $[Redacted]/ Income $[Redacted] = [Redacted]. |
Reviewer Comment (2022-06-20): Received, Clearing. Seller Comment (2022-06-17): Valid, Please find attached the HOA information and a Final CD from loan that closed simultaneously, DTI closed correctly with this information. |
06/20/2022 | 1 | A | CO | Investment | Refinance - Rate/Term | C | B | C | B | B | B | A | A | N/A | N/A | No | ||||||||||||||
| 438639357 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Lender exception provided for personal bank statement transfer deposits into business account. Allowed as indicated were rental payments into the personal account. Comp factors: Residual Income; Fico; LTV. |
The representative FICO score exceeds the guideline minimum by at least 40 points. The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-06-15): Prefunding exception approval, waived with compensating factors |
06/15/2022 | 2 | B | CO | Investment | Refinance - Rate/Term | C | B | C | B | B | B | A | A | N/A | N/A | No | ||||||||||||
| 438639357 | Compliance | Compliance | Federal Compliance | TILA | TILA - Impermissible Prepayment Penalty | Unable to determine whether loan is compliant with Prepayment Penalty testing due to missing information. | Received, Clearing. | Reviewer Comment (2022-06-29): Received, Clearing. Buyer Comment (2022-06-29): Is this condition still open? Based on comment it appears clear |
06/29/2022 | 1 | A | CO | Investment | Refinance - Rate/Term | C | B | C | B | B | B | A | A | N/A | N/A | No | |||||||||||||
| 438639357 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General Ability To Repay Provision Investor Guidelines | Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk. | Received, Clearing. | Reviewer Comment (2022-06-20): Received, Clearing. |
06/20/2022 | 1 | A | CO | Investment | Refinance - Rate/Term | C | B | C | B | B | B | A | A | N/A | N/A | No | |||||||||||||
| 438639360 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted]months with a Fixed Expense Ratio of (Redacted) | Reviewer Comment (2022-07-19): Accepted as is |
2 | B | CA | Second Home | Refinance - Cash-out - Other | B | B | B | B | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639360 | Credit | Borrower and Mortgage Eligibility | Mortgage / Program Eligibility | Borrower and Mortgage Eligibility | Guideline Requirement: Combined High loan to value discrepancy. | Calculated high loan to value percentage of ___ exceeds Guideline high loan to value percentage of ___ | Per Guidelines Cash out second home not allowable over (Redacted) LTV | The representative FICO score exceeds the guideline minimum by at least 40 points. The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-06-22): Prefunding lender exception approved with compensating factors |
06/22/2022 | 2 | B | CA | Second Home | Refinance - Cash-out - Other | B | B | B | B | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||
| 438639360 | Credit | Borrower and Mortgage Eligibility | Mortgage / Program Eligibility | Borrower and Mortgage Eligibility | Guideline Requirement: Loan to value discrepancy. | Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___. | Per Guidelines Cash out second home not allowable over (Redacted) LTV | The representative FICO score exceeds the guideline minimum by at least 40 points. The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-06-22): Prefunding lender exception approved with compensating factors |
06/22/2022 | 2 | B | CA | Second Home | Refinance - Cash-out - Other | B | B | B | B | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||
| 438639360 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: Combined loan to value discrepancy. | Calculated combined loan to value percentage of ___ exceeds Guideline combined loan to value percentage of ___. | Per Guidelines Cash out second home not allowable over (Redacted) LTV | The representative FICO score exceeds the guideline minimum by at least 40 points. The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-06-22): Prefunding lender exception approved with compensating factors |
06/22/2022 | 2 | B | CA | Second Home | Refinance - Cash-out - Other | B | B | B | B | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||
| 438820781 | Compliance | Compliance | Federal Compliance | Federal Defect | (Fed High Cost) Federal High-Cost Mortgage Loan (Points and Fees) | Truth in Lending Act (High-Cost Mortgage): Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of [Redacted] of the Federal Total Loan Amount. Points and Fees of [Redacted] on a Federal Total Loan Amount of [Redacted] vs. an allowable total of [Redacted] (an overage of [Redacted] or [Redacted]). Non-Compliant High Cost Loan. | Missing evidence of undiscounted interest rate and price to determine if discount points are bona fide | Reviewer Comment (2022-07-06): [Redacted]received (1) Signed letter from borrower indicating their choice to (a) accept refund and make loan non-high-cost and (2) a copy of principal reduction. Seller Comment (2022-07-06): Additional principal reduction has posted - pay history attached Reviewer Comment (2022-06-30): [Redacted] follows guidance from outside counsel that the truncated unrounded value is the appropriate one to use in determining the applicable points and fees threshold since the high cost regulations do not address rounding methods for purposes of determining percentage-based points and fees thresholds. For this loan, the actual HOEPA points and fees maximum was $[Redacted] ($[Redacted] x 5%). Therefore, the points and fees total of $[Redacted] exceeds the threshold by $[Redacted], which means that a cure of $[Redacted] falls short of the cure amount required. Please note that we will accept a principal reduction in the amount of $[Redacted] to cover the remainder of the cure. We would accept a screen print as documentation to show the principal reduction given. Seller Comment (2022-06-29): Please see attached cure docs - borrower elected to have a principal reduction done. Also, please see breakdown of refund calculation - we came to a different number due to rounding that we believe to be correct. Total LA $[Redacted] x 5% = $[Redacted] - Total Points and Fees $[Redacted]= $[Redacted]. Overage of $[Redacted] is accurate |
07/06/2022 | 2 | B | WA | Primary | Purchase | (1) Signed letter from borrower indicating their choice to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (2) Assuming option (a) is selected, a copy of refund check and proof of mailing; (3) Assuming option (b) is selected, proof of cure for each of the prohibited practices violations noted. | C | B | B | B | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820781 | Compliance | Legal / Regulatory / Compliance | Anti-Predatory Violation | Federal Defect | (Fed High Cost Provision) Federal High-Cost Mortgage Loan (Counseling Requirement) | Truth in Lending Act (HOEPA): Borrower did not receive pre-loan counseling. | Lender to provide evidence of HOEPA pre loan counseling. | Reviewer Comment (2022-07-06): DF HOEPA cure made. Loan is no longer high cost. |
07/06/2022 | 1 | A | WA | Primary | Purchase | C | B | B | B | C | B | A | A | Non QM | Non QM | No | |||||||||||||
| 438820781 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of [Redacted] exceeds tolerance of [Redacted] plus [Redacted] or [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Fee out of tolerance with sufficient cure. | Reviewer Comment (2022-06-15): Sufficient Cure Provided At Closing |
06/15/2022 | 1 | A | WA | Primary | Purchase | Final CD evidences Cure | C | B | B | B | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820781 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Fee out of tolerance with sufficient cure. | Reviewer Comment (2022-06-15): Sufficient Cure Provided At Closing |
06/15/2022 | 1 | A | WA | Primary | Purchase | Final CD evidences Cure | C | B | B | B | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820781 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Credit exceptions made by lender: 1) borrower does not have 12 mos' housing history; 2) use of business assets from Sch C business; 3) CPA does not address using business assets. Exceptions were all made by lender. | The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-06-15): Pre-funding exception approved, waived with compensating factors. Reviewer Comment (2022-06-15): reopened Reviewer Comment (2022-06-15): Lender made exception for several credit items. |
06/15/2022 | 2 | B | WA | Primary | Purchase | C | B | B | B | C | B | A | A | Non QM | Non QM | No | ||||||||||||
| 438639358 | Credit | Loan Package Documentation | Application / Processing | Insurance | Missing Document: Flood Certificate not provided | Reviewer Comment (2022-06-17): Received, cleared Seller Comment (2022-06-16): Valid, [Redacted]update stopped before the flood so it was not included in upload. Please see attached. |
06/17/2022 | 1 | A | CO | Investment | Refinance - Rate/Term | C | A | C | A | A | A | A | A | N/A | N/A | No | |||||||||||||||
| 438639358 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - | Mortgage statement not provided for [Redacted] if escrows not verified TIA documentation also required to cure. | Reviewer Comment (2022-06-17): Received, cleared Seller Comment (2022-06-16): Valid, REO closed simultaneously with this loan and final CD from that closing was not included in package. Please see attached |
06/17/2022 | 1 | A | CO | Investment | Refinance - Rate/Term | C | A | C | A | A | A | A | A | N/A | N/A | No | |||||||||||||
| 438639359 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on 24 months with a Fixed expense ratio of [Redacted]. | Reviewer Comment (2022-08-17): Accepted as is Reviewer Comment (2022-06-17): EV2-B |
2 | B | CO | Primary | Refinance - Cash-out - Other | B | B | B | B | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639359 | Compliance | Compliance | State Compliance | Misc. State Level | Colorado Consumer Credit Code (First Lien Refinance Notice Not Provided) | Colorado Consumer Credit Code: Borrower not provided First Lien Refinance Notice. | Lender to provide signed/dated copy of Colorado first lien refinance notice - not in file. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | CO | Primary | Refinance - Cash-out - Other | B | B | B | B | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639359 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | A maximum of six* (6) Non-Sufficient Funds (NSF) charges or Overdraft incidents per every twelve consecutive month look-back period. | The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-06-16): Pre-funding exception approved, waived with compensating factors |
06/16/2022 | 2 | B | CO | Primary | Refinance - Cash-out - Other | B | B | B | B | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438820787 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | Lender to provide satisfactory verification that borrower owns (Redacted) of (Redacted), which is the company the lease is made out to. | Reviewer Comment (2022-06-22): Received, Clearing. Seller Comment (2022-06-22): Uploaded showing ownership |
06/22/2022 | 1 | A | NY | Primary | Refinance - Rate/Term | C | B | C | B | A | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820787 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | If the property is owned for 6 months or less at the time of application, the LTV/CLTV will be based on the lesser of the original purchase price or current appraised value | Borrower has verified disposable income of at least $2500.00. | SitusAMC | Reviewer Comment (2022-06-16): Prefunding exception approval, waived with compensating factors |
06/16/2022 | 2 | B | NY | Primary | Refinance - Rate/Term | C | B | C | B | A | A | A | A | Non QM | Non QM | No | ||||||||||||
| 438820787 | Credit | Guideline | Guideline Issue | Guideline | Borrower does not have the minimum active tradelines per guidelines. | Borrower has verified disposable income of at least $2500.00. | SitusAMC | Reviewer Comment (2022-06-16): Prefunding exception approval, waived with compensating factors |
06/16/2022 | 2 | B | NY | Primary | Refinance - Rate/Term | C | B | C | B | A | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438820791 | Compliance | Compliance | State Compliance | State Defect | (State High Cost) Georgia High-Cost Loan (Points and Fees) | Georgia Fair Lending Act: Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of [Redacted] of the Total Loan Amount. Points and Fees total [Redacted] on a Total Loan Amount of [Redacted] vs. an allowable total of [Redacted] (an overage of [Redacted] or [Redacted]). Compliant High Cost Loan. | Reviewer Comment (2022-07-21): Cure documentation received. Seller Comment (2022-07-20): Please see attached screenshot from the Servicer's platform showing the reduction of [Redacted] cent and the LOX which was mailed to the borrower Reviewer Comment (2022-07-15): The exception states an overage of $[Redacted]. [Redacted]made a refund back to consumer for $[Redacted]. They were $[Redacted] off which still results in the loan being over the threshold so it is still considered a high-cost loan. If [Redacted] wishes to make a principal reduction for the remaining $[Redacted] and can show evidence that the adjustment was made (e.g., print screen of pay history, etc.) along with notification to the consumer, we can cure the exception to EV2-B. Seller Comment (2022-07-13): Uploaded PCCD, LOX, check and shipping label Reviewer Comment (2022-06-24): The [Redacted] high cost points and fees test does not use the same criteria as HOEPA to evaluate whether discount points are bona fide and excludable. Rather than comparing the undiscounted/starting adjusted rate to the APOR, [Redacted] compares it to the Fannie and Freddie RNY 90 day commitment. For this loan, the undiscounted/starting adjusted rate of [Redacted]% is more than [Redacted]% higher than the greater of the Fannie or Freddie 90 day commitment (see definition below). The index used for testing for this loan was [Redacted]%, which was the FNMA RNY from [Redacted] (which was the index available 10 business days prior to consummation). The [Redacted]Fair Lending Act 7-6A-2 defines bona fide discount points as: "Bona fide discount points" means loan discount points knowingly paid by the borrower for the express purpose of reducing, and which in fact do result in a bona fide reduction of, the interest rate applicable to the home loan; provided, however, that the undiscounted interest rate for the home loan does not exceed by more than one percentage point the required net yield for a 90 day standard mandatory delivery commitment for a home loan with a reasonably comparable term from either the Federal National Mortgage Association or the Federal Home Loan Mortgage Corporation, whichever is greater. Seller Comment (2022-06-22): The loan passes both high cost test with the benefit of excluding up to two discount as bona fide. The total discount on this loan was less than [Redacted]%, so the entire discount of $[Redacted] can be excluded. |
07/21/2022 | 2 | B | GA | Primary | Refinance - Cash-out - Other | Within 90 days of loan closing and prior to receiving notice from the borrower: (a) offer restitution and make appropriate adjustments; or (b) to correct failure related to financing of insurance, make appropriate restitution by returning premiums paid plus interest charged on the premiums upon receipt of the notice of compliance failure. (Narrow Defense - Requires approval by CHD) Within 90 days of discovery, which compliance failure was not intentional and resulted from a bona fide error, creditor must: (1) provide Lender Attestation to AMC attesting the failure was not intentional and was a bona fide error notwithstanding procedures in place to prevent such loans from being made (specific details on how high-cost loan was made despite procredures to prevent); (2) notify the borrower, and (3) make appropriate restitution/adjustments to the loan. |
C | B | A | A | C | B | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438820791 | Compliance | Legal / Regulatory / Compliance | Anti-Predatory Violation | Federal Defect | (Fed High Cost Provision) Federal High-Cost Mortgage Loan (Financed Points and Fees) | Truth in Lending Act (HOEPA): Mortgage loan financed Points and Fees. | Reviewer Comment (2022-06-24): Undiscounted rate/price provided. HOEPA exception cleared after exclusion of bona fide discount points |
06/24/2022 | 1 | A | GA | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820791 | Compliance | Legal / Regulatory / Compliance | Anti-Predatory Violation | Federal Defect | (Fed High Cost Provision) Federal High-Cost Mortgage Loan (Late Charge) | Truth in Lending Act (HOEPA): Mortgage loan contains a late charge that exceeds the greater of 4% of the amount past due or grace period of less than 15 days. | Reviewer Comment (2022-06-24): Undiscounted rate/price provided. HOEPA exception cleared after exclusion of bona fide discount points |
06/24/2022 | 1 | A | GA | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820791 | Compliance | Compliance | Federal Compliance | Federal Defect | (Fed High Cost) Federal High-Cost Mortgage Loan (Points and Fees) | Truth in Lending Act (High-Cost Mortgage): Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of [Redacted] of the Federal Total Loan Amount. Points and Fees of [Redacted] on a Federal Total Loan Amount of [Redacted] vs. an allowable total of [Redacted] (an overage of [Redacted] or [Redacted]). Non-Compliant High Cost Loan. | Reviewer Comment (2022-06-24): Undiscounted rate/price provided. HOEPA exception cleared after exclusion of bona fide discount points Buyer Comment (2022-06-22): undiscounted rate/price of [Redacted]%/[Redacted]allows up to [Redacted] points to be excluded, test passes with bona fide points Seller Comment (2022-06-22): The loan passes both high cost test with the benefit of excluding up to two discount as bona fide. The total discount on this loan was less than [Redacted]%, so the entire discount of $[Redacted] can be excluded. |
06/24/2022 | 1 | A | GA | Primary | Refinance - Cash-out - Other | (1) Signed letter from borrower indicating their choice to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (2) Assuming option (a) is selected, a copy of refund check and proof of mailing; (3) Assuming option (b) is selected, proof of cure for each of the prohibited practices violations noted. | C | B | A | A | C | B | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438820791 | Compliance | Legal / Regulatory / Compliance | Anti-Predatory Violation | Federal Defect | (Fed High Cost Provision) Federal High-Cost Mortgage Loan (2015 Counseling Requirement) | Truth in Lending Act (HOEPA): Pre-loan counseling requirements not met. | Reviewer Comment (2022-06-24): Undiscounted rate/price provided. HOEPA exception cleared after exclusion of bona fide discount points |
06/24/2022 | 1 | A | GA | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820792 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Originator Loan Designation failing due to high points and fees | Reviewer Comment (2022-07-01): Restated. Buyer Comment (2022-07-01): Please restate as NonQM |
07/01/2022 | 1 | A | AZ | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM status | C | B | C | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | Yes | ||||||||||||
| 438820792 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of [Redacted] of the Federal Total Loan Amount. Points and Fees total [Redacted] on a Federal Total Loan Amount of [Redacted] vs. an allowable total of [Redacted] (an overage of [Redacted] or [Redacted]). | Provide evidence of undiscounted rate and price to determine if any part of discount points are bona fide | Reviewer Comment (2022-07-01): Restated. Buyer Comment (2022-07-01): Please restate as NQM |
07/01/2022 | 1 | A | AZ | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | No | |||||||||||||
| 438820792 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of revised valuation to applicant three (3) business days prior to consummation. | The initial appraisal delivery date is [Redacted], however, a revised appraisal report was completed [Redacted]. Missing evidence of the delivery of the revised appraisal to the borrower 3 business days prior to closing. | Reviewer Comment (2022-07-06): Received, Clearing. Seller Comment (2022-07-06): Uploaded appraisal completed on [Redacted] |
07/06/2022 | 1 | A | AZ | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | No | |||||||||||||
| 438820792 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Missing UW cert for GSE ineligibility. | Reviewer Comment (2022-07-06): Received, Clearing. Seller Comment (2022-07-06): Document attached. |
07/06/2022 | 1 | A | AZ | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | No | ||||||||||||||
| 438820792 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - General Ability to Repay | Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not match. However, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. | Restated. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | AZ | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | No | ||||||||||||||
| 438820790 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Fails QM due to points and fees. | Reviewer Comment (2022-07-01): Restated. |
07/01/2022 | 1 | A | NJ | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | A | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | Yes | ||||||||||||
| 438820790 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of [Redacted] of the Federal Total Loan Amount. Points and Fees total [Redacted] on a Federal Total Loan Amount of [Redacted] vs. an allowable total of [Redacted] (an overage of [Redacted] or [Redacted]). | Missing evidence of undiscounted interest rate price to determine if any points are bone fide | Reviewer Comment (2022-07-01): Restated. Buyer Comment (2022-07-01): please restate as NQM |
07/01/2022 | 1 | A | NJ | Primary | Purchase | C | B | A | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | No | |||||||||||||
| 438820790 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - General Ability to Repay | Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not match. However, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. | Restated. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NJ | Primary | Purchase | C | B | A | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | No | ||||||||||||||
| 438820793 | Compliance | Compliance | Federal Compliance | Missing Disclosure | Notice of Special Flood Hazard Disclosure Not Provided Timely | FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing. | Federal Flood Disclosure was not provided to Borrower on within a reasonable time prior to closing. Document was provided on [Redacted]. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | TX | Investment | Purchase | C | B | C | A | B | B | A | A | N/A | Non QM | No | ||||||||||||||
| 438820793 | Credit | Credit | Credit Documentation | Credit | No evidence of fraud report in file | - | Reviewer Comment (2022-06-23): Received, Clearing. Seller Comment (2022-06-23): The attached fraud report is to cure the finding below. |
06/23/2022 | 1 | A | TX | Investment | Purchase | C | B | C | A | B | B | A | A | N/A | Non QM | No | ||||||||||||||
| 438820799 | Compliance | Compliance | Federal Compliance | TILA | TILA - Impermissible Prepayment Penalty | Truth in Lending Act (Dodd-Frank 2014): Covered transaction contains impermissible prepayment penalty. | Max prepayment penalty exceeds 2%, 2%, 1% in years 1, 2, and 3 | Reviewer Comment (2022-07-05): Clearing after re-review. |
07/05/2022 | 1 | A | NY | Investment | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Non QM | N/A | No | |||||||||||||
| 438820799 | Compliance | Compliance | Federal Compliance | ATR/QM | Investment Property submitted as Non-QM / Exempt from ATR | Ability to Repay (Dodd-Frank 2014): Improper Originator Loan Designation. Investment property not subject to Ability to Repay requirements. | Investment property not subject to Ability to Repay requirements. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Investment | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Non QM | N/A | No | ||||||||||||||
| 438820798 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - ___ | Reviewer Comment (2022-07-06): Received, Clearing. Seller Comment (2022-07-06): Uploaded REO docs showing Property is a coop therefore a tax cert is not required, borrower pays maintenance |
07/06/2022 | 1 | A | NJ | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438820798 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - | Reviewer Comment (2022-06-27): Received, Clearing. Seller Comment (2022-06-27): Uploaded tax bill |
06/27/2022 | 1 | A | NJ | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438820789 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Fee out of tolerance with sufficient cure made. | Reviewer Comment (2022-06-22): Sufficient Cure Provided At Closing |
06/22/2022 | 1 | A | FL | Primary | Purchase | Final CD evidences Cure | C | A | A | A | C | A | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820789 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Closing Disclosure Timing without Waiver | TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. | Lender provided initial CD on [Redacted], closing date is [Redacted]. | Reviewer Comment (2022-07-08): [Redacted] received Lender attestation and documentation to confirm which CD is initial CD and which not disclosed to borrower Seller Comment (2022-07-06): Uploaded reference docs showing first initial CD issued on [Redacted] was not signed, second initial CD was sent on the same day due to a change made after the 1st version was sent, 2nd initial CD was signed by both borrowers [Redacted]. screenshots show last doc was never sent to borrower and was ran to test numbers Reviewer Comment (2022-06-27): Please provide proof of receipt for documents 230, 232 and 245. Seller Comment (2022-06-23): Uploaded initial CD issued [Redacted] and acknowledged and signed by both borrowers on [Redacted], borrowers signed the initial CD on [Redacted], the closing date of [Redacted] is within disclosure timing requirements |
07/08/2022 | 1 | A | FL | Primary | Purchase | No Defined Cure | C | A | A | A | C | A | A | A | Non QM | Non QM | No | ||||||||||||
| 438820789 | Compliance | Compliance | Federal Compliance | TRID | TRID Seller Closing Disclosure Contains Fees not reflected on Consumer's Final Closing Disclosure | TILA-RESPA Integrated Disclosure: the Seller's final CD contained fees not reflected on the consumer's CD. | Lender to provide final CD disclosing all seller paid fees. | Reviewer Comment (2022-07-08): [Redacted] CD issue date with[Redacted] at closing date now revised CD due to attestation on [Redacted] CD issue date is now final CD |
07/08/2022 | 1 | A | FL | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | A | A | A | C | A | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820796 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of [Redacted] of the Federal Total Loan Amount. Points and Fees total [Redacted] on a Federal Total Loan Amount of [Redacted] vs. an allowable total of [Redacted] (an overage of [Redacted] or [Redacted]). | Missing evidence of undiscounted rate and price in order to determine if any portion of discount points are bona fide | Reviewer Comment (2022-06-28): Received, Clearing. Seller Comment (2022-06-28): Based on the rate stack, the loan passes the QM [Redacted]% Points & Fees with the benefit of excluding 1 bona fide discount, uploaded rate stack |
06/28/2022 | 1 | A | FL | Primary | Purchase | C | B | B | B | C | B | B | B | Higher Priced QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438820796 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | . | Reviewer Comment (2022-07-05): Loan is SHQM(APOR). Buyer Comment (2022-07-05): This was restated - this condition shouldn't remain an open 3 Reviewer Comment (2022-06-28): Loan designation mismatch exception remains as loan originator designation is submitted as HPQM (APOR) but findings result in a due diligence designation of SHQM(APOR) restated loan originator designation required to address loan designation mismatch exception. |
07/05/2022 | 1 | A | FL | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | B | B | C | B | B | B | Higher Priced QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438820796 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Appraisal Fee was not disclosed on LE as [Redacted] and CD as [Redacted] a cure of [Redacted] was provided to the Borrower. | Reviewer Comment (2022-06-23): Sufficient Cure Provided At Closing |
06/23/2022 | 1 | A | FL | Primary | Purchase | Final CD evidences Cure | C | B | B | B | C | B | B | B | Higher Priced QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438820796 | Property | Property - Appraisal | Appraisal Reconciliation | Property - Appraisal | Appraisal is required to be in name of Lender | - | Missing appraisal transfer letter | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | FL | Primary | Purchase | C | B | B | B | C | B | B | B | Higher Priced QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438820796 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Business has been active less than 2 years | The representative FICO score exceeds the guideline minimum by at least 40 points. The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has verified disposable income of at least $2500.00. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-06-23): Prefunding credit exception approved, waived with compensating factors |
06/23/2022 | 2 | B | FL | Primary | Purchase | C | B | B | B | C | B | B | B | Higher Priced QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438820796 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on 12 months with a Fixed expense ratio of [Redacted] | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | FL | Primary | Purchase | C | B | B | B | C | B | B | B | Higher Priced QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438820796 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - QM / ATR | Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Safe Harbor QM (APOR) matches the Due Diligence Loan Designation of Safe Harbor QM (APOR). | Loan resubmitted as SHQM(APOR). | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | FL | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | B | B | C | B | B | B | Higher Priced QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438820797 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Loan designation failure due to QM failure. This exception will be cleared once all QM specific exceptions have been cured/cleared. | Reviewer Comment (2022-07-08): Loan is HPQM (APOR). Buyer Comment (2022-07-08): Credit finding has been cleared, please update this one. Reviewer Comment (2022-06-27): Unable to downgrade bank statement exception until all credit exceptions are addressed. Missing UW cert of agency ineligibility. Exception remains. Seller Comment (2022-06-27): The attached SOS for [Redacted] is to cure the COMPLIANCE finding. |
07/08/2022 | 1 | A | GA | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | C | B | C | B | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | Yes | ||||||||||||
| 438820797 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Reviewer Comment (2022-08-17): Accepted as is Reviewer Comment (2022-07-08): Bank Statement income was based on [Redacted] months with a fixed expense ratio of [Redacted]%. Buyer Comment (2022-07-08): Credit finding has been cleared, please update this one. Reviewer Comment (2022-06-27): Unable to downgrade bank statement exception until all credit exceptions are addressed. Missing UW cert of agency ineligibility. Exception remains. Seller Comment (2022-06-27): The attached SOS for [Redacted] is to cure the COMPLIANCE findings below. |
2 | B | GA | Primary | Purchase | C | B | C | B | C | B | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | |||||||||||||||
| 438820797 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Reviewer Comment (2022-08-17): Accepted as is Reviewer Comment (2022-07-08): Bank Statement income was based on [Redacted]months with a fixed expense ratio of [Redacted]%. Buyer Comment (2022-07-08): Credit finding has been cleared please updated this one. Reviewer Comment (2022-06-27): Unable to downgrade bank statement exception until all credit exceptions are addressed. Missing UW cert of agency ineligibility. Exception remains. Seller Comment (2022-06-27): The attached SOS for [Redacted] is to cure the COMPLIANCE findings below. |
2 | B | GA | Primary | Purchase | C | B | C | B | C | B | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | |||||||||||||||
| 438820797 | Credit | Credit | Credit Calculation / Analysis | Guideline | Guideline Requirement: Representative FICO score discrepancy. | Representative FICO score of ___ is less than Guideline representative FICO score of ___. | Based on the LTV and loan amount representative credit score is [Redacted]. Lender exception approval provided to use the higher of the two borrowers representative scores for qualifying with the following comp factors: Reserves; year at current home | Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-06-23): Pre-funding exception approved, waived with compensating factors |
06/23/2022 | 2 | B | GA | Primary | Purchase | C | B | C | B | C | B | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | |||||||||||
| 438820797 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Missing UW cert for GSE ineligibility. | Reviewer Comment (2022-07-06): Received, Clearing. Seller Comment (2022-07-06): Document attached. |
07/06/2022 | 1 | A | GA | Primary | Purchase | C | B | C | B | C | B | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | ||||||||||||||
| 438820800 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | The Bank Statement income was based on [Redacted] with a Fixed Expense Ratio of [Redacted] | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | FL | Primary | Refinance - Rate/Term | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438820800 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Borrower did not acknowledge that they received an appraisal and there is no notice of Appraisal in file. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | FL | Primary | Refinance - Rate/Term | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438820795 | Compliance | Compliance | Federal Compliance | RESPA | RESPA - Initial Escrow Account statement Inaccurate | RESPA: Initial escrow account statement does not match charges on HUD-1/Final Closing Disclosure. | Lender to provide escrow disclosure and final CD with matching figures for initial escrow. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NV | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||||
| 438820795 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | Fee was out of tolerance with no cure given or valid change. Credit was pulled [Redacted] and then repulled on [Redacted]. | Reviewer Comment (2022-07-05): [Redacted]received Supporting Documents. Seller Comment (2022-07-01): Uploaded snippet evidence of UW requesting an updated report on [Redacted]; and[Redacted], [Redacted], and [Redacted] Credit Reports Reviewer Comment (2022-06-30): [Redacted] the fee was increased on LE dated[Redacted]. As per COC the report required due to original report get expired however, as per your comment there are multiple reports were pulled but no copy of credit report is available before [Redacted]. The report was expired on [Redacted] so the fee should have been increased after CD dated [Redacted]. Kindly provide additional information or need cure. Exception remains. Seller Comment (2022-06-29): Initial credit report was pulled on [Redacted] with expiration date of [Redacted]. Re-pulled multiple times required due to not all three scores were available during the loan process and new reports required for closing date of [Redacted] and disbursement date of [Redacted]. Reviewer Comment (2022-06-28): [Redacted] upon further review fee was increased on LE dated [Redacted] and COC was there dated [Redacted] but two credit report is in file dated [Redacted] , [Redacted] and there is no credit report prior to COC date. We need initial credit report when it was issued / need confirmation from lender that when earlier credit report was expired or need cure. Seller Comment (2022-06-27): Review: No Cure Required. [Redacted] COC LE was issued for credit report fee increased due to original report expired and refresh required for closing. Borrower was not charged for [Redacted] credit refresh. See attached COC LE and Credit invoices. |
07/05/2022 | 1 | A | NV | Primary | Refinance - Cash-out - Other | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820795 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Credit | Guideline Requirement: Loan purpose discrepancy. | Loan purpose of ___ does not match Guideline loan purpose of ___. | Loan originated as rate/term but refi paid off delinquent taxes on subject, which is not allowed under rate/term guides. | Reviewer Comment (2022-08-04): Received, Clearing. Seller Comment (2022-08-04): Agree - corrected 1003 and 1008 |
08/04/2022 | 1 | A | NV | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Non QM | Non QM | No | |||||||||||||
| 438820801 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of revised valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | FL | Primary | Purchase | C | B | A | A | C | B | A | A | Non QM | Non QM | No | |||||||||||||||
| 438820801 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien | TRID Final Closing Disclosure [Redacted] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) | Seller CD not provided, Seller paid fees not shown on Final CD. | Reviewer Comment (2022-07-06): [Redacted]received signed Settlement Statement Seller Comment (2022-07-01): Uploaded seller paid statement |
07/06/2022 | 1 | A | FL | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820801 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Originator Compensation (YSP). Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | COC not provided for the added fee and no cure provided for fee exceeding tolerance. | Reviewer Comment (2022-07-07): [Redacted] received COC dated [Redacted] and as per associated comment no tolerance cure is required. Buyer Comment (2022-07-06): broker elected to flip to BPC to pass testing therefore no COC needed Reviewer Comment (2022-07-05): [Redacted]received COC & Rate Lock dated [Redacted], stating Compensation changed from LPC to BPC at brokers request. It does not give sufficient information on why the Loan Originator Compensation changed from [Redacted] to [Redacted]. In order to determine if the COC is valid more information is necessary on reason why broker request fee added and when lender became aware of the change. A valid COC or cure is required. Cure consists of Corrected CD, LOE to borrower, proof of mailing and copy of refund check. Seller Comment (2022-07-01): Originator Compensation was added to Initial CD dated [Redacted] as Lender Paid, no responsibility to the borrower. Fee changed from Lender Paid to Borrower paid on XXXX CD with COC stating at broker's request. The fee remained the same through Final CD. There is no tolerance cure due - reason for the change was stated on COC. |
07/07/2022 | 1 | A | FL | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820802 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Bank Statement income was based on 12 months with a Fixed Expense Ratio of [Redacted]. | Reviewer Comment (2022-08-17): Accepted as is Reviewer Comment (2022-06-28): Regraded. Seller Comment (2022-06-28): Income was calculated based on [Redacted]% expense ratio, [Redacted]page 1207, attached for faster review |
2 | B | TX | Primary | Purchase | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Higher Priced QM (APOR) | No | ||||||||||||||
| 438820802 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-06-23): Sufficient Cure Provided At Closing |
06/23/2022 | 1 | A | TX | Primary | Purchase | Final CD evidences Cure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Higher Priced QM (APOR) | Yes | |||||||||||||
| 438820802 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of Higher Priced QM (APOR). | Bank Statement income was based on 12 months with a Fixed Expense Ratio of [Redacted]. | Reviewer Comment (2022-06-28): Restated Seller Comment (2022-06-28): Invalid, income was calculated based on [Redacted]% expense ratio, [Redacted]page 1207, attached for faster review |
06/28/2022 | 1 | A | TX | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Higher Priced QM (APOR) | Yes | ||||||||||||
| 438820802 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Total Of Payments | TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on [Redacted] disclosed an inaccurate Total of Payments on page 5 that does not match the actual total of payments for the loan (fee amounts included in TOP calculation are based on Closing Disclosure dated [Redacted]). | Total payments under-disclosed by [Redacted]. PCCD on file. LOE, refund check and evidence of delivery required in order to cure. | Reviewer Comment (2022-07-07): [Redacted]received LOE, closing statement, and corrected CD reflecting survey fee as charged at closing. Seller Comment (2022-07-05): Disagree - - [Redacted] PCCD was issued with an incorrect Survey Fee, thus resulted in inaccurate TOP. |
07/07/2022 | 1 | A | TX | Primary | Purchase | TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected CD, and Re-open Rescission if Applicable | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Higher Priced QM (APOR) | Yes | ||||||||||||
| 438820802 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - QM / ATR | Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Higher Priced QM (APOR) matches the Due Diligence Loan Designation of Higher Priced QM (APOR). | Restated | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | TX | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Higher Priced QM (APOR) | No | |||||||||||||
| 438820804 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of [Redacted] of the Federal Total Loan Amount. Points and Fees total [Redacted] on a Federal Total Loan Amount of [Redacted] vs. an allowable total of [Redacted] (an overage of [Redacted] or [Redacted]). | Missing evidence of undiscounted interest rate and price to determine if any portion of discount points are bona fide | Reviewer Comment (2022-07-06): Restated. Seller Comment (2022-07-06): Disagree - 2 out of [Redacted]% discount points are eligible for bona fide, thus $[Redacted] was excluded from the P & F calculation |
07/06/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||
| 438820804 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Missing evidence of undiscounted interest rate and price to determine if any portion of discount points are bona fide | Reviewer Comment (2022-07-06): Restated. Buyer Comment (2022-07-06): Please reinstate NQM |
07/06/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM status | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438820804 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - General Ability to Repay | Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not match. However, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. | Restated. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | FL | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||||
| 438820811 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | Income calculation worksheet not provided | Reviewer Comment (2022-06-30): Received, Clearing. Seller Comment (2022-06-30): Uploaded income calc worksheet |
06/30/2022 | 1 | A | NY | Primary | Purchase | C | A | C | A | C | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438820811 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Sales Tax. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | Missing cure and valid change of circumstance | Reviewer Comment (2022-07-01): [Redacted]Received PCCD dated [Redacted] along with LOE. Exception Cleared. Seller Comment (2022-06-30): Uploaded PCD and LOX for clerical adjustment to correct title fee name of "Sales Tax" to Title- Title Search Sales Tax |
07/01/2022 | 1 | A | NY | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | A | C | A | C | A | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820805 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | MI | Primary | Purchase | C | B | A | A | C | B | A | A | Non QM | Non QM | No | |||||||||||||||
| 438820805 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien | TRID Final Closing Disclosure [Redacted] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) | No seller paid fees disclosed on Final Closing Disclosure | Reviewer Comment (2022-07-01): [Redacted]received Seller settlement statement Seller Comment (2022-06-29): Uploaded seller paid stmt |
07/01/2022 | 1 | A | MI | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820810 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Not Provided Timely | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Receive a Copy" appraisal disclosure to applicant within three (3) business days of application or determination of first lien status. | Borrower signed document [Redacted], app date [Redacted], no proof that the lender sent this to the borrower at time of application. Lender to document when the disclosure was sent to the borrower. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | FL | Investment | Purchase | B | B | A | A | B | B | A | A | N/A | No | |||||||||||||||
| 438820812 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - ATR Risk | Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk. | Reviewer Comment (2022-08-03): Received, Clearing. |
08/03/2022 | 1 | A | NY | Primary | Refinance - Rate/Term | Lender to provide updated ATR/QM Loan Designation | C | A | C | A | C | A | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438820812 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines | Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of [Redacted] significantly exceeds the guideline maximum of [Redacted]. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.) | loan is an [Redacted] year fixed first [Redacted] years interest only, investor qualifies full amortized PI only the interest only payment was used to Qualify. | Reviewer Comment (2022-08-03): Received, Clearing. |
08/03/2022 | 1 | A | NY | Primary | Refinance - Rate/Term | C | A | C | A | C | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438820812 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: Investor qualifying total debt ratio discrepancy. | after Qualifying borrower on fully amortized payment DTI goes from [Redacted] to [Redacted] | Reviewer Comment (2022-08-03): Received, Clearing. Seller Comment (2022-08-03): Uploaded corrected 1003, 1008, income calculator, lender's initial 1003 w/correct income and letter from Partner and [Redacted]% of the borrower's bank statements are used |
08/03/2022 | 1 | A | NY | Primary | Refinance - Rate/Term | C | A | C | A | C | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820812 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General Ability To Repay Provision Investor Guidelines | Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk. | due to DTI being over 50% | Reviewer Comment (2022-08-03): Received, Clearing. |
08/03/2022 | 1 | A | NY | Primary | Refinance - Rate/Term | C | A | C | A | C | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438820812 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | [Redacted]received clarification, cure provided at closing. | Reviewer Comment (2022-07-15): Sufficient Cure Provided At Closing |
07/15/2022 | 1 | A | NY | Primary | Refinance - Rate/Term | Final CD evidences Cure | C | A | C | A | C | A | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820813 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | Reviewer Comment (2022-07-08): Not found in the original file. Clearing. Seller Comment (2022-07-08): Rebut: [Redacted] Month BS Program. The Calc was in the File |
07/08/2022 | 1 | A | FL | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | No | |||||||||||||||
| 438820815 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Closing Disclosure Timing without Waiver | TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. | Data is correct | Reviewer Comment (2022-07-14): [Redacted] received proof of receipt. Seller Comment (2022-07-12): Response: The ICD was disclosed [Redacted] - the borrower consented, signed and completed - ICD is attached. The Final CD is dated the day of closing - [Redacted], therefore, the ICD was disclosed at least 3 days prior to closing, resulting in no timing issue. |
07/14/2022 | 1 | A | OR | Primary | Purchase | No Defined Cure | C | A | A | A | C | A | A | A | Non QM | Non QM | No | ||||||||||||
| 438820816 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of [Redacted] of the Federal Total Loan Amount. Points and Fees total [Redacted] on a Federal Total Loan Amount of [Redacted] vs. an allowable total of [Redacted] (an overage of [Redacted] or [Redacted]). | Loan fails QM due to points and fees. | Reviewer Comment (2022-07-20): Restated. Buyer Comment (2022-07-20): Valid fail - please restate as Non QM |
07/20/2022 | 1 | A | PA | Primary | Purchase | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||
| 438820816 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Loan fails QM due to points and fees. | Reviewer Comment (2022-07-20): Restated. |
07/20/2022 | 1 | A | PA | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438820816 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | Borrower has been self employed <[Redacted]. Lender made exception. | The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-06-29): Lender made exception with compensating factors. |
06/29/2022 | 2 | B | PA | Primary | Purchase | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||
| 438820816 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - General Ability to Repay | Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not match. However, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. | Restated. | Reviewer Comment (2022-08-17): Accepted as is Reviewer Comment (2022-07-21): Already restated. All are level 2's. Buyer Comment (2022-07-21): Please reinstate to NQM |
2 | B | PA | Primary | Purchase | C | B | B | B | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||||
| 438820803 | Credit | Missing Document | General | Missing Document | Missing Document: 1007 Rent Comparison Schedule not provided | Reviewer Comment (2022-07-14): Received, Clearing. Seller Comment (2022-07-14): 1007 Rent Comparison Schedule has been attached. |
07/14/2022 | 1 | A | NY | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | No | ||||||||||||||||
| 438820803 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - | Missing evidence of new PITI payment | Reviewer Comment (2022-07-11): Received, Clearing. Seller Comment (2022-07-11): Tax statement for [Redacted] Reviewer Comment (2022-07-08): Provided was for [Redacted] when we need [Redacted]. Seller Comment (2022-07-08): Mortgage statement for[Redacted] has been attached. |
07/11/2022 | 1 | A | NY | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | No | ||||||||||||||
| 438820817 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - | Missing copy of tax/insurance verification | Reviewer Comment (2022-07-11): Received, Clearing. Seller Comment (2022-07-11): Uploaded final CD and PITI for property Reviewer Comment (2022-07-08): Final CD provided isn't for either of the properties missing the information in the properties listed in the exception. Seller Comment (2022-07-08): Uploaded final CD |
07/11/2022 | 1 | A | NY | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | No | ||||||||||||||
| 438820807 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Articles of Organization/Formation not provided | Reviewer Comment (2022-07-08): Received, Clearing. Seller Comment (2022-07-08): SOS attached |
07/08/2022 | 1 | A | TX | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438820807 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Corporate Resolution not provided | Reviewer Comment (2022-07-08): Received, Clearing. Seller Comment (2022-07-08): Rebut: Corporate Resolution was in the File |
07/08/2022 | 1 | A | TX | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438820807 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Operating Agreement not provided | Reviewer Comment (2022-07-08): Received, Clearing. Seller Comment (2022-07-08): Rebut: Agreement was int the File |
07/08/2022 | 1 | A | TX | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438820807 | Credit | Insurance | Insurance Documentation | Insurance | Hazard Insurance Error: Subject hazard insurance premium is missing from evidence of insurance. | Hazard policy and premium for subject is not provided in loan file. Unable to accurately calculate DSCR without premium amount. | Reviewer Comment (2022-07-08): Received, Clearing. Seller Comment (2022-07-08): Rebut: The insurance is covered by the HOA. Master policy was in the file. |
07/08/2022 | 1 | A | TX | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | |||||||||||||||||
| 438820807 | Credit | Loan Package Documentation | Loan File | Missing Document | Missing Document: Hazard Insurance Policy not provided | Reviewer Comment (2022-07-08): Received, Clearing. Seller Comment (2022-07-08): Rebut: Policy was in File |
07/08/2022 | 1 | A | TX | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438820808 | Credit | Loan Package Documentation | Closing / Title | Loan Package Documentation | Missing Document: Closing Protection Letter not provided | Reviewer Comment (2022-07-06): Not found in the original file, clearing. Seller Comment (2022-07-06): Rebut CPL was in the File. |
07/06/2022 | 1 | A | TX | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438820808 | Credit | Loan Package Documentation | Application / Processing | Insurance | Missing Document: Flood Certificate not provided | Reviewer Comment (2022-07-06): Received, Clearing. Seller Comment (2022-07-06): Rebut Flood Cert was in the File |
07/06/2022 | 1 | A | TX | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438820808 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Operating Agreement not provided | Reviewer Comment (2022-07-06): Received, Clearing.. |
07/06/2022 | 1 | A | TX | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438820806 | Credit | Loan Package Documentation | Application / Processing | Insurance | Missing Document: Flood Certificate not provided | Reviewer Comment (2022-07-05): Received, Clearing. Seller Comment (2022-07-05): Uploaded flood certificate |
07/05/2022 | 1 | A | TX | Investment | Refinance - Cash-out - Other | C | B | C | B | A | A | N/A | No | ||||||||||||||||||
| 438820806 | Credit | Borrower and Mortgage Eligibility | Mortgage / Program Eligibility | Borrower and Mortgage Eligibility | Guideline Requirement: Debt Service Coverage Ratio (Subject DSCR) discrepancy. | Calculated Debt Service Coverage Ratio (Subject DSCR) of ___ does not meet Guideline Debt Service Coverage Ratio (Subject DSCR) ___. | DSCR of .98 is < the required DSCR for this transaction of 1.00. An approved exception to credit policy was in the file, however was contingent upon meeting the reserve requirement. | The representative FICO score exceeds the guideline minimum by at least 40 points. The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%. |
SitusAMC SitusAMC |
Reviewer Comment (2022-07-05): Pre-funding exception provided. Seller Comment (2022-07-05): Approved exception uploaded |
07/05/2022 | 2 | B | TX | Investment | Refinance - Cash-out - Other | C | B | C | B | A | A | N/A | No | ||||||||||||||
| 438820806 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Articles of Organization/Formation not provided | Reviewer Comment (2022-07-06): Received, Clearing. |
07/06/2022 | 1 | A | TX | Investment | Refinance - Cash-out - Other | C | B | C | B | A | A | N/A | No | ||||||||||||||||||
| 438820806 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Certificate of Good Standing not provided | The file was missing a copy of the Certificate of Fact. ([Redacted] version of the Certificate of Good Standing) | Reviewer Comment (2022-07-06): Received, Clearing. Seller Comment (2022-07-06): Uploaded cert of formation |
07/06/2022 | 1 | A | TX | Investment | Refinance - Cash-out - Other | C | B | C | B | A | A | N/A | No | |||||||||||||||||
| 438820806 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Corporate Resolution not provided | Reviewer Comment (2022-07-06): Received, Clearing. |
07/06/2022 | 1 | A | TX | Investment | Refinance - Cash-out - Other | C | B | C | B | A | A | N/A | No | ||||||||||||||||||
| 438820806 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Operating Agreement not provided | Reviewer Comment (2022-07-06): Received, Clearing. |
07/06/2022 | 1 | A | TX | Investment | Refinance - Cash-out - Other | C | B | C | B | A | A | N/A | No | ||||||||||||||||||
| 438820806 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | The borrower has a total of 4 financed properties. The reserve requirement is 6 months on the subject plus two months for each additional financed REO (additional 6 months). 12 months reserves was not documented in the file. There were additional assets on the application and referred to in the file that were not present for review. Only the [Redacted] account was present. | Reviewer Comment (2022-07-11): Received, Clearing. Seller Comment (2022-07-11): Uploaded funds transfer sheet along with the updated 1008 showing required reserves Reviewer Comment (2022-07-08): An updated 1008 doesn't resolve missing reserves. Seller Comment (2022-07-08): Uploaded updated 1008 |
07/11/2022 | 1 | A | TX | Investment | Refinance - Cash-out - Other | C | B | C | B | A | A | N/A | No | |||||||||||||||||
| 438820809 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Articles of Organization/Formation not provided | Reviewer Comment (2022-07-06): Received, Clearing. Seller Comment (2022-07-06): Operating Agreement, Articles of Organization, and Corporate Resolution have been attached. |
07/06/2022 | 1 | A | TX | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438820809 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Certificate of Good Standing not provided | Reviewer Comment (2022-07-06): Received, Clearing. Seller Comment (2022-07-06): Certificate of Fact has been attached. ([Redacted]version of the Certificate of Good Standing) |
07/06/2022 | 1 | A | TX | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438820809 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Corporate Resolution not provided | Reviewer Comment (2022-07-06): Received, Clearing. Seller Comment (2022-07-06): Operating Agreement, Articles of Organization, and Corporate Resolution have been attached. |
07/06/2022 | 1 | A | TX | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438820809 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Operating Agreement not provided | Reviewer Comment (2022-07-06): Received, Clearing. Seller Comment (2022-07-06): Operating Agreement, Articles of Organization, and Corporate Resolution have been attached. |
07/06/2022 | 1 | A | TX | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438820819 | Credit | Credit | Credit Eligibility | Guideline | Public Record Issue: | - | Collections amount is greater than the Guidelines-allowed [Redacted] for non-medical debts. | Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower has worked in the same position for more than 3 years. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-09-20): Comp Factors Reviewer Comment (2022-09-20): . Reviewer Comment (2022-09-19): Accepted as is |
09/20/2022 | 2 | B | CT | Primary | Purchase | C | B | C | B | A | A | A | A | Non QM | Non QM | No | |||||||||||
| 438820819 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Hazard Insurance coverage is insufficient by [Redacted]. Dwelling coverage [Redacted] per policy. Replacement cost estimator reflects calculated value of [Redacted] | Reviewer Comment (2022-07-08): Sufficient hazard coverage received Seller Comment (2022-07-08): See Attach Policy with Dwelling of [Redacted] |
07/08/2022 | 1 | A | CT | Primary | Purchase | C | B | C | B | A | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820820 | Compliance | Legal / Regulatory / Compliance | Anti-Predatory Violation | Federal Defect | (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (Notice to Assignee) | Truth in Lending Act (HOEPA): Required Statement was not provided to purchaser or assignee for loan that was sold or assigned. (Note: This notice only applies when selling or assigning a HOEPA loan and may not be found in the file for loans that have not been previously sold) | Reviewer Comment (2022-07-08): Received, Clearing. |
07/08/2022 | 1 | A | CO | Primary | Refinance - Rate/Term | C | B | A | A | C | B | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820820 | Compliance | Legal / Regulatory / Compliance | Anti-Predatory Violation | Federal Defect | (Fed High Cost Provision) Federal High-Cost Mortgage Loan (Late Charge) | Truth in Lending Act (HOEPA): Mortgage loan contains a late charge that exceeds the greater of 4% of the amount past due or grace period of less than 15 days. | Reviewer Comment (2022-07-08): Received, Clearing. |
07/08/2022 | 1 | A | CO | Primary | Refinance - Rate/Term | C | B | A | A | C | B | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820820 | Compliance | Compliance | State Compliance | Misc. State Level | Colorado Consumer Credit Code (First Lien Refinance Notice Not Provided) | Colorado Consumer Credit Code: Borrower not provided First Lien Refinance Notice. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | CO | Primary | Refinance - Rate/Term | C | B | A | A | C | B | A | A | Non QM | Non QM | No | |||||||||||||||
| 438820820 | Compliance | Compliance | State Compliance | State Defect | (State High Cost Disclosure) Colorado Covered Loan (Consumer Caution Notice Not Provided) | Colorado Covered Loan: Consumer Caution Notice not provided to borrower. | Reviewer Comment (2022-07-08): Received, Clearing. |
07/08/2022 | 1 | A | CO | Primary | Refinance - Rate/Term | For application prior to 1/10/14, no obvious cure. For applications on or after 1/10/14, see any available cure under the Colorado Consumer Protection Act threshold exception. |
C | B | A | A | C | B | A | A | Non QM | Non QM | No | |||||||||||||
| 438820820 | Compliance | Compliance | State Compliance | State Defect | (State High Cost) Colorado Covered Loan (Points and Fees) | Colorado Consumer Equity Protection Act: Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of [Redacted] of the Total Loan Amount. Points and Fees total [Redacted] on a Total Loan Amount of [Redacted] vs. an allowable total of [Redacted] (an overage of [Redacted] or [Redacted]). Non-Compliant High Cost Loan. | Missing undiscounted rate price in order to test the discount points for possible exclusion | Reviewer Comment (2022-07-08): Received, Clearing. Seller Comment (2022-07-08): finding based on a [Redacted]% threshold, however the [Redacted]Consumer Equity Protection Act permits a [Redacted]% threshold. The State High Cost test passes with no need to consider bona fide discount |
07/08/2022 | 1 | A | CO | Primary | Refinance - Rate/Term | For application prior to 1/10/14, no obvious cure. For applications on or after 1/10/14, same as DF HOEPA cure: (1) Signed letter from borrower indicating their choice to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (2) Assuming option (a) is selected, a copy of refund check and proof of mailing; (3) Assuming option (b) is selected, proof of cure for each of the prohibited practices violations noted. |
C | B | A | A | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820820 | Compliance | Legal / Regulatory / Compliance | Anti-Predatory Violation | Federal Defect | (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (HOEPA Disclosure Not Provided) | Truth in Lending Act (HOEPA): HOEPA disclosure was not provided to the Borrower | Reviewer Comment (2022-07-08): Received, Clearing. |
07/08/2022 | 1 | A | CO | Primary | Refinance - Rate/Term | C | B | A | A | C | B | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820820 | Compliance | Compliance | Federal Compliance | Federal Defect | (Fed High Cost) Federal High-Cost Mortgage Loan (Points and Fees) | Truth in Lending Act (High-Cost Mortgage): Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of [Redacted] of the Federal Total Loan Amount. Points and Fees of [Redacted] on a Federal Total Loan Amount of [Redacted] vs. an allowable total of [Redacted] (an overage of [Redacted] or [Redacted]). Non-Compliant High Cost Loan. | Reviewer Comment (2022-07-08): Received, Clearing. Seller Comment (2022-07-08): the undiscounted rate of [Redacted] permits the exclusion of one bona fide discount point. The test passes with $[Redacted] discount excluded Seller Comment (2022-07-08): Rate stack shows eligible discount points for this loan to pass federal and [Redacted]high cost |
07/08/2022 | 1 | A | CO | Primary | Refinance - Rate/Term | (1) Signed letter from borrower indicating their choice to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (2) Assuming option (a) is selected, a copy of refund check and proof of mailing; (3) Assuming option (b) is selected, proof of cure for each of the prohibited practices violations noted. | C | B | A | A | C | B | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438820820 | Compliance | Legal / Regulatory / Compliance | Anti-Predatory Violation | Federal Defect | (Fed High Cost Provision) Federal High-Cost Mortgage Loan (Counseling Requirement) | Truth in Lending Act (HOEPA): Borrower did not receive pre-loan counseling. | Reviewer Comment (2022-07-08): Received, Clearing. |
07/08/2022 | 1 | A | CO | Primary | Refinance - Rate/Term | C | B | A | A | C | B | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820822 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - | Reviewer Comment (2022-07-11): Received, Clearing. Seller Comment (2022-07-11): See Tax Cert that was in the file. |
07/11/2022 | 1 | A | CA | Primary | Purchase | C | A | C | A | A | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438820825 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - ATR Risk | Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk. | Loan designation failure due to ATR failure. This exception will be cleared once all ATR specific exceptions have been cured/cleared. | Reviewer Comment (2022-07-21): Received, Clearing. Reviewer Comment (2022-07-12): These will be resolved when the DTI exceeding [Redacted]% is resolved. Buyer Comment (2022-07-12): These are Trigger findings and should be cleared. |
07/21/2022 | 1 | A | NY | Primary | Purchase | Lender to provide updated ATR/QM Loan Designation | C | A | A | A | C | A | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820825 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General Ability To Repay Provision Non QM DTI significantly exceeds Guidelines | Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the 1026.43(c)(5) of [Redacted] significantly exceeds the guideline maximum of [Redacted]. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.) | Lender used higher monthly income based on [Redacted] ownership and [Redacted] fixed expense ratio. | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Loan qualifies at full amort at [Redacted]. See corrected 1008 attached |
07/21/2022 | 1 | A | NY | Primary | Purchase | C | A | A | A | C | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438820825 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: Investor qualifying total debt ratio discrepancy. | Lender qualified at the note rate however, the mortgage is I/O, therefore should be qualified at the fully amortized payment after the I/O period, which is the variance in the DTI | Reviewer Comment (2022-07-21): Received, Clearing. Reviewer Comment (2022-07-12): These will be resolved when the DTI exceeding [Redacted]% is resolved. Buyer Comment (2022-07-12): These are Trigger findings and should be cleared. |
07/21/2022 | 1 | A | NY | Primary | Purchase | C | A | A | A | C | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820823 | Credit | Asset | Asset Documentation | Asset | Guideline Issue:Insufficient asset documentation. | - | Missing most recent two (2) month's bank statements required per guidelines. | Reviewer Comment (2022-07-08): Received, Clearing. Seller Comment (2022-07-08): Uploaded Bank Statement from [redacted] which was in File |
07/08/2022 | 1 | A | FL | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | A | A | N/A | No | ||||||||||||||
| 438820824 | Credit | Credit | Credit Documentation | Credit | There is no lease in place for the subject property and the absence of this document casts doubt on business purpose of loan. | Transaction is a purchase, no leases are in place | Reviewer Comment (2022-07-08): Received, Clearing. Buyer Comment (2022-07-08): [redacted] Invalid, Leases are not required on a purchase, 1007 is in file and and borrower signed statement of occupancy as an investment. |
07/08/2022 | 1 | A | FL | Investment | Purchase | C | A | C | A | A | A | N/A | No | |||||||||||||||||
| 438639365 | Property | Property - Appraisal | Appraisal Documentation | Property - Appraisal | Loan is to be securitized. Secondary valuation is missing.; Sec ID: 2 | The file is missing a copy of the secondary valuation required for securitization purposes. | Reviewer Comment (2022-07-07): Received, Clearing. Seller Comment (2022-07-07): please find the CDA report |
07/07/2022 | 1 | A | PA | Primary | Purchase | D | B | A | A | C | B | D | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639365 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-07-05): Received, Clearing. Seller Comment (2022-07-05): Please see attached for the HOC Disclosure. |
07/05/2022 | 1 | A | PA | Primary | Purchase | D | B | A | A | C | B | D | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639365 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Lender Credit Tolerance Violation | TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of [Redacted] is less than amount of binding Lender Credit previously disclosed in the amount of [Redacted]. | Lender credit decreased from [Redacted] without a valid COC. | Reviewer Comment (2022-07-18): received Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD. Seller Comment (2022-07-14): Please see attached for the PCCD, LOE, Proof of Delivery and Proof of Refund Reviewer Comment (2022-07-12): The fee and Specific Lender Credit are shown correctly on the CD, disappear on theCD and then show as a Tolerance Cure on the CD. Any PCCD is considered a correction for testing. Please provide PCCD showing the Specific Lender Credit in place as it is shown on the CD, including LOE, Proof of mailing and final closing statement showing the fee paid by seller to cure. Buyer Comment (2022-07-08): This lender credit was applied specifically to pay for the Property Value Report as required by our guidelines. The way our system works, it shows it as a general lender credit which is then directly reflected to that specific fee on the Closing Disclosures- thereby appearing to reduce lender credits even though in actuality this did not change. It was always applied/intended for that specific fee. |
07/18/2022 | 2 | B | PA | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | D | B | A | A | C | B | D | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639364 | Credit | Loan Package Documentation | Loan File | Missing Document | Missing Document: Hazard Insurance Policy not provided | Missing evidence of co-op blanket policy | Reviewer Comment (2022-07-14): Received, Clearing. Buyer Comment (2022-07-14): HO-6 is optional on co-op. So no HO6 is required for co-op. |
07/14/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639364 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: Borrower's ability to repay not verified with reliable documentation. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639364 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639364 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639364 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Escrow Not Established) | New York Subprime Loan: Mandatory escrow account not established for the collection of property taxes and insurance. (Note: Does not apply to a subordinate lien when the taxes and insurance are escrowed through another home loan. It also does not apply if the borrower can demonstrate a record of 12 months of timely payments of taxes and insurance on a previous home loan.) | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639364 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate 3.76000 + 1.75%, or 5.51000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639364 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639364 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Abstract / Title Search. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | Insufficient or no cure was provided to the borrower. | Reviewer Comment (2022-07-27): [redacted] received : Letter of Explanation, Proof of Mailing, Copy of Refund Check, and Corrected PCCD Seller Comment (2022-07-26): Please see attached for the PCCD, LOE, Proof of Delivery and Proof of Refund Reviewer Comment (2022-07-21): [redacted] upon further review, received Pre-CD dated [redacted] & COC [redacted]. It states "Necessary co-op fees added". It's not a valid reason for addition of Title - Abstract/Title Search. Please provide a valid COC reason of the required purpose for the fee been added. Seller Comment (2022-07-20): Please see attached for the pre-cd provided to us and its associated COC CD done on the same day. The lien search is for the required lien search. The recording service fee is for the recorded initial UCC-1 needed on co-ops. Reviewer Comment (2022-07-20): [redacted] upon further review, Title - Settlement Fee was updated in Section B (Services You Cannot Shop For) on Final LE. Title - Abstract/Title Search fee was updated in Section C Services you can shop for on CD [redacted]. COC states Title fees updated. It does not give sufficient information on why the fee was added. In order to determine if the COC is valid more information is necessary on reason fee added and when lender became aware of the change. A valid COC or cure is required. Cure consists of Corrected CD, LOE to borrower, proof of mailing and copy of refund check. Buyer Comment (2022-07-19): According to TRID guidelines section 10.1 [redacted], we may estimate disclosures using the best information reasonably available when the actual term or cost is not reasonably available to the creditor at the time the disclosure is made. We made the update as we got this information on the pre-CD provided by the settlement agent. We could not have added it prior because this information was not yet made available to us yet. Reviewer Comment (2022-07-19): [redacted] received CD dated [redacted] and corresponding COC however, reason for increase in fee is not mentioned on it. Please provide updated COC with reason for increase or any additional information to validate the change. Otherwise cure will be required. Seller Comment (2022-07-18): Please see attached for the COC CD regarding this fee change. Reviewer Comment (2022-07-18): [redacted] - As per TRID Guidelines [redacted], For certain costs or terms, creditors are permitted to charge consumers more than the amount disclosed on the Loan Estimate without any tolerance limitation. As per, [redacted] - "For services required by the creditor if the creditor permits the consumer to shop and the consumer selects a third-party service provider not on the creditor's written list of service providers". However, in this case, the 'Title -Lien Search' & 'Title - Recording Service' Fee were not disclosed in section C of LE i.e borrower was not given an option to shop for. Since borrower did not have an option to shop for these fees & they were directly added in section C of final CD without a valid COC, hence there is a tolerance violation. A total cure is due for [redacted] in absence of valid COC for 'Title - Lien Search' & 'Title - Recording Service Fee' added on final CD. Cure documents consist of PCCD, LOE, copy of refund check, proof of mailing. Exception remains. Buyer Comment (2022-07-15): According to TRID guidelines section 7.3 [redacted] , these third-party service charges may change without regard to a tolerance limitation. Specifically with the third-party services, they are services permitted to the borrower to shop for and not same service listed on our SSPL that was initially disclosed. Reviewer Comment (2022-07-15): [redacted] - 'Title - Lien Search' & 'Title - Recording Service Fee' were not disclosed on LE & were added directly on final CD dated [redacted]. There is no valid COC in file for addition of these fees. Also, Section C of LE's & CD's until [redacted] shows 'Co-op Lien Search' & 'Recognition Agreements' as borrower shopped fees. An attestation would be required if fees disclosed in section C of 5/19 final CD are the same diclosed previously on LE & CD's or a valid COC/cure would be required for addition of 'Title - Lien Search' & 'Title - Recording Service fee' on [redacted] CD. Exceptions remains. Buyer Comment (2022-07-14): The service provider selected was not the one listed on the SSPL. Therefore, this fee is not subject to a tolerance limit. No cure required. |
07/27/2022 | 2 | B | NY | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639364 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Recording Service Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | Insufficient or no cure was provided to the borrower. | Reviewer Comment (2022-07-27): [redacted] received: Letter of Explanation, Proof of Mailing, Copy of Refund Check, and Corrected PCCD Seller Comment (2022-07-26): Please see attached for the PCCD, LOE, Proof of Delivery and Proof of Refund. Reviewer Comment (2022-07-19): [redacted] received CD dated [redacted] and corresponding COC however, reason for increase in fee is not mentioned on it. Please provide updated COC with reason for increase or any additional information to validate the change. Otherwise cure will be required. Seller Comment (2022-07-18): Please see attached for the COC CD regarding this fee change. Reviewer Comment (2022-07-15): [redacted] - 'Title - Lien Search' & 'Title - Recording Service Fee' were not disclosed on LE & were added directly on final CD dated [redacted]. There is no valid COC in file for addition of these fees. Also, Section C of LE's & CD's until 5/6 shows 'Co-op Lien Search' & 'Recognition Agreements' as borrower shopped fees. An attestation would be required if fees disclosed in section C of [redacted] final CD are the same diclosed previously on LE & CD's or a valid COC/cure would be required for addition of 'Title - Lien Search' & 'Title - Recording Service fee' on [redacted] CD. Exceptions remains. Buyer Comment (2022-07-14): The service provider selected was not the one listed on the SSPL. Therefore, this fee is not subject to a tolerance limit. No cure required. |
07/27/2022 | 2 | B | NY | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639364 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided Within 3 Business Days of Application | RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Organizations not provided to applicant within three (3) business days of application. | Evidence of earlier receipt was not received | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639364 | Credit | Insurance | Insurance Documentation | Insurance | Hazard Insurance Error: Missing HO-6 policy, blanket hazard insurance policy provided does not contain unit interior coverage. | Missing evidence of walls-in coverage | Reviewer Comment (2022-07-14): Received, Clearing. Buyer Comment (2022-07-14): HO-6 is optional on co-op. So no HO6 is required for co-op. |
07/14/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639371 | Credit | Credit | Credit Calculation / Analysis | Guideline | Guideline Requirement: Representative FICO score discrepancy. | Reviewer Comment (2022-07-08): Received, Clearing. Seller Comment (2022-07-07): please find final credit report with fico [redacted], it meets the guideline now |
07/08/2022 | 1 | A | NY | Primary | Purchase | C | A | C | A | A | A | C | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639371 | Credit | Credit | Credit Documentation | Guideline | Aged document: Credit Report is more than 90 days prior to the note date. | - | Reviewer Comment (2022-07-08): Received, Clearing. Seller Comment (2022-07-07): see updated one, fico [redacted] |
07/08/2022 | 1 | A | NY | Primary | Purchase | C | A | C | A | A | A | C | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639371 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.17% + 2.5%, or 7.67000%. Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-07-25): Second appraisal received |
07/25/2022 | 1 | A | NY | Primary | Purchase | C | A | C | A | A | A | C | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639371 | Property | Property - Appraisal | Appraisal Documentation | Property - Appraisal | The property type differs between the valuation documents in file. Unable to verify the property type. Ineligible per guidelines. | 2 appraisals required due to Loan Amount, however, One appraisal is completed on a Coop 2090 form - the Other appraisal was completed on a Condo form 1073 | Reviewer Comment (2022-07-25): Second appraisal completed post closing Seller Comment (2022-07-25): Please see attached revised appraisal. |
07/25/2022 | 1 | A | NY | Primary | Purchase | C | A | C | A | A | A | C | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639371 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Credit | Guideline Requirement: Property type discrepancy. | Reviewer Comment (2022-07-25): Received, Clearing. Seller Comment (2022-07-25): Please see attached revised appraisal. |
07/25/2022 | 1 | A | NY | Primary | Purchase | C | A | C | A | A | A | C | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639371 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.17% + 2.5%, or 7.67000%. Non-Compliant Higher Priced Mortgage Loan. | Second appraisal completed post closing | Reviewer Comment (2022-07-26): Received, clearing. Buyer Comment (2022-07-26): The date of signature report [redacted] shows when the appraisal was revised, not the original delivery date. The appraisal was delivered to the borrower more than 3 days prior to consummation, thus the timing is within compliance. Reviewer Comment (2022-07-26): The updated appraisal form was received in trailing documents on [redacted] and was completed post closing Buyer Comment (2022-07-26): Pending the clearing of related condition. |
07/26/2022 | 1 | A | NY | Primary | Purchase | C | A | C | A | A | A | C | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639371 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal Not Obtained Timely) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained prior to consummation. | Second appraisal completed post closing | Reviewer Comment (2022-07-26): Received, clearing. Buyer Comment (2022-07-26): The date of signature report [redacted] shows when the appraisal was revised, not the original delivery date. The appraisal was delivered to the borrower more than 3 days prior to consummation, thus the timing is within compliance. Reviewer Comment (2022-07-26): The updated appraisal form was received in trailing documents on [redacted] and was completed post closing Seller Comment (2022-07-26): Please see attached for the appraisal delivery letter. This was in the shipped file. |
07/26/2022 | 1 | A | NY | Primary | Purchase | C | A | C | A | A | A | C | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639371 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Second appraisal completed post closing | Reviewer Comment (2022-07-26): Received, clearing. Buyer Comment (2022-07-26): The date of signature report [redacted] shows when the appraisal was revised, not the original delivery date. The appraisal was delivered to the borrower more than 3 days prior to consummation, thus the timing is within compliance. Reviewer Comment (2022-07-26): The updated appraisal form was received in trailing documents on [redacted] and was completed post closing Seller Comment (2022-07-26): Please see attached for the appraisal delivery letter. This was in the shipped file. |
07/26/2022 | 1 | A | NY | Primary | Purchase | C | A | C | A | A | A | C | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639369 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.38% + 1.5%, or 6.88000%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-07-18): Received PCCD, copy of the Refund Check, Proof of Delivery, and Cover Letter Buyer Comment (2022-07-18): requeuing this again as it was officially delivered Reviewer Comment (2022-07-14): Received cure documentation. Please requeue the loan once the package has been delivered by the borrower after so exception can be cured Buyer Comment (2022-07-14): Cure provided and package has been picked up. |
07/18/2022 | 1 | A | NY | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639369 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Closing Disclosure Timing without Waiver | TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. | The file does not contain evidence of the date borrower received the Closing Disclosure. | Reviewer Comment (2022-07-11): received the initial CD. Seller Comment (2022-07-07): Please see attached for the initial and final CD with borrower acknowledgement. |
07/11/2022 | 1 | A | NY | Primary | Purchase | No Defined Cure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639369 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Flipped Property - Borrower Charged for 2 Appraisals) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Flipped Property - Creditor improperly charged consumer for two (2) appraisals. | Reviewer Comment (2022-07-18): Received PCCD, copy of the Refund Check, Proof of Delivery, and Cover Letter Buyer Comment (2022-07-18): requeuing this again as it was officially delivered Buyer Comment (2022-07-14): Docs for the cure provided. Package now picked up.[Redacted] Reviewer Comment (2022-07-14): Received cure documentation. Please requeue the loan once the package has been delivered by the borrower after so exception can be cured Seller Comment (2022-07-14): Please see attached for the PCCD, LOE, Proof of Delivery and Proof of Refund Reviewer Comment (2022-07-08): This is a result of borrower improperly being charged for two appraisals, cure option is to provide evidence of the refund of the amount charged to the consumer for the second appraisal performed on the subject property. (Include a copy of the Refund Check, Proof of Delivery, and Cover Letter). Seller Comment (2022-07-08): Please see attached for the COC LE regarding this fee change. |
07/18/2022 | 2 | B | NY | Primary | Purchase | Provide evidence of the refund of the amount charged to the consumer for the second appraisal performed on the subject property. (Include a copy of the Refund Check, Proof of Delivery, and Cover Letter) | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639366 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___. | The representative FICO score exceeds the guideline minimum by at least 40 points. The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-07-27): Post funding exception, waived with compensating factors Seller Comment (2022-07-27): Please see attached exceptional approval. |
07/27/2022 | 2 | B | FL | Primary | Refinance - Cash-out - Other | C | B | C | B | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639363 | Credit | Title | Document Error | Title | The Preliminary title policy is within CA or NV and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided. | There is no proposed loan amount listed on title. | 2 | B | CA | Primary | Purchase | C | B | B | B | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||||
| 438639363 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | 2 | B | CA | Primary | Purchase | C | B | B | B | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||||
| 438639363 | Compliance | Compliance | State Compliance | State Defect | (State High Cost) California Covered Loan (Points and Fees) | California Anti-Predatory Lending Statute: Points and Fees on subject loan of (Redacted) is in excess of the allowable maximum of (Redacted) of the Total Loan Amount. Points and Fees total (Redacted) on a Total Loan Amount of (Redacted) vs. an allowable total of (Redacted) (an overage of (Redacted) or (Redacted)). Compliant High Cost Loan. | Please provide documentation clarifying specific details (detailed fee description and payee) for [Redacted] Security Escrow from Section H. | Reviewer Comment (2022-07-18): Offset provided for Security Escrow from CA P&F calculation. Seller Comment (2022-07-15): Please see attached for an LOE and PCCD explaining this error. |
07/18/2022 | 1 | A | CA | Primary | Purchase | (Very Narrow Defense - CHD Approval Required) Within 45 days of discovery, provide: (1) Lender Attestation to AMC attesting the failure was not intentional and was a bona fide error notwithstanding procedures in place to prevent such loans from being made; (2) refund of amount over the high-cost threshold maximum; and (3) proof of delivery. | C | B | B | B | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639363 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure APR | TILA-RESPA Integrated Disclosure - Loan Calculations: APR of [Redacted] on Final Closing Disclosure provided on [Redacted] is under-disclosed from the calculated APR of (Redacted) outside of (Redacted) tolerance. | Loan Calculations: APR of (Redacted) on Final Closing Disclosure provided on (Redacted) is under-disclosed from the calculated APR of (Redacted) outside of (Redacted) tolerance. (Final (Redacted)) | Reviewer Comment (2022-07-20): received Corrected CD and LOE to borrower. FSS in file to support the release of the escrow funds back to borrower. Reviewer Comment (2022-07-20): correcting status Reviewer Comment (2022-07-20): received Corrected CD and LOE to borrower removing escrow fee Buyer Comment (2022-07-18): This should no longer be applicable as the high cost fail has been cleared up. Putting this back into review queue. |
07/20/2022 | 1 | A | CA | Primary | Purchase | TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected CD, and Re-open Rescission if Applicable | C | B | B | B | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639363 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Finance Charge | TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on (Redacted) disclosed an inaccurate Finance Charge on page 5 that does not match the actual Finance Charge for the loan (fee amounts included in Finance Charge calculation are based on Closing Disclosure dated (Redacted)). | The final CD reflects finance charge of (Redacted), calculated finance charge is (Redacted), a variance of (Redacted). | Reviewer Comment (2022-07-20): received Corrected CD and LOE to borrower. FSS in file to support the release of the escrow funds back to borrower. Buyer Comment (2022-07-18): This should no longer be applicable as the high cost fail has been cleared up. Putting this back into review queue. |
07/20/2022 | 1 | A | CA | Primary | Purchase | TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission if Applicable | C | B | B | B | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639368 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Hazard insurance coverage must equal or exceed the loan amount. | Reviewer Comment (2022-07-22): Received, Clearing. Seller Comment (2022-07-22): Please see attached for the RCE. |
07/22/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639368 | Credit | Property - Appraisal | Appraisal Adjustments | Property - Appraisal | Excessive site value noted on appraisal without appraiser comments to justify | - | Appraiser comments the land value to total property values ratio is common for this market. | Reviewer Comment (2022-07-13): Received, Clearing. Seller Comment (2022-07-13): Site value is noted in Cost Approach and ADJ for such in Addendum. |
07/13/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639368 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Safe Harbor requirements not satisfied. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639368 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Missing Homeownership Counseling Organizations disclosure. | Reviewer Comment (2022-07-13): Received, Clearing. Seller Comment (2022-07-13): Please see attached for the HOC disclosure. |
07/13/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639368 | Credit | Asset | Asset Documentation | Asset | Asset documentation requirements not met. | EMD required to be sourced. | Reviewer Comment (2022-07-12): Received, Clearing. Seller Comment (2022-07-12): Please see attached for the EMD |
07/12/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639368 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | EMD required to be sourced. | Reviewer Comment (2022-07-13): Received, Clearing. |
07/13/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639368 | Credit | Asset | Asset Calculation / Analysis | Asset | Available for Closing is insufficient to cover Cash From Borrower. | EMD required to be sourced. | Reviewer Comment (2022-07-13): Received, Clearing. Seller Comment (2022-07-13): Cash Available: [redacted]. Borrower has sufficient funds to close, therefore EMD does not need to be sourced. |
07/13/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639367 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-07-13): Received, Clearing. Seller Comment (2022-07-13): Please see attached for the HOC Disclosure. |
07/13/2022 | 1 | A | CA | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639367 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure PAD Fee | TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on (Redacted)disclosed a Pad fee that was not allocated to a specific cost or service performed. | Padding is an estimation which is not permitted. | Reviewer Comment (2022-07-18): received Letter of Explanation, Proof of Delivery, Copy of [redacted] Check if applicable, and Corrected CD. Seller Comment (2022-07-14): Please see attached for the docs provided along with the requested LOE. Reviewer Comment (2022-07-14): received Corrected CD issued[Redacted]. Missing copy of LOE to borrower which should accompany the correction in order to finalize cure. Seller Comment (2022-07-13): Updated PCCD and settlement statement provided. I noticed that the abstract search for was listed incorrectly and lumped with another fee for another party. This has now been updated. If this is not correct, can you let us know what fee you're referring to and go into detail on the issue? Buyer Comment (2022-07-13): Which one are you referring to as the fee and can this be remedied by issuing a cure? |
07/18/2022 | 2 | B | CA | Primary | Purchase | Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Pad Refund Check if applicable, and Corrected CD | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639367 | Credit | Missing Document | General | Missing Document | Missing Document: Donor Check not provided | Transfer of (Redacted) gift was not documented with gift check and transfer of funds to borrower's account. | Reviewer Comment (2022-07-13): Received, Clearing. Seller Comment (2022-07-13): Please see attached asset documents. The following is the trail of the gift funds which is all documented. • gift was gifted from to our borrower, [Redacted]. • The donor wired the funds from his account into his daughter's account ([Redacted], borrowers wife) on [Redacted]. • On [Redacted], [Redacted]transferred of the into her account (joint with our borrower). • On [Redacted], they transferred into (also joint with borrower) which is where the money remained verified for closing. • On [Redacted], the account also had a transfer in from however I deducted this from the ending balance and we still have ample funds. |
07/13/2022 | 1 | A | CA | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639372 | Credit | Loan Package Documentation | Application / Processing | Missing Document | Missing Document: Divorce Decree / Child Support not provided | Reviewer Comment (2022-07-19): Received, Clearing. Seller Comment (2022-07-19): Please see attached credit letter of explanation for child support. |
07/19/2022 | 1 | A | CA | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639372 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure - 1026.19(f)(2) Cure | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax. Fee Amount of (Redacted) exceeds tolerance of (Redacted). Sufficient or excess cure was provided to the borrower. | Transfer tax Fee was not disclosed on Loan Estimate. File does not contain a valid COC for this fee, cure provided at closing. | Reviewer Comment (2022-07-08): Sufficient Cure Provided within [Redacted]Days of Closing |
07/08/2022 | 1 | A | CA | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639372 | Credit | Asset | Asset Documentation | Asset | Asset documentation requirements not met. | EMD required to be sourced. | Reviewer Comment (2022-07-12): Received, Clearing. Seller Comment (2022-07-12): See attached for EMD |
07/12/2022 | 1 | A | CA | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639370 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | MD | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639370 | Compliance | Compliance | State Compliance | Misc. State Level | Maryland Counseling Agencies Disclosure Not in File | Maryland HB1399 - No evidence of counseling agencies list per Maryland HB 1399. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | MD | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639370 | Credit | Asset | Asset Documentation | Asset | Asset documentation requirements not met. | EMD required to be sourced. | Reviewer Comment (2022-07-26): Sufficient funds to close without the EMD source Buyer Comment (2022-07-26): The EMD check is for [redacted]. If we do not give them credit then they would need to show [redacted] plus [redacted] months reserves [redacted]. A total of [redacted]. We verified [redacted]. Even if you subtract the [redacted] from the balance, they still have [redacted]. Borrower has sufficient funds so EMD does not need to be sourced. This should be removed. Reviewer Comment (2022-07-12): We have a copy of the check we need to see the source of where those funds came from. Seller Comment (2022-07-12): Please see attached for EMD |
07/26/2022 | 1 | A | MD | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639374 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Reviewer Comment (2022-08-05): Clearing based on meeting FNMA guidelines and client approval of that. Seller Comment (2022-07-27): Please see attached exceptional approval. |
08/05/2022 | 1 | A | CA | Investment | Refinance - Cash-out - Debt Consolidation | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438639373 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Reviewer Comment (2022-07-19): Received, Clearing. Seller Comment (2022-07-19): Per attached HOI, it's RC for property in FL, and RCE is not required in FL by law, this is sufficient. |
07/19/2022 | 1 | A | FL | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438639373 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Operating Agreement not provided | Reviewer Comment (2022-07-15): Received, Clearing. Seller Comment (2022-07-15): Operating Agreement |
07/15/2022 | 1 | A | FL | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438639373 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Corporate Resolution not provided | Reviewer Comment (2022-07-15): Received, Clearing. Seller Comment (2022-07-15): corporate Resolution |
07/15/2022 | 1 | A | FL | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438639373 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Articles of Organization/Formation not provided | Reviewer Comment (2022-07-05): Received, Clearing. Seller Comment (2022-07-01): Articles of Organization. |
07/05/2022 | 1 | A | FL | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438639373 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Employer Identification Number (EIN) not provided | Reviewer Comment (2022-07-15): Received, Clearing. Seller Comment (2022-07-15): EIN |
07/15/2022 | 1 | A | FL | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438639376 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Operating Agreement not provided | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Operating Agreement |
07/21/2022 | 1 | A | CT | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438639376 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Certificate of Good Standing not provided | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Cert of good standing |
07/21/2022 | 1 | A | CT | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438639376 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Corporate Resolution not provided | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): [redacted] Resolution. |
07/21/2022 | 1 | A | CT | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438639375 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | FEMA Disaster Issue: The most recent valuation inspection is dated prior to the most recent FEMA disaster. | 07/15/2022 | 1 | A | OK | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | |||||||||||||||||||
| 438639375 | Credit | Insurance | Insurance Documentation | Insurance | Rent loss insurance is required on all properties and there is no evidence of this insurance in the file. | Reviewer Comment (2022-07-21): Received, Clearing. |
07/21/2022 | 1 | A | OK | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438820814 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Reviewer Comment (2022-07-08): Received, Clearing. Seller Comment (2022-07-08): Rebut Property is Condo, Walls in coverage is sufficient. Master Policy was provided. |
07/08/2022 | 1 | A | NY | Investment | Purchase | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438820831 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Total Property Costs Year 1 - October 2018 Test | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of [Redacted] on Final Closing Disclosure provided on [Redacted] not accurate. | The final CD disclosed the Amount of Total Property Costs over Year 1 as [Redacted] on page 4; however the annual taxes ([Redacted]) and homeowners insurance ([Redacted])are [Redacted] per year. Final CD reflects Estimated Taxes, Insurance & Assessments of [Redacted] monthly, correct amount is [Redacted]. Provide a post-close CD correcting on page 4 and Estimated Taxes, Insurance & Assessments on page 1; and a copy of the letter of explanation letter sent to the borrower disclosing the changes made. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | Letter of Explanation & Corrected Closing Disclosure | B | B | B | B | B | B | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438820831 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-07-07): Sufficient Cure Provided At Closing |
07/07/2022 | 1 | A | NY | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | B | B | B | B | B | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820831 | Credit | Credit | Credit Documentation | Credit | Credit Report Error: Missing source document for credit/housing history. | The borrower has no housing history, has been living rent free however rent-free letter is missing | The representative FICO score exceeds the guideline minimum by at least 40 points. The qualifying DTI on the loan is at least 10% less than the guideline maximum. The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-07-07): Prefunding exception, waived with compensating factors |
07/07/2022 | 2 | B | NY | Primary | Refinance - Cash-out - Other | B | B | B | B | B | B | A | A | Non QM | Non QM | No | ||||||||||||
| 438820832 | Compliance | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Missing Lender's Initial 1003 | Missing copy of lender's initial 1003 | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | FL | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438820832 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | FL | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438820833 | Credit | Income / Employment | Income Documentation | Income / Employment | Verification(s) of employment is not within 10 calendar days of the Note. | - | Missing vvoe dated within 10 business days of the Note date for [Redacted] current employment with [Redacted]. | Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): Please see attached |
07/20/2022 | 1 | A | CA | Primary | Purchase | C | A | C | A | A | A | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | |||||||||||||
| 438820833 | Credit | Income / Employment | Income Documentation | Income / Employment | Verification(s) of employment is not within 10 calendar days of the Note. | - | Missing vvoe dated within 10 business days of the Note date for [Redacted] current employment with [Redacted]. | Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): Please see attached |
07/20/2022 | 1 | A | CA | Primary | Purchase | C | A | C | A | A | A | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | |||||||||||||
| 438820833 | Credit | Income / Employment | Income Documentation | Income / Employment | The verification of employment is required and was not found in file. | - | Missing VVOE from [Redacted]. | Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): Please see attached |
07/20/2022 | 1 | A | CA | Primary | Purchase | C | A | C | A | A | A | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | |||||||||||||
| 438820833 | Credit | Income / Employment | Income Documentation | Income / Employment | The verification of employment is required and was not found in file. | - | Missing VVOE from [Redacted]. | Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): Please see attached |
07/20/2022 | 1 | A | CA | Primary | Purchase | C | A | C | A | A | A | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | |||||||||||||
| 438820834 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of [Redacted] exceeds tolerance of [Redacted] plus [Redacted] or [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-07-07): Sufficient Cure Provided At Closing |
07/07/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | A | A | A | A | A | A | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | Yes | |||||||||||||
| 438820834 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-07-07): Sufficient Cure Provided At Closing |
07/07/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | A | A | A | A | A | A | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | Yes | |||||||||||||
| 438820838 | Compliance | Legal / Regulatory / Compliance | Anti-Predatory Violation | Federal Defect | (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (Notice to Assignee) | Truth in Lending Act (HOEPA): Required Statement was not provided to purchaser or assignee for loan that was sold or assigned. (Note: This notice only applies when selling or assigning a HOEPA loan and may not be found in the file for loans that have not been previously sold) | The file contained evidence of the undiscounted rate, but did not contain evidence of the undiscounted rate price in order to potentially exclude any bony fide points. Please provide evidence of the undiscounted rate price for further testing. | Reviewer Comment (2022-07-19): Received, Clearing. |
07/19/2022 | 1 | A | FL | Primary | Purchase | C | A | A | A | C | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438820838 | Compliance | Legal / Regulatory / Compliance | Anti-Predatory Violation | Federal Defect | (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (HOEPA Disclosure Not Provided) | Truth in Lending Act (HOEPA): HOEPA disclosure was not provided to the Borrower | The file contained evidence of the undiscounted rate, but did not contain evidence of the undiscounted rate price in order to potentially exclude any bony fide points. Please provide evidence of the undiscounted rate price for further testing. | Reviewer Comment (2022-07-19): Received, Clearing. |
07/19/2022 | 1 | A | FL | Primary | Purchase | C | A | A | A | C | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438820838 | Compliance | Legal / Regulatory / Compliance | Anti-Predatory Violation | Federal Defect | (Fed High Cost Provision) Federal High-Cost Mortgage Loan (Late Charge) | Truth in Lending Act (HOEPA): Mortgage loan contains a late charge that exceeds the greater of 4% of the amount past due or grace period of less than 15 days. | The file contained evidence of the undiscounted rate, but did not contain evidence of the undiscounted rate price in order to potentially exclude any bony fide points. Please provide evidence of the undiscounted rate price for further testing. | Reviewer Comment (2022-07-19): Received, Clearing. |
07/19/2022 | 1 | A | FL | Primary | Purchase | C | A | A | A | C | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438820838 | Compliance | Compliance | Federal Compliance | Federal Defect | (Fed High Cost) Federal High-Cost Mortgage Loan (Points and Fees) | Truth in Lending Act (High-Cost Mortgage): Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of [Redacted] of the Federal Total Loan Amount. Points and Fees of [Redacted] on a Federal Total Loan Amount of [Redacted] vs. an allowable total of [Redacted] (an overage of [Redacted] or [Redacted]). Non-Compliant High Cost Loan. | The file contained evidence of the undiscounted rate, but did not contain evidence of the undiscounted rate price in order to potentially exclude any bony fide points. Please provide evidence of the undiscounted rate price for further testing. | Reviewer Comment (2022-07-19): Received, Clearing. Buyer Comment (2022-07-19): undiscounted rate/price [redacted]. Loan passes with bona fide points |
07/19/2022 | 1 | A | FL | Primary | Purchase | (1) Signed letter from borrower indicating their choice to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (2) Assuming option (a) is selected, a copy of refund check and proof of mailing; (3) Assuming option (b) is selected, proof of cure for each of the prohibited practices violations noted. | C | A | A | A | C | A | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820838 | Compliance | Legal / Regulatory / Compliance | Anti-Predatory Violation | Federal Defect | (Fed High Cost Provision) Federal High-Cost Mortgage Loan (Counseling Requirement) | Truth in Lending Act (HOEPA): Borrower did not receive pre-loan counseling. | The file contained evidence of the undiscounted rate, but did not contain evidence of the undiscounted rate price in order to potentially exclude any bony fide points. Please provide evidence of the undiscounted rate price for further testing. | Reviewer Comment (2022-07-19): Received, Clearing. |
07/19/2022 | 1 | A | FL | Primary | Purchase | C | A | A | A | C | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438820839 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | FL | Primary | Purchase | C | B | A | A | C | B | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | |||||||||||||||
| 438820839 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien | TRID Final Closing Disclosure [Redacted] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) | No seller paid fees disclosed on Final Closing Disclosure | Reviewer Comment (2022-07-13): [redacted] received Seller CD. Seller Comment (2022-07-11): Uploaded seller paid stmts that were in file pg [redacted] |
07/13/2022 | 1 | A | FL | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | Yes | ||||||||||||
| 438820851 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NJ | Primary | Purchase | B | B | B | B | B | B | A | A | Non QM | Non QM | No | |||||||||||||||
| 438820851 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Credit | Payment Shock exceeds credit guidelines. | Payment Shock: ___ | The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-07-07): Prefunding credit exception approval, waived with compensating factors |
07/07/2022 | 2 | B | NJ | Primary | Purchase | B | B | B | B | B | B | A | A | Non QM | Non QM | No | ||||||||||||
| 438820852 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-07-08): Sufficient Cure Provided At Closing |
07/08/2022 | 1 | A | NY | Primary | Purchase | Final CD evidences Cure | A | A | A | A | A | A | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438820854 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of [Redacted] of the Federal Total Loan Amount. Points and Fees total [Redacted] on a Federal Total Loan Amount of [Redacted] vs. an allowable total of [Redacted] (an overage of [Redacted] or [Redacted]). | Missing proof of undiscounted rate so any excludable points can be applied. | Reviewer Comment (2022-07-18): Restated. Seller Comment (2022-07-18): Loan passes the QM [redacted] points and fees threshold with the benefit of excluding the discount [redacted] as bona fide based on the undiscounted rate. Undiscounted Rate is [redacted]. |
07/18/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||
| 438820854 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Verified Loan Designation of Safe Harbor QM | Reviewer Comment (2022-07-18): Restated. Buyer Comment (2022-07-18): Please reinstate to NQM |
07/18/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM status | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438820854 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Closing Disclosure Timing without Waiver | TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. | Missing evidence or proof that [Redacted] Closing disclosure was sent to borrower and received | Reviewer Comment (2022-07-22): [redacted] received electronically signed earlier initial CD Seller Comment (2022-07-20): [redacted] CD was signed by the borrower and viewed by Non Borrowing Spouse. Attached Doc[redacted] and CD - timing is met Reviewer Comment (2022-07-20): Initial CD is dated [redacted] and is not signed. Mailbox rule indicates receipt of initial CD on [redacted], and closing on [redacted]. Initial CD was not received 3 or more days prior to closing. No obvious cure available on this timing issue. Seller Comment (2022-07-18): Response: Please see attached CD with COC dated [redacted] executed by the borrowers - this should satisfy both the [redacted] day COC timing and the[redacted] day CD delivery timing prior to the closing on [redacted] per Executed Final CD attached. |
07/22/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | No Defined Cure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||
| 438820854 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - General Ability to Repay | Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not match. However, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. | Restated. | Reviewer Comment (2022-09-19): Accepted as is Reviewer Comment (2022-07-22): We were advised to restate to NQM in provided response to exception: (Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of [redacted] QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail.) Buyer Comment (2022-07-22): this wasn't restated, loan passes testing |
2 | B | FL | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||||
| 438820846 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of [Redacted] of the Federal Total Loan Amount. Points and Fees total [Redacted] on a Federal Total Loan Amount of [Redacted] vs. an allowable total of [Redacted] (an overage of [Redacted] or [Redacted]). | Discount Points, MERS, Processing and Underwriting fees included for testing | Reviewer Comment (2022-07-20): Restated. Buyer Comment (2022-07-20): This is a valid fail, please restate as NQM |
07/20/2022 | 1 | A | MO | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||
| 438820846 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Loan fails QM testing due to excessive points & fees | Reviewer Comment (2022-07-20): Restated. |
07/20/2022 | 1 | A | MO | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM status | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438820846 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - General Ability to Repay | Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not match. However, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. | Restated. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MO | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||||
| 438820842 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | There is a shortfall for the hazard insurance, RCE on file shows value of home at [Redacted]. HOI coverage is still insufficient at [Redacted]. | Reviewer Comment (2022-07-15): Received, Clearing. Seller Comment (2022-07-15): Attached HOI with [redacted] dwelling amount. |
07/15/2022 | 1 | A | CA | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | |||||||||||||||||
| 438820843 | Credit | Borrower and Mortgage Eligibility | Mortgage / Program Eligibility | Borrower and Mortgage Eligibility | Guideline Requirement: Debt Service Coverage Ratio (Subject DSCR) discrepancy. | Reviewer Comment (2022-07-11): Received, Clearing. Buyer Comment (2022-07-11): The leases provided do show rent collected of [redacted], the utilities amount separated should be included as the borrower receives that payment included in the rent. It is not necessary to subtract the utilities from the collected funds. The [redacted] amount is [redacted] and that is what was used to qualify since it is lower then the provided leases. Reviewer Comment (2022-07-08): There are leases in the the that total less than the [redacted] your using for rental income. Seller Comment (2022-07-08): Finding: Calculated Debt Service Coverage Ratio (Subject DSCR) of [redacted] does not meet Guideline Debt Service Coverage Ratio (Subject DSCR) [redacted]. |
07/11/2022 | 1 | A | CA | Investment | Purchase | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438820844 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | Earnest Money Deposit. | Reviewer Comment (2022-07-11): Received, Clearing. Seller Comment (2022-07-11): Attached the EMD source of funds and check. |
07/11/2022 | 1 | A | FL | Investment | Purchase | C | A | C | A | A | A | N/A | No | |||||||||||||||||
| 438820844 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | Gift Funds. | Reviewer Comment (2022-07-13): Received, Clearing. Seller Comment (2022-07-13): Source of funds for the Gift Letter. Reviewer Comment (2022-07-11): We already had gift letter, what we need is the Source of Funds/Deposit. Seller Comment (2022-07-11): Uploaded gift documentation |
07/13/2022 | 1 | A | FL | Investment | Purchase | C | A | C | A | A | A | N/A | No | |||||||||||||||||
| 438820853 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM (APOR) Threshold Fail | Qualified Mortgage: QM APR on subject loan of [Redacted] is equal to or greater than the threshold of [Redacted]. | Reviewer Comment (2022-08-17): Restated. Buyer Comment (2022-08-17): please restate as NQM Reviewer Comment (2022-08-16): The APR on subject loan of[redacted] is greater than the threshold of [redacted].. A transaction's annual percentage rate is compared to the average prime offer rate as of the date the transaction's interest rate is set (or "locked") before consummation. Sometimes a creditor sets the interest rate initially and then re-sets it at a different level before consummation. The creditor should use the last date the interest rate is set before consummation." Buyer Comment (2022-08-16): Confirmed loan designation is QM HPML Rebuttable Presumption. |
08/17/2022 | 1 | A | CO | Primary | Purchase | C | B | C | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | No | ||||||||||||||
| 438820853 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM (APOR) does not match Due Diligence Loan Designation of Non QM. | Loan is failing APR testing and is waterfalling to a Due Diligence Loan Designation of Temporary HPQM. | Reviewer Comment (2022-08-17): Restated. Buyer Comment (2022-08-17): please restate as NQM Reviewer Comment (2022-08-16): The APR on subject loan of [redacted] is greater than the threshold of [redacted]. Buyer Comment (2022-08-16): Confirmed loan designation is QM HPML Rebuttable Presumption. Reviewer Comment (2022-08-03): Qualified Mortgage: QM APR on subject loan of [redacted] is equal to or greater than the threshold of [redacted]. Buyer Comment (2022-08-03): Disagree - Confirmed loan designation is QM Rebuttable Presumption. |
08/17/2022 | 1 | A | CO | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | C | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | Yes | ||||||||||||
| 438820853 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of [Redacted] exceeds tolerance of [Redacted] plus [Redacted] or [Redacted]. Insufficient or no cure was provided to the borrower. | No COC or cure was provided to the borrower for tolerance overages. | Reviewer Comment (2022-08-17): [redacted] sufficient cure provided at closing. Seller Comment (2022-08-16): Uploaded PCCD, LOX and shipping label , cure docs Reviewer Comment (2022-08-04): [redacted] agree with the comment however, provided cure is not sufficient to cover all cited [redacted] tolerance exceptions. We will clear this exception once we received any resolution or cure for the other cited exceptions. Seller Comment (2022-08-03): Recording fee cure for [redacted] is on Final CD and is correct |
08/17/2022 | 1 | A | CO | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | Yes | ||||||||||||
| 438820853 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Settlement / Closing / Escrow Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | No COC or cure was provided to the borrower for tolerance overages. | Reviewer Comment (2022-08-17): [redacted] received Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected PCCD. Seller Comment (2022-08-16): Uploaded PCCD, LOX and Shipping label provided for [redacted] Title-Closing Fee Reviewer Comment (2022-08-04): [redacted] The determination of tolerance category is based on whether the borrower was permitted to shop for the service. Since the title fees were disclosed in Section B of the LE (Services You Cannot Shop For), fees are subject to [redacted] tolerance as borrower was not given the option to shop for the service or provider. The SSPL does not come into play since the fees were not disclosed to borrower as 'shoppable' services. Kindly provide valid COC for increase in fee or need cure documents. Seller Comment (2022-08-03): The title fees at the time of initial disclosures were listed in the incorrect section of the LE, cannot shop- Section B. The borrower was in fact permitted to shop for title providers all along, as evidenced by the SSPL and Final CD, therefore no cure is due |
08/17/2022 | 2 | B | CO | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | Yes | ||||||||||||
| 438820853 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Electronic Document Delivery Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | No COC or cure was provided to the borrower for tolerance overages. | Reviewer Comment (2022-08-17): [redacted] received Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected PCCD. Seller Comment (2022-08-16): Uploaded PCCD, LOX and Shipping label provided for [redacted] Title-Electronic Doc Delivery Fee Reviewer Comment (2022-08-04): [redacted] The determination of tolerance category is based on whether the borrower was permitted to shop for the service. Since the title fees were disclosed in Section B of the LE (Services You Cannot Shop For), fees are subject to [redacted] tolerance as borrower was not given the option to shop for the service or provider. The SSPL does not come into play since the fees were not disclosed to borrower as 'shoppable' services. Kindly provide valid COC for increase in fee or need cure documents. Seller Comment (2022-08-03): The title fees at the time of initial disclosures were listed in the incorrect section of the LE, cannot shop- Section B. The borrower was in fact permitted to shop for title providers all along, as evidenced by the SSPL and Final CD, therefore no cure is due |
08/17/2022 | 2 | B | CO | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | Yes | ||||||||||||
| 438820853 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Signing Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | No COC or cure was provided to the borrower for tolerance overages. | Reviewer Comment (2022-08-17): [redacted] received Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected PCCD. Seller Comment (2022-08-16): Uploaded PCCD, LOX and Shipping label provided for [redacted] Title-Mobile Notary Fee Reviewer Comment (2022-08-04): [redacted] The determination of tolerance category is based on whether the borrower was permitted to shop for the service. Since the title fees were disclosed in Section B of the LE (Services You Cannot Shop For), fees are subject to [redacted]% tolerance as borrower was not given the option to shop for the service or provider. The SSPL does not come into play since the fees were not disclosed to borrower as 'shoppable' services. Kindly provide valid COC for increase in fee or need cure documents. Seller Comment (2022-08-03): The title fees at the time of initial disclosures were listed in the incorrect section of the LE, cannot shop- Section B. The borrower was in fact permitted to shop for title providers all along, as evidenced by the SSPL and Final CD, therefore no cure is due |
08/17/2022 | 2 | B | CO | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | Yes | ||||||||||||
| 438820853 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Tax Certificate Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | No COC or cure was provided to the borrower for tolerance overages. | Reviewer Comment (2022-08-17): [redacted] received Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected PCCD. Seller Comment (2022-08-16): Uploaded PCCD, LOX and Shipping label provided for [redacted] Title-Tax Cert Fee Reviewer Comment (2022-08-04): [redacted] The determination of tolerance category is based on whether the borrower was permitted to shop for the service. Since the title fees were disclosed in Section B of the LE (Services You Cannot Shop For), fees are subject to [redacted] tolerance as borrower was not given the option to shop for the service or provider. The SSPL does not come into play since the fees were not disclosed to borrower as 'shoppable' services. Kindly provide valid COC for increase in fee or need cure documents. Seller Comment (2022-08-03): The title fees at the time of initial disclosures were listed in the incorrect section of the LE, cannot shop- Section B. The borrower was in fact permitted to shop for title providers all along, as evidenced by the SSPL and Final CD, therefore no cure is due |
08/17/2022 | 2 | B | CO | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | Yes | ||||||||||||
| 438820853 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | No COC or cure was provided to the borrower for tolerance overages. | Reviewer Comment (2022-08-17): [redacted] received Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected PCCD. Seller Comment (2022-08-16): Uploaded PCCD, LOX and Shipping label provided for [redacted] Title-Endorsement Fee Reviewer Comment (2022-08-04): [redacted] The determination of tolerance category is based on whether the borrower was permitted to shop for the service. Since the title fees were disclosed in Section B of the LE (Services You Cannot Shop For), fees are subject to [redacted] tolerance as borrower was not given the option to shop for the service or provider. The SSPL does not come into play since the fees were not disclosed to borrower as 'shoppable' services. Kindly provide valid COC for increase in fee or need cure documents. Seller Comment (2022-08-03): The title fees at the time of initial disclosures were listed in the incorrect section of the LE, cannot shop- Section B. The borrower was in fact permitted to shop for title providers all along, as evidenced by the SSPL and Final CD, therefore no cure is dueThe title fees at the time of initial disclosures were listed in the incorrect section of the LE, cannot shop- Section B. The borrower was in fact permitted to shop for title providers all along, as evidenced by the SSPL and Final CD, therefore no cure is due |
08/17/2022 | 2 | B | CO | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | Yes | ||||||||||||
| 438820853 | Credit | Asset | Asset Documentation | Asset | Asset documentation requirements not met. | EMD and Donor gift funds not sourced. | Reviewer Comment (2022-07-15): Received, Clearing. Seller Comment (2022-07-15): Uploaded EMD cancelled checks and gift documentation |
07/15/2022 | 1 | A | CO | Primary | Purchase | C | B | C | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | No | ||||||||||||||
| 438820853 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Appraisal receipt dated [Redacted], however the appraisal was signed [Redacted]. Provide evidence the borrower received all copies of each appraisal prior to 3 days of closing | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | CO | Primary | Purchase | C | B | C | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | No | ||||||||||||||
| 438820853 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - General Ability to Repay | Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not match. However, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. | Restated. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | CO | Primary | Purchase | C | B | C | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | No | ||||||||||||||
| 438820856 | Credit | Loan Package Documentation | Application / Processing | Missing Document | Missing Document: Approval not provided | Reviewer Comment (2022-07-15): Received, Clearing. Seller Comment (2022-07-15): Uploaded approval |
07/15/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | A | C | A | C | A | A | A | Non QM | Non QM | No | |||||||||||||||
| 438820856 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - ATR Risk | Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk. | The Qualification Method used by the lender does not match the ATR payment calculation methods. | Reviewer Comment (2022-08-16): Additional assets for utilization received Seller Comment (2022-08-16): Used Asset Utilization supplemental income from the[redacted] that is attached since there are no reserves required due to the LTV being less than [redacted]. DTI is now is now [redacted]. |
08/16/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM Loan Designation | C | A | C | A | C | A | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820856 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines | Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of [Redacted] significantly exceeds the guideline maximum of [Redacted]. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.) | Reviewer Comment (2022-08-16): Additional assets for utilization received Seller Comment (2022-08-16): Used Asset Utilization supplemental income from the[redacted] that is attached since there are no reserves required due to the LTV being less than [redacted]). DTI is now is now [redacted]. |
08/16/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | A | C | A | C | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820856 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: Investor qualifying total debt ratio discrepancy. | Due to qualifying rate for Interest Only loan. | Reviewer Comment (2022-08-16): Cleared with additional assets Seller Comment (2022-08-16): Used Asset Utilization supplemental income from the[redacted] that is attached since there are no reserves required due to the LTV being less than [redacted]. DTI is now is now [redacted]. |
08/16/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | A | C | A | C | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820856 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General Ability To Repay Provision Investor Guidelines | Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk. | Due to qualifying rate for Interest Only loan. | Reviewer Comment (2022-08-16): Additional assets for utilization received Seller Comment (2022-08-16): Used Asset Utilization supplemental income from the [redacted] that is attached since there are no reserves required due to the LTV being less than [redacted] DTI is now is now [redacted] |
08/16/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | A | C | A | C | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438639414 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | Missing a current 30 day [Redacted]. 30day bank statement (as to where the [Redacted] earnest money/deposit check came from). | Reviewer Comment (2022-07-22): Received, Clearing. Seller Comment (2022-07-22): Front and back of cancelled EMD check provided in shipped file. Thus, no bank statement is required. |
07/22/2022 | 1 | A | NY | Investment | Purchase | C | A | C | A | A | A | N/A | No | |||||||||||||||||
| 438639379 | Credit | Missing Document | General | Missing Document | Missing Document: Cash-Out Utilization not provided | Missing documentation: Cash-Out Utilization not provided. | Reviewer Comment (2022-07-22): Received, Clearing. Seller Comment (2022-07-22): Letter of cash out utilization |
07/22/2022 | 1 | A | NY | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | |||||||||||||||||
| 438639415 | Credit | Borrower and Mortgage Eligibility | Mortgage / Program Eligibility | Borrower and Mortgage Eligibility | Guideline Requirement: Debt Service Coverage Ratio (Subject DSCR) discrepancy. | Reviewer Comment (2022-07-22): Received, Clearing. Seller Comment (2022-07-22): Please see attached DSCR worksheet, The DSCR is calculated using the Gross Rental Income less the Real Estate Taxes, Insurance, and HOA , divided by the proposed Principal and Interest payment. So DSCR is 1. 01, which meets our requirement of minimum [redacted]. |
07/22/2022 | 1 | A | FL | Investment | Purchase | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438639415 | Credit | Credit | Credit Eligibility | Credit | Borrower has open Tradelines which are less than the minimum required by guidelines. | - | Reviewer Comment (2022-07-22): Received, Clearing. Seller Comment (2022-07-22): per attached Credit Report, borrower has more than [redacted] minimum tradelines, which meets our requirement. |
07/22/2022 | 1 | A | FL | Investment | Purchase | C | A | C | A | A | A | N/A | No | |||||||||||||||||
| 438639415 | Credit | Credit | Credit Eligibility | Credit | Borrower has active Tradelines which are less than the minimum required by guidelines. | - | Reviewer Comment (2022-07-22): Received, Clearing. Seller Comment (2022-07-22): per attached Credit Report, borrower has more than 3 minimum tradelines, which meets our requirement. |
07/22/2022 | 1 | A | FL | Investment | Purchase | C | A | C | A | A | A | N/A | No | |||||||||||||||||
| 438639415 | Credit | Credit | Credit Documentation | Guideline | Missing Document: Asset not provided | EMD not sourced. | Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): Please see attached for the source of funds. |
07/20/2022 | 1 | A | FL | Investment | Purchase | C | A | C | A | A | A | N/A | No | |||||||||||||||||
| 438639415 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | Donor gift funds are required to be sourced. | Reviewer Comment (2022-07-22): Received, Clearing. Seller Comment (2022-07-22): Please see attached gift letter for your reference. Gift letter present in shipped file. |
07/22/2022 | 1 | A | FL | Investment | Purchase | C | A | C | A | A | A | N/A | No | |||||||||||||||||
| 438639394 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Articles of Organization/Formation not provided | Reviewer Comment (2022-07-27): Provided Seller Comment (2022-07-27): Please see attached. |
07/27/2022 | 1 | A | FL | Investment | Purchase | D | A | D | A | A | A | N/A | No | ||||||||||||||||||
| 438639394 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Certificate of Good Standing not provided | Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): Please see attached for the Certificate of Good Standing. |
07/20/2022 | 1 | A | FL | Investment | Purchase | D | A | D | A | A | A | N/A | No | ||||||||||||||||||
| 438639394 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Corporate Resolution not provided | Reviewer Comment (2022-07-20): Received, cleared Seller Comment (2022-07-20): Please see attached for the Corporate Resolution. |
07/20/2022 | 1 | A | FL | Investment | Purchase | D | A | D | A | A | A | N/A | No | ||||||||||||||||||
| 438639394 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Operating Agreement not provided | Reviewer Comment (2022-07-20): Received, cleared Seller Comment (2022-07-20): Please see attached for the Operating Agreement. |
07/20/2022 | 1 | A | FL | Investment | Purchase | D | A | D | A | A | A | N/A | No | ||||||||||||||||||
| 438639394 | Credit | Missing Document | General | Missing Document | Missing Document: Verification of Non-US Citizen Status not provided | Reviewer Comment (2022-07-22): Received, Clearing. Reviewer Comment (2022-07-22): Operating agreement received which doesn't resolve this exception. Seller Comment (2022-07-22): Please see attached for foreign passport. |
07/22/2022 | 1 | A | FL | Investment | Purchase | D | A | D | A | A | A | N/A | No | ||||||||||||||||||
| 438639394 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Verification of Identification not provided | Reviewer Comment (2022-07-22): Received, Clearing. Reviewer Comment (2022-07-22): Operating agreement received which doesn't resolve this exception. Seller Comment (2022-07-22): Please see attached for foreign passport. |
07/22/2022 | 1 | A | FL | Investment | Purchase | D | A | D | A | A | A | N/A | No | ||||||||||||||||||
| 438639394 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Employer Identification Number (EIN) not provided | Per guides, the following is required: IRS Letter evidencing the EIN | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): EIN |
07/21/2022 | 1 | A | FL | Investment | Purchase | D | A | D | A | A | A | N/A | No | |||||||||||||||||
| 438639394 | Credit | Loan Package Documentation | Application / Processing | Missing Document | Missing Document: Other not provided | Per guides, the following is required: CPA/Accountant/Attorney letter confirming members, their social security numbers, and percentage of ownership (if Operating Agreement or Bylaws do not provide ownership breakdown). | Reviewer Comment (2022-07-22): Received, Clearing. Seller Comment (2022-07-22): As per the Operating Agreement, there is only one member and has [redacted] ownership. Please see attached for reference. |
07/22/2022 | 1 | A | FL | Investment | Purchase | D | A | D | A | A | A | N/A | No | |||||||||||||||||
| 438639394 | Credit | Business Purpose | General | Business Purpose | Person who signed on behalf of the Business Entity is not an authorized signer of the entity. | Per lender guides, the following is required: Certificate of Authorization for the persons executing all documents on behalf of the entity. Condition set due to missing critical documentation to determine ownership/members in company. | Reviewer Comment (2022-07-22): Received, Clearing. Seller Comment (2022-07-22): Please see attached corporate resolution giving authorization to sign on behalf of the business entity. |
07/22/2022 | 1 | A | FL | Investment | Purchase | D | A | D | A | A | A | N/A | No | |||||||||||||||||
| 438639394 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): It's Replacement Cost included in insurance, and Replacement Cost Estimate is not required in [redacted] by law, so this is sufficient. |
07/21/2022 | 1 | A | FL | Investment | Purchase | D | A | D | A | A | A | N/A | No | ||||||||||||||||||
| 438639394 | Credit | Borrower and Mortgage Eligibility | Mortgage / Program Eligibility | Borrower and Mortgage Eligibility | The ID documentation (license, passport, Visa) does not show the borrower(s) at an address different than the subject and thus casts doubt on the business purpose of the loan. | Citing set due to missing any ID documentation as required by guidelines. | Reviewer Comment (2022-07-22): Received, Clearing. Reviewer Comment (2022-07-22): Operating agreement received, which doesn't resolve this exception. Seller Comment (2022-07-22): Please see attached for foreign passport. |
07/22/2022 | 1 | A | FL | Investment | Purchase | D | A | D | A | A | A | N/A | No | |||||||||||||||||
| 438639394 | Credit | Income / Employment | Income Documentation | Income / Employment | Missing Document: Employment Income Documentation not provided | In addition to the other documentation required for self employed borrowers, the following is also required for foreign nationals: A signed letter from borrower's CPA/accountant or auditor on firm's letterhead stating: Name and description of borrower's business(es). Borrower's position/title. Length of time borrower has held position/title. Prior two years' and current year-to-date personal income. Letter must evidence contact telephone number, address, and email, if applicable. Letter will expire 90 days from date of issuance on letter. Letters / documents written in borrower's language of origin must be translated to English (see translation requirements below) and income reflected in country's national currency must be converted to US Dollars. |
Reviewer Comment (2022-07-22): Received, Clearing. Buyer Comment (2022-07-22): CPA letter is not required for DSCR loan program. |
07/22/2022 | 1 | A | FL | Investment | Purchase | D | A | D | A | A | A | N/A | No | |||||||||||||||||
| 438639403 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Amount of Non-Escrowed Property Costs over Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] did not disclose Amount of Non-Escrowed Property Costs over Year 1. | Appraisal indicates HOA dues on the subject property of [Redacted]/mo. Final CD does not reflect HOA dues. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | AL | Primary | Refinance - Rate/Term | Letter of Explanation & Corrected Closing Disclosure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639403 | Credit | Missing Document | General | Missing Document | Missing Document: Evidence of Access to Funds not provided | Per guides, the following is required for joint bank accounts: Joint account holders not on the loan application must provide a letter stating that Borrower has access to 100% of funds in the bank account(s). |
Reviewer Comment (2022-07-22): Received, Clearing. Seller Comment (2022-07-22): Access letter. Reviewer Comment (2022-07-20): Letter received in trailing docs is not for the subject loan. Exception remains Seller Comment (2022-07-20): Access letter. |
07/22/2022 | 1 | A | AL | Primary | Refinance - Rate/Term | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639391 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) Maryland Higher-Priced Mortgage Loan (Disclosure of Non-HPML Loans Borrower Qualifies For Not Provided) | [Redacted]Higher-Priced Mortgage Loan: Borrower not provided with written disclosure of non-higher priced loans otherwise qualified for. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | MD | Primary | Purchase | Lender attestation indicating that (1) the borrower did not qualify for any non-higher-priced loans or (2) the lender does not offer non-higher-priced loans. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639391 | Compliance | Compliance | State Compliance | State HPML | Maryland HPML Threshold Test Non-Compliant | [Redacted]Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.17% + 1.5%, or 6.67000%. Non-Compliant Higher Priced Loan. | APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.17% + 1.5%, or 6.67000%. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | MD | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639391 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Reviewer Comment (2022-07-22): Received invoice for Appraisal paid outside of closing Seller Comment (2022-07-22): POC of appraisal [redacted] is paid per attached receipt. Reviewer Comment (2022-07-20): Calculated cash to close is [redacted]. [redacted] closing costs + [redacted] down payment - [redacted] seller credits - [redacted] adjustments and other credits + [redacted] Gift of equity. Verified funds to close [redacted] [redacted] wells fargo checking + $ [redacted] Gift of equity) [redacted] - [redacted] = [redacted] remaining for reserves. Seller Comment (2022-07-20): Per final CD, cash to close required [redacted] plus [redacted] months PITIA [redacted], total required [redacted] to close. We've verified assets from the transaction activity of [redacted] at [redacted], which is sufficient for this transaction. |
07/22/2022 | 1 | A | MD | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639405 | Credit | Property - Appraisal | Property Eligibility - Site and Utilities | Property - Appraisal | Subject property has environmental problems noted by appraiser or visible in the photos | - | Reviewer Comment (2022-07-25): Received, Clearing. Seller Comment (2022-07-25): Please see attached revised appraisal. |
07/25/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639405 | Credit | Title | General | Title | Title Policy Coverage is less than Original Loan Amount. | The Title Policy Amount of ___ is less than the note amount of ___ based on the ___ in file. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | CA | Primary | Refinance - Rate/Term | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639405 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | CA | Primary | Refinance - Rate/Term | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639380 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | MD | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639380 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) Maryland Higher-Priced Mortgage Loan (Disclosure of Non-HPML Loans Borrower Qualifies For Not Provided) | Maryland Higher-Priced Mortgage Loan: Borrower not provided with written disclosure of non-higher priced loans otherwise qualified for. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | MD | Primary | Purchase | Lender attestation indicating that (1) the borrower did not qualify for any non-higher-priced loans or (2) the lender does not offer non-higher-priced loans. | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639380 | Compliance | Compliance | State Compliance | State HPML | Maryland HPML Threshold Test Non-Compliant | [Redacted]Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.33% + 1.5%, or 6.83000%. Non-Compliant Higher Priced Loan. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | MD | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639380 | Compliance | Compliance | State Compliance | State Defect | Maryland Ability to Repay Not Verified | [Redacted]SB270: File does not contain evidence that analysis of borrower's ability to repay was performed based on verified income, obligations, assets, and/or employment using PITI payment based on fully indexed rate, if applicable. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | MD | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639380 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Amount of Escrowed Property Costs over Year 1 - October 2018 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Escrowed Property Costs over Year 1 of [Redacted] on Final Closing Disclosure provided on [Redacted] not accurate. | Reviewer Comment (2022-07-20): [redacted] received Letter of Explanation & Corrected Closing Disclosure. Seller Comment (2022-07-18): PCCD, LOE, and tracking provided. |
07/20/2022 | 2 | B | MD | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639419 | Credit | Income / Employment | Income Documentation | Income / Employment | Income documentation requirements not met. | Missing the following self employment documentations; CPA Letter, P&L Statement, Third Party Verification. | Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): Please see attached for the CPA Letter, P&L Statement, and business verification. |
07/20/2022 | 1 | A | NY | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639400 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Calculated PITIA months reserves of [Redacted] is less than Guideline PITIA months reserves of [Redacted] | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Please see attached transaction statement of[redacted] #[redacted], $[redacted] and $[redacted] were credited and deposited to the account. And total EMD is $[redacted], it separated to two parts [redacted] source from gift and rest [redacted] from borrower). So [redacted]asset is sufficient for closing cost and reserve. Reviewer Comment (2022-07-20): Gifts of [redacted] and [redacted] were deducted from the [redacted] balance of [redacted], as they were previously deposited. Qualifying balance is [redacted]. EMD of [redacted]. Total funds to close is [redacted]. Additional assets required. Seller Comment (2022-07-20): Per HUD-1, cash to close required [redacted] plus [redacted]months PITIA [redacted], total required [redacted] to close. We've verified assets from the transaction activity of [redacted] [redacted], which is sufficient for this transaction. Also,attached gift letters and canceled checks for [redacted], and [redacted]. And Canceled check for [redacted] of [redacted] EMD. And [redacted] [redacted] bank statements for the above transaction. |
07/21/2022 | 1 | A | NY | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639400 | Credit | Asset | Asset Documentation | Asset | Asset documentation requirements not met. | Gift funds not sourced and reserves not met. | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Please see attached transaction statement of[redacted] #[redacted] $[redacted] and $[redacted] were credited and deposited to the account. And total EMD is [redacted], it separated to two parts [redacted] source from gift and rest $[redacted] from borrower). So $[redacted] asset is sufficient for closing cost and reserve. Reviewer Comment (2022-07-20): Gifts of [redacted] and [redacted] were deducted from the [redacted] balance of [redacted], as they were previously deposited. Qualifying balance is [redacted]. EMD of [redacted] Total funds to close is [redacted]. Additional assets required. Seller Comment (2022-07-20): Per HUD-1, cash to close required [redacted] plus [redacted] months PITIA [redacted], total required [redacted] to close. We've verified assets from the transaction activity of [redacted] #[redacted] at [redacted], which is sufficient for this transaction. Also,attached gift letters and canceled checks for [redacted] and [redacted]). And Canceled check for [redacted] And [redacted] [redacted] bank statements for the above transaction. |
07/21/2022 | 1 | A | NY | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639400 | Credit | Asset | Asset Calculation / Analysis | Asset | Available for Closing is insufficient to cover Cash From Borrower. | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Please see attached transaction statement of [redacted] #[redacted], $[redacted] and $[redacted] were credited and deposited to the account. And total EMD is $[redacted], it separated to[redacted] parts ($[redacted] source from gift and rest $[redacted] from borrower). So $[redacted] asset is sufficient for closing cost and reserve. Reviewer Comment (2022-07-20): Gifts of [redacted] and [redacted] were deducted from the [redacted] balance of [redacted], as they were previously deposited. Qualifying balance is [redacted]. EMD of [redacted]. Total funds to close is [redacted]. Additional assets required. Seller Comment (2022-07-20): Per HUD-1, cash to close required [redacted] plus[redacted] months PITIA [redacted], total required [redacted] to close. We've verified assets from the transaction activity of [redacted] [redacted], which is sufficient for this transaction. Also,attached gift letters and canceled checks for [redacted], [redacted], and [redacted]). And Canceled check for [redacted] of $[redacted]. And [redacted] [redacted] bank statements for the above transaction. |
07/21/2022 | 1 | A | NY | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | |||||||||||||||
| 438639430 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: Investor qualifying total debt ratio discrepancy. | Lender qualified the borrower using interest only payment versus fully amortized payment | Reviewer Comment (2022-07-22): Received, Clearing. Buyer Comment (2022-07-22): Subject property PITIA = P&[redacted] + Ins[redacted] + Prop Tax [redacted]=[redacted] Credit card debt=[redacted]+[redacted]+[redacted]+[redacted]+[redacted]=[redacted]; Total debt=[redacted]+[redacted]=[redacted]; Income=[redacted]/month; So DTI=[redacted]% meets our requirement. |
07/22/2022 | 1 | A | MA | Primary | Refinance - Cash-out - Other | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639430 | Compliance | Compliance | State Compliance | State HPML | Massachusetts HPML Threshold Test Compliant | [Redacted]Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.18% + 1.5%, or 6.68000% Compliant Higher Priced Loan. | APR of [Redacted] is in excess of allowable threshold of APOR 5.18% + 1.5%, or 6.68000% | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | MA | Primary | Refinance - Cash-out - Other | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639430 | Compliance | Compliance | State Compliance | Misc. State Level | Massachusetts Mortgage Lender and Broker Regulation (Ability to Repay not Verified) | [Redacted]Mortgage Lender and Broker Regulation: File does not contain evidence that analysis of borrower's ability to repay was performed based on verified income, obligations, assets, and/or employment using PITI payment based on fully indexed rate and fully amortizing payment, if applicable | Documents not provided | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | MA | Primary | Refinance - Cash-out - Other | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639411 | Credit | Asset | Asset Documentation | Asset | Asset documentation requirements not met. | Donor gift funds are required to be sourced. | Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): Please see attached Gift letter and cancelled check for $[redacted], and transaction statement for deposit. |
07/20/2022 | 1 | A | OH | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639411 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Donor gift funds are required to be sourced. | Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): Per final CD, cash to close required $[redacted] plus [redacted] months PITIA $[redacted], total required $ [redacted]to close. We've verified assets from the transaction activity of [redacted] [redacted] at $[redacted], which is sufficient for this transaction. Attached [redacted] #[redacted] last transaction, Gift letter & Canceled check for $[redacted], and a $[redacted] canceled check transferred from borrower's another account (don't need to source the fund that was transferred from borrower's account). |
07/20/2022 | 1 | A | OH | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639411 | Credit | Asset | Asset Calculation / Analysis | Asset | Available for Closing is insufficient to cover Cash From Borrower. | Donor gift funds are required to be sourced. | Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): Per final CD, cash to close required $[redacted] plus[redacted] months PITIA $[redacted], total required $ [redacted] to close. We've verified assets from the transaction activity of [redacted] #[redacted] at $[redacted], which is sufficient for this transaction. Attached[redacted] #[redacted]last transaction, Gift letter & Canceled check for $[redacted], and a $[redacted] canceled check transferred from borrower's another account (don't need to source the fund that was transferred from borrower's account). |
07/20/2022 | 1 | A | OH | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639401 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Per Guidelines, minimum reserves requirements is 3 months PITIA. | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Funds to close per the closing statement is $[redacted], per attached transaction activity, wired $[redacted] to agent. So Balance to close is [redacted]- it is zeroed out. Cash reserves is [redacted] months which = $[redacted] Balance in Chase after the wire to closing agent as noted above is $[redacted], which is sufficient to meet the reserve requirement. |
07/21/2022 | 1 | A | CT | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639435 | Compliance | Compliance | Federal Compliance | RESPA | RESPA - Initial Escrow Account statement Inaccurate | RESPA: Initial escrow account statement does not match charges on HUD-1/Final Closing Disclosure. | This is because the property taxes are not included on the post close CD. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | CO | Primary | Purchase | C | B | A | A | C | B | B | B | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639435 | Compliance | Compliance | State Compliance | Misc. State Level | Colorado Home Loan (Tangible Net Benefit Disclosure Not Provided) | Colorado Home Loan (HB1322): Loan file does not contain a Tangible Net Benefit Disclosure (or similar document). | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | CO | Primary | Purchase | C | B | A | A | C | B | B | B | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639435 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Property Taxes Included In Escrow | TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether property taxes are included in escrow. | This is because the property taxes are not included on the post close CD. | Reviewer Comment (2022-07-21): Cured prior to discovery. Seller Comment (2022-07-19): Taxes were removed because it was already paid for prior. Supporting doc attached. |
07/21/2022 | 2 | B | CO | Primary | Purchase | TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable | C | B | A | A | C | B | B | B | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639435 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-07-13): Sufficient Cure Provided At Closing |
07/13/2022 | 1 | A | CO | Primary | Purchase | Final CD evidences Cure | C | B | A | A | C | B | B | B | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639435 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Revised Loan Estimate Timing Before Closing | TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on XXXX not received by borrower at least four (4) business days prior to closing. | No evidence that the loan estimate was received earlier in file, therefore, defaulted to mail away date... | Reviewer Comment (2022-07-28): [redacted]received [redacted]LE with electronic receipt on[redacted] Seller Comment (2022-07-28): Our first document provided was the [redacted]LE acknowledged the day it was issued. Both LEs were signed the day of. Please see attached for both signed LEs. Buyer Comment (2022-07-26): Our first document provided was the[redacted] LE acknowledged the day it was issued. Both LEs were signed the day of. Reviewer Comment (2022-07-26): [redacted] received [redacted] LE with proof of receipt. However, the issue relates to the prior LE issued [redacted] for which we do not have proof of receipt by borrower within[redacted] business days of closing. No proof of receipt and so mailbox rule is in effect. Provide proof of earlier receipt of[redacted] LE. Seller Comment (2022-07-22): Please see attached for the final LE with borrower acknowledgement. The borrower received and acknowledged on the same day, making it compliant with timing requirements. Reviewer Comment (2022-07-21): Loan closed on[redacted] and Final LE was received on [redacted]. Final LE was not received [redacted] or more days prior to closing. This is a timing issue with no obvious cure. Seller Comment (2022-07-19): Please see attached for the COC LE with borrower acknowledgement. |
07/28/2022 | 1 | A | CO | Primary | Purchase | No Defined Cure | C | B | A | A | C | B | B | B | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639435 | Property | Property - Appraisal | Appraisal Reconciliation | Property - Appraisal | Appraisal is required to be in name of Lender | - | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | CO | Primary | Purchase | C | B | A | A | C | B | B | B | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639435 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | No valid COC or cure provided. | Reviewer Comment (2022-07-28): [redacted] received LOE, proof of mailing, copy of refund check, and corrected CD. Buyer Comment (2022-07-28): The cure has been received by the borrower. Please clear. Reviewer Comment (2022-07-27): [redacted] has received Corrected PCCD, Proof of mailing ,copy of check and LOE to borrower. However, tracking indicates the label has been created; however, it has not been picked up for shipping. Proof of mailing is required in order to cure the exception. Seller Comment (2022-07-26): Please see attached for the PCCD, LOE, Proof of Delivery and Proof of Refund Reviewer Comment (2022-07-20): [redacted] Received COC and CD dated [redacted], However Appraisal Transfer Invoice received not a valid reason for increase in Appraisal fee. Please provide an updated COC with a valid reason for increase in Appraisal fee. Seller Comment (2022-07-19): Please see attached for the COC CD with borrower acknowledgement regarding this fee change. |
07/28/2022 | 2 | B | CO | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | B | B | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639435 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Property Inspection Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | No valid COC or cure provided. | Reviewer Comment (2022-07-28): [redacted] received LOE, proof of delivery, copy of refund check, and corrected CD. Buyer Comment (2022-07-28): The cure has been received by the borrower. Please clear. Reviewer Comment (2022-07-27): [redacted] received Corrected Post CD,LOX, proof of mailing and copy of check. However, the tracking indicates that label has been created. However, it has not been picked up for shipping .Proof of mailing is required in order to cure the exception. Seller Comment (2022-07-26): Please see attached for the PCCD, LOE, Proof of Delivery and Proof of Refund. Reviewer Comment (2022-07-20): [redacted] Received COC and CD dated[redacted], However Appraisal Transfer Invoice received not a valid reason for increase in Property Inspection fee. Please provide an updated COC with a valid reason for increase in Property Inspection fee.. Seller Comment (2022-07-19): Please see attached for the COC LE with borrower acknowledgement regarding this fee change. |
07/28/2022 | 2 | B | CO | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | B | B | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639435 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | No valid COC or cure provided. | Reviewer Comment (2022-07-28): Cure provided at closing. Buyer Comment (2022-07-28): The cure has been received by the borrower. Please clear. Reviewer Comment (2022-07-20): [redacted] We agree and understand that the cure was given at closing for [redacted] for Transfer Tax Fee. The exception will be cleared once we receive the cure/resolution for the Appraisal Fee and Property inspection fee. Exception remains. Seller Comment (2022-07-19): Please see attached for the Final CD. Lender credits were applied for this fee increase. |
07/28/2022 | 1 | A | CO | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | B | B | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639396 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Provide updated coverage or a replacement cost estimator to verify current coverage is sufficient. | Reviewer Comment (2022-07-18): Received, Clearing. Seller Comment (2022-07-18): Dwelling coverage $[redacted] is just right on the replacement cost of [redacted] per attached RCE. |
07/18/2022 | 1 | A | CA | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639396 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | CA | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639396 | Compliance | Compliance | Federal Compliance | FACTA | Federal FACTA Disclosure Timing Test | FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | CA | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639396 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Per final CD, cash to close required $[redacted] plus [redacted] months PITIA $[redacted] , total required $[redacted] to close. We've verified assets from the transaction activities of[redacted] (#[redacted], #[redacted]& #[redacted], [redacted] (#[redacted], #[redacted]& #[redacted]) and[redacted] #[redacted], total asset $[redacted] is sufficient for this transaction. |
07/21/2022 | 1 | A | CA | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639385 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: Investor qualifying total debt ratio discrepancy. | Calculated dti exceeds max allowable DTI of [Redacted]. The UW comments state the XXXX debt was excluded due to having less than 10 payments remaining, however per the credit report there are still 12 months remaining. | Reviewer Comment (2022-07-25): Received, Clearing. Seller Comment (2022-07-25): Please see attached payoff letter, the balance of account [redacted]was paid off. So total debt of DTI should exclude monthly debt[redacted]. Therefore DTI=(PITIA [redacted] + credit debt [redacted])/income [redacted]=[redacted]%, which meets our requirement of minimum [redacted]%. |
07/25/2022 | 1 | A | TX | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639406 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | New York Subprime Counseling Disclosure missing in file. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639406 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639406 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | New York Subprime Disclosure missing in file. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639406 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Escrow Not Established) | New York Subprime Loan: Mandatory escrow account not established for the collection of property taxes and insurance. (Note: Does not apply to a subordinate lien when the taxes and insurance are escrowed through another home loan. It also does not apply if the borrower can demonstrate a record of 12 months of timely payments of taxes and insurance on a previous home loan.) | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639406 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate 4.67000 + 1.75%, or 6.42000%. Non-Compliant SubPrime Loan. | Verified : APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate 4.67000 + 1.75%, or 6.42000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639406 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | New York Subprime Tax Disclosure missing in file. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639406 | Credit | Income / Employment | Income Documentation | Income / Employment | Large deposits were not sourced and/or letter of explanation was not provided. | Borrower shows a large deposit of [Redacted] on [Redacted] into account ending [Redacted]. The source of these funds was not provided in the file. | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Please see attached for the check from borrower's own account. According to our guidelines if the funds came from another account held by the borrower, then it is not required to be sourced. |
07/21/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639390 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Non Escrowed Property Costs Year 1 Test | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted] on Final Closing Disclosure provided on [Redacted] not accurate. | The final CD disclosed the Amount of Non-Escrowed Property Costs over Year 1 as [Redacted] on page 4; however the HOA dues total [Redacted] per year. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | PA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639390 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Loan Estimate Timing Electronically Provided | TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application. | Missing Initial Loan Estimate. Intent to proceed in file is dated [Redacted]. Earliest LE in file is [Redacted] | Reviewer Comment (2022-07-21): [redacted] received missing initial LE dated[redacted] Seller Comment (2022-07-20): Please see attached for the initial LE. |
07/21/2022 | 1 | A | PA | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639384 | Credit | Loan Package Documentation | Loan File | Missing Document | Missing Document: Hazard Insurance Policy not provided | Missing the master condo insurance policy on the project '[Redacted]' building. | Reviewer Comment (2022-07-18): Received, Clearing. Seller Comment (2022-07-18): Master Insurance |
07/18/2022 | 1 | A | FL | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639384 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | FL | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639384 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Amount of Non-Escrowed Property Costs over Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted] on Final Closing Disclosure provided on [Redacted] not accurate. | Discrepancy appears to be due to the HOA dues. The appraisal indicates the dues are [Redacted]/mo however the lender is using [Redacted]/mo. File does not contain additional evidence showing the higher amount. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | FL | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639384 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Wire /Funding/ Disbursement Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | There is a Zero Percent Fee Tolerance exceeded for Title - Wire /Funding/ Disbursement Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. File is missing a valid COC and no cure was provided to the borrower. | Reviewer Comment (2022-07-19): [redacted]: Upon further review Title Wire and Courier Fee added on CD and fee is paid to same provider and service provider is not listed in Settlement Service Providers list. Buyer Comment (2022-07-18): The service provider selected for this was a third party service provider not listed on the SSPL. Therefore, this fee may change without being subject to a tolerance limit. |
07/19/2022 | 1 | A | FL | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639384 | Credit | Credit | Credit Documentation | Guideline | Missing Document: Verification of Rent (VOR) / Verification of Mortgage (VOM) not provided | File is missing the most recent 12 month rental history showing paid as agreed. | Reviewer Comment (2022-07-22): Received, Clearing. Buyer Comment (2022-07-22): The comment is Received & Clearing. But it's rejected. Please advise and confirm. Reviewer Comment (2022-07-21): Received, Clearing. Buyer Comment (2022-07-21): per our [redacted] guideline, when borrowers purchase a primary residence, we don't require VOR for the property they will exit, it won't affect DTI |
07/22/2022 | 1 | A | FL | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639421 | Credit | Legal / Regulatory / Compliance | Title / Lien Defect | Title | Title Policy is Preliminary or Commitment, and not a Final Title Policy. | Reviewer Comment (2022-07-20): Received, Clearing. |
07/20/2022 | 1 | A | FL | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | |||||||||||||||
| 438639421 | Credit | Title | Document Error | Title | The Preliminary/Commitment does not reflect a coverage amount (no final title policy in file). Unable to determine if appropiate coverage is provided. | Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): Final title policy attached. |
07/20/2022 | 1 | A | FL | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | |||||||||||||||
| 438639434 | Compliance | Compliance | Federal Compliance | Missing Non-Required Data | (Missing Data) Last Rate Set Date | Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing. | Rate lock is missing from file. File must have an actual rate lock to enable verification of the lock date. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | CA | Primary | Refinance - Rate/Term | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639434 | Credit | Loan Package Documentation | Loan File | Missing Document | Missing Document: Hazard Insurance Policy not provided | The HOI policy provided indicates the policy premium is [Redacted]. Lender is using [Redacted]. Supporting documentation reflecting the updated premium is missing from the file. | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Final CD is showing HOI premium of $[redacted]. Please clarify how the $[redacted]was derived. |
07/21/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639434 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-07-18): Received, Clearing. |
07/18/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639434 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 3.83% + 1.5%, or 5.33000%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-07-18): Received, Clearing. Seller Comment (2022-07-18): Proof of appraisal transfer provided. |
07/18/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639434 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-07-18): Received, Clearing. Seller Comment (2022-07-18): Proof of appraisal transfer attached. |
07/18/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639434 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | SitusAMC uses FannieMae's definition of acceptable coverage. Fannie Mae requires coverage equal to the lesser of the following: Property insurance coverage of [Redacted] is insufficient to cover the loan amount of [Redacted] or [Redacted] of the estimated cost new of [Redacted]x [Redacted] = [Redacted]. | Reviewer Comment (2022-07-20): RCE received Seller Comment (2022-07-20): Dwelling coverage of $[redacted] is just right to cover the replacement cost of[redacted] per attached RCE. |
07/20/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639383 | Compliance | Compliance | State Compliance | State Defect | Connecticut Prepaid Finance Charge | Connecticut Abusive Home Loan Lending Practices Act: Prepaid Finance Charge Fees of [Redacted] exceed the greater of [Redacted] or [Redacted]. | Failure due to loan being higher priced. | Reviewer Comment (2022-07-28): Cure documentation received. Seller Comment (2022-07-26): Please see attached for the PCCD, LOE, Proof of Delivery, and Proof of refund. Reviewer Comment (2022-07-19): Cure docs would include LOE, copy of refund check for the overage of [redacted]and proof of delivery to consumer. Buyer Comment (2022-07-18): Can we cure the difference? If so, can you advise if a $[redacted] refund along with its supporting docs will help clear this condition? |
07/28/2022 | 2 | B | CT | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639383 | Credit | Asset | Asset Documentation | Asset | Asset documentation requirements not met. | EMD required to be sourced. | Reviewer Comment (2022-07-22): Received, Clearing. Seller Comment (2022-07-22): Please see attached for gift letter and donor's bank statement. |
07/22/2022 | 1 | A | CT | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639383 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | The VOE in the file is signed by the loan processor not the employer. | Reviewer Comment (2022-07-22): Received WVOE signed by the employer |
07/22/2022 | 1 | A | CT | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639429 | Credit | Asset | Asset Documentation | Asset | Asset documentation requirements not met. | EMD is not sourced. | Reviewer Comment (2022-07-21): Received, Clearing. Buyer Comment (2022-07-21): We don't need to source $[redacted]EMD because they have sufficient funds to close and reserves. Per final CD, borrower received $[redacted] funds to close, without $[redacted], it is still sufficient to cover the [redacted] months reserves requirement. |
07/21/2022 | 1 | A | FL | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639389 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Verification appraisal was delivered to borrower was not provided. | Reviewer Comment (2022-07-20): Received, Clearing. |
07/20/2022 | 1 | A | CT | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639389 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.33% + 1.5%, or 6.83000%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-07-20): Received, Clearing. |
07/20/2022 | 1 | A | CT | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639389 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): Please see attached for the appraisal letter to borrower. |
07/20/2022 | 1 | A | CT | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639428 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien | TRID Final Closing Disclosure [Redacted] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) | No seller paid fees reflected. | Reviewer Comment (2022-07-22): [redacted] received sales contract which confirms no seller paid costs on transaction. Seller Comment (2022-07-20): As per the amendment page [redacted], costs for closing are all paid for by the Buyer. Correct as is. |
07/22/2022 | 1 | A | TN | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639428 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Finance Charge | TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on [Redacted] disclosed an inaccurate Finance Charge on page 5 that does not match the actual Finance Charge for the loan (fee amounts included in Finance Charge calculation are based on Closing Disclosure dated [Redacted]). | The final CD reflects finance charge of [Redacted], calculated finance charge is [Redacted]. | Reviewer Comment (2022-07-28): [redacted] received Letter of Explanation, Copy of cure refund, proof of mailing & Corrected Closing Disclosure. Seller Comment (2022-07-26): Please see attached for the PCCD, LOE, Proof of Refund, and Proof of Delivery. |
07/28/2022 | 2 | B | TN | Primary | Purchase | TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission if Applicable | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639416 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Purchase Agreement / Sales Contract not provided | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Purchase contract was provided in shipped file. Please see attached contract for reference. |
07/21/2022 | 1 | A | NY | Investment | Purchase | D | A | D | A | A | A | A | A | N/A | N/A | No | |||||||||||||||
| 438639416 | Credit | Asset | Asset Documentation | Asset | Earnest Money Deposit is unsourced. Per guidelines EMD source is required. | EMD of [Redacted] not sourced. | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Please see attached for source of EMD. |
07/21/2022 | 1 | A | NY | Investment | Purchase | D | A | D | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639398 | Credit | 1003 | Document Error | 1003 | Borrower(s) is not a U.S. Citizen, and the guideline required documentation was not provided. | - | Permanent Resident Card | Reviewer Comment (2022-07-21): Received, cleared Seller Comment (2022-07-21): Please see attached Permanent Resident Card. |
07/21/2022 | 1 | A | IN | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639398 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.16% + 1.5%, or 6.66000%. Non-Compliant Higher Priced Mortgage Loan. | Final CD APR is [Redacted] | Reviewer Comment (2022-07-28): HPML Appraisal exception was cured. |
07/28/2022 | 1 | A | IN | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639398 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Flipped Property - Borrower Charged for 2 Appraisals) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Flipped Property - Creditor improperly charged consumer for two (2) appraisals. | Two appraisals charges are listed on final CD | Reviewer Comment (2022-07-28): [redacted]received PCCD, copy of the Refund Check, Proof of Delivery, and Cover Letter. Seller Comment (2022-07-27): Please see attached for the PCCD, LOE, Proof of Delivery, and Proof of Refund. |
07/28/2022 | 2 | B | IN | Primary | Purchase | Provide evidence of the refund of the amount charged to the consumer for the second appraisal performed on the subject property. (Include a copy of the Refund Check, Proof of Delivery, and Cover Letter) | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639402 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): Please see attached Cancelled check as Source of EMD and bank statement. |
07/20/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | C | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639402 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): Please see attached CPA letter, P&L from CPA and PTIN. |
07/20/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | C | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639402 | Property | Valuation | Valuation Issue | Valuation | The desk review has a effective date that is other than what the appraisal effective date is. The desk review should have the same effective date as the appraisal | Reviewer Comment (2022-07-20): Received, Clearing. |
07/20/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | C | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639402 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-07-19): Received, Clearing. |
07/19/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | C | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639402 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | C | B | C | A | C | B | C | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639402 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.16% + 1.5%, or 6.66000%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-08-01): [redacted] second appraisal fee exception was cured. |
08/01/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | C | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639402 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-07-19): Received, Clearing. Seller Comment (2022-07-19): Appraisal delivery email attached. |
07/19/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | C | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639402 | Compliance | Compliance | Federal Compliance | TILA | TILA NMLSR - Missing NMLS Information on 1003 | Truth in Lending Act (NMLSR Dodd- Frank 2014): NMLSR information not present on loan application. | Reviewer Comment (2022-07-19): Received, Clearing. Seller Comment (2022-07-19): [redacted] information is present on the loan application. |
07/19/2022 | 1 | A | NY | Primary | Purchase | Need evidence that lender provided consumer with accurate NMLS information post close (updated 1003) | C | B | C | A | C | B | C | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639402 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | C | B | C | A | C | B | C | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639402 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: Borrower's ability to repay not verified with reliable documentation. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | C | B | C | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639402 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | C | B | C | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639402 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | C | B | C | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639402 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate 5.09000 + 1.75%, or 6.84000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | C | B | C | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639402 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | C | B | C | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639402 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | No valid COC or cure provided. | Reviewer Comment (2022-08-01): [redacted] received: Letter of Explanation, Proof of Mailing, Copy of Refund Check, and Corrected PCCD. Buyer Comment (2022-08-01): The cure has been received by the borrower. Please clear. Reviewer Comment (2022-07-27): [redacted] received corrected PCCD, LOE, Copy of refund check and shipping label. However, Tracking still indicates the label has been created; however, it has not been picked up for shipping. Proof of mailing is required to cure. Seller Comment (2022-07-26): Please see attached for the PCCD, LOE, Proof of delivery, and Proof of refund. |
08/01/2022 | 2 | B | NY | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | C | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639402 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | No valid COC or cure provided. | Reviewer Comment (2022-08-01): [redacted] received: Letter of Explanation, Proof of Mailing, Copy of Refund Check, and Corrected PCCD. Buyer Comment (2022-08-01): The cure has been received by the borrower. Please clear. Reviewer Comment (2022-07-27): [redacted]received corrected PCCD, LOE, Copy of refund check and shipping label. However, Tracking still indicates the label has been created; however, it has not been picked up for shipping. Proof of mailing is required to cure. Seller Comment (2022-07-26): Please see attached for the PCCD, LOE, Proof of delivery, and Proof of refund. Reviewer Comment (2022-07-19): [redacted] - Appraisal reinspection fee added on[redacted] and increased on 0[redacted]; however, COC dated[redacted] and [redacted] are not acceptable and required additional information due to following points. COC dated[redacted] states Property address updated which is not valid reason. Need COC dated[redacted]updated with reason as per Appraisal reinspection report which states Roof repair completed. COC dated [redacted] showing reason as "Appraisal Final inspection fee updated" is not valid. Need additional information as to why the Appraisal re-inspection fee increased. Provide COC dated [redacted] and[redacted] with additional information or provide Cure Docs. Seller Comment (2022-07-18): Please see attached for the COC LEs regarding this fee change. |
08/01/2022 | 2 | B | NY | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | C | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639402 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Appraisal receipt is dated prior to signature on the appraisal | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | C | B | C | A | C | B | C | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639402 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Flipped Property - Borrower Charged for 2 Appraisals) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Flipped Property - Creditor improperly charged consumer for two (2) appraisals. | Lender charged borrower for second appraisal fee | Reviewer Comment (2022-08-01): [redacted] received PCCD, copy of the Refund Check, Proof of Delivery, and Cover Letter. Seller Comment (2022-07-26): Please see attached for the PCCD, LOE, Proof of delivery, and Proof of refund. |
08/01/2022 | 2 | B | NY | Primary | Purchase | Provide evidence of the refund of the amount charged to the consumer for the second appraisal performed on the subject property. (Include a copy of the Refund Check, Proof of Delivery, and Cover Letter) | C | B | C | A | C | B | C | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639425 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639425 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639425 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639425 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate 5.25000 + 1.75%, or 7.00000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639425 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639426 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Letter and P&L must be dated and signed on accounting firm's letterhead and must include signer's contact information. CPA/Accountant/Tax Preparer/Enrolled Agent must have a valid PTIN (preparer tax identification number). P&Ls on file are not signed by CPA. | Reviewer Comment (2022-07-26): Received, Clearing. Seller Comment (2022-07-26): Please see attached for the [redacted] Cert. Reviewer Comment (2022-07-25): Still missing [redacted] (preparer tax identification number). Seller Comment (2022-07-25): Please see attached for the P&L statement. |
07/26/2022 | 1 | A | NY | Primary | Purchase | A | A | A | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639393 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Closing Disclosure Timing without Waiver | TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. | MIssing initial CD. | Reviewer Comment (2022-07-22): [redacted] received[redacted] CD Seller Comment (2022-07-20): Please see attached for the initial CD. |
07/22/2022 | 1 | A | OR | Primary | Purchase | No Defined Cure | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639412 | Credit | Missing Document | General | Missing Document | Missing Document: Verification of Non-US Citizen Status not provided | Missing the borrower's 'Permanaent Resident' card. | Reviewer Comment (2022-07-22): Received, Clearing. Reviewer Comment (2022-07-22): Whatever format this is being provided in is coming through as a blank page. Seller Comment (2022-07-22): Re-uploaded Permanent Resident card. Reviewer Comment (2022-07-19): Only blank pages arrived. Seller Comment (2022-07-19): Please see attached borrower's Permanent Resident Card. |
07/22/2022 | 1 | A | FL | Second Home | Purchase | C | B | C | B | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639412 | Credit | 1003 | Document Error | 1003 | Borrower(s) is not a U.S. Citizen, and the guideline required documentation was not provided. | - | Missing the borrower's 'Permanent Resident' card. | Reviewer Comment (2022-07-22): Received, Clearing. Reviewer Comment (2022-07-22): Whatever format this is being provided in is coming through as a blank page. Seller Comment (2022-07-22): Re-uploaded borrower's Permanent Resident" card. Reviewer Comment (2022-07-19): Only blank pages arrived. Seller Comment (2022-07-19): Borrower's permanent resident card |
07/22/2022 | 1 | A | FL | Second Home | Purchase | C | B | C | B | A | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639412 | Credit | Hazard Insurance | Insufficient Coverage | Hazard Insurance | The Hazard Insurance Policy Effective Date is after closing. | Hazard Insurance Policy Effective Date ___, Disbursement Date: ___ | The Hazard Insurance Policy Effective Date is after the later of the note or transaction date. The Hazard Insurance Policy Effective Date [Redacted], and the NOTE Date is [Redacted]. | The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-07-26): Client approved exception. Seller Comment (2022-07-26): Please see attached exceptional approval. |
07/26/2022 | 2 | B | FL | Second Home | Purchase | C | B | C | B | A | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||
| 438639412 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | 1003 Error: Citizenship Source Documentation was not provided | - | Missing the borrower's 'Permanent Resident' card. | Reviewer Comment (2022-07-22): Received, Clearing. Reviewer Comment (2022-07-22): Whatever format this is being provided in is coming through as a blank page. Seller Comment (2022-07-22): Re-uploaded borrower's Permanent Resident card. Reviewer Comment (2022-07-19): Only blank pages arrived. Seller Comment (2022-07-19): Borrower's permanent resident card. |
07/22/2022 | 1 | A | FL | Second Home | Purchase | C | B | C | B | A | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639431 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | Missing VVOE for borrower. | Reviewer Comment (2022-07-22): Received, Clearing. Seller Comment (2022-07-22): Please see attached. VVOE was provided in shipped file. |
07/22/2022 | 1 | A | IL | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639431 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-07-22): Received, Clearing. |
07/22/2022 | 1 | A | IL | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639431 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 4.35% + 1.5%, or 5.85000%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-07-22): Received, Clearing. |
07/22/2022 | 1 | A | IL | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639431 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Missing evidence of receipt of appraisal | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | IL | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639431 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-07-22): Received, Clearing. Seller Comment (2022-07-22): Please see attached. |
07/22/2022 | 1 | A | IL | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639431 | Credit | Guideline | Guideline Issue | Guideline | Borrower has been on current job less than 2 years, and prior employment history was not documented as required. | - | Missing documentation for prior employer. | Reviewer Comment (2022-07-22): Received, Clearing. Seller Comment (2022-07-22): Please see attached VOE and business research for the prior employment. |
07/22/2022 | 1 | A | IL | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639431 | Credit | Asset | Asset Documentation | Asset | Asset Issue: Gift funds are missing evidence of receipt | Missing deposit receipt for [Redacted] gift given in 3 separate checks ([Redacted], [Redacted], [Redacted]) | Reviewer Comment (2022-07-22): Received, Clearing. Buyer Comment (2022-07-22): Provided with shipped file were cancelled checks. Therefore, no bank statements are required. |
07/22/2022 | 1 | A | IL | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639417 | Property | Property - Appraisal | Appraisal Documentation | Property - Appraisal | Missing Document: Appraisal was made "subject to" and Form 1004D/442 was not provided. | - | Appraisal was made subject to and [Redacted]is not in images, document not provided | Reviewer Comment (2022-07-18): Received, Clearing. Seller Comment (2022-07-18): [redacted] |
07/18/2022 | 1 | A | NY | Investment | Refinance - Rate/Term | C | A | A | A | A | A | C | A | N/A | N/A | No | |||||||||||||
| 438639397 | Property | Property - Appraisal | Appraisal Documentation | Property - Appraisal | Loan is to be securitized. Secondary valuation is missing.; Sec ID: 2 | Missing secondary valuation for securitization. | Reviewer Comment (2022-07-12): Received, Clearing. Seller Comment (2022-07-12): See attached for the CDA report. |
07/12/2022 | 1 | A | ME | Primary | Purchase | D | B | C | A | B | B | D | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639397 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Missing List of Homeownership Counseling Organizations. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | ME | Primary | Purchase | D | B | C | A | B | B | D | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639397 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Escrowed Property Costs Year 1 - October 2018 Testing | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Escrowed Property Costs over Year 1 of [Redacted] on Final Closing Disclosure provided on [Redacted] not accurate. | Amount of Escrowed Property Costs over Year 1 of [Redacted] on Final Closing Disclosure provided on [Redacted] not accurate. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | ME | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | D | B | C | A | B | B | D | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639397 | Credit | Credit | Credit Documentation | Guideline | Missing Document: Verification of Rent (VOR) / Verification of Mortgage (VOM) not provided | Missing 12 months VOM for departing primary. | Reviewer Comment (2022-07-22): Received, Clearing. Seller Comment (2022-07-22): Borrower[redacted]owned the property[redacted]. But no liability on the mortgage, because borrower's name is on deed but no reflecting in the mortgage statement. |
07/22/2022 | 1 | A | ME | Primary | Purchase | D | B | C | A | B | B | D | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639395 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of [Redacted] exceeds tolerance of [Redacted] plus [Redacted] or [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | 10% tolerance was exceeded, No valid COC provided, cure provided at closing. | Reviewer Comment (2022-07-12): Sufficient Cure Provided At Closing |
07/12/2022 | 1 | A | NJ | Primary | Purchase | Final CD evidences Cure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639395 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of [Redacted] exceeds tolerance of [Redacted] plus [Redacted] or [Redacted]. Insufficient or no cure was provided to the borrower. | No valid COC or cure provided. | Reviewer Comment (2022-07-28): Sufficient cure at closing. Buyer Comment (2022-07-28): The cure has been received by the borrower. Please clear. Reviewer Comment (2022-07-13): [redacted]: Cure provided at closing is insufficient to cure for all the citing (additional exception - Property Inspection Fee ) exception. Exception remains. Seller Comment (2022-07-12): Final CD reflects a [redacted] lender credit. Bottom Pages 1 and 2 of the Final CD reflects this amount. |
07/28/2022 | 1 | A | NJ | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639395 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Property Inspection Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | No valid COC or cure provided. | Reviewer Comment (2022-07-28): [redacted] received Letter of Explanation, Copy of cure refund, proof of mailing & Corrected Closing Disclosure. Buyer Comment (2022-07-28): The cure has been received by the borrower. Please clear. Reviewer Comment (2022-07-27): [redacted] Received PCCD, LOE, Copy of check & Shipping label. Tracking indicates the label has been created; however, it has not been picked up for shipping. Proof of mailing is required. Seller Comment (2022-07-26): Please see attached for the PCCD, LOE, Proof of Refund, and Proof of Delivery. Reviewer Comment (2022-07-19): [redacted] upon further review require additional information to specify the reason for addition of fee. Please provide valid COC or cure documents. Seller Comment (2022-07-18): Please see attached for the COC LE regarding this fee change. |
07/28/2022 | 2 | B | NJ | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639381 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Reviewer Comment (2022-07-15): Received, Clearing. Seller Comment (2022-07-15): Dwelling coverage $[redacted]is sufficient to cover the replacement cost of[redacted]per attached RCE. |
07/15/2022 | 1 | A | FL | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639381 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Reviewer Comment (2022-07-20): Received, Clearing. Buyer Comment (2022-07-20): Per final CD, we requested [redacted] months PITIA $[redacted] as a reserve. Cash to close $[redacted] to borrower, per our[redacted]guidelines, cash-out proceeds can be applied to reserves, so it is sufficient to meet the 3 months reserve requirements. |
07/20/2022 | 1 | A | FL | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639399 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Please provide another bank statement | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Borrower has sufficient funds. Required: Cash to Close $[redacted] + PITIA $[redacted] x [redacted] + EMD $[redacted] + POC $[redacted]+ POC [redacted]= [redacted]. Available:[redacted] Therefore, borrower has sufficient funds. |
07/21/2022 | 1 | A | CA | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639410 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | LA | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639410 | Compliance | Compliance | Federal Compliance | TILA | ARM Disclosure Timing Test | TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application. | Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): Please see attached for the ARM Disclosure. |
07/20/2022 | 1 | A | LA | Primary | Purchase | No Defined Cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639410 | Credit | Asset | Asset Calculation / Analysis | Asset | Available for Closing is insufficient to cover Cash From Borrower. | EMD and Donor Gift Funds not sourced. | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Per final CD, cash to close required $[redacted] plus[redacted] months PITIA [redacted], total required [redacted] to close. We've verified assets from the transaction activities of[redacted] [redacted] at [redacted] and[redacted] [redacted]at $[redacted], total asset [redacted]is sufficient for this transaction. |
07/21/2022 | 1 | A | LA | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639410 | Credit | Asset | Asset Documentation | Asset | Asset documentation requirements not met. | EMD and Donor Gift Funds not sourced. | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Gift letters and checks |
07/21/2022 | 1 | A | LA | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639410 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | EMD and Donor Gift Funds not sourced. | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Per final CD, cash to close required [redacted] plus [redacted] months PITIA $[redacted], total required [redacted] to close. We've verified assets from the transaction activities of[redacted] #[redacted]at [redacted] and[redacted] #[redacted]at $[redacted], total asset $[redacted] is sufficient for this transaction. |
07/21/2022 | 1 | A | LA | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438820850 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | The subject property Hazard Insurance Coverage Amount is insufficient by [Redacted] | The representative FICO score exceeds the guideline minimum by at least 40 points. The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-08-23): Client approved exception. Reviewer Comment (2022-07-27): Decline by [redacted]you would need to increase the coverage amount. Seller Comment (2022-07-27): Please see attached exceptional approval. |
08/23/2022 | 2 | B | NY | Primary | Purchase | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438820850 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Reviewer Comment (2022-08-23): Accepted as is. |
2 | B | NY | Primary | Purchase | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438820850 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: Borrower's ability to repay not verified with reliable documentation. | Reviewer Comment (2022-08-23): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438820850 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-08-23): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438820850 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-08-23): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438820850 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-08-23): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438820850 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate 5.09000 + 1.75%, or 6.84000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-08-23): Accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438820850 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-08-23): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438820850 | Credit | Asset | Asset Documentation | Asset | Asset documentation requirements not met. | Donor gift funds are required to be sourced. | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Please see attached for source of funds. |
07/21/2022 | 1 | A | NY | Primary | Purchase | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438820850 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Donor gift funds are required to be sourced. | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Please see attached for the source of gift funds. |
07/21/2022 | 1 | A | NY | Primary | Purchase | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639392 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Missing evidence of borrower's receipt of the appraisal. | Reviewer Comment (2022-07-22): Received, Clearing. |
07/22/2022 | 1 | A | WA | Primary | Purchase | C | A | C | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639392 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.16% + 1.5%, or 6.66000%. Non-Compliant Higher Priced Mortgage Loan. | APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.16% + 1.5%, or 6.66000%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-07-22): Received, Clearing. |
07/22/2022 | 1 | A | WA | Primary | Purchase | C | A | C | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639392 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Missing evidence of borrower's receipt of the appraisal. | Reviewer Comment (2022-07-22): Received, Clearing. Seller Comment (2022-07-22): Please see attached for the appraisal letter. |
07/22/2022 | 1 | A | WA | Primary | Purchase | C | A | C | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639392 | Credit | Loan Package Documentation | Loan File | Missing Document | Missing Document: Hazard Insurance Policy not provided | Reviewer Comment (2022-07-15): Received, Clearing. Seller Comment (2022-07-15): Attached HOI & RCE. Dwelling coverage [redacted]is sufficient to cover the replacement cost of [redacted]per attached RCE. |
07/15/2022 | 1 | A | WA | Primary | Purchase | C | A | C | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639392 | Credit | 1003 | Document Error | 1003 | Borrower(s) is not a U.S. Citizen, and the guideline required documentation was not provided. | - | Employment authorization provided was expired at origination. | Reviewer Comment (2022-07-21): Borrower has automatic extension of employment authorization Buyer Comment (2022-07-21): card expired [redacted]. Applied for extension on[redacted]. Auto extension for [redacted] days (per[redacted] website). New expiration date would be [redacted] a.[redacted] |
07/21/2022 | 1 | A | WA | Primary | Purchase | C | A | C | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639392 | Credit | Asset | Asset Documentation | Asset | Missing Document: Gift Letter not provided | Missing gift letter for gift in the amount of [Redacted]. | Reviewer Comment (2022-07-22): Received, Clearing. Seller Comment (2022-07-22): Without [redacted] total asset is still sufficient to cover closing costs and reserves. Per final CD, cash to close $[redacted] plus[redacted] months PITIA $[redacted], total required[redacted]to close. We've verified transaction activities of[redacted] #[redacted] at $[redacted] and[redacted]#[redacted][redacted] Total asset is[redacted], without [redacted], we still have $[redacted], which is still sufficient |
07/22/2022 | 1 | A | WA | Primary | Purchase | C | A | C | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639432 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - ___ | The file is missing copies of the tax/insurance verification. | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Please see attached for REO docs. |
07/21/2022 | 1 | A | VA | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639432 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | VA | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639432 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | Copy of valid COC needed as the one provided does not detail why the appraisal fee increased | Reviewer Comment (2022-07-19): [redacted] received corrected [redacted] Seller Comment (2022-07-18): COC CD provided. |
07/19/2022 | 1 | A | VA | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639432 | Compliance | Compliance | Federal Compliance | TILA | ARM Disclosure Timing Test | TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application. | Disclosure was provided on [Redacted] not within three days of [Redacted] application date. | Reviewer Comment (2022-07-18): Received, Clearing. Seller Comment (2022-07-18): The initial disclosures were sent altogether in one package. This includes the Early ARM disclosure, acknowledgement of the CHARM Booklet, CHARM booklet itself, etc. Does this information suffice to clear up this misunderstanding? |
07/18/2022 | 1 | A | VA | Primary | Purchase | No Defined Cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639432 | Compliance | Compliance | Federal Compliance | TILA | CHARM Booklet Disclosure Status | TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower. | Reviewer Comment (2022-07-18): Received, Clearing. Seller Comment (2022-07-18): See attached for the acknowledgement of the receipt of the CHARM Booklet. We sent this along with the full initial disclosure package along with the CHARM Booklet itself. |
07/18/2022 | 1 | A | VA | Primary | Purchase | No Defined Cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639407 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | It appears that EMD for [Redacted] was not document making loan short reserves. | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Please see attached for the source of EMD. Required: Cash to Close [redacted] + PITIA[redacted] + EMD [redacted] + POC [redacted] =[redacted]Available: Cash [redacted] + EMD $[redacted] POC[redacted] = [redacted] Therefore, borrower has sufficient funds. |
07/21/2022 | 1 | A | PA | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639386 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Amount of Non-Escrowed Property Costs over Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted] on Final Closing Disclosure provided on [Redacted] not accurate. | The Appraisal disclosed HOA fees fof [Redacted] per yearl the final Closing Disclosure disclosed costs of [Redacted]; difference is [Redacted] | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NJ | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | D | B | D | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639386 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Purchase Agreement / Sales Contract not provided | Missing the Condominium/Homeowner's Associations addendum to purchase contract | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Please see attached for the purchase contract with addendums. |
07/21/2022 | 1 | A | NJ | Primary | Purchase | D | B | D | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639422 | Compliance | Compliance | Federal Compliance | FACTA | Federal FACTA Disclosure Timing Test | FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | CT | Investment | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | N/A | N/A | No | |||||||||||||||
| 438639422 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Missing CPA/Accountant/Tax Preparer's letter stating: borrower's position/title, ownership percentage, and business inception date. Letter must be dated and signed on firm's letterhead, and must include signer's contact information. CPA/Accountant/Tax Preparer must have a valid PTIN (preparer tax identification number). | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): CPA Letter & PTIN |
07/21/2022 | 1 | A | CT | Investment | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | N/A | N/A | No | ||||||||||||||
| 438639418 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Document not Provided in File | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639418 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Document not Provided in File | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639418 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Document not Provided in File | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639418 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate 5.09000 + 1.75%, or 6.84000%. Non-Compliant SubPrime Loan. | Document not Provided in File | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639418 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Document not Provided in File | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639418 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Per final CD, cash to close required [redacted]plus [redacted] months PITIA [redacted], total required $ [redacted] to close. We've verified assets from the transaction activities of[redacted] [redacted] at[redacted] and[redacted] #[redacted] at[redacted], total asset $[redacted] is sufficient for this transaction. |
07/21/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639420 | Credit | Credit | Credit Calculation / Analysis | Guideline | Guideline Requirement: Representative FICO score discrepancy. | Representative FICO score of ___ is less than Guideline representative FICO score of ___. | Representative FICO score of [Redacted] is less than Guideline minimum required FICO score of [Redacted] | Borrower has verified disposable income of at least $2500.00. Borrower has owned the subject property for at least 5 years. |
SitusAMC SitusAMC |
Reviewer Comment (2022-07-26): Post funding exception, waived per client approval Seller Comment (2022-07-25): Please see attached Exceptional approval. |
07/26/2022 | 2 | B | NY | Primary | Refinance - Cash-out - Other | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||
| 438639420 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Mortgage Broker Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Mortgage broker Fee was last disclosed as [Redacted] on LE but disclosed as [Redacted] on Final Closing Disclosure. File does not contain a valid COC for this fee, cure provided at closing. | Reviewer Comment (2022-07-13): Sufficient Cure Provided At Closing |
07/13/2022 | 1 | A | NY | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639420 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Appraisal Re-Inspection Fee was last disclosed as [Redacted] on LE but disclosed as [Redacted] on Final Closing Disclosure. File does not contain a valid COC for this fee, cure provided at closing. | Reviewer Comment (2022-07-13): Sufficient Cure Provided At Closing |
07/13/2022 | 1 | A | NY | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639420 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: Borrower's ability to repay not verified with reliable documentation. | Reviewer Comment (2022-07-26): Accepted as is per client |
2 | B | NY | Primary | Refinance - Cash-out - Other | No obvious cure | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639420 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-07-26): Accepted as is per client |
2 | B | NY | Primary | Refinance - Cash-out - Other | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639420 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate 5.23000 + 1.75%, or 6.98000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-07-26): Accepted as is per client |
2 | B | NY | Primary | Refinance - Cash-out - Other | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639420 | Compliance | Compliance | Federal Compliance | Missing Non-Required Data | (Missing Data) Last Rate Set Date | Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing. | Reviewer Comment (2022-07-26): Accepted as is per client |
2 | B | NY | Primary | Refinance - Cash-out - Other | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639413 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate 5.30000 + 1.75%, or 7.05000%. Non-Compliant SubPrime Loan. | APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate 5.30000 + 1.75%, or 7.05000%. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639413 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639413 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639424 | Credit | Credit | Credit Calculation / Analysis | Guideline | Guideline Requirement: Representative FICO score discrepancy. | Minimum FICO is [Redacted] for LTV of [Redacted] | Reviewer Comment (2022-07-22): Received, Clearing. Seller Comment (2022-07-22): Please see attached updated credit report, [redacted] score is[redacted], which meets the min [redacted] requirement. |
07/22/2022 | 1 | A | CT | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639424 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Amount of Non-Escrowed Property Costs over Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted] on Final Closing Disclosure provided on [Redacted] not accurate. | Due to calculation of HOA dues on the final Closing Disclosure, which should reflect the amount of [Redacted]. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | CT | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639382 | Credit | Loan Package Documentation | Closing / Title | Loan Package Documentation | Missing Document: Rider - PUD not provided | Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): Please see attached for the PUD Rider. |
07/20/2022 | 1 | A | TX | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639382 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | TX | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639382 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Borrower was not provided with a COC | Reviewer Comment (2022-07-13): Sufficient Cure Provided At Closing |
07/13/2022 | 1 | A | TX | Primary | Purchase | Final CD evidences Cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639433 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | The Hazard Insurance Coverage Amount is insufficient by [Redacted] | Reviewer Comment (2022-07-20): RCE received Seller Comment (2022-07-20): Dwelling coverage of [redacted] is sufficient to cover the replacement cost of [redacted]per attached RCE. |
07/20/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639433 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639433 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-07-13): Sufficient Cure Provided At Closing |
07/13/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639423 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Verification appraisal was delivered to borrower was not provided. | Reviewer Comment (2022-07-20): Received, Clearing. |
07/20/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639423 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 4.56% + 1.5%, or 6.06000%. Non-Compliant Higher Priced Mortgage Loan. | APR on subject loan of 7.31860% or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 4.56% + 1.5%, or 6.06000%. | Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): appraisal delivery letter provided |
07/20/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639423 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): appraisal delivery letter provided |
07/20/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639387 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Hazard coverage of [Redacted] is insufficient to cover the mortgage amount of [Redacted]. Please provide a letter from the Insurer stating the maximum insurable amount and/or a replacement costs estimator from the insurer. | Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): it's Replacement Cost included property in[redacted]per attached HOI, and RCE is not required in [redacted]by law, this is sufficient. |
07/20/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | A | C | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639387 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-07-19): Received, Clearing. Seller Comment (2022-07-19): Please see attached for the appraisal letter. |
07/19/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | A | C | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639387 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.31% + 1.5%, or 6.81000%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-07-19): Received, Clearing. |
07/19/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | A | C | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639387 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-07-19): Received, Clearing. |
07/19/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | A | C | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639404 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Amount of Non-Escrowed Property Costs over Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on [Redacted] not accurate. | The final CD reflects Non-Escrowed Property Costs over Year 1 of [Redacted], the appraisal reflects HOA of [Redacted]. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | FL | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639404 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | MIssing donor check/wire for gift in the amount of [Redacted]. | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Please see attached for the source of funds. |
07/21/2022 | 1 | A | FL | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438820847 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-07-21): Received, Clearing. |
07/21/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438820847 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.33% + 1.5%, or 6.83000%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-07-21): Received, Clearing. |
07/21/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438820847 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Please see attached for the appraisal letter. |
07/21/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438820847 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-08-22): Accepted as is. |
2 | B | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438820847 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-08-22): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438820847 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-08-22): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438820847 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate 5.25000 + 1.75%, or 7.00000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-08-22): Accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438820847 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | A valid COC or sufficient Cure for the increase in the Appraisal fee was not provided in the loan file. | Reviewer Comment (2022-07-28): [redacted] Received PCCD, LOE, Refund Check and Proof of Mailing. Buyer Comment (2022-07-28): The cure has been received by the borrower. Please clear. Reviewer Comment (2022-07-27): [redacted] Received PCCD, LOE, Copy of check & Shipping label. Tracking indicates the label has been created; however, it has not been picked up for shipping. Proof of mailing is required. Seller Comment (2022-07-26): Please see attached for the PCCD, LOE, Proof of delivery, and proof of refund. |
07/28/2022 | 2 | B | NY | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438820847 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Review Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | A valid COC or sufficient Cure for the Appraisal Update/Review fee was not provided in the loan file. | Reviewer Comment (2022-07-28): [redacted]Sufficient cure provided at Closing. Buyer Comment (2022-07-28): The cure has been received by the borrower. Please clear. Reviewer Comment (2022-07-22): [redacted]: Cure provided at closing is insufficient to cure for all the citing[redacted] exception. We will clear the exception once we received resolution on the Appraisal fee exception citing. Exception remains. Seller Comment (2022-07-21): Please see attached final CD. Lender credits of [redacted] were applied for this fee change. |
07/28/2022 | 1 | A | NY | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438820847 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Hazard Policy does not sates Guaranteed Replacement Coverage or state Extended Replacement Cost Coverage with a $ or % amount, therefore Dwelling coverage is insufficient for the loan amount. | Reviewer Comment (2022-08-22): Clearing, after review with client and meeting [redacted] standards. Reviewer Comment (2022-08-05): The letter doesn't reach the [redacted] guideline since letter only states $[redacted]s sufficient and not that [redacted]% of the insurable value of the improvements is being provided. Seller Comment (2022-07-27): Please see attached. |
08/22/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639409 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639409 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639409 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639409 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate 5.09000 + 1.75%, or 6.84000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639409 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639409 | Credit | Credit | Credit Documentation | Guideline | Missing Document: Verification of Rent (VOR) / Verification of Mortgage (VOM) not provided | File is missing the most recent 12 month rental payment history as required by lender guides. | Reviewer Comment (2022-07-21): Received, Clearing. Buyer Comment (2022-07-21): It's a purchase loan for primary property. And borrower hasn't owned REO per [redacted] so there is no required for[redacted] months rental payment history. |
07/21/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639409 | Compliance | Compliance | Federal Compliance | Missing Non-Required Data | (Missing Data) Last Rate Set Date | Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639408 | Credit | Loan Package Documentation | Loan File | Missing Document | Missing Document: Hazard Insurance Policy not provided | Reviewer Comment (2022-07-20): [Redacted]% replacement cost Seller Comment (2022-07-20): it's [Redacted]% Replacement Cost Coverage Included for property in [redacted], RCE is not required in[redacted] by law, this is sufficient. |
07/20/2022 | 1 | A | FL | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639388 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - ___ | Missing insurance and tax verifications for XXXX, NY property. | Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): Per attached [Redacted] guideline, only need to list borrower's owned real estate on [Redacted]application. |
07/20/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639388 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: Borrower's ability to repay not verified with reliable documentation. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639388 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639388 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639388 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639388 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate 5.23000 + 1.75%, or 6.98000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639388 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639427 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Reviewer Comment (2022-07-22): Received, Clearing. Buyer Comment (2022-07-22): It was a typo. total [Redacted] months PITIA is [Redacted] Updated: Per final CD, cash to close required [Redacted] plus [Redacted] months PITIA [Redacted] , total required [Redacted] to close. We've verified assets from the transaction activity of [Redacted] [Redacted] at [Redacted] and [Redacted] [Redacted] at [Redacted], total asset [Redacted] is sufficient for this transaction. Reviewer Comment (2022-07-20): [Redacted] months reserves required on this loan amount. Seller Comment (2022-07-20): Per final CD, cash to close required [Redacted] plus [Redacted] months PITIA [Redacted] , total required [Redacted] to close. We've verified assets from the transaction activity of [Redacted] [Redacted] at [Redacted] and [Redacted] [Redacted] at [Redacted], total asset [Redacted] is sufficient for this transaction. |
07/22/2022 | 1 | A | FL | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639427 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Verification appraisal was delivered to borrower was not provided. | Reviewer Comment (2022-08-17): Accepted as is |
2 | B | FL | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639427 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Missing Accountant/CPA/Tax Preparer letter to verify that business will not be adversely impacted by Borrower withdrawals. | Reviewer Comment (2022-07-20): Received, Clearing. Seller Comment (2022-07-20): CPA letter confirming no adversely impacted by withdrawals. |
07/20/2022 | 1 | A | FL | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438820861 | Compliance | Compliance | State Compliance | State Defect | (TX50(a)(6)) Texas Cash-out Loan (Acknowledgment of Fair Market Value Disclosure Not Signed by the Lender) | Texas Constitution Section 50(a)(6): Acknowledgment of the Fair Market Value not properly executed by the Lender. | Reviewer Comment (2022-07-19): Received, Clearing. Seller Comment (2022-07-19): Attached corrected document |
07/19/2022 | 1 | A | TX | Primary | Refinance - Cash-out - Other | To Remediate: the lender or holder may either: (1) Deliver to the borrower the required disclosure documents, (AFMV signed by the lender), and obtain an executed copy; OR (2) refund or credit the borrower $1,000 and offer the borrower the right to refinance the extension of credit for the remaining term of the loan at no cost to the borrower on the same terms, including interest, as the original extension of credit with any modifications necessary to comply with this section or on terms on which the borrower and the lender or holder otherwise agree. Letter of explanation and proof of delivery of cure documents required, and, if cured with refund or credit, copy of refund check or evidence of principal reduction also required. | D | A | A | A | D | A | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438820861 | Compliance | Compliance | State Compliance | Misc. State Level | (TX50(a)(6)) Texas Cash-out Loan (The lender/Assignee cannot conclusively rely on the Value reflected on the Acknowledgement of Fair Market Value as it does not match the appraised value) | Texas Constitution Section 50(a)(6): The lender/Assignee cannot conclusively rely on the Value on Acknowledgement of Fair Market Value as it does not match the appraised value. | Reviewer Comment (2022-07-19): Received, Clearing. Seller Comment (2022-07-19): Attached corrected document |
07/19/2022 | 1 | A | TX | Primary | Refinance - Cash-out - Other | To Remediate: the lender or holder may either: (1) Deliver to the borrower the required disclosure documents and obtain an executed copy; OR, (2) refund or credit the borrower $1,000 and offer the borrower the right to refinance the extension of credit for the remaining term of the loan at no cost to the borrower on the same terms, including interest, as the original extension of credit with any modifications necessary to comply with this section or on terms on which the borrower and the lender or holder otherwise agree. Letter of explanation and proof of delivery of cure documents required, and, if cured with refund or credit, copy of refund check or evidence of principal reduction also required. | D | A | A | A | D | A | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438820861 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of [Redacted] exceeds tolerance of [Redacted] plus [Redacted] or [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-07-13): Sufficient Cure Provided At Closing |
07/13/2022 | 1 | A | TX | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | D | A | A | A | D | A | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438820865 | Credit | Missing Document | General | Missing Document | Missing Document: Official Check not provided | File is missing a copy of the wire or check for the EMD. | Reviewer Comment (2022-07-15): Received, Clearing. Seller Comment (2022-07-15): Uploaded confirmation of wire EMD |
07/15/2022 | 1 | A | FL | Investment | Purchase | C | A | C | A | A | A | N/A | No | |||||||||||||||||
| 438820870 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-07-15): Sufficient Cure Provided At Closing |
07/15/2022 | 1 | A | FL | Primary | Purchase | Final CD evidences Cure | A | A | A | A | A | A | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438820871 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | CO | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Non QM | Non QM | No | |||||||||||||||
| 438820878 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Credit | Payment Shock exceeds credit guidelines. | Payment Shock: ___ | Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-07-18): Prefunding exception, waived with compensating factors |
07/18/2022 | 2 | B | CA | Primary | Purchase | C | B | C | B | C | A | A | A | Non QM | Non QM | No | ||||||||||||
| 438820878 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - ATR Risk | Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk. | Reviewer Comment (2022-07-25): Received, Clearing. |
07/25/2022 | 1 | A | CA | Primary | Purchase | Lender to provide updated ATR/QM Loan Designation | C | B | C | B | C | A | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438820878 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: Investor qualifying total debt ratio discrepancy. | Borrower qualified using the note rate however the mortgage is interest only for 120 months so should be qualified using the fully amortized payment at the greater of the fully indexed or the note rate, to repay the loan over the remaining term after the I/O period | Reviewer Comment (2022-07-25): Received, Clearing. Seller Comment (2022-07-25): Please find attached updated income calc, original UW did not consider paypal transfers as income and should have been included. Reviewer Comment (2022-07-21): The new 1008 received shows the borrower being qualified with a P&I payment of [Redacted], which is a [Redacted] year amortized payment. The borrower should be qualified using the P&I payment after the [Redacted] year I/O period, which is [Redacted]. Seller Comment (2022-07-21): Loan qualifies at full amort with [Redacted] months, please see corrected 1008 |
07/25/2022 | 1 | A | CA | Primary | Purchase | C | B | C | B | C | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820878 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General Ability To Repay Provision Investor Guidelines | Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk. | Due to excessive DTI | Reviewer Comment (2022-07-25): Received, Clearing. |
07/25/2022 | 1 | A | CA | Primary | Purchase | C | B | C | B | C | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438820878 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines | Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of [Redacted] moderately exceeds the guideline maximum of [Redacted]. (DTI Exception is eligible to be regraded with compensating factors.) | Borrower qualified using the note rate however the mortgage is interest only for 120 months so should be qualified using the fully amortized payment at the greater of the fully indexed or the note rate, to repay the loan over the remaining term after the I/O period | Reviewer Comment (2022-07-25): Received, Clearing. |
07/25/2022 | 1 | A | CA | Primary | Purchase | C | B | C | B | C | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438820877 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | Reviewer Comment (2022-07-18): Received, Clearing. Seller Comment (2022-07-18): Valid, Excel version of calc in file but did not make the upload to visionet, see attached. |
07/18/2022 | 1 | A | NJ | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | No | |||||||||||||||
| 438820883 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Mortgage Statement(s) not provided | Per lender guides, Minimum 12 months of housing history required for the current/primary residence and any other real estate owned. The borrower's primary residence is only reporting 6 months history and the additional investment property is reporting no history. | The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. |
SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-08-30): Post funding credit exception, waived per client approval Seller Comment (2022-08-30): Approved Exception attached for Mortgage History. Reviewer Comment (2022-08-09): Per lender guides, Minimum [Redacted] months of housing history required for the current/primary residence and any other real estate owned. Seller Comment (2022-08-09): Disagree - borrower's primary residence located at [Redacted] is only reporting [Redacted] months history because owned the property free and clear prior to the mortgage with [Redacted] and the additional property at [Redacted] is reporting no history because it just closed , uploaded Lexis Nexis and CD Reviewer Comment (2022-07-29): A guideline exception is needed for this exception. Seller Comment (2022-07-29): The borrower's primary residence located at [Redacted] is only reporting [Redacted] months history because owned the property free and clear prior to the mortgage with [Redacted], and the additional property at [Redacted] is reporting no history because it just closed with us, I have attached the CD. Reviewer Comment (2022-07-20): Provide housing history prior to [Redacted] for a complete [Redacted]month history in order to clear exception Seller Comment (2022-07-20): borrower's primary residence located at [Redacted] is only reporting [Redacted] months history because he has only had it since [Redacted], and the additional property at [Redacted] is reporting no history because it just closed, uploaded final CD |
08/30/2022 | 2 | B | FL | Investment | Purchase | C | B | C | B | A | A | N/A | No | |||||||||||||||
| 438820881 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of [Redacted] of the Federal Total Loan Amount. Points and Fees total [Redacted] on a Federal Total Loan Amount of [Redacted] vs. an allowable total of [Redacted](an overage of [Redacted] or [Redacted]). | Missing evidence of Undiscounted Par rate to determine any excludable points | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Disagree - [Redacted] of up to [Redacted] are eligible for bona fide discount points as such, the amount of [Redacted] is excluded from the calculation; therefore, the total Points & Fees of [Redacted] is less than an allowable of [Redacted]. Uploaded calculation, undiscounted rate, DM Compliance Report, and Final CD. |
07/21/2022 | 1 | A | CA | Primary | Purchase | C | A | A | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438820881 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien | TRID Final Closing Disclosure [Redacted] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) | There are no seller fees listed on the final CD | Reviewer Comment (2022-07-28): [Redacted] received Seller CD Seller Comment (2022-07-26): Uploaded Seller CD which was in Executed Closing Documents labeled Sellers. Reviewer Comment (2022-07-25): Please provide final seller CD for testing. Seller Comment (2022-07-21): Uploaded Settlement Statement which was in the Loan Doc Review pp. 802-804 has provided Seller paid fees |
07/28/2022 | 1 | A | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | A | A | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438820881 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Due to QM fees and points exception | Reviewer Comment (2022-07-21): Received, Clearing. Seller Comment (2022-07-21): Disagree - [Redacted] of up to [Redacted] are eligible for bona fide discount points as such, the amount of [Redacted] is excluded from the calculation; therefore, the total Points & Fees of [Redacted] is less than an allowable of [Redacted]. Uploaded calculation, undiscounted rate, DM Compliance Report, and Final CD. |
07/21/2022 | 1 | A | CA | Primary | Purchase | Lender to provide updated ATR/QM status | C | A | A | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438820882 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - | Missing verification of PITIA for REO property. | Reviewer Comment (2022-07-19): Received final CD Seller Comment (2022-07-19): Uploaded final CD |
07/19/2022 | 1 | A | FL | Investment | Purchase | C | A | C | A | A | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438820884 | Credit | Missing Document | General | Missing Document | Missing Document: Official Check not provided | Missing earnest money deposit check in the amount of [Redacted] | Reviewer Comment (2022-07-20): Received, cleared Seller Comment (2022-07-20): Uploaded EMD check |
07/20/2022 | 1 | A | CT | Primary | Purchase | C | A | C | A | A | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820885 | Credit | Hazard Insurance | Insufficient Coverage | Hazard Insurance | The Hazard Insurance Policy Effective Date is after closing. | Reviewer Comment (2022-08-10): Received, Clearing. Seller Comment (2022-08-10): Updated insurance showing the date of the [Redacted]. Reviewer Comment (2022-07-22): Need [Redacted] approval as this is a post closing exception. Seller Comment (2022-07-22): Uploaded approved exception |
08/10/2022 | 1 | A | MD | Primary | Purchase | C | A | C | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438820885 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Loan Estimate Timing Electronically Provided | TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated [Redacted] was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations. | Reviewer Comment (2022-07-29): [Redacted] received E- consent dated [Redacted] which suffices Initial Loan Estimate Timing. Seller Comment (2022-07-28): Please see attached eDisclosure Agreement provided by the Correspondent, accepted by the borrower [Redacted]. This should clear both exceptions on this loan. Reviewer Comment (2022-07-26): [Redacted] received rebuttal however, Page 6 of the application seems to consent to an electronic signature for the application. It does not mention E-consent for the transaction, or the relationship. As such, please provide separate documented e-consent for testing. Seller Comment (2022-07-25): Disagree - the acknowledgement and consent for electronic records and signature is located on Page 6, Section 6: Acknowledgments and Agreements (4). The borrower executed on [Redacted] - there is no longer a separate e-Consent form - it is within the 1003/application - effective as of [Redacted], therefore the Initial LE, disclosed, delivered and executed on [Redacted] is within [Redacted] days of application Reviewer Comment (2022-07-22): [Redacted] received duplicate copy of initial LE and executed initial 1003 however, these documents cannot be considered as the borrower's agreement to receive documents electronically. To address the exception, provide E-consent agreement within [Redacted] days of application date or proof initial LE was sent via alternative method. Seller Comment (2022-07-21): Response: Please see attached Initial LE dated & executed [Redacted], as well as, Initial Executed 1003 - Section 6, Acknowledgements and Agreements #4 outlines Electronic Records and Signatures - borrower executed [Redacted]. The Initial LE was disclosed same day as the application & the borrower agreed to electronic delivery. Please clear exception per the documents provided showing proof of delivery within [Redacted] business days of application. |
07/29/2022 | 1 | A | MD | Primary | Purchase | C | A | C | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438820885 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points. Fee Amount of [Redacted]exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | Valid COC on file. All data entries are correct. Exception is invalid. | Reviewer Comment (2022-07-29): [Redacted]Received E - consent agreement accepted by borrower on [Redacted]. Seller Comment (2022-07-28): Please see attached eDisclosure Agreement provided by the Correspondent, accepted by the borrower [Redacted]. This should clear both exceptions on this loan. Reviewer Comment (2022-07-26): [Redacted] received rebuttal however, Page 6 of the application seems to consent to an electronic signature for the application. It does not mention E-consent for the transaction, or the relationship. As such, please provide separate documented e-consent for testing. Seller Comment (2022-07-25): Response: Disagree - Per response to additional exception for this loan # [Redacted] - - Initial Executed 1003/application is located on Pages 254-263 & Initial Executed LE is located on Pages 841-843 of Loan Doc Review folder. The acknowledgement and consent for electronic records and signature is located on Page 6, Section 6: Acknowledgments and Agreements (4). The borrower executed on [Redacted] - there is no longer a separate e-Consent form - it is within the 1003/application - effective as of [Redacted]. Initial LE was disclosed, delivered and executed on [Redacted] & is within [Redacted] days of application. See attached Initial Executed 1003 & Initial Executed LE - delivered electronically [Redacted]. Reviewer Comment (2022-07-22): [Redacted] received duplicate copy of LE dated [Redacted] and COC. The fees is not baseline because of e-sign consent is missing in the file. We need e-signed consent on or before the initial LE was signed date. Please provide the same to clear this exception. Seller Comment (2022-07-21): Loan was locked, points added for the change - loan discount remained the same through Executed Final CD , uploaded COC CD which was in file pg 1033-1036 |
07/29/2022 | 1 | A | MD | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | A | C | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438820858 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | The file is missing a copy of the 1084 or income worksheet | Reviewer Comment (2022-07-25): Received, Clearing. Seller Comment (2022-07-25): Uploaded income wksht |
07/25/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | B | C | B | A | A | A | A | Non QM | Non QM | No | |||||||||||||
| 438820858 | Credit | Title | General | Title | Title Policy Coverage is less than Original Loan Amount. | The Title Policy Amount of ___ is less than the note amount of ___ based on the ___ in file. | The title policy coverage amount is less than the loan amount. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | CA | Primary | Refinance - Cash-out - Other | C | B | C | B | A | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820859 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Hazard insurance company does not have an AM Best rating | The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has owned the subject property for at least 5 years. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-07-21): Prefunding exception approval, waived with compensating factors |
07/21/2022 | 2 | B | FL | Primary | Refinance - Cash-out - Other | B | B | B | B | A | A | A | A | Non QM | Non QM | No | ||||||||||||
| 438820888 | Credit | Missing Document | General | Missing Document | Missing Document: 1007 Rent Comparison Schedule not provided | Reviewer Comment (2022-07-25): Received, Clearing. Seller Comment (2022-07-25): Uploaded rent 1007 |
07/25/2022 | 1 | A | FL | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438820896 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Missing evidence of undiscounted interest rate price to determine if any portion of discount points are considered bona fide | Reviewer Comment (2022-07-25): Received, Clearing. Seller Comment (2022-07-25): Review:[Redacted] of [Redacted] discount points is eligible for bona file as such, the amount of [Redacted] can be excluded from the calculation. Therefore, the total Points & Fees of[Redacted] is less than an allowable of [Redacted]. See attached calculation, undiscounted rate, DM Compliance Report, and Final CD. |
07/25/2022 | 1 | A | NY | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | B | B | C | A | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | Yes | ||||||||||||
| 438820896 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of [Redacted] of the Federal Total Loan Amount. Points and Fees total [Redacted] on a Federal Total Loan Amount of [Redacted] vs. an allowable total of [Redacted](an overage of [Redacted] or [Redacted]). | Missing evidence of undiscounted interest rate price to determine if any portion of discount points are considered bona fide | Reviewer Comment (2022-07-25): Received, Clearing. Seller Comment (2022-07-25): Review: [Redacted] of [Redacted] discount points is eligible for bona file as such, the amount of [Redacted] can be excluded from the calculation. Therefore, the total Points & Fees of [Redacted] is less than an allowable of [Redacted]. See attached calculation, undiscounted rate, DM Compliance Report, and Final CD. |
07/25/2022 | 1 | A | NY | Primary | Purchase | C | B | B | B | C | A | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | |||||||||||||
| 438820896 | Credit | Guideline | Guideline Issue | Guideline | The minimum housing history was not met as required by guidelines for First Time Homebuyer. | The borrower does not have a documentable housing history | The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. |
SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-07-22): Prefunding exception approval, waived with compensating factors |
07/22/2022 | 2 | B | NY | Primary | Purchase | C | B | B | B | C | A | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | ||||||||||||
| 438820895 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Less than 12 months housing history documented. Only 10 months cancelled checks provided. Per landlord, 2 months were paid in cash | The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-07-22): Prefunding exception approval, waived with compensating factors |
07/22/2022 | 2 | B | FL | Primary | Purchase | B | B | B | B | A | A | A | A | Non QM | Non QM | No | ||||||||||||
| 438820895 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Hazard insurance company is not rated by AM Best | The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-07-22): Prefunding exception approval, waived with compensating factors |
07/22/2022 | 2 | B | FL | Primary | Purchase | B | B | B | B | A | A | A | A | Non QM | Non QM | No | ||||||||||||
| 438820899 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee. Fee Amount of [Redacted]exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | The Appraisal Re-Inspection Fee Amount Paid was [Redacted] | Reviewer Comment (2022-07-26): Sufficient Cure Provided At Closing |
07/26/2022 | 1 | A | GA | Primary | Purchase | Final CD evidences Cure | A | A | A | A | A | A | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820900 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Payment Adjusts Every Starting In | TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on [Redacted] with an increasing payment did not disclose the due date of the first adjustment. | Final CD does not list the increase of payment but it was updated at post closing | Reviewer Comment (2022-07-26): Letter of Explanation & Corrected Closing Disclosure |
07/26/2022 | 2 | B | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820900 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Payment Interest Only Until | TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on [Redacted] with an increasing payment did not disclose the due date of the last payment of interest only. | Final CD does not list the increase of payment but it was updated at post closing | Reviewer Comment (2022-07-26): Letter of Explanation & Corrected Closing Disclosure |
07/26/2022 | 2 | B | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820900 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Payment Max Amount | TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on [Redacted] with an increasing payment did not disclose the maximum possible amount of principal and interest. | Final CD does not list the increase of payment but it was updated at post closing | Reviewer Comment (2022-07-26): Letter of Explanation & Corrected Closing Disclosure |
07/26/2022 | 2 | B | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820900 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Payment Max Amount In Year | TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on [Redacted] with an increasing payment did not disclose the earliest date of the maximum possible amount of principal and interest. | Final CD did not list the disclose date but it was updated at post closing | Reviewer Comment (2022-07-26): Letter of Explanation & Corrected Closing Disclosure |
07/26/2022 | 2 | B | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820900 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Product Feature Test | TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [Redacted] did not disclose a Product Feature for a loan that contains a product feature. | Final CD does not list the product feature but it was updated at post closing | Reviewer Comment (2022-07-26): Letter of Explanation & Corrected Closing Disclosure |
07/26/2022 | 2 | B | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820907 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | AR | Investment | Purchase | B | B | A | A | B | B | A | A | N/A | No | ||||||||||||||||
| 438820904 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM (APOR) does not match Due Diligence Loan Designation of Safe Harbor QM (APOR). | Originator Loan Designation of Higher Priced QM (APOR) does not match Due Diligence Loan Designation of Safe Harbor QM (APOR). | Reviewer Comment (2022-07-29): Restated. Buyer Comment (2022-07-29): please restate as Safe Harbor Reviewer Comment (2022-07-29): We have this as Safe Harbor QM (APOR) but was stated originally by you as Higher Priced QM (APOR).. You will need to restate this to Safe Harbor QM (APOR). Buyer Comment (2022-07-29): [Redacted] month bank statement loan, should be queued for regrade to a [Redacted] |
07/29/2022 | 1 | A | CO | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | A | A | C | B | A | A | Higher Priced QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438820904 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - QM / ATR | Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Safe Harbor QM (APOR) matches the Due Diligence Loan Designation of Safe Harbor QM (APOR). | Restated. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | CO | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | A | A | C | B | A | A | Higher Priced QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438820893 | Compliance | Compliance | State Compliance | State HPML | Massachusetts HPML Threshold Test Compliant | Massachusetts Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.86% + 1.5%, or 7.36000% Compliant Higher Priced Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MA | Primary | Refinance - Cash-out - Other | No obvious cure | C | B | A | A | C | B | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | ||||||||||||||
| 438820893 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Loan Estimate Timing Electronically Provided | TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated [Redacted] was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations. | Reviewer Comment (2022-08-19): [Redacted] upon further review received supporting document no further action required. Buyer Comment (2022-08-18): Manual or mail fulfillment is the printing and mailing of the hard copy disclosure package that is triggered when the borrower has failed to accept and open the initial disclosure package to consent to eSign in conjunction with the mortgage application. In order to meet timing requirements, the document provider undertakes the functional task via mailing the hard copy package on behalf of the lender so that the initial disclosures are issued within and no later than three [Redacted] business days from the date of application. Reviewer Comment (2022-08-17): [Redacted] received comment that LE was sent via manual fulfillment. Screenshot provided shows LE created [Redacted] was sent via email and [Redacted] is presumed received date email. Additional clarification on the manual fulfillment process is needed to determine if the [Redacted] LE was sent in time. Please confirm how LE is sent in manual fulfillment. Seller Comment (2022-08-16): Disagree - [Redacted] Initial Disclosure Package was issued, but borrower didn't pick up; therefore, manual fulfillment was delivered on [Redacted] which is within [Redacted] business days of application date with presumed received date on [Redacted] |
08/19/2022 | 1 | A | MA | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | ||||||||||||||
| 438820908 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NJ | Primary | Refinance - Rate/Term | C | B | C | B | B | B | A | A | Non QM | Non QM | No | |||||||||||||||
| 438820908 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-07-29): Sufficient Cure Provided At Closing |
07/29/2022 | 1 | A | NJ | Primary | Refinance - Rate/Term | Final CD evidences Cure | C | B | C | B | B | B | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438820908 | Credit | Guideline | Guideline Issue | Guideline | Housing history reflects lates that do not meet guidelines | Borrower has a 1x30 mortgage late (Dec 2021) in the last 12 months which is not allowed per guidelines. LOE for delinquency was not provided. | The qualifying DTI on the loan is at least 10% less than the guideline maximum. The Loan to Value (LTV) on the loan is less than the guideline maximum by at least 10%. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has owned the subject property for at least 5 years. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-08-04): Pre-funding exception in the file. Seller Comment (2022-08-04): Uploaded LOE |
08/04/2022 | 2 | B | NJ | Primary | Refinance - Rate/Term | C | B | C | B | B | B | A | A | Non QM | Non QM | No | ||||||||||||
| 438820909 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Application Fee. Fee Amount of [Redacted]exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | Fee was not disclosed on LE and on final Closing Disclosure as [Redacted]. File does not contain a valid Change of Circumstance for the fee, nor evidence of cure in file. Provide a post-close CD disclosing the tolerance cure to include [Redacted] a copy of refund check, proof of delivery, and a copy of the letter of explanation sent it the Borrower disclosing the changes made. | Reviewer Comment (2022-08-19): [Redacted] Received copy of check and proof of mailing. Corrected PCCD and LOE already present on file. Seller Comment (2022-08-18): Uploaded PCCD, LOX, check and shipping label Reviewer Comment (2022-08-18): [Redacted] received PCCD and LOE however we still require copy of refund check and proof of mailing for cure to be applied, Seller Comment (2022-08-17): Uploaded PCCD and LOE for required cure of [Redacted] for the Application fee , initial LE [Redacted] Reviewer Comment (2022-08-08): [Redacted] The initial LE in the transaction is dated [Redacted] and was signed by the borrower. All applications in loan file indicate an application date after [Redacted]. Please provide copy of initial application for testing. Seller Comment (2022-08-05): Disagree - Application fee of [Redacted] disclosed on Initial LE found on pg 1192 of upload pkg |
08/19/2022 | 2 | B | NJ | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | Yes | ||||||||||||
| 438820909 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | Fee was disclosed on LE as [Redacted] and on Closing Disclosure as [Redacted]. File does not contain a valid Change of Circumstance for the fee, nor evidence of cure in file. Provide a post-close CD disclosing the tolerance cure to include [Redacted] a copy of refund check, proof of delivery, and a copy of the letter of explanation sent it the Borrower disclosing the changes made. | Reviewer Comment (2022-08-19): [Redacted] Received copy of check and proof of mailing. Corrected PCCD and LOE already present on file. Seller Comment (2022-08-18): Uploaded PCCD, LOX, check and shipping label Reviewer Comment (2022-08-18): [Redacted] received PCCD and LOE however we still require copy of refund check and proof of mailing for cure to be applied. Seller Comment (2022-08-17): Uploaded PCCD and LOE for required cure of [Redacted] for the Credit Report Fee, initial LE is dated [Redacted] Reviewer Comment (2022-08-08): [Redacted] The initial LE in the transaction is dated [Redacted] and was signed by the borrower. All applications in loan file indicate an application date after [Redacted]. Please provide copy of initial application for testing. Seller Comment (2022-08-05): Disagree - Credit report fee of [Redacted] disclosed on Initial LE and found on page 1192 of upload pkg |
08/19/2022 | 2 | B | NJ | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | Yes | ||||||||||||
| 438820909 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Loan Estimate Timing Electronically Provided | TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated [Redacted] was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations. | Initial E-sign was signed on [Redacted] ,First initial Loan Estimate was signed on [Redacted]. | Reviewer Comment (2022-08-25): [Redacted]received LOE confirming E-sign consent dated [Redacted] which suffices Initial LE Timing. Seller Comment (2022-08-24): E-consent requested is attached Reviewer Comment (2022-08-18): [Redacted] received Loan Application dated [Redacted]. However, the E-consent received is dated [Redacted]which is not within [Redacted] days of Application and there is an e-consent dated [Redacted] was being issued by the lender. It is dated even prior to the application date that is of [Redacted] and does not have any information which can confirm if it is relationship or loan specific authorization. Lender must also provide an attestation that borrower never withdrew the e-consent authorization if the e-consent was a relational consent. Seller Comment (2022-08-17): Disagree - first LE dated [Redacted] as the initial baseline LE. The broker 1003 dated [Redacted] is attached as well as e-consent, which was accepted by the borrower on [Redacted] when the broker began working with the borrower while they shopped for properties. The LE dated [Redacted] is to be viewed as superfluous to the transaction. Reviewer Comment (2022-08-08): SitusAMC The initial LE in the transaction is dated XXXX and was signed by the borrower. All applications in loan file indicate an application date after XXXX. Please provide copy of initial application for testing. Seller Comment (2022-08-05): Disagree - Loan documents dated [Redacted], Loan # [Redacted] Lender: [Redacted] were uploaded in error to [Redacted] and should be disregarded. The loan was first submitted by the broker to [Redacted] on [Redacted]. The loan disclosed by [Redacted] is Loan# [Redacted], initial disclosures were sent and signed on [Redacted]. |
08/25/2022 | 1 | A | NJ | Primary | Purchase | C | B | A | A | C | B | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | |||||||||||||
| 438820909 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Loan Estimate Timing Electronically Provided | TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated [Redacted] was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations. | Reviewer Comment (2022-08-25): [Redacted] received LOE confirming E-sign consent dated [Redacted] which suffices Initial LE Timing. Seller Comment (2022-08-24): E-consent requested is attached. Reviewer Comment (2022-08-18): [Redacted] received Loan Application dated [Redacted]. However, the E-consent received is dated [Redacted] which is not within[Redacted] days of Application and there is an e-consent dated [Redacted] was being issued by the lender. It is dated even prior to the application date that is of [Redacted] and does not have any information which can confirm if it is relationship or loan specific authorization. Lender must also provide an attestation that borrower never withdrew the e-consent authorization if the e-consent was a relational consent. Seller Comment (2022-08-17): Disagree - first LE dated [Redacted] as the initial baseline LE. The broker 1003 dated [Redacted] is attached as well as e-consent, which was accepted by the borrower on [Redacted] when the broker began working with the borrower while they shopped for properties. The LE dated [Redacted] is to be viewed as superfluous to the transaction. |
08/25/2022 | 1 | A | NJ | Primary | Purchase | C | B | A | A | C | B | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | ||||||||||||||
| 438820910 | Compliance | Compliance | State Compliance | State Defect | Illinois SB 1894 | IL Predatory Lending Database Program (SB 1894) - Certificate of Compliance or Exemption not attached to mortgage for recording. | Illinois SB 1894 was missing | Reviewer Comment (2022-08-10): Received, Clearing. Seller Comment (2022-08-10): Review: Agree - see attached the missing Certificate of Compliance. |
08/10/2022 | 1 | A | IL | Primary | Purchase | C | A | A | A | C | A | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | |||||||||||||
| 438820910 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Loan Estimate Timing Electronically Provided | TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated [Redacted] was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations. | Loan Estimate not delivered to Borrower(s) within three (3) business days of application | Reviewer Comment (2022-08-11): [Redacted] Received E- sign Consent dated [Redacted]which suffices Initial LE Timing. Seller Comment (2022-08-10): Review: Disagree - [Redacted] Initial Disclosure Package was issued, and borrower has received and esigned on the same day for application date of [Redacted]. See attached eConsent, signed initial LE and ITP. |
08/11/2022 | 1 | A | IL | Primary | Purchase | C | A | A | A | C | A | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | |||||||||||||
| 438820910 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Zero Percent Fee Tolerance exceeded for Appraisal Fee | Reviewer Comment (2022-07-29): Sufficient Cure Provided At Closing |
07/29/2022 | 1 | A | IL | Primary | Purchase | Final CD evidences Cure | C | A | A | A | C | A | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | Yes | ||||||||||||
| 438820912 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of [Redacted] exceeds tolerance of [Redacted] plus [Redacted] or [Redacted]. Insufficient or no cure was provided to the borrower. | 10% tolerance was exceeded by [Redacted] due to increase of recording fee. No valid COC provided, nor evidence of cure in file. | Reviewer Comment (2022-08-11): [Redacted] received PCCD dated [Redacted], LOE & True and Certified Final Settlement Statement. Seller Comment (2022-08-10): Rebut #3: According to the Final Buyer's Statement per [Redacted], a refund in the amount of[Redacted] was issued at the closing to the borrower. See attached PCCD has provided showing a balance due to borrower in the amount of [Redacted], Refund Check was issued at the closing, and LOX. Reviewer Comment (2022-08-10): [Redacted] Disagree. Received True and Certified copy of Final settlement statement reflecting Balance due to buyer of [Redacted] at debit side and cure was not provided at Final Closing Disclosure. Please provide valid COC with additional information which can explain why recording fee increased on CD dated [Redacted] or provide PCCD along with cure documents. Seller Comment (2022-08-09): Disagree - According to the Final Buyer's Statement per [Redacted], a refund in the amount of [Redacted] was issued at the closing to the borrower, uploaded final buyer stmt Reviewer Comment (2022-08-04): [Redacted] received COC dated [Redacted] and LOE stating date of change should be considered as [Redacted]. However the reason stated in COC "Recording fee increase due to additional recording of affidavit per closing Agent Fees" is not valid. Fee cannot increase based on estimate received from closing agent. Please provide COC with more information on what was the change happened which was unaware by the lender before and due to which recording fee increased with supporting documents or provide cure. Cure consists of Corrected CD, LOE to borrower, proof of mailing and copy of refund check. Seller Comment (2022-08-03): Review: It's a clerical error, no Cure required.[Redacted] ICD was issued with a valid COC for the increase in Recording Fee; however, it appears that the date of change was printed in error. The change in increasing the Recording Fee was first acknowledged on [Redacted]which is the same date as the ICD was issued. See attached Prelim CD printed on [Redacted] was received from the closing agent, COC ICD, and Lender Attestation Letter. |
08/11/2022 | 1 | A | CA | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | A | A | A | C | A | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820913 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Loan Estimate Timing Electronically Provided | TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated [Redacted] was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations. | Reviewer Comment (2022-08-08): Received earlier E-consent dated [Redacted], cleared Seller Comment (2022-08-08): Uploaded eConsent showing Electronic Consent Date [Redacted] by the borrower on Page 3 - it was required for the hard credit pull, so was in place prior to disclosing Initial LE on [Redacted]. |
08/08/2022 | 1 | A | IN | Primary | Purchase | C | A | A | A | C | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820901 | Credit | Borrower and Mortgage Eligibility | Mortgage / Program Eligibility | Borrower and Mortgage Eligibility | Guideline Requirement: Combined High loan to value discrepancy. | Calculated high loan to value percentage of ___ exceeds Guideline high loan to value percentage of ___ | The representative FICO score exceeds the guideline minimum by at least 40 points. The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-08-01): Pre-funding exception. |
08/01/2022 | 2 | B | PA | Primary | Purchase | B | B | B | B | A | A | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | ||||||||||||
| 438820901 | Credit | Borrower and Mortgage Eligibility | Mortgage / Program Eligibility | Borrower and Mortgage Eligibility | Guideline Requirement: Loan to value discrepancy. | Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___. | The representative FICO score exceeds the guideline minimum by at least 40 points. The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-08-01): Pre-funding exception. |
08/01/2022 | 2 | B | PA | Primary | Purchase | B | B | B | B | A | A | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | ||||||||||||
| 438820901 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: Combined loan to value discrepancy. | Calculated combined loan to value percentage of ___ exceeds Guideline combined loan to value percentage of ___. | The representative FICO score exceeds the guideline minimum by at least 40 points. The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-08-01): Pre-funding exception. |
08/01/2022 | 2 | B | PA | Primary | Purchase | B | B | B | B | A | A | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | ||||||||||||
| 438820917 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Non Escrowed Property Costs Year 1 Test | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted] on Final Closing Disclosure provided on [Redacted] not accurate. | The final CD list the HOA dues at [Redacted] and the appraisal has the dues listed as [Redacted] a month | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | FL | Second Home | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | Yes | |||||||||||||
| 438820917 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Closing Disclosure Timing without Waiver | TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. | Missing evidence of receipt of [Redacted] CD | Reviewer Comment (2022-08-10): [Redacted] received Attestation for Initial CD [Redacted]. Seller Comment (2022-08-09): Uploaded attestation Reviewer Comment (2022-08-08): [Redacted] The evidence for receipt of CD dated [Redacted] is missing. Please provide an attestation stating that the CD dated [Redacted] is not needed and was not sent/issued to the Borrower. Seller Comment (2022-08-04): The [Redacted] CD is superfluous to the transaction. This CD was not viewed by the borrower so [Redacted] would not be able to re-baseline any increased fees reflected on the CD as compared to the last LE. However, in this case, the [Redacted] CD only reflected fees being reduced, and fee reductions are not required to be redisclosed per the Reg. The [Redacted] CD was sent and received on [Redacted], which satisfied the CD delivery timing requirements prior to closing, and was also provided within [Redacted] days of the valid COC. The review should be completed using the [Redacted] CD, which would be considered the "initial" CD for both timing and tolerance analysis. Reviewer Comment (2022-08-04): [Redacted] Require evidence that CD dated [Redacted] is received by borrower atleast three days prior to closing in order to clear this exception. Seller Comment (2022-08-03): Response: There is no evidence the CD sent on [Redacted] was received, however another CD was sent on [Redacted] with additional changes and was received on [Redacted]. This is still within [Redacted] days of the original COC date of [Redacted], and also satisfies the [Redacted] day timing for receipt of CD prior to closing, which was on [Redacted]. Since the changes that occurred on the initial CD were in the borrowers benefit - the Origination Fee decreased from Final LE to ICD, Lender Credit increased & APR decreased - coupled with the additional CD that was re-disclosed to show further changes, and all changes was completed/provided/received at least [Redacted] days prior to closing, there are no issues with tolerance or timing. |
08/10/2022 | 1 | A | FL | Second Home | Purchase | No Defined Cure | C | B | A | A | C | B | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | ||||||||||||
| 438639436 | Compliance | Compliance | Federal Compliance | Missing Non-Required Data | (Missing Data) Last Rate Set Date | Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MA | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639436 | Compliance | Compliance | State Compliance | State HPML | Massachusetts HPML Threshold Test Compliant | Massachusetts Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.16% + 1.5%, or 6.66000% Compliant Higher Priced Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MA | Primary | Purchase | No obvious cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639436 | Compliance | Compliance | Federal Compliance | TRID Defect | TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File | TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s). The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing. Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to [Redacted] may be required. | The Loan Estimate is missing from the file. | Reviewer Comment (2022-08-23): [Redacted] received [Redacted] & [Redacted]& [Redacted] LE's , valid changed circumstance and SSPL disclosure Seller Comment (2022-08-19): Please see attached for all LE's to this file. The time period from the last LE disclosed to the initial CD is greater than [Redacted] days, and therefore is not required to be signed by the borrower. |
08/23/2022 | 1 | A | MA | Primary | Purchase | No Defined Cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639436 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of [Redacted] exceeds tolerance of [Redacted] plus [Redacted] or [Redacted]. Insufficient or no cure was provided to the borrower. | A cure for [Redacted] was reflected on the final Closing Disclosure. | Reviewer Comment (2022-08-23): [Redacted] received [Redacted] & [Redacted] & [Redacted]LE's , valid changed circumstance and SSPL disclosure |
08/23/2022 | 1 | A | MA | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639436 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Service Charges. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | Title - Service Charge increased from [Redacted] to [Redacted] without a valif vhnge of circumstance. | Reviewer Comment (2022-08-23): [Redacted] received [Redacted] & [Redacted] & [Redacted] LE's , valid changed circumstance and SSPL disclosure |
08/23/2022 | 1 | A | MA | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639436 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Business bank statement program - CPA letter missing the business inception date as required per guidelines | Reviewer Comment (2022-08-09): Clearing with client comfortability with meeting guideline requirement. |
08/09/2022 | 1 | A | MA | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639436 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of [Redacted] exceeds tolerance of [Redacted] plus [Redacted] or [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | SitusAMC received [Redacted] & [Redacted] & [Redacted] LE's , valid changed circumstance and SSPL disclosure. cured at closing | Reviewer Comment (2022-08-23): Sufficient Cure Provided At Closing |
08/23/2022 | 1 | A | MA | Primary | Purchase | Final CD evidences Cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438820918 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Borrower has been in business for less than 2 years | The representative FICO score exceeds the guideline minimum by at least 40 points. The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower has verified disposable income of at least $2500.00. |
SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-08-03): Prefunding credit exception, waived with compensating factors |
08/03/2022 | 2 | B | PA | Primary | Purchase | A | B | A | B | A | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||
| 438820918 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Loan fails for points and fees | Reviewer Comment (2022-08-15): Restated to Non QM |
08/15/2022 | 1 | A | PA | Primary | Purchase | Lender to provide updated ATR/QM status | A | B | A | B | A | B | A | A | Safe Harbor QM (APOR) | Non QM | Yes | ||||||||||||
| 438820918 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of [Redacted] of the Federal Total Loan Amount. Points and Fees total [Redacted] on a Federal Total Loan Amount of [Redacted] vs. an allowable total of [Redacted] (an overage of [Redacted] or [Redacted]). | Missing undiscounted interest rate price to determine if any portion of discount points are bona fide | Reviewer Comment (2022-08-15): Restated to Non QM Buyer Comment (2022-08-15): Please reinstate to NQM |
08/15/2022 | 1 | A | PA | Primary | Purchase | A | B | A | B | A | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||
| 438820918 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - General Ability to Repay | Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not match. However, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. | Restated to Non QM | Reviewer Comment (2022-08-15): Accepted as is |
2 | B | PA | Primary | Purchase | A | B | A | B | A | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||||
| 438820923 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-08-04): Sufficient Cure Provided At Closing |
08/04/2022 | 1 | A | TX | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | C | B | B | B | C | A | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438820923 | Credit | Insurance | Insurance Analysis | Insurance | Hazard Insurance Policy expires within 90 days of the Note Date. | Hazard Insurance Policy Expiration Date ___, Note Date ___ | Policy should be in effective for 60 days after closing per guidelines | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | TX | Primary | Refinance - Cash-out - Other | C | B | B | B | C | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820923 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | Sufficient cure provided for appraisal increase. Exception will be revisited once all other tolerance violations are addressed | Reviewer Comment (2022-08-18): [Redacted] - Sufficient cure was provided at closing. Reviewer Comment (2022-08-17): [Redacted] agree that the cure was given for appraisal fee increase on closing. This will be cleared once we received the resolution for appraisal review fee exception as the cure provided at closing is insufficient to cure both the citing. Seller Comment (2022-08-16): Final CD page 2, Section J reflects Appraisal fee cure of [Redacted] and is correct. |
08/18/2022 | 1 | A | TX | Primary | Refinance - Cash-out - Other | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | B | B | C | A | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820923 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Review Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | Invalid COC and insufficient cure provided for addition of appraisal review fee | Reviewer Comment (2022-08-18): [Redacted] received supporting documenation that validates the COC dated [Redacted]. Seller Comment (2022-08-17): The appraisal was first received, uploaded, and reviewed on [Redacted]. Please see attached screenshots regarding the requested documentation that supports the earliest initial underwriting review of the appraisal took place on [Redacted] and due to the CU score, they required a CDA be ordered at that time. Reviewer Comment (2022-08-17): [Redacted] upon further review require additional information as the COC only states appraisal review is required and also we require supporting document regarding when the UW reviewed the appraisal as the Appraisal Report is dated [Redacted] and the fee was added on [Redacted] which is not within [Redacted] days of Appraisal report. Seller Comment (2022-08-16): On [Redacted], Underwriting required a CDA and the LE was redisclosed at this time. Please see COC LE [Redacted] located on pages 174-177 of the upload package. The CDA was missing from the original upload and the final CD mistakenly showed the Appraisal Review Fee as paid to Appraiser -[Redacted]. Attached is the CDA Report dated [Redacted] (please see last page which matches [Redacted] fee) along with a PCCD and LOE for the clerical error correcting the payee name. |
08/18/2022 | 1 | A | TX | Primary | Refinance - Cash-out - Other | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | B | B | C | A | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820924 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-08-04): Sufficient Cure Provided At Closing |
08/04/2022 | 1 | A | TX | Primary | Refinance - Rate/Term | Final CD evidences Cure | A | A | A | A | A | A | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438820925 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | Borrower was not provided with a COC | Reviewer Comment (2022-08-08): [Redacted] sufficient cure provided at closing. Seller Comment (2022-08-05): Disagree - Cure of [Redacted] for increase in appraisal fee had applied in section J of ICD page 2 |
08/08/2022 | 1 | A | CA | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | A | A | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438820925 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Lender Credit Tolerance Violation | TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of [Redacted] is less than amount of binding Lender Credit previously disclosed in the amount of [Redacted]. | Final CD list the lender credit as [Redacted] | Reviewer Comment (2022-08-09): [Redacted] received valid changed circumstance with additional information Seller Comment (2022-08-05): Disagree - [Redacted] COC CD was issued for lock extension at a cost of [Redacted] to borrower, lender credit was adjusted to reflect |
08/09/2022 | 1 | A | CA | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | A | A | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438820925 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | sufficient cure at closing | Reviewer Comment (2022-08-09): Sufficient Cure Provided At Closing |
08/09/2022 | 1 | A | CA | Primary | Purchase | Final CD evidences Cure | C | A | A | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438820928 | Credit | Title | General | Title | Title Policy Coverage is less than Original Loan Amount. | The Title Policy Amount of ___ is less than the note amount of ___ based on the ___ in file. | The file is missing a copy of the updated title policy that shows the updated policy amount. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | CA | Investment | Refinance - Cash-out - Other | B | B | B | B | A | A | N/A | No | |||||||||||||||||
| 438820926 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Evidence initial appraisal was provided to the borrower on [Redacted] however the signature date of the appraisal on file is [Redacted]. Provide evidence all appraisals were provided to the borrower prior to 3 days of closing | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | FL | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | ||||||||||||||
| 438820926 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-08-05): Sufficient Cure Provided At Closing |
08/05/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | C | B | A | A | C | B | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | Yes | |||||||||||||
| 438820926 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Closing Disclosure Timing without Waiver | TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. | Evidence of earlier receipt was missing from the file | Reviewer Comment (2022-08-08): Received initial CD, cleared Seller Comment (2022-08-08): Please see attached Initial CD issued and signed [Redacted], which was missing from the original upload. |
08/08/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | No Defined Cure | C | B | A | A | C | B | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | ||||||||||||
| 438639377 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | Missing the 2020 W-2 for co-borrower | Reviewer Comment (2022-08-09): Received, Clearing. Seller Comment (2022-08-09): XXXX W-2 [Redacted] is attached |
08/09/2022 | 1 | A | DC | Investment | Refinance - Cash-out - Other | C | A | C | A | C | A | A | A | Safe Harbor QM | Safe Harbor QM | No | |||||||||||||
| 438639377 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General Ability To Repay Provision Employment - W-2 | Ability to Repay (Dodd-Frank 2014): Unable to verify current Wages/W-2 employment status using reasonably reliable third-party records. | Missing Co Borrowers W2 for 2020 | Reviewer Comment (2022-08-09): Received, Clearing. Seller Comment (2022-08-09): W-2 for XXXX is attached |
08/09/2022 | 1 | A | DC | Investment | Refinance - Cash-out - Other | C | A | C | A | C | A | A | A | Safe Harbor QM | Safe Harbor QM | No | |||||||||||||
| 438639377 | Compliance | Compliance | Federal Compliance | ATR/QM | NonQM ATR | Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied. | Missing Co Borrowers W2 for 2020 | Reviewer Comment (2022-08-09): Received, Clearing. |
08/09/2022 | 1 | A | DC | Investment | Refinance - Cash-out - Other | C | A | C | A | C | A | A | A | Safe Harbor QM | Safe Harbor QM | No | |||||||||||||
| 438639377 | Compliance | Compliance | Federal Compliance | Missing Required Data (other than HUD-1 or Note) | Disparity in Occupancy - Not Tested As Primary | The mortgage loan file contains documenting evidence the consumer intends to occupy the subject property as their primary residence. (Compliance testing performed based on the Occupancy Type of Investment). Determination has not been made as to whether the loan would be High Cost and/or HPML if ran as a Primary Residence. | The initial and final 1003 declarations section indicates the co-borrower intends to occupy the property as a primary residence | Reviewer Comment (2022-08-09): Received, Clearing. Seller Comment (2022-08-09): 1003 has the property marked as an Investment Property |
08/09/2022 | 1 | A | DC | Investment | Refinance - Cash-out - Other | C | A | C | A | C | A | A | A | Safe Harbor QM | Safe Harbor QM | No | |||||||||||||
| 438639377 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Hazard coverage of [Redacted] is insufficient to cover the mortgage amount of [Redacted] with an estimated cost new of [Redacted]. Please provide a letter from the Insurer stating the maximum insurable amount and/or a replacement costs estimator from the insurer. | Reviewer Comment (2022-08-09): Received, Clearing. Seller Comment (2022-08-09): RCE is attached |
08/09/2022 | 1 | A | DC | Investment | Refinance - Cash-out - Other | C | A | C | A | C | A | A | A | Safe Harbor QM | Safe Harbor QM | No | ||||||||||||||
| 438639378 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: Investor qualifying total debt ratio discrepancy. | The Investor DTI exceeds the guidelines. Subject property rental of [Redacted] was used to qualify however, the comparable rent schedule on file was blank and there was no lease agreement on file | Reviewer Comment (2022-08-11): Received, Clearing. |
08/11/2022 | 1 | A | KY | Investment | Purchase | C | A | C | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639378 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines | Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of [Redacted] moderately exceeds the guideline maximum of [Redacted]. (DTI Exception is eligible to be regraded with compensating factors.) | Reviewer Comment (2022-08-11): Received, Clearing. |
08/11/2022 | 1 | A | KY | Investment | Purchase | C | A | C | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639378 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM Provision Investor and QM DTIs match and both moderately exceed Guidelines | General QM: The DTI calculated in accordance with the Lenders Guidelines and 1026.43(e) of [Redacted] moderately exceeds the guideline maximum of [Redacted]. (DTI Exception is eligible to be regraded with compensating factors.) | Reviewer Comment (2022-08-11): Received, Clearing. |
08/11/2022 | 1 | A | KY | Investment | Purchase | C | A | C | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639378 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM Provision Investor Guidelines Violation | General QM: Based on the loan failing one or more guideline components, the loan is at QM risk. | Reviewer Comment (2022-08-11): Received, Clearing. |
08/11/2022 | 1 | A | KY | Investment | Purchase | C | A | C | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639378 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General Ability To Repay Provision Investor Guidelines | Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk. | The file is missing proof of income documents for the rental income | Reviewer Comment (2022-08-11): Received, Clearing. Seller Comment (2022-08-11): RENTAL CALCULATIONS |
08/11/2022 | 1 | A | KY | Investment | Purchase | C | A | C | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639378 | Credit | Income / Employment | Income Documentation | Missing Document | REO Documents are missing. | - | The file is missing a copy of the insurance verification for these properties | Reviewer Comment (2022-08-11): Received, Clearing. |
08/11/2022 | 1 | A | KY | Investment | Purchase | C | A | C | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639378 | Credit | Asset | Asset Calculation / Analysis | Asset | Available for Closing is insufficient to cover Cash From Borrower. | Missing[Redacted] Savings account listed on the 1003 and balance of [Redacted] account from 1003 does not match the documentation on file | Reviewer Comment (2022-08-15): Received additional assets to clear Reviewer Comment (2022-08-12): Exception Explanation Updated from: Documented qualifying Assets for Closing of [Redacted] is less than Cash From Borrower [Redacted]. Seller Comment (2022-08-11): ASSETS |
08/15/2022 | 1 | A | KY | Investment | Purchase | C | A | C | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438820929 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of [Redacted] exceeds tolerance of [Redacted] plus [Redacted] or [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Endorsement fee was last disclosed as $165.00 on LE but disclosed as $577.00 on Final Closing Disclosure. File does not contain a valid COC for this fee, nor evidence of cure in file. Provide a post-close CD disclosing the tolerance cure to include $3, a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made. Some other fee like recording fee also were increased on the CD. | Reviewer Comment (2022-08-09): Sufficient Cure Provided At Closing |
08/09/2022 | 1 | A | TX | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | A | A | A | A | A | A | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820931 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Amount of Non-Escrowed Property Costs over Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted] on Final Closing Disclosure provided on [Redacted] not accurate. | The final Closing Disclosure disclosed [Redacted] for Non-Escrowed Property Costs over Year 1 on page 4; however, HOA dues for [Redacted], and POC Insurance for [Redacted] were not verified. Provide a post-close CD correcting the seller-paid fees and a copy of the letter of explanation to the borrower disclosing the changes made. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | B | B | B | B | B | B | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | Yes | |||||||||||||
| 438820931 | Credit | Title | Document Error | Title | The Preliminary title policy is within CA or NV and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | CA | Primary | Purchase | B | B | B | B | B | B | A | A | Higher Priced QM (APOR) | Higher Priced QM (APOR) | No | ||||||||||||||||
| 438820932 | Compliance | Legal / Regulatory / Compliance | Anti-Predatory Violation | Federal Defect | (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (HOEPA Disclosure Not Provided) | Truth in Lending Act (HOEPA): HOEPA disclosure was not provided to the Borrower | Reviewer Comment (2022-08-15): Cleared with evidence of undiscounted interest rate and price |
08/15/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | A | A | A | C | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820932 | Compliance | Legal / Regulatory / Compliance | Anti-Predatory Violation | Federal Defect | (Fed High Cost Provision) Federal High-Cost Mortgage Loan (Financed Points and Fees) | Truth in Lending Act (HOEPA): Mortgage loan financed Points and Fees. | Reviewer Comment (2022-08-15): Cleared with evidence of undiscounted interest rate and price |
08/15/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | A | A | A | C | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820932 | Compliance | Legal / Regulatory / Compliance | Anti-Predatory Violation | Federal Defect | (Fed High Cost Provision) Federal High-Cost Mortgage Loan (Late Charge) | Truth in Lending Act (HOEPA): Mortgage loan contains a late charge that exceeds the greater of [Redacted] of the amount past due or grace period of less than 15 days. | Reviewer Comment (2022-08-15): Cleared with evidence of undiscounted interest rate and price |
08/15/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | A | A | A | C | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820932 | Compliance | Compliance | Federal Compliance | Federal Defect | (Fed High Cost) Federal High-Cost Mortgage Loan (Points and Fees) | Truth in Lending Act (High-Cost Mortgage): Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of [Redacted] of the Federal Total Loan Amount. Points and Fees of[Redacted] on a Federal Total Loan Amount of [Redacted] vs. an allowable total of [Redacted] (an overage of [Redacted] or [Redacted]. Non-Compliant High Cost Loan. | Reviewer Comment (2022-08-15): Cleared with evidence of undiscounted interest rate and price Seller Comment (2022-08-15): The undiscounted rate of [Redacted] permits the exclusion of one bona fide discount point. The test passes with [Redacted] discount excluded. This should also clear the 4 other exceptions which are related to the High Cost finding |
08/15/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | (1) Signed letter from borrower indicating their choice to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (2) Assuming option (a) is selected, a copy of refund check and proof of mailing; (3) Assuming option (b) is selected, proof of cure for each of the prohibited practices violations noted. | C | A | A | A | C | A | A | A | Non QM | Non QM | Yes | |||||||||||||
| 438820932 | Compliance | Legal / Regulatory / Compliance | Anti-Predatory Violation | Federal Defect | (Fed High Cost Provision) Federal High-Cost Mortgage Loan (Counseling Requirement) | Truth in Lending Act (HOEPA): Borrower did not receive pre-loan counseling. | Reviewer Comment (2022-08-15): Cleared with evidence of undiscounted interest rate and price |
08/15/2022 | 1 | A | CA | Primary | Refinance - Cash-out - Other | C | A | A | A | C | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820936 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Loan failing due to high points and fees. | Reviewer Comment (2022-08-22): Received, Clearing. Seller Comment (2022-08-22): Disagree - Based on the rate stack attached, the loan passes the QM points & fees threshold with the benefit of excluding one bona fide discount point. |
08/22/2022 | 1 | A | CT | Primary | Purchase | Lender to provide updated ATR/QM status | C | A | A | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438820936 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of[Redacted] of the Federal Total Loan Amount. Points and Fees total [Redacted] on a Federal Total Loan Amount of[Redacted] vs. an allowable total o[Redacted] (an overage of $[Redacted] or [Redacted]). | Verified Points and Fees on subject loan of[Redacted] is in excess of the allowable maximum of [Redacted] of the Federal Total Loan Amount. Points and Fees total [Redacted] on a Federal Total Loan Amount of [Redacted] vs. an allowable total of $[Redacted] (an overage of [Redacted] or .[Redacted]. | Reviewer Comment (2022-08-22): Received, Clearing. Seller Comment (2022-08-22): Disagree - Based on the rate stack attached, the loan passes the QM points & fees threshold with the benefit of excluding one bona fide discount point. |
08/22/2022 | 1 | A | CT | Primary | Purchase | C | A | A | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438820937 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Loan designation failure due to QM failure. This exception will be cleared once all QM specific exceptions have been cured/cleared. | Reviewer Comment (2022-08-24): Proof of Bonafide points received Buyer Comment (2022-08-24): Undiscounted rate is [Redacted], not [Redacted] per the previously attached rate stack. Note rate is [Redacted] Reviewer Comment (2022-08-22): Based on [Redacted] undiscounted rate and price of [Redacted] it doesn't meet QM Points and Fees. Exception remains. Seller Comment (2022-08-22): Based on the rate stack, the loan passes the QM points & fees threshold with the benefit of excluding one bona fide discount point. |
08/24/2022 | 1 | A | WA | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM status | C | A | A | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438820937 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of[Redacted] is in excess of the allowable maximum of [Redacted] of the Federal Total Loan Amount. Points and Fees total [Redacted] on a Federal Total Loan Amount of [Redacted] vs. an allowable total of [Redacted] (an overage of [Redacted] or [Redacted]). | Reviewer Comment (2022-08-24): Proof of Bonafide points received Buyer Comment (2022-08-24): Undiscounted rate is [Redacted], not [Redacted] per the previously attached rate stack. Note rate is [Redacted] Reviewer Comment (2022-08-22): Based on [Redacted] undiscounted rate and price of [Redacted] it doesn't meet QM Points and Fees. Exception remains. Seller Comment (2022-08-22): Based on the rate stack, the loan passes the QM points & fees threshold with the benefit of excluding one bona fide discount point. |
08/24/2022 | 1 | A | WA | Primary | Refinance - Cash-out - Other | C | A | A | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438820940 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Loan designation failure due to ATR failure. This exception will be cleared once all ATR specific exceptions have been cured/cleared. | Reviewer Comment (2022-08-24): Proof of bonafide points provided Buyer Comment (2022-08-24): per previous attachment, undiscounted rate is [Redacted], not [Redacted] Reviewer Comment (2022-08-23): Based on an Undiscounted Rate of [Redacted] and Undiscounted Price of [Redacted] the loans doesn't meet QM points and fees. Seller Comment (2022-08-23): Disagree - Based on the rate stack attached, the loan passes QM points & fees [Redacted] threshold with the benefit of excluding [Redacted] bona fide discount point |
08/24/2022 | 1 | A | AZ | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM status | C | A | A | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438820940 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of [Redacted] of the Federal Total Loan Amount. Points and Fees total [Redacted] on a Federal Total Loan Amount of [Redacted] vs. an allowable total of [Redacted] (an overage of $[Redacted] or [Redacted]). | Likely due to bonafide discount points. Please send the undiscounted rate and price. | Reviewer Comment (2022-08-24): Proof of bonafide points provided Buyer Comment (2022-08-24): per previous attachment, undiscounted rate is [Redacted], not [Redacted] Reviewer Comment (2022-08-23): Based on an Undiscounted Rate of [Redacted] and Undiscounted Price of [Redacted] the loans doesn't meet QM points and fees. Seller Comment (2022-08-23): Disagree - Based on the rate stack attached, the loan passes QM points & fees [Redacted] threshold with the benefit of excluding [Redacted] bona fide discount point |
08/24/2022 | 1 | A | AZ | Primary | Refinance - Cash-out - Other | C | A | A | A | C | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||
| 438639439 | Compliance | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Missing Lender's Initial 1003 | Reviewer Comment (2022-08-19): Received, Clearing. Seller Comment (2022-08-19): Please see attached for the initial 1003. |
08/19/2022 | 1 | A | NY | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639439 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Appraisal receipt document in file reflects the date of [Redacted], however the appraisal signature date is [Redacted]. Provide evidence the borrower received all copies of the appraisal | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639439 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.06% + 1.5%, or 6.56000%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-08-22): Received, Clearing. |
08/22/2022 | 1 | A | NY | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639439 | Compliance | Compliance | Federal Compliance | Missing Non-Required Data | (Missing Data) Last Rate Set Date | Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639439 | Compliance | Compliance | Federal Compliance | Missing Application Date | Missing Initial Loan Application Test | No evidence of application date located in file. Compliance tests were run using an application date of [Redacted] which is 1 months prior to consummation. A lookback was performed to determine this application date. | Reviewer Comment (2022-08-19): Received, Clearing. |
08/19/2022 | 1 | A | NY | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639439 | Compliance | Compliance | Federal Compliance | TILA | NMLS - Missing Evidence of Initial Loan Application Date | Truth in Lending Act (NMLSR Dodd- Frank 2014): Unable to determine compliance with NMLSR timing requirements due to missing evidence of initial loan application date. | Reviewer Comment (2022-08-19): Received, Clearing. |
08/19/2022 | 1 | A | NY | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639439 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639439 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639439 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639439 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639439 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate 5.54000 + 1.75%, or 7.29000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is Reviewer Comment (2022-08-22): Exception Detail Updated from: [Redacted]: APR on subject loan of [Redacted]or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted], or [Redacted]. Non-Compliant SubPrime Loan. Reviewer Comment (2022-08-19): Exception Detail Updated from: [Redacted] Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted], or [Redacted]. Non-Compliant SubPrime Loan. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639439 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639439 | Compliance | Compliance | Federal Compliance | TRID | TRID Appraisal Disclosure - ECOA Timing | ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date. | Unable to determine missing supporting documentation for application date | Reviewer Comment (2022-08-22): Received, Clearing. Seller Comment (2022-08-19): Please see attached for the Notice of Right to Copy of Appraisal. |
08/22/2022 | 1 | A | NY | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639439 | Compliance | Compliance | Federal Compliance | TRID | TRID Appraisal Disclosure - HPML Timing | HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date. | Unable to determine missing supporting documentation for application date | Reviewer Comment (2022-08-22): Received, Clearing. Seller Comment (2022-08-19): Please see attached. |
08/22/2022 | 1 | A | NY | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639439 | Compliance | Compliance | Federal Compliance | TRID Defect | TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File | TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s). The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing. Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to [Redacted] may be required. | Loan Estimate missing from file | Reviewer Comment (2022-08-22): Received, Clearing. Seller Comment (2022-08-19): Please see attached for all loan estimates to this file. |
08/22/2022 | 1 | A | NY | Primary | Purchase | No Defined Cure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639439 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Service Charges. Fee Amount of [Redacted] exceeds tolerance of $0.00. Insufficient or no cure was provided to the borrower. | No COC or Cure was provided to Borrower for tolerance overages | Reviewer Comment (2022-08-22): [Redacted] received SSPL and Loan Estimates. Seller Comment (2022-08-19): Please see attached SSPL. The service provider for the title fees was not the one listed on the SSPL and therefore, not subject to a tolerance limit. No cure required. |
08/22/2022 | 1 | A | NY | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639438 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NJ | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639437 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | Missing business narrative that includes a description of the business, the outlook for the future of the business, information about the products or services, an outline of how the business and management team is organized and the number of full-time employees and/or contractors. | Reviewer Comment (2022-08-29): Received, Clearing. Seller Comment (2022-08-29): Please see attached business narrative. |
08/29/2022 | 1 | A | NH | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639437 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | Copy of business license from the state regulatory agency or state licensing bureau is missing from file | Reviewer Comment (2022-08-30): Received, Clearing. Seller Comment (2022-08-30): Business license. |
08/30/2022 | 1 | A | NH | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639437 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | Reviewer Comment (2022-08-30): Received, Clearing. Seller Comment (2022-08-30): Third party verification. |
08/30/2022 | 1 | A | NH | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639437 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-08-26): Received, Clearing. |
08/26/2022 | 1 | A | NH | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639437 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.37% + 1.5%, or 6.87000%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-08-26): Received, Clearing. |
08/26/2022 | 1 | A | NH | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639437 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-08-26): Received, Clearing. Seller Comment (2022-08-26): Please see attached for the appraisal delivery letter. |
08/26/2022 | 1 | A | NH | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639437 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | NH | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438820943 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM (APOR) does not match Due Diligence Loan Designation of Non QM. | QM Failure due to the loan being HPML. | Reviewer Comment (2022-08-31): Restated. Buyer Comment (2022-08-31): please restate as NQM |
08/31/2022 | 1 | A | FL | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | A | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | Yes | ||||||||||||
| 438820943 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM (APOR) Threshold Fail | Qualified Mortgage: QM APR on subject loan of [Redacted] is equal to or greater than the threshold of [Redacted] | APR exceeds threshold for a designation of Higher Priced QM (APOR) loan | Reviewer Comment (2022-08-31): Restated. Buyer Comment (2022-08-31): Please restate to NQM |
08/31/2022 | 1 | A | FL | Primary | Purchase | C | B | A | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | No | |||||||||||||
| 438820943 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - General Ability to Repay | Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not match. However, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. | Restated. | Reviewer Comment (2022-08-31): Accepted as is. |
2 | B | FL | Primary | Purchase | C | B | A | A | C | B | A | A | Higher Priced QM (APOR) | Non QM | No | ||||||||||||||
| 438820942 | Credit | Hazard Insurance | Insufficient Coverage | Hazard Insurance | The Hazard Insurance Policy Effective Date is after closing. | The homeowner's insurance declarations page in the file verified an effective date of[Redacted] which is after the transaction date of[Redacted]. Provide a revised homeowner's insurance declaration page or policy verifying coverage in effect at or prior to transaction. | Reviewer Comment (2022-08-22): Previous policy received Seller Comment (2022-08-22): Uploaded prior HOI showing coverage from[Redacted] - [Redacted] |
08/22/2022 | 1 | A | TX | Primary | Refinance - Cash-out - Other | C | A | C | A | C | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820942 | Credit | Loan Package Documentation | Application / Processing | Insurance | Missing Document: Flood Certificate not provided | Flood Certificate is missing | Reviewer Comment (2022-08-22): Received, Clearing. Seller Comment (2022-08-22): Uploaded flood certificate |
08/22/2022 | 1 | A | TX | Primary | Refinance - Cash-out - Other | C | A | C | A | C | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820942 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Credit | AUS Findings: Property type discrepancy. | The security agreement reflects the PUD rider however, the appraisal shows Single Family . No evidence of HOA dues in file. | Reviewer Comment (2022-08-23): Received, Clearing. Seller Comment (2022-08-23): The AUS is correct, this is a PUD Property, We have attached the PUD Rider, Mortgage, DU and Title Report. There are no HOA fees on this. Reviewer Comment (2022-08-22): Updated AUS received Seller Comment (2022-08-22): Updated AUS, removed PUD, there is no HOA on this property. |
08/23/2022 | 1 | A | TX | Primary | Refinance - Cash-out - Other | C | A | C | A | C | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820942 | Compliance | Compliance | State Compliance | State Defect | (TX50(a)(6)) Texas Cash-out Loan (Points and Fees Exceeds 2% of Original Principal Balance) | Texas Constitution Section 50(a)(6): Points and fees on subject loan of [Redacted] is in excess of the allowable maximum of 2.0000% of the Original Principal Loan Amount. Points and Fees total [Redacted] on an Original Principal Loan Amount of [Redacted] vs. an allowable total of [Redacted] (an overage of [Redacted]or [Redacted].) | Provide evidence of undiscounted rate price in order to determine if any portion of discount points are bona fide | Reviewer Comment (2022-08-31): Received, Clearing. Buyer Comment (2022-08-31): undiscounted rate [Redacted] |
08/31/2022 | 1 | A | TX | Primary | Refinance - Cash-out - Other | Refund the borrower, or credit their account, an amount equal to any overcharge paid by the borrower. (Provide Proof of Delivery, LOE, and Copy of Check. [A servicing screen print can be provided in place of a check when a credit is applied to the borrowers account.]) | C | A | C | A | C | A | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820942 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Hazard coverage of [Redacted] + [Redacted] is sufficient to cover the mortgage amount of [Redacted], however is insufficient to cover the estimated cost new of [Redacted]. Please provide a letter from the Insurer stating the maximum insurable amount and/or a replacement costs estimator from the insurer. | Reviewer Comment (2022-08-22): Received RCE Seller Comment (2022-08-22): RCE attached at [Redacted] within coverage amount. |
08/22/2022 | 1 | A | TX | Primary | Refinance - Cash-out - Other | C | A | C | A | C | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820958 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | CO | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | |||||||||||||||
| 438820958 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted] is in excess of the allowable maximum of [Redacted] of the Federal Total Loan Amount. Points and Fees total [Redacted] on a Federal Total Loan Amount of[Redacted] vs. an allowable total of[Redacted] (an overage of [Redacted] or [Redacted]). | Reviewer Comment (2022-09-01): Received, Clearing. Seller Comment (2022-09-01): Disagree - [Redacted] of the total discount points of [Redacted]was eligible for bona fide; thus, [Redacted] was excluded from points and fees calculation. Therefore, the total points and fees of [Redacted] was less than an allowable [Redacted] or [Redacted]. |
09/01/2022 | 1 | A | CO | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438820958 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Reviewer Comment (2022-09-01): Received, Clearing. Seller Comment (2022-09-01): Disagree - [Redacted]of the total discount points of [Redacted] was eligible for bona fide; thus, [Redacted] was excluded from points and fees calculation. Therefore, the total points and fees of [Redacted] was less than an allowable [Redacted] or[Redacted]. |
09/01/2022 | 1 | A | CO | Primary | Refinance - Cash-out - Other | Lender to provide updated ATR/QM status | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438820958 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Closing Disclosure Timing without Waiver | TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. | Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[Redacted]) | Reviewer Comment (2022-09-02): [Redacted] received signed Initial CD dated [Redacted]. Seller Comment (2022-09-01): Disagree -[Redacted] was issued; and borrower received and signed on [Redacted] for closing on [Redacted] which was more than [Redacted] business days prior to closing |
09/02/2022 | 1 | A | CO | Primary | Refinance - Cash-out - Other | No Defined Cure | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||
| 438820958 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points. Fee Amount of [Redacted] exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | No valid change in circumstance for this fee change | Reviewer Comment (2022-09-02): [Redacted] received LE & COC dated [Redacted]. Seller Comment (2022-09-01): Disagree - [Redacted] COC LE was issued for rate locked with [Redacted] discount points charged to reflect market rate |
09/02/2022 | 1 | A | CO | Primary | Refinance - Cash-out - Other | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | ||||||||||||
| 438820941 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Appraisal receipt is dated [Redacted] however the appraisal signature date is [Redacted] | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | FL | Second Home | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | No | ||||||||||||||
| 438639441 | Credit | Guideline | Guideline Issue | Guideline | Employment was not verified within 10 days of the note date. | - | Reviewer Comment (2022-09-08): Clearing |
09/08/2022 | 1 | A | CA | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639441 | Credit | Income / Employment | Income Documentation | Income / Employment | Verification(s) of employment is not within 10 business days of the Note. | - | Reviewer Comment (2022-09-08): Clearing. Seller Comment (2022-09-08): Comment from [Redacted] ([Redacted]): Please see attached XXXX guidelines for retail Investor-Foreign National program. Per guidelines, employment letter will expire[Redacted] days from date of issuance on letter. The attached employment letter dated on [Redacted] is still valid on closing date [Redacted]. |
09/08/2022 | 1 | A | CA | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639442 | Credit | Credit | Credit Documentation | Missing Document | Missing Document: Credit Report not provided | Reviewer Comment (2022-09-01): Foreign National Program. |
09/01/2022 | 1 | A | CA | Investment | Purchase | D | B | D | A | B | B | A | A | Exempt from ATR | N/A | No | |||||||||||||||
| 438639442 | Compliance | Compliance | Federal Compliance | FACTA | Federal FACTA Disclosure Timing Test | FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score. | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | CA | Investment | Purchase | D | B | D | A | B | B | A | A | Exempt from ATR | N/A | No | |||||||||||||||
| 438639442 | Compliance | Compliance | Federal Compliance | ATR/QM | Investment Property submitted as Non-QM / Exempt from ATR | Ability to Repay (Dodd-Frank 2014): Improper Originator Loan Designation. Investment property not subject to Ability to Repay requirements. | The loan was Investor [Redacted] approved and meets all requirements. However fails the Non QM documentation requirements | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | CA | Investment | Purchase | D | B | D | A | B | B | A | A | Exempt from ATR | N/A | No | ||||||||||||||
| 438639443 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | The file is missing a copy of the source of funds/deposit for the earnest money. | Reviewer Comment (2022-09-08): Received, cleared Seller Comment (2022-09-08): Comment from [Redacted] ([Redacted]): Attached wire confirmations are sourcing the EMD ([Redacted] + [Redacted] + [Redacted]). |
09/08/2022 | 1 | A | NC | Investment | Purchase | C | B | C | A | B | B | A | A | N/A | N/A | No | ||||||||||||||
| 438639443 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | The file is missing a copy of the source of funds/deposit for the earnest money. | Reviewer Comment (2022-09-08): Received, cleared Seller Comment (2022-09-08): Comment from[Redacted] ([Redacted]): Attached wire confirmations are sourcing the EMD ([Redacted]+ [Redacted] + [Redacted]). |
09/08/2022 | 1 | A | NC | Investment | Purchase | C | B | C | A | B | B | A | A | N/A | N/A | No | ||||||||||||||
| 438639443 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | The file is missing a copy of the source of funds/deposit for the earnest money. | Reviewer Comment (2022-09-08): Received, cleared Seller Comment (2022-09-08): Comment from [Redacted] ([Redacted]): Attached wire confirmations are sourcing the EMD ([Redacted] + [Redacted] + [Redacted]). |
09/08/2022 | 1 | A | NC | Investment | Purchase | C | B | C | A | B | B | A | A | N/A | N/A | No | ||||||||||||||
| 438639443 | Compliance | Compliance | State Compliance | State Late Charge | North Carolina First Lien Late Charge Percent Testing | North Carolina Late Charge: Note late charge percent of [Redacted] exceeds the state maximum of 4%. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NC | Investment | Purchase | C | B | C | A | B | B | A | A | N/A | N/A | Yes | |||||||||||||||
| 438639445 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Reviewer Comment (2022-09-06): Received, Clearing. Seller Comment (2022-09-02): Comment from [Redacted] ([Redacted]): Per settlement statement ([Redacted]), required [Redacted]plus [Redacted] months PITIA [Redacted], total required [Redacted]. We've verified the transaction activity of [Redacted] # [Redacted] as of [Redacted] at [Redacted], which is sufficient to cover this transaction. Attached updated [Redacted] and [Redacted] #[Redacted] reflecting[Redacted]. And total [Redacted] ([Redacted] + [Redacted] + [Redacted]) deposit is under [Redacted], so it doesn't need to source as per attached Q&A & Guidelines. |
09/06/2022 | 1 | A | TX | Investment | Purchase | C | B | C | A | B | B | A | A | N/A | N/A | No | |||||||||||||||
| 438639445 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Borrower acknowledged the receipt of the appraisal on [Redacted] however the appraisal on file is signed [Redacted]. Provide evidence the borrower signed all copies of the appraisal. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | TX | Investment | Purchase | C | B | C | A | B | B | A | A | N/A | N/A | No | ||||||||||||||
| 438639445 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Hazard coverage of [Redacted]is sufficient to cover the mortgage amount of [Redacted], however is insufficient to cover the estimated cost new of [Redacted]. Please provide a letter from the Insurer stating the maximum insurable amount and/or a replacement costs estimator from the insurer. | Reviewer Comment (2022-09-02): Received, Clearing. Seller Comment (2022-09-02): Comment from [Redacted] ([Redacted]): Dwelling [Redacted] plus other structures [Redacted], total coverage of [Redacted] is sufficient to cover the replacement cost [Redacted] per attached RCE. |
09/02/2022 | 1 | A | TX | Investment | Purchase | C | B | C | A | B | B | A | A | N/A | N/A | No | ||||||||||||||
| 438639446 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Profit & Loss Statement must include attestation confirming no material COVID-19 impact on ability to make mortgage payments. This is missing from the statement on file | Reviewer Comment (2022-08-29): Received, Clearing. Seller Comment (2022-08-29): Please see attached CDL guideline for Investor-Lite Doc program as of [Redacted]. "confirming no material COVID-[Redacted] impact on ability to make mortgage payments" is no longer required. Application date for this loan is [Redacted], but disbursement date is [Redacted], so this loan must follow the guideline as of [Redacted] before closing. Reviewer Comment (2022-08-26): App date was [Redacted] which predates those guides. Seller Comment (2022-08-26): Per attached updated CDL guideline as of [Redacted], it's no longer required "confirming no material COVID-[Redacted] impact on ability to make mortgage payments" for P&L. |
08/29/2022 | 1 | A | TX | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639447 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Hazard coverage of $[Redacted] is insufficient to cover the mortgage amount and the appraiser did not provide an estimated cost to rebuild. Please provide a letter from the Insurer stating the maximum insurable amount and/or a replacement costs estimator from the insurer. | Reviewer Comment (2022-08-26): Received, Clearing. Seller Comment (2022-08-26): Please see attached for the RCE. |
08/26/2022 | 1 | A | TX | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639448 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Hazard coverage of $[Redacted] is insufficient to cover the mortgage amount and the appraiser did not provide an estimated cost to rebuild. Please provide a letter from the Insurer stating the maximum insurable amount and/or a replacement costs estimator from the insurer. | Reviewer Comment (2022-09-02): Received, Clearing. Seller Comment (2022-09-02): Comment from [Redacted] ([Redacted]): Dwelling [Redacted] plus other structures [Redacted], total coverage of [Redacted] is sufficient to cover the replacement cost of [Redacted] per attached RCE. |
09/02/2022 | 1 | A | TX | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639449 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | insufficient assets due to short fund due to paying the appraisal fee outside of closing | Reviewer Comment (2022-08-25): Received, Clearing. Seller Comment (2022-08-25): Please see attached [Redacted][Redacted] and [Redacted] [Redacted] bank statement and appraisal invoice confirming the appraisal fee was paid by account [Redacted], which is paid from a different account than asset bank account ([Redacted] [Redacted] and [Redacted][Redacted]). Per final CD, cash to close required [Redacted] plus[Redacted] months PITIA [Redacted], total required [Redacted]. We've verified assets from the transaction activities of [Redacted] [Redacted] at [Redacted] and [Redacted] [Redacted]at [Redacted], total asset is[Redacted], which is sufficient for this transaction. |
08/25/2022 | 1 | A | CA | Investment | Refinance - Rate/Term | C | A | C | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639450 | Compliance | Compliance | State Compliance | State Defect | Pennsylvania Prepayment Penalty First Lien | Pennsylvania Prepayment Penalty: A prepayment penalty not permissible on a first lien loan less than or equal to $278,204.00. | Reviewer Comment (2022-09-28): Accepted after regrade Reviewer Comment (2022-09-22): Regrade due to bank preemption. |
2 | B | PA | Investment | Purchase | C | B | A | A | C | B | A | A | N/A | N/A | No | |||||||||||||||
| 438639454 | Credit | Income / Employment | Income Documentation | Income / Employment | Verification(s) of employment is not within 10 business days of the Note. | - | Reviewer Comment (2022-08-26): Received, Clearing. Seller Comment (2022-08-26): Please see attached VOW within [Redacted] business days of note date. |
08/26/2022 | 1 | A | NY | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639455 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Investment | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | N/A | N/A | No | |||||||||||||||
| 438639456 | Compliance | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Missing Lender's Initial 1003 | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MA | Investment | Purchase | B | B | A | A | B | B | A | A | N/A | N/A | No | ||||||||||||||||
| 438639456 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Not Provided Timely | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Receive a Copy" appraisal disclosure to applicant within three (3) business days of application or determination of first lien status. | Unable to determine due to missing initial 1003 | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MA | Investment | Purchase | B | B | A | A | B | B | A | A | N/A | N/A | No | ||||||||||||||
| 438639457 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Hazard policy does not have enough coverage or extended replacement cost listed | Reviewer Comment (2022-09-07): Received, Clearing. Seller Comment (2022-09-07): Comment from [Redacted] ([Redacted]): [Redacted] coverage is sufficient to cover the replacement cost of [Redacted] per attached RCE. |
09/07/2022 | 1 | A | WA | Investment | Purchase | C | A | C | A | A | A | A | A | N/A | N/A | No | ||||||||||||||
| 438639458 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | The file is missing proof of the source of funds for the earnest money. | Reviewer Comment (2022-08-30): Received, Clearing. Seller Comment (2022-08-30): Per XXXX guideline, cancelled down payment check is evidencing the source of EMD. |
08/30/2022 | 1 | A | WA | Investment | Purchase | C | B | C | A | B | B | A | A | N/A | N/A | No | ||||||||||||||
| 438639458 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Not Provided Timely | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Receive a Copy" appraisal disclosure to applicant within three (3) business days of application or determination of first lien status. | Data is correct as the letter in file was signed and dated [Redacted] | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | WA | Investment | Purchase | C | B | C | A | B | B | A | A | N/A | N/A | No | ||||||||||||||
| 438639462 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided at Application but within Three Days) | New York Subprime Loan: Counseling Disclosure not provided to borrower at the time of application, but within three days of application. | Counseling Disclosure not provided to borrower at the time of application, but within three days of application. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639462 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate 4.16000 + 1.75%, or 5.91000%. Compliant SubPrime Loan. | APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate 4.16000 + 1.75%, or 5.91000%. Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639464 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | The lender on the appraisal does not match the lender on the note | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Rate/Term | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639464 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Property Inspection Fee. Fee Amount of $[Redacted] exceeds tolerance of $0.00. Insufficient or no cure was provided to the borrower. | Fee was not disclosed on LE it was disclosed on Closing Disclosure as[Redacted]. File does not contain a valid Change of Circumstance for the fee, nor evidence of cure in file. Provide a post-close CD disclosing the tolerance cure to include $[Redacted] a copy of refund check, proof of delivery, and a copy of the letter of explanation sent it the Borrower disclosing the changes made. | Reviewer Comment (2022-09-15): [Redacted] received PCCD, LOE, proof of mailing & copy of refund check. Seller Comment (2022-09-14): Comment from [Redacted]([Redacted]): Please see attached for the PCCD, LOE, Proof of Delivery and Proof of Refund. Reviewer Comment (2022-09-13): [Redacted] received reference document, which is dated on [Redacted] and provided Appraisal document signed and reported on [Redacted]. However, the Property Condition Inspection fee further disclosed on CD dated [Redacted] and the fee should not have been disclosed within[Redacted] days of receipt of the appraisal. Also, provided corresponding COC dated [Redacted] does not reflects valid reason for the fee added. Please provide valid COC with supporting documents when lender become aware of the Property Condition Inspection is required or Cure is required to borrower. Seller Comment (2022-09-12): Comment from [Redacted] ([Redacted]): The PCI was added as a result of the appraisal transfer. Please see attached for reference. No cure required. |
09/15/2022 | 2 | B | NY | Primary | Refinance - Rate/Term | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639465 | Compliance | Compliance | State Compliance | State HPML | Massachusetts HPML Threshold Test Compliant | Massachusetts Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.31% + 1.5%, or 6.81000% Compliant Higher Priced Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MA | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639466 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Reviewer Comment (2022-08-31): Appraisal transfer letter provided |
08/31/2022 | 1 | A | CA | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639466 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Amount of Non-Escrowed Property Costs over Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted] on Final Closing Disclosure provided on [Redacted] not accurate. | HOA dues per the appraisal are [Redacted]however were $[Redacted] on the CD. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639468 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: Borrower's ability to repay not verified with reliable documentation. | New York Subprime Loan: Counseling Disclosure not provided to borrower | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639468 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | New York Subprime Loan: Counseling Disclosure not provided to borrower | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639468 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of[Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate 5.10000 + 1.75%, or 6.85000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639469 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | The file is missing a copy of source of funds for the earnest money. | Reviewer Comment (2022-09-08): Received, Clearing. Seller Comment (2022-09-08): Comment from [Redacted]([Redacted]): Attached EMD cancelled checks ([Redacted] +[Redacted]) are the sourcing the funds. |
09/08/2022 | 1 | A | TN | Primary | Purchase | C | A | C | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639469 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | Reviewer Comment (2022-09-08): Received, Clearing. Seller Comment (2022-09-08): Comment from [Redacted] ([Redacted]): Attached EMD cancelled checks ([Redacted] + [Redacted]) are sourcing the funds. |
09/08/2022 | 1 | A | TN | Primary | Purchase | C | A | C | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639469 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | The file does not have proof that the customer received a copy of the appraisal within 3 days | Reviewer Comment (2022-09-07): Received evidence of appraisal delivery Seller Comment (2022-09-07): Comment from [Redacted] ([Redacted]): Please see attached for the appraisal delivery letter. |
09/07/2022 | 1 | A | TN | Primary | Purchase | C | A | C | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639469 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.31% + 1.5%, or 6.81000%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-09-07): Received evidence of appraisal delivery |
09/07/2022 | 1 | A | TN | Primary | Purchase | C | A | C | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639469 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | The file does not have proof that the customer received a copy of the appraisal within 3 days | Reviewer Comment (2022-09-07): Received evidence of appraisal delivery |
09/07/2022 | 1 | A | TN | Primary | Purchase | C | A | C | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639471 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | File is missing a copy of New York subprime doc. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639471 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | File is missing a copy of New York subprime doc. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639471 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate 5.27000 + 1.75%, or 7.02000%. Non-Compliant SubPrime Loan. | File is missing a copy of New York subprime doc. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639471 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | File is missing a copy of New York subprime doc. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639472 | Compliance | Compliance | Federal Compliance | Missing Non-Required Data | (Missing Data) Last Rate Set Date | Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | TX | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639473 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639473 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639473 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate 5.09000 + 1.75%, or 6.84000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639473 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639474 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | P&L is not signed and dated by the CPA | Reviewer Comment (2022-08-29): Received, Clearing. Seller Comment (2022-08-29): Re-uploaded P&L with signed and dated. Reviewer Comment (2022-08-26): Document coming through doesn't have signature or date on it. Seller Comment (2022-08-26): Please see attached P&L with signed and dated by CPA. |
08/29/2022 | 1 | A | NJ | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639474 | Credit | Asset | Asset Calculation / Analysis | Asset | Available for Closing is insufficient to cover Cash From Borrower. | Lender used [Redacted]% of stocks however evidence of liquidation is missing from the file. | Reviewer Comment (2022-08-25): Received, Clearing. Seller Comment (2022-08-25): Per final CD, cash to close required [Redacted] plus [Redacted] months PITIA [Redacted], total required [Redacted]. We've verified assets from the transaction activities of Citi[Redacted] at[Redacted] and [Redacted] [Redacted][Redacted] at [Redacted], total asset [Redacted], which is sufficient for this transaction. Please see attached asset statements, EMD, EMD escrow receipt & appraisal paid receipt. |
08/25/2022 | 1 | A | NJ | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639476 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Reviewer Comment (2022-08-25): Received, Clearing. Seller Comment (2022-08-25): Per final CD, cash to close required [Redacted] plus [Redacted] months PITIA [Redacted], total required [Redacted]. We've verified assets from the transaction activity of [Redacted] [Redacted] at [Redacted], which is sufficient for this transaction. Please see attached [Redacted] [Redacted] statement. |
08/25/2022 | 1 | A | NJ | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639477 | Property | Property - Appraisal | Appraisal Documentation | Property - Appraisal | Loan is to be securitized. Secondary valuation is missing.; Sec ID: 2 | The file is missing a copy of the secondary valuation required for securitization purposes. | Reviewer Comment (2022-08-31): Received, Clearing. Seller Comment (2022-08-31): uploaded CDA report of [Redacted] is within [Redacted] variance and supports the appraisal/qualifying value [Redacted] |
08/31/2022 | 1 | A | VT | Primary | Purchase | D | B | C | A | B | B | D | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639477 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Appraisal receipt date per acknowledgement is [Redacted] however the signature date of the appraisal is [Redacted] | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | VT | Primary | Purchase | D | B | C | A | B | B | D | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639477 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Reviewer Comment (2022-09-01): Received, Clearing. Seller Comment (2022-09-01): Per final CD, cash to close required [Redacted] plus [Redacted] months PITIA reserves requirement of [Redacted], total required [Redacted] to close. We've verified asset from the transaction activity of [Redacted] [Redacted] at [Redacted], which is sufficient for this transaction. Attached [Redacted] cancelled check for EMD. |
09/01/2022 | 1 | A | VT | Primary | Purchase | D | B | C | A | B | B | D | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639477 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | Unable to determine if the borrower signed a valuation receipt acknowledgment due to missing information. | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | VT | Primary | Purchase | D | B | C | A | B | B | D | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639478 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639478 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639478 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.23000 + 1.75%, or 6.98000%. Non-Compliant SubPrime Loan. | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.23000 + 1.75%, or 6.98000%. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639479 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Verification appraisal was delivered to borrower was not provided | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | FL | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639479 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Amount of Non-Escrowed Property Costs over Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted] on Final Closing Disclosure provided on [Redacted] not accurate. | The final CD disclosed the Amount of Non-Escrowed Property Costs over Year 1 as [Redacted] on page 4; however HOA Monthly Amount is ($[Redacted]) Annually is $[Redacted]. Provide a post-close CD correcting the Escrow Account section | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | FL | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639480 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-09): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639480 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-09): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639480 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.23000 + 1.75%, or 6.98000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-09): Accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639480 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Loan Estimate Timing Electronically Provided | TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application. | Missing the LE dated XXXX | Reviewer Comment (2022-09-12): [Redacted] received Initial LE dated [Redacted] was not electronically signed by the borrower for which is within that time frame. No further action is required. Seller Comment (2022-09-09): Comment from [Redacted] ([Redacted]): Please see attached for the initial LE. |
09/12/2022 | 1 | A | NY | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639480 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Documentation was not provided in a timely matter. | Reviewer Comment (2022-09-09): Received, Clearing. |
09/09/2022 | 1 | A | NY | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639480 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.31% + 1.5%, or 6.81000%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-09-09): Received, Clearing. |
09/09/2022 | 1 | A | NY | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639480 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Documentation was not provided in a timely matter. | Reviewer Comment (2022-09-09): Received, Clearing. Seller Comment (2022-09-09): Comment from [Redacted] ([Redacted]): Please see attached for the appraisal delivery letter. |
09/09/2022 | 1 | A | NY | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639482 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Missing Final 1003 | Reviewer Comment (2022-08-25): Received, Clearing. Seller Comment (2022-08-25): Please see attached for the final[Redacted]. Document was in file provided. |
08/25/2022 | 1 | A | NJ | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639484 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Appraisal receipt date is [Redacted] however the appraisal signature date is [Redacted]. Provide evidence all copies of appraisal was received by Borrower | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | OH | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639484 | Compliance | Compliance | State Compliance | Misc. State Level | Ohio Consumer Sales Practices Act (Acknowledgement of Receipt of Home Mortgage Loan Information Document Not Retained by Lender) | Ohio Consumer Sales Practices Act: Acknowledgement of Receipt of Home Mortgage Loan Information Document not retained by lender. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | OH | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639484 | Compliance | Compliance | State Compliance | Misc. State Level | Ohio Consumer Sales Practices Act (Demand Feature) | Ohio Consumer Sales Practices Act: Mortgage loan contains an impermissible demand feature. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | OH | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639486 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Verification appraisal was delivered to borrower was not provided. | Reviewer Comment (2022-08-25): Received, Clearing. |
08/25/2022 | 1 | A | WI | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639486 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of[Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR 5.31% + 1.5%, or 6.81000%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-08-25): Received, Clearing. |
08/25/2022 | 1 | A | WI | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639486 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Verification appraisal was delivered to borrower was not provided. | Reviewer Comment (2022-08-25): Received, Clearing. Seller Comment (2022-08-25): Please see attached for the appraisal delivery letter. |
08/25/2022 | 1 | A | WI | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639487 | Property | Property - Appraisal | Appraisal Data Integrity | Property - Appraisal | Appraiser's license or certification was not active at the time of the appraisal. | - | 09/06/2022 | 1 | A | RI | Primary | Refinance - Cash-out - Other | C | A | A | A | C | A | C | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639487 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.86% + 1.5%, or 7.36000%. Non-Compliant Higher Priced Mortgage Loan. | 09/06/2022 | 1 | A | RI | Primary | Refinance - Cash-out - Other | C | A | A | A | C | A | C | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639487 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal Not Obtained Timely) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained prior to consummation. | 09/06/2022 | 1 | A | RI | Primary | Refinance - Cash-out - Other | C | A | A | A | C | A | C | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639487 | Compliance | Compliance | State Compliance | State Defect | Rhode Island Home Loan (Prohibited Acts and Practices Regarding High-Cost Home Loans Disclosure Not Provided) | Rhode Island Home Loan: Prohibited Acts and Practices Regarding High-Cost Home Loans disclosure not provided. | Reviewer Comment (2022-09-22): Received, Clearing. Seller Comment (2022-09-21): Comment from XXXX (XXXX): Please see attached for the prohibited acts disclosure-high cost. |
09/22/2022 | 1 | A | RI | Primary | Refinance - Cash-out - Other | C | A | A | A | C | A | C | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639487 | Compliance | Compliance | State Compliance | State Defect | Rhode Island Home Loan (High Cost Analysis Not In File) | Rhode Island Home Loan: Loan file did not contain record(s) documenting high-cost home loan analysis. | Reviewer Comment (2022-09-23): Received compliance report, added exception for post closing timing. Seller Comment (2022-09-23): Comment from XXXX (Quontic Bank): See attached for our compliance report showing the pass on its analysis for high-cost. Reviewer Comment (2022-09-22): The RI Home Loan Protection Act requires that a high cost analysis be performed and documented for each and every loan file substantiating the “high cost loans” analysis performed during the transaction. It is not only required to be performed on high-cost loans, but not high-cost as well. The analysis on a non-high-cost loan would support the creditor’s determination on how the loan did not exceed the thresholds whereas an analysis on a high-cost loan would support how it did exceed the thresholds. The creditor must maintain on file and be in possession of documentation clearly identifying and substantiating the high cost calculation. The text for the full requirement is shown below: R.I. Banking Regulation 3, Section (5)(A)(ii) and (iii) states that: Each Person subject to the requirements of the Act shall maintain records for each and every loan file supporting and substantiating the tangible net benefit and/or High-Cost Home Loan analysis performed during the transaction. (ii) Each Person subject to the requirements of the Act must keep a list of all loans in which the High-Cost Home Loan has been assented to by the borrower. The analysis performed regarding whether or not a loan is a “High-Cost Home Loan” must be accurate and based upon verified information as reflected by the Forms 4 and HLPA 5 Disclosures entitled, respectively, “Rhode Island Home Loan Protection Disclosure High Cost Home Loan” and “Rhode Island Home Loan Protection Disclosure Consumer Caution and Home Ownership Counseling Notice and Certification” as required by this regulation. Failure to clearly identify, document, and substantiate the respective High-Cost Home Loan will be deemed a violation of this regulation, and a basis for administrative action pursuant to R.I. Gen. Laws § 19-14-13. (iii) The individual authorizing the Home Loan after reviewing said tangible net benefit and/or High Cost-Home Loan analysis shall date and sign the written record of analysis by confirming that he/she has reviewed the analysis and confirms whether or not the loan is a High Cost-Home Loan and whether or not there is a tangible net benefit under the terms of the Act. Buyer Comment (2022-09-22): Comment from XXXX (Quontic Bank): This is only required when it is a high-cost loan and this loan isn't. Total loan amount is $385,000 , threshold of 5% for points and fees not to be exceeded is $19,250 - points and fees for this file adds up to $12,042.50 which is lower. Buyer Comment (2022-09-21): Comment from XXXX (Quontic Bank): This is only required when it is a high-cost loan and this loan isn't. Total loan amount is $385,000 , threshold of 5% for points and fees not to be exceeded is $19,250 - points and fees for this file adds up to $12,042.50 which is lower. |
09/23/2022 | 1 | A | RI | Primary | Refinance - Cash-out - Other | C | A | A | A | C | A | C | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639487 | Compliance | Compliance | State Compliance | State Defect | Rhode Island Home Loan (Prohibited Acts and Practices Regarding Home Loans Disclosure Not Provided) | Rhode Island Home Loan: Prohibited Acts and Practices Regarding Home Loans disclosure not provided. | Reviewer Comment (2022-09-22): Received, Clearing. Seller Comment (2022-09-21): Comment from XXXX (XXXX): Please see attached for the prohibited acts disclosure. |
09/22/2022 | 1 | A | RI | Primary | Refinance - Cash-out - Other | C | A | A | A | C | A | C | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639487 | Compliance | Compliance | State Compliance | State Defect | Rhode Island Home Loan (Tangible Net Benefit Disclosure Not Provided) | Rhode Island Home Loan: Tangible Net Benefit Disclosure not provided to borrower for refinance within 60 months. | Reviewer Comment (2022-09-22): Received, Clearing. Seller Comment (2022-09-21): Comment from XXXX (XXXX): Attached |
09/22/2022 | 1 | A | RI | Primary | Refinance - Cash-out - Other | C | A | A | A | C | A | C | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639487 | Compliance | Compliance | State Compliance | State Defect | Rhode Island High Cost Analysis Timing | Rhode Island Home Loan: High-cost Analysis not documented and substantiated prior to closing of the loan. | Received compliance report, added exception for post closing timing. | Reviewer Comment (2022-09-23): Received, Clearing. Seller Comment (2022-09-23): Comment from XXXX (XXXX): Please see attached for the compliance report ran at closing. |
09/23/2022 | 1 | A | RI | Primary | Refinance - Cash-out - Other | C | A | A | A | C | A | C | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639488 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: Borrower's ability to repay not verified with reliable documentation. | New York Subprime Loan Document not provided in file | Reviewer Comment (2022-09-02): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639488 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | New York Subprime Counseling Disclosure not provided in file | Reviewer Comment (2022-09-02): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639488 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Document not provided in file | Reviewer Comment (2022-09-02): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639488 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.23000 + 1.75%, or 6.98000%. Non-Compliant SubPrime Loan. | Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR [Redacted]% | Reviewer Comment (2022-09-02): Accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639488 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Document not provided | Reviewer Comment (2022-09-02): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639488 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Verification appraisal was delivered to borrower was not provided. | Reviewer Comment (2022-09-01): Received, Clearing. |
09/01/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639488 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.31% + 1.5%, or 6.81000%. Non-Compliant Higher Priced Mortgage Loan. | Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 6.81000% | Reviewer Comment (2022-09-01): Received, Clearing. |
09/01/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639488 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Verification appraisal was delivered to borrower was not provided. | Reviewer Comment (2022-09-01): Received, Clearing. Seller Comment (2022-09-01): Please see attached for the appraisal delivery letter. |
09/01/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639488 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Missing evidence of appraisal invoice showing paid outside of closing | Reviewer Comment (2022-09-02): Received, Clearing. Seller Comment (2022-09-02): Comment from[Redacted] ([Redacted]): Per final CD, required cash to close [Redacted] plus [Redacted] months PITIA [Redacted], total required [Redacted] to close. We've verified the transaction activity of [Redacted] [Redacted] at [Redacted], which is sufficient to cover this transaction. Attached paid receipts of appraisal fee and HOI premium. |
09/02/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639489 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639489 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of[Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.25000 + 1.75%, or 7.00000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639489 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided within Three Days of Application) | New York Subprime Loan: Counseling Disclosure not provided to borrower within three days of application. | The file was missing a copy of New York Subprime Loan: Counseling Disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639490 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Verification appraisal was delivered to borrower was not provided. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | CT | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639492 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Amount of Non-Escrowed Property Costs over Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted] on Final Closing Disclosure provided on [Redacted] not accurate. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Second Home | Purchase | Letter of Explanation & Corrected Closing Disclosure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639494 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | RESPA Homeownership Counseling List was not provided | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MO | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639495 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639496 | Compliance | Compliance | State Compliance | State HPML | Massachusetts HPML Threshold Test Compliant | Massachusetts Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.31% + 1.5%, or 6.81000% Compliant Higher Priced Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MA | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639499 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | TX | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639500 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient cure in the amount of $[Redacted]was provided to the borrower at Closing. | Reviewer Comment (2022-08-24): Sufficient Cure Provided At Closing |
08/24/2022 | 1 | A | IL | Primary | Purchase | Final CD evidences Cure | A | A | A | A | A | A | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639501 | Compliance | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Missing Lender's Initial 1003 | Initial 1003 not in file | Reviewer Comment (2022-08-25): Received, Clearing. Seller Comment (2022-08-25): Please see attached for the initial [Redacted]. |
08/25/2022 | 1 | A | TX | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639501 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Homeownership Counselling not provided. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | TX | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639501 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.31% + 1.5%, or 6.81000%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-08-25): Received, Clearing. |
08/25/2022 | 1 | A | TX | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639501 | Compliance | Compliance | Federal Compliance | TRID | TRID Appraisal Disclosure - ECOA Timing | ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date. | Not provided | Reviewer Comment (2022-08-25): Received, Clearing. Seller Comment (2022-08-25): Please see attached for the right to copy of appraisal. |
08/25/2022 | 1 | A | TX | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639501 | Compliance | Compliance | Federal Compliance | TRID | TRID Appraisal Disclosure - HPML Timing | HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date. | Not provided | Reviewer Comment (2022-08-25): Received, Clearing. Seller Comment (2022-08-25): Please see attached for right to copy of appraisal. |
08/25/2022 | 1 | A | TX | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639501 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Loan Estimate Timing | TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application. | Not provided | Reviewer Comment (2022-08-25): Received, Clearing. Seller Comment (2022-08-25): Please see attached for the initial LE. |
08/25/2022 | 1 | A | TX | Primary | Purchase | No Defined Cure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639502 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Verification appraisal was delivered to borrower was not provided | Reviewer Comment (2022-08-25): Received, Clearing. |
08/25/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639502 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-08-25): Received, Clearing. Seller Comment (2022-08-25): Please see attached for the Appraisal Delivery letter. |
08/25/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639502 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.86% + 1.5%, or 7.36000%. Non-Compliant Higher Priced Mortgage Loan. | Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 7.36000% | Reviewer Comment (2022-08-25): Received, Clearing. |
08/25/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639502 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Reviewer Comment (2022-08-25): Accepted as is. |
2 | B | FL | Primary | Refinance - Cash-out - Other | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639504 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-08-25): Received, Clearing. |
08/25/2022 | 1 | A | WA | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639504 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.86% + 1.5%, or 7.36000%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-08-25): Received, Clearing. |
08/25/2022 | 1 | A | WA | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639504 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-08-25): Received, Clearing. Seller Comment (2022-08-25): Please see attached for the appraisal delivery letters. |
08/25/2022 | 1 | A | WA | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639505 | Credit | Loan Package Documentation | Application / Processing | Missing Document | Missing Document: Tax Certificate not provided | The file is missing a copy of the tax certificate. | Reviewer Comment (2022-08-26): Received, clearing. Seller Comment (2022-08-26): Please see attached for the Tax Cert. |
08/26/2022 | 1 | A | TX | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639505 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | The file is missing a copy of the List of Homeownership Counseling. | Reviewer Comment (2022-08-26): Accepted as is. |
2 | B | TX | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639505 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $[Redacted]exceeds tolerance of $[Redacted]plus 10% or $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Borrower was not provided with a COC | Reviewer Comment (2022-08-24): Sufficient Cure Provided At Closing |
08/24/2022 | 1 | A | TX | Primary | Purchase | Final CD evidences Cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639508 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | The file is missing a copy of the RESPA Homeownership Counseling List. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | FL | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639509 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639509 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: Borrower's ability to repay not verified with reliable documentation. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639509 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639509 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639509 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.23000 + 1.75%, or 6.98000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639509 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639510 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-07): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639510 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-07): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639510 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.78000 + 1.75%, or 7.53000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-07): Accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639510 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-09-07): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639510 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Reviewer Comment (2022-09-07): Received, Clearing. Seller Comment (2022-09-07): Comment from [Redacted] ([Redacted]): Per final CD, required cash to close [Redacted], plus [Redacted] months PITIA [Redacted], total required [Redacted] to close. We've verified the transaction activities of Chase [Redacted] at [Redacted] and [Redacted][Redacted] at [Redacted], total at [Redacted], which is sufficient to cover this transaction. Also, attached appraisal fee paid receipt, HOI paid receipt, and bank statement for [Redacted][Redacted] and [Redacted][Redacted]. |
09/07/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639511 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Verification appraisal was delivered to borrower was not provided. | Reviewer Comment (2022-08-26): Received, Clearing. |
08/26/2022 | 1 | A | NY | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639511 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.16% + 1.5%, or 6.66000%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-08-26): Received, Clearing. |
08/26/2022 | 1 | A | NY | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639511 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Reviewer Comment (2022-08-26): Received, Clearing. Seller Comment (2022-08-26): Please see attached for the Appraisal Delivery Letter. |
08/26/2022 | 1 | A | NY | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639511 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-08-26): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639511 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-08-26): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639511 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.23000 + 1.75%, or 6.98000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-08-26): Accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639512 | Compliance | Compliance | State Compliance | Misc. State Level | Maryland Mortgage Lending Regulations (Tangible Net Benefit Worksheet Not Provided) | Maryland Mortgage Lending Regulations: Net Tangible Benefit Worksheet not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MD | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639512 | Compliance | Compliance | State Compliance | Misc. State Level | Maryland Ability to Repay Not Verified | Maryland SB270: Borrower's ability to repay not verified with reliable documentation. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MD | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639513 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639513 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639513 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639513 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.78000 + 1.75%, or 7.53000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639513 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Appraisal increased from $[Redacted]to $[Redacted]without a valid change of circumstance. A Credit for $[Redacted]was reflected on the final Closing Disclosure. | Reviewer Comment (2022-09-06): Sufficient Cure Provided At Closing |
09/06/2022 | 1 | A | NY | Primary | Purchase | Final CD evidences Cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639514 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | New York Subprime Disclosure not found in file. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639514 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.23000 + 1.75%, or 6.98000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639514 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | New York Subprime Disclosure not found in file. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639515 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | List of Homeownership Counseling Organizations is missing, please provide | Reviewer Comment (2022-09-07): Accepted as is. |
2 | B | NY | Primary | Purchase | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639515 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Counseling Disclosure is missing, please provide | Reviewer Comment (2022-09-07): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639515 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan, please provide | Reviewer Comment (2022-09-07): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639515 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | The Subprime Mortgage Disclosure is missing, please provide | Reviewer Comment (2022-09-07): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639515 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.25000 + 1.75%, or 7.00000%. Non-Compliant SubPrime Loan. | The loan is identified as higher priced mortgage loan, APR is in excess of allowable threshold. | Reviewer Comment (2022-09-07): Accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639515 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___. | Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-09-07): Client approved exception. Seller Comment (2022-09-06): Comment from [Redacted] ([Redacted]): Please see attached Exceptional approval for insufficient reserves. |
09/07/2022 | 2 | B | NY | Primary | Purchase | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639517 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639517 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Evidence of receipt of New York Subprime Counseling Disclosure not found in file. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639517 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Evidence of receipt of New York Subprime Disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639517 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Evidence of receipt of New York Subprime Disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639517 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.23000 + 1.75%, or 6.98000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639517 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Evidence of receipt of New York Subprime Tax Disclosure |
Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639518 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | Reviewer Comment (2022-09-12): Received, Clearing. Seller Comment (2022-09-12): Comment from [Redacted] ([Redacted]): Please see attached CPA letter. |
09/12/2022 | 1 | A | NC | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639520 | Compliance | Compliance | State Compliance | State Defect | Rhode Island Home Loan (Prohibited Acts and Practices Regarding High-Cost Home Loans Disclosure Not Provided) | Rhode Island Home Loan: Prohibited Acts and Practices Regarding High-Cost Home Loans disclosure not provided. | Reviewer Comment (2022-09-22): Disclosure received Seller Comment (2022-09-21): Comment from XXXX (XXXX): Please see attached for the prohibited acts disclosure for high cost home loans. Buyer Comment (2022-09-21): Comment from XXXX (XXXX): This disclosure is only required when it is a high-cost loan and this isn't. Total loan amount is XXXX , threshold of 5% for points and fees not to be exceeded is XXXX- it adds up to $9,032 which is lower. |
09/22/2022 | 1 | A | RI | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639520 | Compliance | Compliance | State Compliance | State Defect | Rhode Island Home Loan (High Cost Analysis Not In File) | Rhode Island Home Loan: Loan file did not contain record(s) documenting high-cost home loan analysis. | Reviewer Comment (2022-09-23): Received compliance report, added exception for post closing timing. Seller Comment (2022-09-23): Comment from XXXX (XXXX): See attached for our compliance report showing the pass on its analysis for high-cost. Reviewer Comment (2022-09-22): The RI Home Loan Protection Act requires that a high cost analysis be performed and documented for each and every loan file substantiating the “high cost loans” analysis performed during the transaction. It is not only required to be performed on high-cost loans, but not high-cost as well. The analysis on a non-high-cost loan would support the creditor’s determination on how the loan did not exceed the thresholds whereas an analysis on a high-cost loan would support how it did exceed the thresholds. The creditor must maintain on file and be in possession of documentation clearly identifying and substantiating the high cost calculation Buyer Comment (2022-09-21): Comment from XXXX (XXXX): This is only required when it is a high-cost loan and this loan isn't. Total loan amount is XXXX , threshold of 5% for points and fees not to be exceeded is XXXX- points and fees for this file adds up to $9,032 which is lower. Buyer Comment (2022-09-21): Comment from XXXX (XXXX): This is only required when it is a high-cost loan and this loan isn't. Total loan amount is XXXX , threshold of 5% for points and fees not to be exceeded is XXXX- it adds up to $9,032 which is lower. |
09/23/2022 | 1 | A | RI | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639520 | Compliance | Compliance | State Compliance | State Defect | Rhode Island Home Loan (Prohibited Acts and Practices Regarding Home Loans Disclosure Not Provided) | Rhode Island Home Loan: Prohibited Acts and Practices Regarding Home Loans disclosure not provided. | Reviewer Comment (2022-09-22): Disclosure received Seller Comment (2022-09-21): Comment from XXXX (XXXX): Please see attached for the prohibited acts disclosure. |
09/22/2022 | 1 | A | RI | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639520 | Compliance | Compliance | State Compliance | State Defect | Rhode Island High Cost Analysis Timing | Rhode Island Home Loan: High-cost Analysis not documented and substantiated prior to closing of the loan. | Received compliance report, added exception for post closing timing. | Reviewer Comment (2022-09-23): Received, Clearing. Seller Comment (2022-09-23): Comment from XXXX (XXXX): Please see attached for the compliance report. |
09/23/2022 | 1 | A | RI | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639522 | Compliance | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Missing Lender's Initial 1003 | Missing 1003 Initial - Lender's. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | C | B | A | A | B | B | C | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639522 | Property | Appraisal Reconciliation | Value Discrepancy | Appraisal Reconciliation | Loan is to be securitized. Highest level secondary valuation does not support the value used to qualify.; Sec ID: 7 | Two CDAs are on file - only 1 supports the value of the primary valuation | Reviewer Comment (2022-08-29): Cleared Buyer Comment (2022-08-29): Old CDA dated[Redacted] is consistent with the old appraisal, and the old appraisal of [Redacted] is replaced by the final updated appraisal with value [Redacted]. So old CDA dated [Redacted]is replaced by final CDA dated [Redacted]. We used final appraisal and final CDA with value [Redacted] to qualify this loan. Reviewer Comment (2022-08-29): There is two CDA's in the file with variances between them. Seller Comment (2022-08-29): attached is final appraisal with value [Redacted], and attached CDA is consistent with the final appraisal, the CDA [Redacted] is the same value as the final appraisal value. |
08/29/2022 | 1 | A | NY | Primary | Refinance - Cash-out - Other | C | B | A | A | B | B | C | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639522 | Compliance | Compliance | Federal Compliance | Missing Non-Required Data | (Missing Data) Last Rate Set Date | Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | C | B | A | A | B | B | C | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639522 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | C | B | A | A | B | B | C | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639522 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: Borrower's ability to repay not verified with reliable documentation. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | No obvious cure | C | B | A | A | B | B | C | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639522 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | No obvious cure | C | B | A | A | B | B | C | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639522 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | A | A | B | B | C | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639522 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.78000 + 1.75%, or 7.53000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | A | A | B | B | C | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639522 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | No obvious cure | C | B | A | A | B | B | C | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639523 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Homeownership Counseling List missing in file. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639523 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | New York Subprime Counseling Disclosure missing in file. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639523 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | New York Subprime Disclosure missing in file. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639523 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.81000 + 1.75%, or 7.56000%. Non-Compliant SubPrime Loan. | Compliant Higher priced loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639523 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | New York Subprime Tax Disclosure missing in file. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639523 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639523 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Appraisal receipt is dated [Redacted], however the appraisal signatures are [Redacted]. Provide evidence the borrower received all copies of the appraisals. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639524 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Appraisal delivered on [Redacted], however, signature date of appraisal is [Redacted]. Provide evidence the borrower provided all copies of the appraisal | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639524 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Appraisal delivered on [Redacted], however, signature date of appraisal is [Redacted]. Provide evidence the borrower provided all copies of the appraisal | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639524 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.23000 + 1.75%, or 6.98000%. Non-Compliant SubPrime Loan. | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.23000 + 1.75%, or 6.98000%. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639524 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639524 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639524 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Escrow Not Established) | New York Subprime Loan: Mandatory escrow account not established for the collection of property taxes and insurance. (Note: Does not apply to a subordinate lien when the taxes and insurance are escrowed through another home loan. It also does not apply if the borrower can demonstrate a record of 12 months of timely payments of taxes and insurance on a previous home loan.) | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639524 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639525 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax. Fee Amount of $[Redacted]exceeds tolerance of $0.00. Insufficient or no cure was provided to the borrower. | Transfer tax Fee was not disclosed on Loan Estimate. File does not contain a valid COC for this fee, nor evidence of cure. Provide a post-close CD disclosing the tolerance cure to include $[Redacted], a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made. | Reviewer Comment (2022-09-19): [Redacted] received: Letter of Explanation, Proof of Mailing, Copy of Refund Check, and Corrected PCCD. Buyer Comment (2022-09-16): Comment from [Redacted] ([Redacted]): This has been received by the borrower. Reviewer Comment (2022-09-13): [Redacted] received corrected PCCD, LOE, Copy of refund check and shipping label. Tracking indicates the label has been created; however, it has not been picked up for shipping. Proof of mailing is required to cure. Seller Comment (2022-09-12): Comment from [Redacted] ([Redacted]): Please see attached for the PCCD, LOE, Proof of delivery, and proof of refund. |
09/19/2022 | 2 | B | PA | Primary | Refinance - Cash-out - Other | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639525 | Credit | Hazard Insurance | Insufficient Coverage | Hazard Insurance | The Hazard Insurance Policy Effective Date is after closing. | The homeowner's insurance declarations page in the file verified an effective date of [Redacted] which is after the consummation date of[Redacted]. Provide a revised homeowner's insurance declaration page or policy verifying coverage in effect at or prior to consummation. | Reviewer Comment (2022-09-01): Received, Clearing. Seller Comment (2022-09-01): Please see attached HOI with effective date [Redacted]and renewed HOI with effective date [Redacted]. It's cash out refinance, the prior HOI cover the closing date. |
09/01/2022 | 1 | A | PA | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639526 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | The file is missing a copy of the source of funds for the earnest money. | Reviewer Comment (2022-08-29): Received, Clearing. Seller Comment (2022-08-29): Total required: Cash to Close [Redacted] + [Redacted] mo. PITIA[Redacted] + EMD [Redacted] = [Redacted] Total verified: [Redacted] [Redacted]: [Redacted] The down payment of [Redacted] was included on the Closing Disclosure, which is fine to do since these are real funds held in escrow. However, the UW did not use the down payment in the QUALIFYING funds. we did not give credit for the DP when underwriting the loan, so I added it back to total assets required from my above calculation. The UW disregarded the DP because it was 'unverifiable'. Therefore, borrower needed to evidence approx.[Redacted] EXCLUSIVE of the down payment to close. Borrower still has sufficient funds for this transaction, please advise. |
08/29/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639526 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.31% + 1.5%, or 6.81000%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-08-31): Received, Clearing. |
08/31/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639526 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal Not Obtained Timely) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained prior to consummation. | The appraisal is dated [Redacted], which is the note date | Reviewer Comment (2022-08-31): Received, Clearing. Seller Comment (2022-08-31): Please see attached for the earlier delivered appraisal. Reviewer Comment (2022-08-29): Need the earlier delivered appraisal. Seller Comment (2022-08-29): Please see attached appraisal delivery letter. The appraisal was delivered to the borrower within required time frame. The signature date of [Redacted] is reflecting revisions made. |
08/31/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639526 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: File does not contain evidence that analysis of borrower's ability to repay was performed based on verified income, obligations, assets, and/or employment using PITI payment based on fully-indexed rate with fully-amortizing payment and taking into account payments on any simultaneously-closed loans. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639526 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639526 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639526 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.23000 + 1.75%, or 6.98000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639526 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639526 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Escrowed Property Costs Year 1 - October 2018 Testing | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on 07/07/2022 not accurate. | The approval reflects escrows in the amount of $[Redacted]however, verified XXXX in county taxes, $[Redacted]in school taxes and $[Redacted]= $[Redacted] | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639527 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | File is missing a copy Counseling Disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639527 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Unable to determine due to missing state subprime disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639527 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | File is missing copy of New York Subprime Disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639527 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | File is missing a copy Notice of Taxes and Insurance | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639527 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $[Redacted]exceeds tolerance of $[Redacted]plus 10% or $[Redacted]. Insufficient or no cure was provided to the borrower. | Recording Fees was last disclosed as $[Redacted]on LE but disclosed as $[Redacted]on Final Closing Disclosure. File does not contain a valid COC for this fee, nor evidence of cure in file. Provide a post-close CD disclosing the tolerance cure to include $[Redacted], a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made. | Reviewer Comment (2022-09-01): Upon further review, the exception was cured at closing. Reviewer Comment (2022-09-01): [Redacted] upon further review agrees that the cure was provided on CD however this will be cleared once we received proof of rounded off amount Seller Comment (2022-08-31): Please see attached for the Final CD. Sufficient lender credits were provided for this fee change at time of closing. |
09/01/2022 | 1 | A | NY | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639527 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.78000 + 1.75%, or 7.53000%. Non-Compliant SubPrime Loan. | Loan is identified to be Higher priced mortgage loan. APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.78000 + 1.75%, or 7.53000% | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639527 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | Missing CPA/Accountant/Tax Preparer/Enrolled Agent's letter confirming borrower's position/title, ownership percentage, and business inception date. | Reviewer Comment (2022-09-01): CPA letter received Seller Comment (2022-09-01): Please see attached CPA letter. Borrower files their income under Schedule C (past [Redacted] years ), which indicates that they are self-employed. Thus, borrower has no registered business and no inception date. |
09/01/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639527 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Transfer tax increased from final LE to final CD in the amount of $[Redacted], with no VCC. The change is beyond rounding requirements and cure is required. | Reviewer Comment (2022-09-01): Sufficient Cure Provided At Closing |
09/01/2022 | 1 | A | NY | Primary | Purchase | Final CD evidences Cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639528 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | The file is missing proof of the source of funds. | Reviewer Comment (2022-08-29): Received, Clearing. Seller Comment (2022-08-29): Per final CD, required [Redacted] months PITIA[Redacted] ($[Redacted]*[Redacted]) plus EMD [Redacted], total required [Redacted]. We total verified [Redacted] [Redacted] at [Redacted] plus received [Redacted] from cash to close, total [Redacted]. The down payment of [Redacted] was included on the Closing Disclosure, which is fine to do since there are real funds held in escrow. However, the UW did not use the down payment in the Qualifying funds, we did not give credit the deposit when underwriting the loan, so I added it back to total asset required from my above calculation. The UW disregarded the deposit because it was "unverifiable". Therefore, borrower needed to evidence [Redacted]EXCLUSIVE OF THE DOWN PAYMENT TO CLOSE. Borrower still has sufficient funds for this transaction. Also, [Redacted] deposit was from purchase of sale as per attached escrow letter and CD from sale of home. |
08/29/2022 | 1 | A | NJ | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639528 | Compliance | Compliance | Federal Compliance | FACTA | Federal FACTA Disclosure Timing Test | FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score. | Reviewer Comment (2022-08-29): Accepted as is. |
2 | B | NJ | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639529 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639529 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639529 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639529 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.23000 + 1.75%, or 6.98000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639530 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | CPA letter does not indicate the business inception date | Reviewer Comment (2022-09-01): Received, Clearing. Seller Comment (2022-09-01): borrower files their income under Schedule C, which indicates that borrower is self-employed. Thus, the borrower has no registered business and no inception date. And per attached CPA letter, it is referenced that borrower has been self employed for 5 years. |
09/01/2022 | 1 | A | NY | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639532 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Reviewer Comment (2022-08-31): Received, Clearing. Seller Comment (2022-08-31): Per final CD, cash to close required [Redacted] plus [Redacted] months PITIA reserves requirement of [Redacted], total required [Redacted] to close. We've verified assets from the transaction activities of XXXX [Redacted][Redacted] at [Redacted] is sufficient for this transaction. Attached statement of XXXX [Redacted][Redacted], gift letter for large deposit [Redacted] and cancelled check and gift letter for deposit[Redacted]. |
08/31/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | C | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639532 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | C | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639532 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | C | A | B | B | C | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639532 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | C | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639532 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.81000 + 1.75%, or 7.56000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | C | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639532 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Appraisal fee increased from $[Redacted]to $[Redacted]without a valid change of circumstance. A cure for $[Redacted]was provided on the final Closing Disclosure. | Reviewer Comment (2022-08-29): Sufficient Cure Provided At Closing |
08/29/2022 | 1 | A | NY | Primary | Purchase | Final CD evidences Cure | C | B | C | A | B | B | C | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639532 | Property | Valuation | Valuation Issue | Valuation | The desk review has a effective date that is other than what the appraisal effective date is. The desk review should have the same effective date as the appraisal | Reviewer Comment (2022-09-01): Received, Clearing. Seller Comment (2022-09-01): Please see attached CDA yellow highlight, the effective date [Redacted] is same with the appraisal effective date. |
09/01/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | C | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639533 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Reviewer Comment (2022-09-13): Received, Clearing. Seller Comment (2022-09-13): Comment from [Redacted] ([Redacted]): Per attached, insurance premium and appraisal fee are paid. So total [Redacted] closing costs paid before closing is evidenced. Therefore, it is sufficient to cover the closing cost and reserves requirement. Reviewer Comment (2022-09-01): Calculated cash to close [Redacted]- (Total Closing Costs = [Redacted] Down Payment = [Redacted], Adjustments and Other Credits = -[Redacted]) Available for closing = [Redacted] (Account ending [Redacted] = [Redacted] , Checking ending[Redacted] [Redacted], EMD [Redacted], documented hazard insurance POC [Redacted]) Available for reserves = [Redacted] is insufficient to meet[Redacted] requirement Seller Comment (2022-09-01): Per final CD, cash to close required [Redacted] plus [Redacted] months PITIA reserves requirement of [Redacted] , total required [Redacted] to close. We've verified assets from the transaction activities of [Redacted] [Redacted] at [Redacted] and [Redacted][Redacted] at [Redacted], total asset is [Redacted], which is sufficient for this transaction. Attached transaction pages of [Redacted] [Redacted] and[Redacted] [Redacted] and deposited [Redacted] cancelled check. |
09/13/2022 | 1 | A | NJ | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639533 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Verification appraisal was delivered to borrower was not provided. | Reviewer Comment (2022-09-13): Accepted as is. |
2 | B | NJ | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639533 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Appraisal receipt is dated [Redacted]which is prior to appraisal signature date of [Redacted]. Provide evidence the borrower received the most receipt appraisal. | Reviewer Comment (2022-09-13): Accepted as is. |
2 | B | NJ | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639534 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Hazard coverage of $[Redacted]x 25% is insufficient to cover the mortgage amount of $[Redacted]with an estimated cost new of $[Redacted]. Please provide a letter from the Insurer stating the maximum insurable amount | Reviewer Comment (2022-08-29): Received, Clearing. Seller Comment (2022-08-29): Dwelling coverage of [Redacted] is sufficient to cover the replacement cost of [Redacted] per attached RCE. |
08/29/2022 | 1 | A | FL | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639535 | Credit | Missing Document | General | Missing Document | Missing Document: Verification of Non-US Citizen Status not provided | The file is missing a copy of the non-us citizen status | Reviewer Comment (2022-09-08): Received, cleared |
09/08/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639535 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | The file is missing a copy of the List of Homeownership Counseling | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639535 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | The file is missing a copy of the Counseling disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639535 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639535 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | The file is missing a copy of the documentation | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639535 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.30000 + 1.75%, or 7.05000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639535 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | The file is missing a copy of the documentation | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639535 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | 1003 Error: Citizenship Source Documentation was not provided | - | The file is missing proof of the citizenship documentation. | Reviewer Comment (2022-09-08): Received cleared |
09/08/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639535 | Credit | 1003 | Document Error | 1003 | Borrower(s) is not a U.S. Citizen, and the guideline required documentation was not provided. | - | The file is missing proof of citizenship. | Reviewer Comment (2022-09-08): Received employment authorization card Seller Comment (2022-09-08): Comment from [Redacted] ([Redacted]): Please see attached employment authorization. |
09/08/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639536 | Compliance | Compliance | State Compliance | State HPML | Massachusetts HPML Threshold Test Compliant | Massachusetts Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.31% + 1.5%, or 6.81000% Compliant Higher Priced Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MA | Primary | Refinance - Cash-out - Other | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639538 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NJ | Primary | Purchase | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639538 | Credit | Asset | Asset Calculation / Analysis | Asset | Available for Closing is insufficient to cover Cash From Borrower. | Documented qualifying Assets for Closing of ___ is less than Cash From Borrower ___. | Missing evidence of liquidation of stocks | The representative FICO score exceeds the guideline minimum by at least 40 points. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. Borrower has been employed in the same industry for more than 5 years. |
SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC |
Reviewer Comment (2022-09-26): Post-funding exception approval, client elects to waive with compensating factors Seller Comment (2022-09-26): Comment from XXXX (XXXX): Please see attached Exceptional Approval for insufficient funds to close. |
09/26/2022 | 2 | B | NJ | Primary | Purchase | C | B | C | B | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||
| 438639541 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | The file is missing a copy of the documentation. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639541 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | The file is missing a copy of the documentation. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639541 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.81000 + 1.75%, or 7.56000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639541 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | The file is missing a copy of the documentation. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639542 | Property | Property - Appraisal | Appraisal Data Integrity | Property - Appraisal | Appraiser's license or certification was not active at the time of the appraisal. | - | Appraiser's license or certification was not active at the time of the appraisal | Reviewer Comment (2022-09-06): Received, Clearing. Seller Comment (2022-09-06): Comment from[Redacted] ([Redacted]): Please see attached for appraiser's license valid at time of inspection. |
09/06/2022 | 1 | A | NY | Primary | Refinance - Cash-out - Other | C | B | A | A | B | B | C | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639542 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided within Three Days of Application) | New York Subprime Loan: Counseling Disclosure not provided to borrower within three days of application. | Evidence of earlier borrower receipt was not found in file. | Reviewer Comment (2022-09-06): Accepted as is. |
2 | B | NY | Primary | Refinance - Cash-out - Other | No obvious cure | C | B | A | A | B | B | C | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639542 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.81000 + 1.75%, or 7.56000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-06): Accepted as is. |
2 | B | NY | Primary | Refinance - Cash-out - Other | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | A | A | B | B | C | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639543 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.81000 + 1.75%, or 7.56000%. Non-Compliant SubPrime Loan. | Verified APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.81000 + 1.75%, or 7.56000%. Non-Compliant Subprime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639543 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | New York Subprime Counseling Disclosure missing in file. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639543 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | New York Subprime Default Rate missing in file. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639543 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | New York Subprime Disclosure missing in file. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639543 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | New York Subprime Tax Disclosure missing in file. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639543 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: Borrower's ability to repay not verified with reliable documentation. | New York Subprime disclosure missing in file. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639544 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee. Fee Amount of $[Redacted]exceeds tolerance of $0.00. Sufficient or excess cure was provided to the borrower at Closing. | Appraisal Re-Inspection fee increased from $0.00 to $[Redacted]without a valid change of circumstance. A Credit for $[Redacted]was reflected on the final Closing Disclosure. | Reviewer Comment (2022-09-02): Sufficient Cure Provided At Closing |
09/02/2022 | 1 | A | CT | Primary | Purchase | Final CD evidences Cure | A | A | A | A | A | A | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639545 | Compliance | Compliance | Federal Compliance | Missing Non-Required Data | (Missing Data) Last Rate Set Date | Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639545 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639545 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639545 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639545 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.81000 + 1.75%, or 7.56000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639545 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639546 | Compliance | Compliance | State Compliance | State Defect | Illinois SB 1894 | IL Predatory Lending Database Program (SB 1894) - Certificate of Compliance or Exemption not attached to mortgage for recording. | The file was missing a copy of Certificate of Compliance or Exemption | Reviewer Comment (2022-09-09): Received, Clearing. Seller Comment (2022-09-09): Comment from [Redacted] ([Redacted]): Please see attached for the IL Cert of Exemption. |
09/09/2022 | 1 | A | IL | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639547 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NJ | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639547 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NJ | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639548 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | HOI coverage is insufficient by $[Redacted]. Provide updated policy reflecting minimum coverage of $[Redacted]OR provide copy of insurer's replacement cost estimate supporting current coverage amount. | Reviewer Comment (2022-09-01): Received, Clearing. Seller Comment (2022-09-01): Per attached HOI, dwelling coverage of [Redacted] is sufficient to cover the loan amount of [Redacted]. |
09/01/2022 | 1 | A | NY | Primary | Refinance - Cash-out - Other | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639548 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: Borrower's ability to repay not verified with reliable documentation. | New York Subprime Loan disclosure not disclosed to the borrower. | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | NY | Primary | Refinance - Cash-out - Other | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639548 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Change Fees) | New York Subprime Loan: Mortgage loan contains possible impermissible modification or deferral fees. (Note: Only applies if original loan was also subprime.) | New York Subprime Loan disclosure not disclosed to the borrower. | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | NY | Primary | Refinance - Cash-out - Other | Provide the following: Letter of Explanation, refund of any modification, renewal, extension or amendment fees paid by borrower and proof of mailing. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639548 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | New York Subprime Loan disclosure not disclosed to the borrower. | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | NY | Primary | Refinance - Cash-out - Other | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639548 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | New York Subprime Loan disclosure not disclosed to the borrower. | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | NY | Primary | Refinance - Cash-out - Other | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639548 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | New York Subprime Loan disclosure not disclosed to the borrower. | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | NY | Primary | Refinance - Cash-out - Other | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639548 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.23000 + 1.75%, or 6.98000%. Non-Compliant SubPrime Loan. | New York Subprime Loan disclosure not disclosed to the borrower. | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | NY | Primary | Refinance - Cash-out - Other | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639548 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | New York Subprime Loan disclosure not disclosed to the borrower. | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | NY | Primary | Refinance - Cash-out - Other | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639549 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-08-26): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639549 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-08-26): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639549 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.23000 + 1.75%, or 6.98000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-08-26): Accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639549 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-08-26): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639549 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | CPA letter indicates withdrawal of business funds will not negatively impact the business however, also states they have not audited or verified this information. | Reviewer Comment (2022-09-02): Clearing after re-review. Reviewer Comment (2022-08-26): Received, Clearing. Seller Comment (2022-08-26): Per attached CDL guidelines for wholesale as of [Redacted], there is no required for audited, only need CPA to verify the withdrawal of business funds will not negative impact the business. We don't request the exact amount verified by CPA. |
09/02/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639550 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Guidelines list the minimum reserves required is 3 months for this loan amount. | Reviewer Comment (2022-09-07): Received Appraisal invoice showing paid outside of closing Seller Comment (2022-09-07): Comment from [Redacted] ([Redacted]): Per final CD, required cash to close [Redacted], plus [Redacted] months PITIA[Redacted], total required [Redacted] to close. We've verified the transaction activities of [Redacted] [Redacted] at [Redacted] and [Redacted][Redacted]at [Redacted], [Redacted] from [Redacted][Redacted] is backed out as it is unverified funds. So total at [Redacted], which is sufficient to cover this transaction. Also, attached appraisal fee paid receipt and bank statements for[Redacted][Redacted] and [Redacted] [Redacted]. |
09/07/2022 | 1 | A | PA | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639550 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | The file is missing a copy of the Homeownership Counseling. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | PA | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639551 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-09): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639551 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-09): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639551 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-09): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639551 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.81000 + 1.75%, or 7.56000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-09): Accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639551 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | Reviewer Comment (2022-09-09): Received, Clearing. Seller Comment (2022-09-08): Comment from [Redacted] ([Redacted]): Please see attached VOE for both borrowers. |
09/09/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639552 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Reviewer Comment (2022-08-25): Received, Clearing. Seller Comment (2022-08-25): Per final CD, cash to close required [Redacted] plus [Redacted] months PITIA [Redacted], total required [Redacted]. We've verified assets from the transaction activity of [Redacted][Redacted]at[Redacted], which is sufficient for this transaction. Please see attached [Redacted][Redacted] statement and EMD wire and receipt. |
08/25/2022 | 1 | A | FL | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639554 | Compliance | Compliance | State Compliance | Misc. State Level | Ohio Consumer Sales Practices Act (Acknowledgement of Receipt of Home Mortgage Loan Information Document Not Retained by Lender) | Ohio Consumer Sales Practices Act: Acknowledgement of Receipt of Home Mortgage Loan Information Document not retained by lender. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | OH | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639554 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Non Escrowed Property Costs Year 1 Test | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on[Redacted] not accurate. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | OH | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639555 | Credit | Property - Appraisal | Property Eligibility - Site and Utilities | Property - Appraisal | Subject property has environmental problems noted by appraiser or visible in the photos | - | Per Appraiser: The subject property back to Washington St., which is heavily traveled and has a negative effect on the value of the subject property, There is no apparent damage or reduction in the subject property's marketability or value due to any recent disaster. | Reviewer Comment (2022-09-12): Clearing after re-review. Seller Comment (2022-09-12): Comment from [Redacted] ([Redacted]): Per attached appraisal page[Redacted] highlighted comment, only negative effect on value, there is no apparent damage or environment problems. |
09/12/2022 | 1 | A | IL | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639556 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | The file is missing a copy of the List of Homeownership Counseling. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | VA | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639557 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639557 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639557 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.78000 + 1.75%, or 7.53000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639558 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.78% + 1.5%, or 7.28000%. Non-Compliant Higher Priced Mortgage Loan. | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.16% + 1.5%, or 6.66000%. | Reviewer Comment (2022-09-01): Received, Clearing. |
09/01/2022 | 1 | A | FL | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639558 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Verification appraisal was delivered to borrower was not provided. | Reviewer Comment (2022-09-01): Received, Clearing. |
09/01/2022 | 1 | A | FL | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639558 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Verification appraisal was delivered to borrower was not provided. | Reviewer Comment (2022-09-01): Received, Clearing. Seller Comment (2022-09-01): Please see attached for the appraisal delivery letter. |
09/01/2022 | 1 | A | FL | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639559 | Compliance | Compliance | Federal Compliance | Missing Non-Required Data | (Missing Data) Last Rate Set Date | Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing. | File is missing a copy of rate lock documentation | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639559 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | File is missing List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639561 | Credit | Loan Package Documentation | Loan File | Missing Document | Missing Document: Hazard Insurance Policy not provided | file is missing hazard insurance documentation | Reviewer Comment (2022-08-29): Received, Clearing. Seller Comment (2022-08-29): Please see attached HOI. Dwelling coverage of [Redacted]is sufficient to cover the replacement cost of [Redacted] per attached RCE. |
08/29/2022 | 1 | A | MT | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639562 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | CA | Primary | Purchase | B | B | A | A | B | B | B | B | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639562 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | CA | Primary | Purchase | B | B | A | A | B | B | B | B | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639562 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-08-25): Sufficient Cure Provided At Closing |
08/25/2022 | 1 | A | CA | Primary | Purchase | Final CD evidences Cure | B | B | A | A | B | B | B | B | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639562 | Property | Property - Appraisal | Appraisal Reconciliation | Property - Appraisal | Appraisal is required to be in name of Lender | - | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | CA | Primary | Purchase | B | B | A | A | B | B | B | B | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639564 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: File does not contain evidence that analysis of borrower's ability to repay was performed based on verified income, obligations, assets, and/or employment using PITI payment based on fully-indexed rate with fully-amortizing payment and taking into account payments on any simultaneously-closed loans. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639564 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639564 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639564 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.23000 + 1.75%, or 6.98000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639564 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639564 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Amount of Non-Escrowed Property Costs over Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on[Redacted] not accurate. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639566 | Credit | Property - Appraisal | Appraisal Adjustments | Property - Appraisal | Excessive site value noted on appraisal without appraiser comments to justify | - | Appraiser commented concerning the excessive site value. | Reviewer Comment (2022-08-31): Received, Clearing. Seller Comment (2022-08-31): SITE VALUE IS NOTED IN COST APPROACH AND FOR SUCH IN ADDENDUM, per uploaded pages (Page [Redacted] of appraisal [Redacted] & Page [Redacted] of appraisal [Redacted]), appraiser commented it. please clear. Reviewer Comment (2022-08-31): Appraiser commented concerning the excessive site value. Seller Comment (2022-08-31): Loan amount [Redacted]. A second appraisal is required for loan amount is greater than[Redacted]. And we used the lesser of two appraisal value as "Appraised Value". So appraisal value [Redacted] is the appraised value, and CDA shows[Redacted], which is supporting the appraisal value. [Redacted] Appraisal: [Redacted] [Redacted] Appraisal: [Redacted] |
08/31/2022 | 1 | A | CT | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639566 | Compliance | Compliance | Federal Compliance | Missing Non-Required Data | (Missing Data) Last Rate Set Date | Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing. | Reviewer Comment (2022-08-31): Accepted as is. |
2 | B | CT | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639566 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | Missing source of funds being held by borrower's attorney in the amount of $[Redacted] | Reviewer Comment (2022-08-31): Received, Clearing. Seller Comment (2022-08-31): Per attached revised letter from borrower's attorney, dated [Redacted], total [Redacted] being held by borrower's attorney. [Redacted] wired to the attorney per attached wire confirmation. Plus[Redacted] cash-out proceeds per attached closing docs. Total [Redacted]. |
08/31/2022 | 1 | A | CT | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639567 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MA | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639567 | Compliance | Compliance | State Compliance | State HPML | Massachusetts HPML Threshold Test Compliant | Massachusetts Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.31% + 1.5%, or 6.81000% Compliant Higher Priced Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MA | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639569 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $68.00 exceeds tolerance of $[Redacted]plus 10% or $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | Reviewer Comment (2022-08-29): Sufficient Cure Provided At Closing |
08/29/2022 | 1 | A | GA | Primary | Purchase | Final CD evidences Cure | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639569 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | CPA letter does not provide business inception date | Reviewer Comment (2022-09-01): Received, Clearing. Seller Comment (2022-09-01): Please see attached CPA letter including business inception date. Reviewer Comment (2022-08-31): Please obtain buyer exception approval as this does not meet guidelines Seller Comment (2022-08-31): Attached VVOE indicates business inception date, which is verified from CPA and supplement to CPA letter. |
09/01/2022 | 1 | A | GA | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639571 | Compliance | Compliance | Federal Compliance | FACTA | Federal FACTA Disclosure Timing Test | FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | FL | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639573 | Compliance | Compliance | Federal Compliance | TRID Defect | TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File | TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s). The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing. Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $[Redacted]may be required. | Evidence of Receipt of Loan estimate not found in file. | Reviewer Comment (2022-09-01): [Redacted] received [Redacted] & [Redacted] LE, changed circumstance and SSPL disclosure. Seller Comment (2022-08-30): Please see attached for the Loan Estimates to this file. |
09/01/2022 | 1 | A | TX | Primary | Refinance - Rate/Term | No Defined Cure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639573 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Lender on the appraisal does not match the lender on the note | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | TX | Primary | Refinance - Rate/Term | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639574 | Compliance | Compliance | Federal Compliance | Missing Application Date | Missing Initial Loan Application Test | No evidence of application date located in file. Compliance tests were run using an application date of [Redacted] which is 1 months prior to consummation. A lookback was performed to determine this application date. | Reviewer Comment (2022-08-29): Received, Clearing. Seller Comment (2022-08-29): Please see attached for the initial [Redacted]. |
08/29/2022 | 1 | A | CT | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639574 | Compliance | Compliance | Federal Compliance | TILA | NMLS - Missing Evidence of Initial Loan Application Date | Truth in Lending Act (NMLSR Dodd- Frank 2014): Unable to determine compliance with NMLSR timing requirements due to missing evidence of initial loan application date. | Reviewer Comment (2022-08-29): Received, Clearing. |
08/29/2022 | 1 | A | CT | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639574 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-08-29): Accepted as is. |
2 | B | CT | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639574 | Compliance | Compliance | State Compliance | State HPML | (State HPML) Connecticut Non-Prime Home Loan (APR Exceeds Non-Prime Threshold) | Connecticut Non-Prime Home Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.78% + 1.5%, or 7.28000%. Non-Compliant Loan. | Reviewer Comment (2022-08-29): Accepted as is. |
2 | B | CT | Primary | Purchase | Within 90 days of closing, and prior to the commencement of any action against a lender, the borrower is notified of the violation and the lender makes appropriate restitution by either: (a) making the nonprime home loan comply with the applicable provisions of the law; or (b) changing the terms of the mortgage in a manner beneficial to the borrower so that the mortgage will no longer be considered a nonprime home loan; Provide: Letter of Explanation and either: For option (a), proof of cure for each of the prohibited practice violations noted; or For option (b), a copy of refund check and proof of mailing. OR (Narrow Defense - CHD Approval Required) The lender is able to show by a preponderance of evidence (no timeframe noted) that the compliance failure was not intentional and resulted from a bona fide error notwithstanding the maintenance of procedures reasonably adapted to avoid such errors. Provide: (1) Lender Attestation to AMC attesting (i) the failure was not intentional and was a bona fide error notwithstanding procedures in place to prevent such loans from being made and (ii) the lender has not received any notice from borrower of the failure; (2) refund of amount over the Non-Prime Home Loan threshold maximum; and (3) proof of delivery. OR The lender and borrower otherwise reach a mutual agreement on an appropriate remedy or curative action. |
C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639574 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) Connecticut Non-Prime Home Loan (Counseling Notice Not Provided) | Connecticut Non-Prime Home Loan (HB5577): Counseling Notice (with toll-free number) not provided to borrower. | Reviewer Comment (2022-08-29): Accepted as is. |
2 | B | CT | Primary | Purchase | See any available cure under the Connecticut Non-Prime Home Loan threshold exception. | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639574 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | An internet search or other satisfactory verification of the business is required with documentation to be included in the credit file to support the business's existence | Reviewer Comment (2022-08-29): Received, Clearing. Seller Comment (2022-08-29): per attached CDL guideline for owner Occupied - Lite Doc program, satisfactory verification of business and CPA are completed as per attached PTIN search and CPA letter. |
08/29/2022 | 1 | A | CT | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639575 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Amount of Non-Escrowed Property Costs over Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] did not disclose Amount of Non-Escrowed Property Costs over Year 1. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | LA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639579 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | PA | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639579 | Compliance | Compliance | Federal Compliance | Missing Non-Required Data | (Missing Data) Last Rate Set Date | Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | PA | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639582 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Municipal Lien Certificate Fee (MLC). Fee Amount of $[Redacted]exceeds tolerance of $0.00. Insufficient or no cure was provided to the borrower. | Fee was not disclosed on Loan Estimate. File does not contain a valid COC for this fee, nor evidence of cure. | Reviewer Comment (2022-09-06): [Redacted] upon review there is no tolerance violence. The fees should be part of the unlimited tolerance category and selected Shoppable override. Buyer Comment (2022-09-02): Comment from [Redacted] ([Redacted]): The provider for this service is not the one listed on the SSPL. Therefore, this fee is not subject to a tolerance limit. This was a fee required by the title company and not us, the lender. Buyer Comment (2022-09-02): Comment from [Redacted]([Redacted]): The provider for this service is not the one listed on the SSPL. Therefore, this fee can change without being subject to a tolerance limit. This was a fee required by the settlement agent and not us, the lender. |
09/06/2022 | 1 | A | NY | Second Home | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639584 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639584 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639584 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639584 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.70000 + 1.75%, or 7.45000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639584 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-08-29): Sufficient Cure Provided At Closing |
08/29/2022 | 1 | A | NY | Primary | Purchase | Final CD evidences Cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639585 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided within Three Days of Application) | New York Subprime Loan: Counseling Disclosure not provided to borrower within three days of application. | Evidence of earlier borrower receipt was not found in file. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639585 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.30000 + 1.75%, or 7.05000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639585 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639588 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided within Three Days of Application) | New York Subprime Loan: Counseling Disclosure not provided to borrower within three days of application. | 2 | B | NY | Primary | Purchase | No obvious cure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639588 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | 2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||||
| 438639588 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.27000 + 1.75%, or 7.02000%. Non-Compliant SubPrime Loan. | 2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||||
| 438639588 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Contact Information - Broker | TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on [Redacted] did not disclose the required Broker Contact Information (Broker Name, Broker NMLS ID, Contact Name, Contact NMLS ID). | Reviewer Comment (2022-09-20): SitusAMC received Letter of Explanation & Corrected Closing Disclosure. |
09/20/2022 | 2 | B | NY | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639588 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | 09/19/2022 | 2 | B | NY | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639589 | Credit | Credit | Credit Documentation | Missing Document | Missing Document: Credit Report not provided | The Credit Report was missing from the file. | Reviewer Comment (2022-09-01): Received, Clearing. Seller Comment (2022-09-01): Credit report |
09/01/2022 | 1 | A | NY | Primary | Purchase | D | B | D | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639589 | Compliance | Compliance | Federal Compliance | FACTA | Federal FACTA Disclosure Timing Test | FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score. | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | NY | Primary | Purchase | D | B | D | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639589 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | D | B | D | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639589 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | D | B | D | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639589 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | D | B | D | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639589 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.78000 + 1.75%, or 7.53000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | D | B | D | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639590 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $[Redacted]exceeds tolerance of $[Redacted]plus 10% or $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Sufficient cure was provided | Reviewer Comment (2022-08-25): Sufficient Cure Provided At Closing |
08/25/2022 | 1 | A | NY | Second Home | Refinance - Cash-out - Other | Final CD evidences Cure | A | A | A | A | A | A | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639591 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Unable to verify due to missing subprime disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639591 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | File is Missing New York Subprime Disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639591 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.30000 + 1.75%, or 7.05000%. Non-Compliant SubPrime Loan. | Unable to verify due to missing subprime disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639591 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | File is missing Subprime Tax disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639592 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639592 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639592 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.81000 + 1.75%, or 7.56000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639592 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639592 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. No cure was provided to the borrower. | Reviewer Comment (2022-09-19): [Redacted] received Post CD,LOX,Copy of refund check and proof of mailing. Buyer Comment (2022-09-16): Comment from [Redacted] ([Redacted]): The cure has been received by the borrower. Reviewer Comment (2022-09-13): [Redacted] received PCCD, LOE, Copy of check & Shipping label. Tracking indicates the label has been created; however, it has not been picked up for shipping. Proof of mailing is required. Seller Comment (2022-09-12): Comment from [Redacted]([Redacted]): Please see attached for the PCCD, LOE, Proof of delivery, and proof of refund. |
09/19/2022 | 2 | B | NY | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639594 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Amount of Non-Escrowed Property Costs over Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on 07/21/2022 not accurate. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | TX | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639594 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-08-25): Sufficient Cure Provided At Closing |
08/25/2022 | 1 | A | TX | Primary | Purchase | Final CD evidences Cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639595 | Compliance | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Missing Lender's Initial 1003 | File was missing a Lender Initial 1003 | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639595 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Missing Final 1003 | File was missing a Final 1003 | Reviewer Comment (2022-08-30): Received, Clearing. Seller Comment (2022-08-30): Final [Redacted] |
08/30/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639595 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | RESPA Homeownership Counseling was not provided | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639595 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Counseling Disclosure not provided to borrower | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639595 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639595 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.70000 + 1.75%, or 7.45000%. Non-Compliant SubPrime Loan. | Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.70000 + 1.75%, | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639596 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | New York Subprime Disclosure not provided | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | B | B | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639596 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | New York Subprime Disclosure not provided | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | B | B | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639596 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.70000 + 1.75%, or 7.45000%. Non-Compliant SubPrime Loan. | New York Subprime Disclosure not provided | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | B | B | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639596 | Property | Property - Appraisal | Appraisal Reconciliation | Property - Appraisal | Appraisal is required to be in name of Lender | - | Missing appraisal transfer letter | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | B | B | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639596 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Missing appraisal transfer letter | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | B | B | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639597 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | The file is missing a copy of the RESPA Homeownership Counseling Organizations List. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MI | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639598 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Survey Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Insufficient or no cure was provided to the borrower. | No COC or Cure was provided to Borrower for tolerance overages | Reviewer Comment (2022-09-01): [Redacted]Received LOE/Attestation therefore no cure required. Seller Comment (2022-08-31): Please see attached for the attestation and survey fee invoice. Reviewer Comment (2022-08-29): [Redacted] is unable to determine from the file whether the lender or title company required the Title -Survey Fee. If the lender required the survey fee then a cure is due to the borrower. If the borrower-chosen service provider further outsourced the Title -Survey Fee, an attestation or comment on exception from the seller is needed. The attestation/letter should confirm that the service was outsourced by the borrower-chosen provider. This attestation would allow us to test the fee under the no tolerance category with the understanding that the new fee added on the CD was imposed by a provider through which the borrower indirectly selected. Buyer Comment (2022-08-26): The provider for this service is not the one listed on the SSPL. Therefore, this fee is not subject to a tolerance limit. No cure is required. |
09/01/2022 | 1 | A | TX | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639599 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639599 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639599 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639599 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.51000 + 1.75%, or 7.26000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639600 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Collateral Desktop Analysis Fee Amount of $205.00 exceeds tolerance of $175.00. Sufficient cure of $30.00 was provided to the borrower at Closing | Reviewer Comment (2022-08-31): Sufficient Cure Provided At Closing |
08/31/2022 | 1 | A | CA | Primary | Purchase | Final CD evidences Cure | A | A | A | A | A | A | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639601 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | NY subprime counseling disclosure not provided to the borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639601 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | NY subprime counseling disclosure not provided to the borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639601 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | NY subprime counseling disclosure not provided to the borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639601 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.78000 + 1.75%, or 7.53000%. Non-Compliant SubPrime Loan. | NY subprime counseling disclosure not provided to the borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639601 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | NY subprime counseling disclosure not provided to the borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Refinance - Cash-out - Other | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639603 | Compliance | Compliance | State Compliance | State HPML | North Carolina Rate Spread Threshold Test Compliant | North Carolina Rate Spread Home Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.37% + 1.5%, or 6.87000%. Compliant Rate Spread Home Loan. | APR of [Redacted]% is in excess of allowable threshold of APOR 5.37% + 1.5%, or 6.87000% | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NC | Primary | Purchase | Within 90 days of closing and prior to institution of any action against the lender, (1) notify the borrower, and (2) make appropriate restitution at the option of the borrower to either (a) make the loan comply with prohibited acts and practices or (b) change the terms of the loan in a manner beneficial to the borrower so the loan is no longer rate spread. (Narrow Defense - Requires CHD Approval) Within 120 days of discovery , which compliance failure was not intentional and resulted from a bona fide error, creditor must: (1) provide Lender Attestation to AMC attesting the failure was not intentional and was a bona fide error notwithstanding procedures in place to prevent such loans from being made (specific details on how rate spread home loan was made despite procredures to prevent); (2) notify the borrower, and make appropriate restitution at the option of the borrower to either (a) make the loan comply with prohibited acts and practices or (b) change the terms of the loan in a manner beneficial to the borrower so the loan is no longer rate spread. |
B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639603 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Appraisal receipt date is [Redacted], however appraisal signature date is [Redacted] Provide evidence the borrower received all copies of the appraisal | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NC | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639604 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Missing paid invoices of appraisal and final inspection fees paid outside of closing | Reviewer Comment (2022-09-06): Received, Clearing. Seller Comment (2022-09-06): Comment from [Redacted] ([Redacted]): Per final CD, required cash to close [Redacted], plus [Redacted] months PITIA [Redacted], total required[Redacted] to close. We've verified the transaction activities of People's [Redacted] [Redacted] at [Redacted], [Redacted] [Redacted]at[Redacted], and[Redacted] [Redacted] at[Redacted], total asset[Redacted], which is sufficient to cover this transaction. Also, attached EMD cancelled check, bank statements, Appraisal fee [Redacted] paid receipt and Final inspection fee [Redacted]paid receipt. |
09/06/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639604 | Compliance | Compliance | Federal Compliance | FACTA | Federal FACTA Disclosure Timing Test | FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score. | Reviewer Comment (2022-09-06): accepted as is. |
2 | B | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639604 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-09-06): accepted as is. |
2 | B | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639604 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-06): accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639604 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.30000 + 1.75%, or 7.05000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-06): accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639604 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-09-06): accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639605 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NJ | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639606 | Compliance | Compliance | State Compliance | State HPML | Massachusetts HPML Threshold Test Compliant | Massachusetts Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.37% + 1.5%, or 6.87000% Compliant Higher Priced Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MA | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639606 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $[Redacted]exceeds tolerance of $[Redacted]plus 10% or $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-09-06): Sufficient Cure Provided At Closing |
09/06/2022 | 1 | A | MA | Primary | Purchase | Final CD evidences Cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639607 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | No COC or Cure was provided to Borrower for tolerance overages | Reviewer Comment (2022-09-01): Sufficient Cure Provided At Closing |
09/01/2022 | 1 | A | AR | Primary | Purchase | Final CD evidences Cure | A | A | A | A | A | A | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639608 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | The file is missing a copy of the source of funds for the earnest money. | Reviewer Comment (2022-09-08): Received, Clearing. Seller Comment (2022-09-08): Comment from [Redacted] ([Redacted]): Attached EMD cancelled check is sourcing the funds. |
09/08/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639608 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | The file is missing a copy of the List of Homeownership Counseling. | Reviewer Comment (2022-09-08): Accepted as is. |
2 | B | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639608 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: File does not contain evidence that analysis of borrower's ability to repay was performed based on verified income, obligations, assets, and/or employment using PITI payment based on fully-indexed rate with fully-amortizing payment and taking into account payments on any simultaneously-closed loans. | Reviewer Comment (2022-09-08): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639608 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | The file is missing proof of the Counseling Disclosure. | Reviewer Comment (2022-09-08): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639608 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | The file is missing proof. | Reviewer Comment (2022-09-08): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639608 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | The file is missing proof. | Reviewer Comment (2022-09-08): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639608 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.30000 + 1.75%, or 7.05000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-08): Accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639608 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-09-08): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639609 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | The file is missing a copy of the source of funds for the earnest money. | Reviewer Comment (2022-08-30): Received, Clearing. Seller Comment (2022-08-30): Attached cancelled check is evidencing the source of EMD. |
08/30/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639609 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: File does not contain evidence that analysis of borrower's ability to repay was performed based on verified income, obligations, assets, and/or employment using PITI payment based on fully-indexed rate with fully-amortizing payment and taking into account payments on any simultaneously-closed loans. | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639609 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.78000 + 1.75%, or 7.53000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639609 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639609 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639609 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639609 | Compliance | Compliance | Federal Compliance | Missing Non-Required Data | (Missing Data) Last Rate Set Date | Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing. | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639610 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639610 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639610 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.30000 + 1.75%, or 7.05000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639611 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639611 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639611 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of 8.44750% or Final Disclosure APR of 8.46500% is in excess of allowable threshold of Prime Mortgage Market Rate 5.30000 + 1.75%, or 7.05000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639612 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: Borrower's ability to repay not verified with reliable documentation. | Document not Provided in File | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639612 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Document not Provided in File | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639612 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Document not Provided in File | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639612 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.30000 + 1.75%, or 7.05000%. Non-Compliant SubPrime Loan. | Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 6.87000% | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639612 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Document not Provided in File | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639612 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $[Redacted]exceeds tolerance of $[Redacted]plus 10% or $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | $[Redacted]Lender Cure was Provided | Reviewer Comment (2022-08-25): Sufficient Cure Provided At Closing |
08/25/2022 | 1 | A | NY | Primary | Purchase | Final CD evidences Cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639613 | Compliance | Compliance | State Compliance | Misc. State Level | Ohio Consumer Sales Practices Act (Acknowledgement of Receipt of Home Mortgage Loan Information Document Not Retained by Lender) | Ohio Consumer Sales Practices Act: Acknowledgement of Receipt of Home Mortgage Loan Information Document not retained by lender. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | OH | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639613 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-08-29): Sufficient Cure Provided At Closing |
08/29/2022 | 1 | A | OH | Primary | Purchase | Final CD evidences Cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639615 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | New York Subprime disclosure not evident in file. | Reviewer Comment (2022-09-06): accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639615 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.81000 + 1.75%, or 7.56000%. Non-Compliant SubPrime Loan. | New York Subprime disclosure not evident in file. | Reviewer Comment (2022-09-06): accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639615 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-09-01): Sufficient Cure Provided At Closing |
09/01/2022 | 1 | A | NY | Primary | Purchase | Final CD evidences Cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639615 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | HOI coverage is insufficient by $[Redacted]. Provide updated policy reflecting minimum coverage of $[Redacted]OR provide copy of insurer's replacement cost estimate supporting current coverage amount. | Reviewer Comment (2022-09-06): Received, Clearing. Seller Comment (2022-09-06): Comment from [Redacted] [Redacted]): Dwelling coverage:[Redacted] (Dwelling [Redacted] + Increased Dwelling [Redacted]+ Dwelling Extension [Redacted]) per attached HOI is sufficient to cover the replacement cost [Redacted] per attached RCE. |
09/06/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639616 | Compliance | Compliance | State Compliance | State Defect | Illinois SB 1894 | IL Predatory Lending Database Program (SB 1894) - Certificate of Compliance or Exemption not attached to mortgage for recording. | Reviewer Comment (2022-08-30): Received certificate of compliance Seller Comment (2022-08-30): Please see attached for the Certificate of Compliance. |
08/30/2022 | 1 | A | IL | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639617 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Hazard coverage of $[Redacted]is insufficient to cover the mortgage amount of $[Redacted]with an estimated cost new of $[Redacted]. Please provide a letter from the Insurer stating the maximum insurable amount and/or a replacement costs estimator from the insurer. | Reviewer Comment (2022-09-08): RCE received Seller Comment (2022-09-08): Comment from [Redacted]([Redacted]): Dwelling coverage [Redacted] is sufficient to cover the replacement cost of [Redacted] per attached RCE |
09/08/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639617 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Document not provided | Reviewer Comment (2022-09-08): Client accepts as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639617 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.51000 + 1.75%, or 7.26000%. Non-Compliant SubPrime Loan. | Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 7.26000%. | Reviewer Comment (2022-09-08): Client accepts as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639617 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Document not provided | Reviewer Comment (2022-09-08): Client accepts as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639618 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | A copy of Donor's cancelled check was in the file and was deposited in Borrower's bank account; however, evidence of donor's bank statement reflecting withdrawal of gift funds was missing. Final Closing Disclosure does not reflect funds received. | Reviewer Comment (2022-09-01): Received, Clearing. Seller Comment (2022-09-01): Per attached CDL guideline, source of gift funds requests gift letter + donor's cancelled check/wire confirmation + borrower's bank statement evidencing deposit of donor's gift. So it meets our requirement. Please clarify. Also, attached transfer confirmation and bank statement for EMD ([Redacted]+ [Redacted] +[Redacted]), total [Redacted] is reflecting in final CD. |
09/01/2022 | 1 | A | IN | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639618 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | Reviewer Comment (2022-09-01): Received, Clearing. Seller Comment (2022-09-01): Per attached CDL guideline, source of gift funds requests gift letter + donor's cancelled check/wire confirmation + borrower's bank statement evidencing deposit of donor's gift. So it meets our requirement. Please clarify. |
09/01/2022 | 1 | A | IN | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639618 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | Reviewer Comment (2022-09-01): Received, Clearing. Seller Comment (2022-09-01): Per attached CDL guideline, source of gift funds requests gift letter + donor's cancelled check/wire confirmation + borrower's bank statement evidencing deposit of donor's gift. So it meets our requirement. Please clarify. |
09/01/2022 | 1 | A | IN | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639625 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Guidelines shows the minimum reserves requirement is 3 months | Reviewer Comment (2022-08-26): Received, Clearing. Seller Comment (2022-08-26): Per final CD, cash to close required [Redacted] plus[Redacted] months PITIA [Redacted], total required [Redacted]. We've verified assets from the transaction activities of[Redacted] [Redacted] at[Redacted] and [Redacted] [Redacted]at[Redacted], total asset is [Redacted], which is sufficient for this transaction. Please see attached wire confirmation for [Redacted] down payment, it was debited on [Redacted] before the date of [Redacted][Redacted]statement. |
08/26/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639625 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | The file is missing a copy of the List of Homeownership Counseling. | Reviewer Comment (2022-08-26): Accepted as is. |
2 | B | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639626 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | There is no evidence the appraisal were delivered to the borrower. | Reviewer Comment (2022-08-30): Received, Clearing. |
08/30/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639626 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | There is no evidence the appraisal were delivered to the borrower. | Reviewer Comment (2022-08-30): Received, Clearing. |
08/30/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639626 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.58% + 1.5%, or 7.08000%. Non-Compliant Higher Priced Mortgage Loan. | Loan is identified as Higher priced mortgage loan. APR of [Redacted]% is in excess of allowable threshold of APOR 5.58% + 1.5%, or 7.08000% | Reviewer Comment (2022-09-08): [Redacted] received Corrected CD, LOE to borrower, copy of cure refund and proof of mailing to refund the [Redacted] appraisal fee on flipped property curing HPML requirements. |
09/08/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639626 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Flipped Property - Borrower Charged for 2 Appraisals) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Flipped Property - Creditor improperly charged consumer for two (2) appraisals. | Closing disclosure reflect borrower paid two separate fee for Appraisal fee and 2nd Appraisal before closing | Reviewer Comment (2022-09-08): [Redacted] received PCCD, LOE to borrower, copy of cure refund for [Redacted] and proof of mailing received. Second appraisal fee has been refunded to borrower. Seller Comment (2022-09-02): Comment from [Redacted] ([Redacted]): Please see attached for the PCCD, LOE, Proof of delivery, and proof of refund. |
09/08/2022 | 2 | B | NY | Primary | Purchase | Provide evidence of the refund of the amount charged to the consumer for the second appraisal performed on the subject property. (Include a copy of the Refund Check, Proof of Delivery, and Cover Letter) | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639626 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | There is no evidence the appraisal were delivered to the borrower. | Reviewer Comment (2022-08-30): Received, Clearing. Seller Comment (2022-08-30): Please see attached for the appraisal delivery letter. |
08/30/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639626 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | There is no evidence the appraisal were delivered to the borrower. | Reviewer Comment (2022-08-30): Received, Clearing. Seller Comment (2022-08-30): Please see attached for the appraisal delivery letter. |
08/30/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639626 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | List of Homeownership Counseling Organizations not in file | Reviewer Comment (2022-09-08): Accepted as is. |
2 | B | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639626 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: Borrower's ability to repay not verified with reliable documentation. | Due to missing documentation | Reviewer Comment (2022-09-08): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639626 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-08): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639626 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Subprime disclosure is not provided in file | Reviewer Comment (2022-09-08): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639626 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Notice of tax and insurance is not provided to borrower. | Reviewer Comment (2022-09-08): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639626 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.51000 + 1.75%, or 7.26000%. Non-Compliant SubPrime Loan. | The loan is not compliant to subprime loan due to missing disclosures. | Reviewer Comment (2022-09-08): Accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639626 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | An internet search or other satisfactory verification of the business is required with documentation to be included in the credit file to support the business's existence. Quontic staff to make notation/explanation on the 1008 is required if there are no returns when attempting an internet search |
Reviewer Comment (2022-08-30): Received, Clearing. Seller Comment (2022-08-30): Please see attached Tel number Google search, CPA Letter, and Schedule C for the borrower's self employed verification. |
08/30/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639627 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Hazard coverage of $[Redacted]is insufficient to cover the mortgage amount of $[Redacted]with an estimated cost new of $[Redacted]. Please provide a letter from the Insurer stating the maximum insurable amount | Reviewer Comment (2022-09-09): Received, Clearing. Buyer Comment (2022-09-09): Comment from [Redacted]([Redacted]): please note that it's a PUD in FL, there is no RCE required by FL local law, also we have master insurance for common area, and HOI indicates[Redacted] Replacement cost, which is sufficient in this scenario. |
09/09/2022 | 1 | A | FL | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639629 | Property | Property - Appraisal | Appraisal Reconciliation | Property - Appraisal | Appraisal is required to be in name of Lender | - | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NJ | Primary | Purchase | B | B | A | A | B | B | B | B | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639629 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Borrower acknowledged the appraisal receipt on XXXX however the appraisal on file is signed XXXX. Provide evidence the borrower received the most receipt appraisal | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NJ | Primary | Purchase | B | B | A | A | B | B | B | B | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639631 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Evidence of earlier borrower receipt was not found in file. | Reviewer Comment (2022-09-07): Received evidence of appraisal receipt |
09/07/2022 | 1 | A | FL | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639631 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.58% + 1.5%, or 7.08000%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-09-07): Received evidence of appraisal receipt |
09/07/2022 | 1 | A | FL | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639631 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Reviewer Comment (2022-09-07): Appraisal receipt received |
09/07/2022 | 1 | A | FL | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639631 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Evidence of earlier borrower receipt was not found in file. | Reviewer Comment (2022-09-07): Received evidence of appraisal receipt Seller Comment (2022-09-07): Comment from [Redacted] ([Redacted]): Please see attached for the appraisal delivery letter. |
09/07/2022 | 1 | A | FL | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639632 | Credit | Loan Package Documentation | Application / Processing | Missing Document | Missing Document: Tax Certificate not provided | Reviewer Comment (2022-09-08): Received, Clearing. Buyer Comment (2022-09-08): Comment from [Redacted] ([Redacted]): Subject property is a new construction. there is no tax history. We used [Redacted] of purchase price [Redacted] for property tax calculation. So it's [Redacted] [Redacted]property tax. |
09/08/2022 | 1 | A | TX | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639632 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided Within 3 Business Days of Application | RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Organizations not provided to applicant within three (3) business days of application. | List of Homeownership Counseling Organizations was provided 06/13/2022 | Reviewer Comment (2022-09-08): Accepted as is. |
2 | B | TX | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639634 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Hazard coverage of $[Redacted]is insufficient to cover the mortgage amount of $[Redacted]. Please provide a letter from the Insurer stating the maximum insurable amount and/or a replacement costs estimator from the insurer. | Reviewer Comment (2022-09-06): Received, Clearing. Buyer Comment (2022-09-06): Comment from [Redacted] ([Redacted]): Hazard coverage of [Redacted] is sufficient to cover the mortgage amount of [Redacted]. Please clarify. |
09/06/2022 | 1 | A | PA | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639635 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Unable to determine due to missing subprime disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639635 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | File is missing a copy of state Subprime Disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639635 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.51000 + 1.75%, or 7.26000%. Non-Compliant SubPrime Loan. | APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.51000 + 1.75%, or 7.26000%. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639635 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | File is missing a copy of Notice of Taxes and Insurance | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639635 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Appraisal Fee was last disclosed as $[Redacted]on LE but disclosed as $[Redacted]on Final Closing Disclosure. File does not contain a valid COC for this fee, nor evidence of cure in file. Provide a post-close CD disclosing the tolerance cure to include $[Redacted], a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made. | Reviewer Comment (2022-09-02): Sufficient Cure Provided At Closing |
09/02/2022 | 1 | A | NY | Primary | Purchase | Final CD evidences Cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639635 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | File is missing a copy of Counseling Disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639636 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-08-29): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639636 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-08-29): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639636 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.51000 + 1.75%, or 7.26000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-08-29): Accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639636 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: Investor qualifying total debt ratio discrepancy. | Lender used biweekly pay in the amount of $[Redacted]for borrower job1, however the YTD calc is $[Redacted]. | Reviewer Comment (2022-08-29): Received, Clearing. Seller Comment (2022-08-29): Per attached processing certificate, borrower [Redacted] XXXX employer XXXX [Redacted] Inc and XXXX are one in the same. So borrower's monthly income [Redacted] is calculated based on YTD from both XXXX [Redacted] Inc and [Redacted]per attached VOE. Then, DTI is below [Redacted] |
08/29/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639637 | Credit | Loan Package Documentation | Application / Processing | Missing Document | Missing Document: Tax Certificate not provided | File is missing a copy of the Tax certificate for verification | Reviewer Comment (2022-08-29): Received, cleared Seller Comment (2022-08-29): Please see attached tax certificate. |
08/29/2022 | 1 | A | TX | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639638 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Evidence of earlier borrower receipt was not found in file. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639638 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided within Three Days of Application) | New York Subprime Loan: Counseling Disclosure not provided to borrower within three days of application. | Evidence of earlier borrower receipt was not found in file. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639638 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639638 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.30000 + 1.75%, or 7.05000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639641 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.58% + 1.5%, or 7.08000%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-09-08): Received, Clearing. |
09/08/2022 | 1 | A | NJ | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639641 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal Not Obtained Timely) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained prior to consummation. | The Appraisal in the file has a report date of [Redacted] after note date of [Redacted], and an effective date as [Redacted]. | Reviewer Comment (2022-09-08): Received, Clearing. Seller Comment (2022-09-08): Comment from [Redacted] ([Redacted]): The appraisal provided had a signature date that reflected a revision made. Please see attached for the original appraisal dated prior to consummation. |
09/08/2022 | 1 | A | NJ | Primary | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639642 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Right to Receive Copy of Appraisal provided date is [Redacted] | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639642 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided Within 3 Business Days of Application | RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Organizations not provided to applicant within three (3) business days of application. | List of Homeownership Counseling Organizations not provided to applicant within three (3) business days of application | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639643 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | File is missing a copy of Counseling Disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639643 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Unable to determine due to missing subprime disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639643 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Unable to determine due to missing subprime disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639643 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.54000 + 1.75%, or 7.29000%. Non-Compliant SubPrime Loan. | APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.54000 + 1.75% or 7.29000% | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639643 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | File is missing a copy of Notice of Taxes and Insurance | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639643 | Credit | Asset | Asset Calculation / Analysis | Asset | Available for Closing is insufficient to cover Cash From Borrower. | Missing evidence of additional assets and source in divorce attorney esc account | Reviewer Comment (2022-09-07): Received, Clearing. Seller Comment (2022-09-07): Comment from [Redacted] ([Redacted]): Per final CD, required cash to close [Redacted], plus [Redacted] months PITIA [Redacted], total required [Redacted] to close. We've verified the transaction activities of [Redacted] [Redacted] at [Redacted]and[Redacted] #[Redacted] at [Redacted], plus [Redacted] divorce attorney escrow holding, total asset at[Redacted], which is sufficient to cover this transaction. |
09/07/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639643 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Missing evidence of additional assets and source in divorce attorney esc account | Reviewer Comment (2022-09-07): Received, Clearing. Seller Comment (2022-09-07): Comment from [Redacted] ([Redacted]): Per final CD, required cash to close [Redacted], plus [Redacted] months PITIA [Redacted], total required [Redacted] to close. We've verified the transaction activities of [Redacted][Redacted] at[Redacted] and [Redacted] [Redacted] at [Redacted], plus [Redacted] divorce attorney escrow holding, total asset at [Redacted], which is sufficient to cover this transaction. |
09/07/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639643 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Escrowed Property Costs Year 1 - October 2018 Testing | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on[Redacted] not accurate. | Property expenses calculated as follows: Taxes = $[Redacted]monthly based on tax cert, Hazard insurance = $[Redacted]. The annual disbursements based upon the file documentation over 12 months is $[Redacted], however page 4 of the final CD reflects $[Redacted] | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639643 | Credit | Loan Package Documentation | Application / Processing | Missing Document | Missing Document: Divorce Decree / Child Support not provided | Missing divorce decree awarding the REO and related expenses to ex-husband | Reviewer Comment (2022-09-12): Received, cleared Seller Comment (2022-09-12): Comment from [Redacted]([Redacted]): Please see attached Executed Divorce Decree. |
09/12/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639644 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Hazard coverage of $[Redacted]is sufficient to cover the mortgage amount of $[Redacted], however is insufficient to cover the estimated cost new of $[Redacted]. Please provide a letter from the Insurer stating the maximum insurable amount and/or a replacement costs estimator from the insurer. | Reviewer Comment (2022-09-13): Received, Clearing. Seller Comment (2022-09-13): Comment from[Redacted] ([Redacted]): Dwelling coverage[Redacted] plus other structures [Redacted], which is[Redacted], so it is sufficient to cover the replacement cost of [Redacted]per attached RCE. |
09/13/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639644 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.54000 + 1.75%, or 7.29000%. Non-Compliant SubPrime Loan. | Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 7.11000% | Reviewer Comment (2022-09-13): Accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639644 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Document not provided in file | Reviewer Comment (2022-09-13): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639644 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Document not provided in file | Reviewer Comment (2022-09-13): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639644 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Document not provided in file | Reviewer Comment (2022-09-13): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639644 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Document not provided in file | Reviewer Comment (2022-09-13): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639646 | Credit | Loan Package Documentation | Application / Processing | Missing Document | Missing Document: Tax Certificate not provided | Reviewer Comment (2022-08-29): Received tax cert Seller Comment (2022-08-29): Please see attached tax certificate. |
08/29/2022 | 1 | A | TX | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639646 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | File was missing a copy of List of Homeownership Counselling | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | TX | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639647 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639647 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639647 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639647 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.51000 + 1.75%, or 7.26000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639648 | Compliance | Compliance | State Compliance | State HPML | North Carolina Rate Spread Threshold Test Compliant | North Carolina Rate Spread Home Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.61% + 1.5%, or 7.11000%. Compliant Rate Spread Home Loan. | Reviewer Comment (2022-09-19): Accepted as is. |
2 | B | NC | Primary | Purchase | Within 90 days of closing and prior to institution of any action against the lender, (1) notify the borrower, and (2) make appropriate restitution at the option of the borrower to either (a) make the loan comply with prohibited acts and practices or (b) change the terms of the loan in a manner beneficial to the borrower so the loan is no longer rate spread. (Narrow Defense - Requires CHD Approval) Within 120 days of discovery , which compliance failure was not intentional and resulted from a bona fide error, creditor must: (1) provide Lender Attestation to AMC attesting the failure was not intentional and was a bona fide error notwithstanding procedures in place to prevent such loans from being made (specific details on how rate spread home loan was made despite procredures to prevent); (2) notify the borrower, and make appropriate restitution at the option of the borrower to either (a) make the loan comply with prohibited acts and practices or (b) change the terms of the loan in a manner beneficial to the borrower so the loan is no longer rate spread. |
C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639648 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Hazard coverage of $[Redacted]x 25% is sufficient to cover the mortgage amount of $[Redacted]however the appraiser did not provide an estimated cost to rebuild. Please provide a letter from the Insurer stating the maximum insurable amount and/or a replacement costs estimator from the insurer. | Reviewer Comment (2022-09-19): Received, Clearing. Seller Comment (2022-09-19): Comment from [Redacted] ([Redacted]): Dwelling coverage of [Redacted] is sufficient to cover the replacement cost of [Redacted] per attached RCE. |
09/19/2022 | 1 | A | NC | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639651 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Amount of Non-Escrowed Property Costs over Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on [Redacted] not accurate. | Non escrowed payments is disclosed as $[Redacted]however the HOA dues per month is $[Redacted]a total of $[Redacted]per year. Provide a post close CD correcting the fee and a copy of the letter of explanation letter sent to the Borrower disclosing the changes made. | Reviewer Comment (2022-09-12): Accepted as is. |
2 | B | PA | Primary | Refinance - Rate/Term | Letter of Explanation & Corrected Closing Disclosure | D | B | D | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639651 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Purchase Agreement / Sales Contract not provided | Transaction is refinance of land contract. Missing contract for deed dated [Redacted]. | Reviewer Comment (2022-09-12): Received, Clearing. Seller Comment (2022-09-12): Comment from [Redacted] ([Redacted]): Please see attached contract for deed. |
09/12/2022 | 1 | A | PA | Primary | Refinance - Rate/Term | D | B | D | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639652 | Compliance | Compliance | State Compliance | State HPML | Massachusetts HPML Threshold Test Compliant | Massachusetts Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.37% + 1.5%, or 6.87000% Compliant Higher Priced Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MA | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639652 | Compliance | Compliance | State Compliance | Misc. State Level | Massachusetts Mortgage Lender and Broker Regulation (Ability to Repay not Verified) | Massachusetts Mortgage Lender and Broker Regulation: File does not contain evidence that analysis of borrower's ability to repay was performed based on verified income, obligations, assets, and/or employment using PITI payment based on fully indexed rate and fully amortizing payment, if applicable | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MA | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639652 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $494.00 exceeds tolerance of $[Redacted]plus 10% or $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Borrower waa not provided with a COC. | Reviewer Comment (2022-08-25): Sufficient Cure Provided At Closing |
08/25/2022 | 1 | A | MA | Primary | Purchase | Final CD evidences Cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639654 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Flipped Property - Borrower Charged for 2 Appraisals) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Flipped Property - Creditor improperly charged consumer for two (2) appraisals. | Reviewer Comment (2022-09-08): Lender provided a corrected CD, copy of [Redacted] refund check, LOE to borrower and proof of delivery. Seller Comment (2022-09-02): Comment from [Redacted] ([Redacted]): Please see attached for the PCCD, LOE, Proof of delivery, and proof of refund. |
09/08/2022 | 2 | B | NY | Primary | Purchase | Provide evidence of the refund of the amount charged to the consumer for the second appraisal performed on the subject property. (Include a copy of the Refund Check, Proof of Delivery, and Cover Letter) | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639654 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639654 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639654 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.51000 + 1.75%, or 7.26000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639654 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.58% + 1.5%, or 7.08000%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-09-08): HPML violation is not compliant. |
09/08/2022 | 1 | A | NY | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639655 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | FL | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639656 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | The file is missing a copy of the List of Homeownership Counseling Organizations | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | IN | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639657 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.58% + 1.5%, or 7.08000%. Non-Compliant Higher Priced Mortgage Loan. | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.58% + 1.5%, or 7.08000%. | Reviewer Comment (2022-08-30): Received, Clearing. |
08/30/2022 | 1 | A | IN | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639657 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Verification appraisal was delivered to borrower was not provided. | Reviewer Comment (2022-08-30): Received, Clearing. |
08/30/2022 | 1 | A | IN | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639657 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Verification appraisal was delivered to borrower was not provided. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | IN | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639657 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Verification appraisal was delivered to borrower was not provided. | Reviewer Comment (2022-08-30): Received, Clearing. Seller Comment (2022-08-30): Please see attached for the appraisal delivery letter. |
08/30/2022 | 1 | A | IN | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639657 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Amount of Non-Escrowed Property Costs over Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on [Redacted] not accurate. | Per appraisal, the annual HOA fee is $[Redacted]however, annual non-escrowed property costs on the CD are reflected as $[Redacted]. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | IN | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639658 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639658 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.51000 + 1.75%, or 7.26000%. Non-Compliant SubPrime Loan. | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.51000 + 1.75%, or 7.26000%. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639658 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Amount of Non-Escrowed Property Costs over Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on 08/01/2022 not accurate. | HOA monthly amount is $[Redacted]or $[Redacted]over 10 months. The final CD, page 4 reflects [Redacted] | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639658 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Reviewer Comment (2022-09-06): Appraisal transfer letter is on file |
09/06/2022 | 1 | A | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639660 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Initial Loan Estimate Timing Electronically Provided | TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application. | The LE was e-signed on [Redacted], which is greater than 3 business days from application date of [Redacted] | Reviewer Comment (2022-08-31): [Redacted] received missing initial LE dated [Redacted] which was not signed electronically by borrower. Seller Comment (2022-08-30): Please see attached for the Initial LE. |
08/31/2022 | 1 | A | FL | Second Home | Purchase | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639660 | Compliance | Compliance | Federal Compliance | TRID | TRID Settlement Service Provider Status | TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers. | Missing proof that the borrower was provided withe the list of service providers. | Reviewer Comment (2022-09-01): [Redacted] received [Redacted] LE |
09/01/2022 | 1 | A | FL | Second Home | Purchase | No Defined Cure | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639660 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Loan Estimate Seven Day Waiting Period | TILA-RESPA Integrated Disclosure: Loan Estimate was not delivered or placed in the mail to the borrower at least seven (7) business days prior to closing. | The initial LE dated [Redacted] is not dated at least 7 business days from the note date | Reviewer Comment (2022-09-01): [Redacted] received [Redacted] LE Seller Comment (2022-08-30): Please see attached for the Initial LE. |
09/01/2022 | 1 | A | FL | Second Home | Purchase | No Defined Cure | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639661 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639661 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: Borrower's ability to repay not verified with reliable documentation. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639661 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639661 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639661 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639661 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate 5.70000 + 1.75%, or 7.45000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639661 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Transfer ReInspection fee increased from $[Redacted]to $[Redacted]without a valid change of circumstance. A Credit for $[Redacted]was reflected on the final Closing Disclosure. | Reviewer Comment (2022-09-06): Sufficient Cure Provided At Closing |
09/06/2022 | 1 | A | NY | Primary | Purchase | Final CD evidences Cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639662 | Compliance | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Missing Lender's Initial 1003 | File is missing a copy of lender's initial 1003 | Reviewer Comment (2022-09-07): Initial 1003 received |
09/07/2022 | 1 | A | OR | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639662 | Compliance | Compliance | Federal Compliance | TRID | TRID Appraisal Disclosure - ECOA Timing | ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date. | The right to receive a copy of the Appraisal Disclosure was not provided within 3days of the loan application date | Reviewer Comment (2022-09-07): Initial LEs received |
09/07/2022 | 1 | A | OR | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639662 | Compliance | Compliance | Federal Compliance | TRID | TRID Appraisal Disclosure - HPML Timing | HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date. | The right to receive a copy of the Appraisal Disclosure was not provided within 3days of the loan application date | Reviewer Comment (2022-09-07): Initial 1003 received Seller Comment (2022-09-07): Comment from [Redacted] ([Redacted]: Please see attached for the HPML right to copy of Appraisal along with the initial 1003. |
09/07/2022 | 1 | A | OR | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639662 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | File is missing a copy List of Homeownership Counseling Organizations | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | OR | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639662 | Compliance | Compliance | Federal Compliance | TRID Defect | TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File | TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s). The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing. Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $[Redacted]may be required. | File is missing a copy of loan estimate | Reviewer Comment (2022-09-07): Initial LE received Seller Comment (2022-09-07): Comment from [Redacted] ([Redacted]): Please see attached for the loan estimates to this file. |
09/07/2022 | 1 | A | OR | Primary | Purchase | No Defined Cure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639662 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR 5.61% + 1.5%, or 7.11000%. Non-Compliant Higher Priced Mortgage Loan. | Loan is identified as higher priced mortgage loan. APR of [Redacted]% is in excess of allowable threshold of APOR 5.61% + 1.5%, or 7.11000%. | Reviewer Comment (2022-09-07): Initial LEs received |
09/07/2022 | 1 | A | OR | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639662 | Compliance | Compliance | Federal Compliance | Missing Application Date | Missing Initial Loan Application Test | No evidence of application date located in file. Compliance tests were run using an application date of 07/02/2022 which is 1 months prior to consummation. A lookback was performed to determine this application date. | File is missing a copy of initial 1003 | Reviewer Comment (2022-09-07): Initial 1003 received |
09/07/2022 | 1 | A | OR | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639662 | Compliance | Compliance | Federal Compliance | TILA | NMLS - Missing Evidence of Initial Loan Application Date | Truth in Lending Act (NMLSR Dodd- Frank 2014): Unable to determine compliance with NMLSR timing requirements due to missing evidence of initial loan application date. | File is missing initial loan application (1003). | Reviewer Comment (2022-09-07): Initial 1003 received Seller Comment (2022-09-07): Comment from [Redacted] ([Redacted]): Please see attached for the initial 1003. |
09/07/2022 | 1 | A | OR | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639663 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | Guidelines require separate [Redacted] and [Redacted]letter. CPA letter and P&L are combined on 1 document | Reviewer Comment (2022-09-12): Received, Clearing. Seller Comment (2022-09-12): Comment from [Redacted] ([Redacted]): Per attached [Redacted] guidelines, it doesn't mention that P&L and CPA letter must be separated. It is ok and as long as the Profit & Loss and CPA confirming business information are provided by CPA. |
09/12/2022 | 1 | A | NJ | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639665 | Credit | Loan Package Documentation | Loan File | Missing Document | Missing Document: Hazard Insurance Policy not provided | Lender to provide master policy. | Reviewer Comment (2022-09-07): Received, Clearing. Seller Comment (2022-09-07): Comment from [Redacted] ([Redacted]): Please see attached master insurance policy. |
09/07/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639665 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639665 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639665 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Escrow Not Established) | New York Subprime Loan: Mandatory escrow account not established for the collection of property taxes and insurance. (Note: Does not apply to a subordinate lien when the taxes and insurance are escrowed through another home loan. It also does not apply if the borrower can demonstrate a record of [Redacted]months of timely payments of taxes and insurance on a previous home loan.) | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639665 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]or Final Disclosure APR of [Redacted]is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted] . Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639665 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639665 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided at Application but within Three Days) | New York Subprime Loan: Counseling Disclosure not provided to borrower at the time of application, but within three days of application. | Please provide document | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639665 | Credit | Insurance | Insurance Documentation | Insurance | Hazard Insurance Error: Missing HO-6 policy, blanket hazard insurance policy provided does not contain unit interior coverage. | Missing evidence of interior coverage | Reviewer Comment (2022-09-07): Received, Clearing. Seller Comment (2022-09-07): Comment from [Redacted] ([Redacted]): Subject property is Co-operative. Per [Redacted] guidelines, it's not required HO6 but co-op master insurance for co-op. Attached master insurance policy. |
09/07/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639666 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | File is missing List of Homeownership Counseling Organizations. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639666 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | File is missing New York Subprime Loan: Counseling Disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639666 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | This can't be verified due to missing documents | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639666 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]or Final Disclosure APR of [Redacted]is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted]. Non-Compliant SubPrime Loan. | Loan is identified to higher priced mortgage loan. APR of [Redacted]is in excess of allowable threshold of APOR [Redacted] | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639666 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | File is missing Notice of Taxes and Insurance | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639667 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Verification appraisal was delivered to borrower was not provided. | Reviewer Comment (2022-09-09): Received verification of appraisal receipt |
09/09/2022 | 1 | A | IL | Primary | Purchase | C | A | C | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639667 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]or Final Disclosure APR of [Redacted]is in excess of allowable threshold of APOR [Redacted]. Non-Compliant Higher Priced Mortgage Loan. | Verification appraisal was delivered to borrower was not provided. | Reviewer Comment (2022-09-09): Received verification of appraisal receipt |
09/09/2022 | 1 | A | IL | Primary | Purchase | C | A | C | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639667 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant [Redacted]business days prior to consummation. | Verification appraisal was delivered to borrower was not provided. | Reviewer Comment (2022-09-09): Received verification of appraisal receipt Seller Comment (2022-09-09): Comment from [Redacted] ([Redacted]): Please see attached for the apprasial delivery letter. |
09/09/2022 | 1 | A | IL | Primary | Purchase | C | A | C | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639667 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | CPA letter is missing statement on good standing of the borrower's business | Reviewer Comment (2022-09-12): Received, Clearing. Seller Comment (2022-09-12): Comment from [Redacted] ([Redacted]): Per attached CPA letter and Schedule C, borrower files income under Schedule C, which indicates borrower is self-employed. Thus, borrower has no registered business, due to this the 'good standing' language would not be applicable, as there is no registry, agency or municipality for which they need to be in good standing for. |
09/12/2022 | 1 | A | IL | Primary | Purchase | C | A | C | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639668 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Appraisal Transfer Letter was Provided | Reviewer Comment (2022-08-26): Appraisal transfer letter on file |
08/26/2022 | 1 | A | MI | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639668 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Amount of Non-Escrowed Property Costs over Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted] on Final Closing Disclosure provided on [Redacted] not accurate. | Final CD disclosed estimated HOA Payment of $[Redacted]Annually; however correct amount is $[Redacted]as reflected on Appraisal Documant. Provide the following. Provide more document for more Clarification | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MI | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639671 | Compliance | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Missing Lender's Initial 1003 | File is missing a copy of initial 1003 | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NJ | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639671 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR [Redacted] . Non-Compliant Higher Priced Mortgage Loan. | Loan is identified as higher priced mortgage loan. APR of [Redacted] is in excess of allowable threshold of APOR [Redacted] |
Reviewer Comment (2022-09-09): Received, Clearing. |
09/09/2022 | 1 | A | NJ | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639671 | Compliance | Compliance | Federal Compliance | TRID | TRID Appraisal Disclosure - HPML Status | HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure. | File is missing a copy of right to receive a copy of the Appraisal Disclosure. | Reviewer Comment (2022-09-09): [Redacted] received [Redacted], [Redacted]& [Redacted] LE's, [Redacted] & [Redacted] changed circumstance and SSPL disclosure. Seller Comment (2022-09-08): Comment from [Redacted] ([Redacted]): Please see attached for the HPML notice of right to copy of appraisal. Attached is also the initial 1003 as a reference for the app date. |
09/09/2022 | 1 | A | NJ | Primary | Purchase | Good faith redisclosure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639671 | Compliance | Compliance | Federal Compliance | Missing Non-Required Data | (Missing Data) Last Rate Set Date | Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing. | File is missing a copy of rate lock | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NJ | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639671 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | File is missing a copy of List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NJ | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639671 | Compliance | Compliance | Federal Compliance | TRID Defect | TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File | TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s). The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing. Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to [Redacted] may be required. | File is missing copy of initial & final loan estimate | Reviewer Comment (2022-09-09): [Redacted] received [Redacted], [Redacted] & [Redacted] LE's, [Redacted] & [Redacted] changed circumstance and SSPL disclosure. Seller Comment (2022-09-07): Comment from [Redacted] ([Redacted]): Please see attached for the Loan Estimates to this file. |
09/09/2022 | 1 | A | NJ | Primary | Purchase | No Defined Cure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639671 | Compliance | Compliance | Federal Compliance | TRID | TRID Appraisal Disclosure - ECOA Status | ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure. | File is missing a copy of right to receive a copy of the Appraisal Disclosure. | Reviewer Comment (2022-09-09): [Redacted] received [Redacted], [Redacted] & [Redacted] LE's, [Redacted] & [Redacted] changed circumstance and SSPL disclosure. |
09/09/2022 | 1 | A | NJ | Primary | Purchase | Good faith redisclosure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639671 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis. Fee Amount of [Redacted] exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | SitusAMC received Redaction changed circumstance and SSPL disclosure. Changed Circumstance increasing fee did not reflect a valid reason for why fee was increased. Please provide additional information to support or cure would be due. | Reviewer Comment (2022-09-14): [Redacted] received valid COC dated [Redacted] Seller Comment (2022-09-13): Comment from [Redacted] ([Redacted]): Please see attached COC LE regarding this change. Seller Comment (2022-09-13): Comment from [Redacted] ([Redacted]): Please see attached for the COC LE provided to the borrower regarding this fee change. |
09/14/2022 | 1 | A | NJ | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639672 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Loan is Higher Priced Mortgage loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | FL | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639673 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | New York Subprime Loan Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639673 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639673 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted]. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639674 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639674 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted]. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639675 | Credit | Loan Package Documentation | Application / Processing | Missing Document | Missing Document: Fraud Report not provided | File was missing a copy of Fraud Report | Reviewer Comment (2022-08-30): Received, Clearing. Seller Comment (2022-08-30): Fraud report. |
08/30/2022 | 1 | A | CT | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639675 | Credit | Credit | Credit Documentation | Credit | No evidence of fraud report in file | - | Fraud Report not provided in File | Reviewer Comment (2022-08-30): Received, Clearing. Seller Comment (2022-08-30): Fraud report. |
08/30/2022 | 1 | A | CT | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639676 | Credit | Guideline | Guideline Issue | Guideline | Aged document: Primary Valuation is older than guidelines permit | - | Appraisal provided was XXXX | Reviewer Comment (2022-09-08): Received, Clearing. Seller Comment (2022-09-08): Comment from XXXX (XXXX): Please see attached updated appraisal with effective date XXXX. |
09/08/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639676 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.81360% or Final Disclosure APR of 7.76400% is in excess of allowable threshold of APOR 5.16% + 1.5%, or 6.66000%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-09-09): Received TRID appraisal disclosure |
09/09/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639676 | Compliance | Compliance | Federal Compliance | Missing Non-Required Data | (Missing Data) Last Rate Set Date | Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639676 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639676 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639676 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639676 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Escrow Not Established) | New York Subprime Loan: Mandatory escrow account not established for the collection of property taxes and insurance. (Note: Does not apply to a subordinate lien when the taxes and insurance are escrowed through another home loan. It also does not apply if the borrower can demonstrate a record of 12 months of timely payments of taxes and insurance on a previous home loan.) | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639676 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of 7.81360% or Final Disclosure APR of 7.76400% is in excess of allowable threshold of Prime Mortgage Market Rate 5.10000 + 1.75%, or 6.85000%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639676 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639676 | Compliance | Compliance | Federal Compliance | TRID | TRID Appraisal Disclosure - ECOA Timing | ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date. | right to receive a copy of the Appraisal Disclosure was provided 8/5/22 | Reviewer Comment (2022-09-09): SitusAMC received Initial 1003 application with application date of XXXX. |
09/09/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639676 | Compliance | Compliance | Federal Compliance | TRID | TRID Appraisal Disclosure - HPML Timing | HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date. | right to receive a copy of the Appraisal Disclosure was provided 8/5/22 | Reviewer Comment (2022-09-09): SitusAMC received initial 1003 application and initial LE Seller Comment (2022-09-07): Comment from XXXX (XXXX): Please see attached for the HPML right to copy of appraisal and the initial 1003. |
09/09/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639676 | Compliance | Compliance | Federal Compliance | TRID Defect | TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File | TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s). The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing. Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $8,589.87 may be required. | Loan Estimate was not provided | Reviewer Comment (2022-09-09): SitusAMC received XXXX LE's and XXXX Changed circumstance. Seller Comment (2022-09-07): Comment from XXXX (XXXX): Please see attached for the loan estimates to this file. |
09/09/2022 | 1 | A | NY | Primary | Purchase | No Defined Cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639676 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Recording Service Fee. Fee Amount of $35.00 exceeds tolerance of $0.00. Insufficient or no cure was provided to the borrower. | Appraisal Fee was last disclosed as $35 on LE but disclosed as $.00 on Final Closing Disclosure. File does not contain a valid COC for this fee, nor evidence of cure in file. Provide a post-close CD disclosing the tolerance cure to include $5.00, a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made. | Reviewer Comment (2022-09-09): SitusAMC received XXXX LE's and XXXX Changed circumstance. |
09/09/2022 | 1 | A | NY | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639676 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Municipal Lien Certificate Fee (MLC). Fee Amount of $255.86 exceeds tolerance of $0.00. Insufficient or no cure was provided to the borrower. | Appraisal Fee was last disclosed as $255.86 on LE but disclosed as $.00 on Final Closing Disclosure. File does not contain a valid COC for this fee, nor evidence of cure in file. Provide a post-close CD disclosing the tolerance cure to include $5.00, a copy of refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made. | Reviewer Comment (2022-09-09): SitusAMC received XXXX LE's and XXXX Changed circumstance. |
09/09/2022 | 1 | A | NY | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639676 | Compliance | Compliance | Federal Compliance | TRID | TRID Settlement Service Provider Status | Unable to determine if the borrower received Settlement Service Provider List due to missing information. | SitusAMC received XXXX LE's and XXXX Changed circumstance. SSPL disclosure is not dated. Provide a SSPL disclosure reflecting when issued. | Reviewer Comment (2022-09-19): Clearing |
09/19/2022 | 1 | A | NY | Primary | Purchase | No Defined Cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639676 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Review Fee. Fee Amount of $275.00 exceeds tolerance of $0.00. Insufficient or no cure was provided to the borrower. | SitusAMC received XXXX LE's and XXXX Changed circumstance. However, fee added on XXXX LE and then increased on XXXX CD. Changed circumstances do not give a valid reason for adding this fee on XXXX and then increasing the fee on XXXX. Please provide additional information to support why this fee was unknown at initial application and added and when lender became aware and why fee increased, unless $25 cure at closing was for that portion of the increase. | Reviewer Comment (2022-09-14): SitusAMC received valid COC with supporting updated Appraisal compliance report for the fee added. Also, sufficient cure provided at closing for the fee increased. Seller Comment (2022-09-13): Comment from XXXX (XXXX): This fee was added for the updated appraisal. Please see attached for reference. Also, final CD contained sufficient lender credits for the fee increase. |
09/14/2022 | 1 | A | NY | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639676 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Review Fee. Fee Amount of $275.00 exceeds tolerance of $250.00. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-09-14): Sufficient Cure Provided At Closing |
09/14/2022 | 1 | A | NY | Primary | Purchase | Final CD evidences Cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639676 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | P&L in the file only covers 7 months. Guideline requires 12 months P&L. | Reviewer Comment (2022-09-26): Received, Clearing. Seller Comment (2022-09-26): Comment from XXXX (XXXX): Please see attached 12 months P&L and final revised 1008. |
09/26/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639677 | Compliance | Compliance | Federal Compliance | RESPA | RESPA - Initial Escrow Account statement Inaccurate | RESPA: Initial escrow account statement does not match charges on HUD-1/Final Closing Disclosure. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||||
| 438639677 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639677 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639677 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of or Final Disclosure APR of is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted] Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639677 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639677 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided at Application but within Three Days) | New York Subprime Loan: Counseling Disclosure not provided to borrower at the time of application, but within three days of application. | please provide document | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639678 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Document not Provided in file | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639678 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Document not Provided in file | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639678 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Document not Provided in file | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639678 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted] Non-Compliant SubPrime Loan. | Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR [Redacted] | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639678 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Document not Provided in file | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639680 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee. Fee Amount of [Redacted]exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | Second Appraisal Fee was not disclosed on Loan Estimate. File does not contain a valid COC for this fee, nor evidence of cure. | Reviewer Comment (2022-09-13): [Redacted] Received explanation from the seller regarding the addition of fees. Supporting documents available on file. No cure is required Seller Comment (2022-09-12): Comment from [Redacted] ([Redacted]): The appraisal re-certification was required due to the original appraisal being dated passed [Redacted] days from closing. Please see attached for the appraisal and appraisal re-cert for reference. Reviewer Comment (2022-09-09): [Redacted] received valid COC dated [Redacted] stating "Appraisal Recertification Fee $[Redacted] added" the information provided is not sufficient to rebaseline the fee. Please provide COC with more information on what was the change due to which Re certification required and when was the lender became aware of the change or provide cure. Cure consists of Corrected CD, LOE to borrower, proof of mailing and copy of refund check. Seller Comment (2022-09-08): Comment from [Redacted] ([Redacted]): Please see attached for the COC CD provided to the borrower regarding this fee change. |
09/13/2022 | 1 | A | MA | Second Home | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639680 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee. Fee Amount of [Redacted]exceeds tolerance of [Redacted]. Insufficient or no cure was provided to the borrower. | Appraisal Re-Inspection Fee was not disclosed on Loan Estimate. File does not contain a valid COC for this fee, nor evidence of cure. | Reviewer Comment (2022-09-09): [Redacted] received valid COC dated [Redacted]. Seller Comment (2022-09-08): Comment from [Redacted] ([Redacted]): Please see attached for the COC CD provided to the borrower regarding this fee change. |
09/09/2022 | 1 | A | MA | Second Home | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639680 | Compliance | Compliance | Federal Compliance | Missing Required Data (other than HUD-1 or Note) | Disparity in Occupancy - Higher Priced as Primary | The mortgage loan file contains documenting evidence the consumer intends to occupy the subject property as their primary residence. (Compliance testing performed based on the Occupancy Type of Second Home). If tested as primary residence, loan exceeds one or more HPML thresholds. Additional compliance testing required to determine if loan would be a compliant or non-compliant HPML. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MA | Second Home | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639681 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR [Redacted]. Non-Compliant Higher Priced Mortgage Loan. | Verified APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR [Redacted] Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-09-09): Received, Clearing. |
09/09/2022 | 1 | A | NJ | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639681 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant [Redacted] business days prior to consummation. | Borrower was not provide with a copy of Appraisals. Primary and secondary valuation missing in file. | Reviewer Comment (2022-09-09): Received, Clearing. |
09/09/2022 | 1 | A | NJ | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639681 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant [Redacted] business days prior to consummation. | Creditor did not provide a copy of Appraisal.No copy of valuation in file | Reviewer Comment (2022-09-09): Received, Clearing. Seller Comment (2022-09-09): Comment from [Redacted] ([Redacted]): Please see attached for the appraisal delivery letter. |
09/09/2022 | 1 | A | NJ | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639681 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided Within 3 Business Days of Application | RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Organizations not provided to applicant within three (3) business days of application. | List of Homeownership counseling organization was provided to the Borrower on [Redacted] ,the Initial application date is [Redacted]. | Reviewer Comment (2022-09-09): Accepted as is. |
2 | B | NJ | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639682 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639682 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639682 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639682 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639682 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted]. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639682 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax. Fee Amount of [Redacted]exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Transfer Tax fee increased from [Redacted] to [Redacted]without a valid change of circumstance. A Credit for [Redacted]was reflected on the final Closing Disclosure. | Reviewer Comment (2022-09-01): Sufficient Cure Provided At Closing |
09/01/2022 | 1 | A | NY | Primary | Purchase | Final CD evidences Cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639683 | Compliance | Compliance | State Compliance | State HPML | Massachusetts HPML Threshold Test Compliant | Massachusetts Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of APOR [Redacted] Compliant Higher Priced Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MA | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639683 | Compliance | Compliance | State Compliance | Misc. State Level | Massachusetts Mortgage Lender and Broker Regulation (Ability to Repay not Verified) | Massachusetts Mortgage Lender and Broker Regulation: File does not contain evidence that analysis of borrower's ability to repay was performed based on verified income, obligations, assets, and/or employment using PITI payment based on fully indexed rate and fully amortizing payment, if applicable | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MA | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639683 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of [Redacted] exceeds tolerance of [Redacted] plus [Redacted]or [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-08-31): Sufficient Cure Provided At Closing |
08/31/2022 | 1 | A | MA | Primary | Purchase | Final CD evidences Cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639686 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639686 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639686 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted] , or [Redacted] . Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639687 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | file is missing a copy of the New York Subprime counseling disclosure not disclosed to borrower for verification.. | Reviewer Comment (2022-09-12): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639687 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | file is missing a copy of the New York Subprime counseling disclosure not disclosed to borrower for verification.. | Reviewer Comment (2022-09-12): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639687 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted]. Non-Compliant SubPrime Loan. | file is missing a copy of the New York Subprime counseling disclosure not disclosed to borrower for verification.. | Reviewer Comment (2022-09-12): Accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639687 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | file is missing a copy of the New York Subprime counseling disclosure notice of taxes and insurance not disclosed to borrower for verification.. | Reviewer Comment (2022-09-12): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639687 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Reviewer Comment (2022-09-12): Received, Clearing. Seller Comment (2022-09-12): Comment from [Redacted] ([Redacted]): Per final CD, required cash to close $[Redacted], plus [Redacted] months PITIA $[Redacted], total required $[Redacted] to close. We've verified the transaction activities of [Redacted]#[Redacted] at $[Redacted] (attached) and [Redacted]#[Redacted] at $[Redacted] (added back the $[Redacted] withdrawal on [Redacted] as it is deposited for closing, so available reserves for [Redacted]#[Redacted] is $[Redacted] =$[Redacted] + current balance $[Redacted]). Therefore, total asset is $[Redacted], which is sufficient to cover $[Redacted] of closing required. Attached Gift letter for $[Redacted] large deposit, [Redacted] #[Redacted] and [Redacted]#[Redacted]. |
09/12/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639687 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - ___ | Per guidelines: CPA/Accountant/Tax Preparer/Enrolled Agent's letter should include - Borrower's position/title, Ownership percentage of company, Business inception date, and, Statement on good standing of the borrower's business. | Reviewer Comment (2022-08-31): Received, Clearing. Seller Comment (2022-08-31): Please see attached CPA letter. Per attached Schedule C, it indicates that borrowr is self-employed. Thus, the borrower has no registered business, due to this the 'good standing' language would not be applicable, as there is no registry, agency or municipality for which they need to be in good standing for. |
08/31/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639687 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-12): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639688 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Amount of Non-Escrowed Property Costs over Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on [Redacted] not accurate. | The final CD disclosed the Amount of Non-Escrowed Property Costs over Year 1 as [Redacted]on page 4; however the HOA dues total [Redacted] per year. Provide a post-close CD correcting the Non-Escrow Property Cost Over Year 1 section on page 4 and a copy of the letter of explanation letter sent to the borrower disclosing the changes made. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Second Home | Purchase | Letter of Explanation & Corrected Closing Disclosure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639689 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639689 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639689 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639689 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted] Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639690 | Credit | Insurance | Insurance Documentation | Insurance | Hazard Insurance Error: Subject hazard insurance policy coverage amount is missing from evidence of insurance. | hazard insurance policy coverage amount is missing from evidence of insurance | Reviewer Comment (2022-08-30): Received hazard insurance with sufficient coverage Seller Comment (2022-08-30): Per attached HOI, Dwelling coverage of $[Redacted] is sufficient to cover the loan amount of $[Redacted]. |
08/30/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639690 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | HOI coverage is insufficient by $328,080.00 Provide updated policy reflecting minimum coverage of [Redacted] OR provide copy of insurer's replacement cost estimate supporting current coverage amount. | Reviewer Comment (2022-08-30): Received hazard insurance with sufficient coverage Seller Comment (2022-08-30): Per attached HOI, Dwelling coverage of $[Redacted] is sufficient to cover the loan amount of $[Redacted]. |
08/30/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639690 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: Borrower's ability to repay not verified with reliable documentation. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639690 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided within Three Days of Application) | New York Subprime Loan: Counseling Disclosure not provided to borrower within three days of application. | Evidence of earlier borrower receipt was not found in file. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639690 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted]. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639691 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639691 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: File does not contain evidence that analysis of borrower's ability to repay was performed based on verified income, obligations, assets, and/or employment using PITI payment based on fully-indexed rate with fully-amortizing payment and taking into account payments on any simultaneously-closed loans. | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639691 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639691 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639691 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted] or Final Disclosure APR of [Redacted] is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted]. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639691 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639691 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | The file is missing a copy of the source of funds for the earnest money. | Reviewer Comment (2022-08-30): Received, Clearing. Seller Comment (2022-08-30): Per attached [Redacted] guideline, attached cancelled down payment check is evidencing the source of EMD. |
08/30/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639692 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639692 | Compliance | Compliance | State Compliance | State Late Charge | New York Late Charge Percent Testing | New York Late Charge: Note late charge percent of [Redacted]% exceeds the state maximum of [Redacted] | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639692 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639692 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted] . Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639692 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of [Redacted]exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-08-26): Sufficient Cure Provided At Closing |
08/26/2022 | 1 | A | NY | Primary | Purchase | Final CD evidences Cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639692 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided at Application but within Three Days) | New York Subprime Loan: Counseling Disclosure not provided to borrower at the time of application, but within three days of application. | Document not provided | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639693 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | File is missing a copy of counseling disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639693 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | File is missing a copy of of State Subprime Disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639693 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted]. Non-Compliant SubPrime Loan. | Unable to determine due to missing state disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639693 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | File is missing a copy of Notice of tax and insurance | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639694 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | File is missing a copy of Counseling Disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639694 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Unable to determine due to missing subprime disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639694 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | File is missing a copy of State Subprime Disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639694 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted]. Non-Compliant SubPrime Loan. | APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted] | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639694 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | File is missing a copy of Subprime Tax Disclosure | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639695 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | File is missing a copy of the New York : counseling disclosure. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639695 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | File is missing a copy of the New York ;Subprime loan disclosure. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639695 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted]. Non-Compliant SubPrime Loan. | File is missing a copy of the New York subprime loan disclosure. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639695 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | File is missing a copy of the New York Subprime loan disclosure. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639696 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | Reviewer Comment (2022-09-09): Received, Clearing. Buyer Comment (2022-09-09): Comment from [Redacted] ([Redacted]): A clean copy was pulled from [Redacted] and loaded for review with [Redacted]. Reviewer Comment (2022-09-08): WVOE received is blank and does not contain any borrower information Seller Comment (2022-09-08): Comment from [Redacted] ([Redacted]): Please see attached WVOE including income. |
09/09/2022 | 1 | A | CA | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639697 | Credit | Hazard Insurance | Document Error | Hazard Insurance | Hazard Insurance policy does not list Lender or Servicer and its successors and assigns, per guideline requirements. | Reviewer Comment (2022-09-12): Received, cleared Seller Comment (2022-09-12): Comment from [Redacted] ([Redacted]): it's a coop loan, please see both master insurance & HO6 with required info. |
09/12/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639697 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639697 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639697 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639697 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639697 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Escrow Not Established) | New York Subprime Loan: Mandatory escrow account not established for the collection of property taxes and insurance. (Note: Does not apply to a subordinate lien when the taxes and insurance are escrowed through another home loan. It also does not apply if the borrower can demonstrate a record of [Redacted]months of timely payments of taxes and insurance on a previous home loan.) | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639697 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted]%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639697 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Total Property Costs Year 1 - October 2018 Test | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of 5,389.01 on Final Closing Disclosure provided on [Redacted] not accurate. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639698 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided within Three Days of Application) | New York Subprime Loan: Counseling Disclosure not provided to borrower within [Redacted]days of application. | Evidence of earlier borrower receipt was not found in file. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639698 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639698 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted]%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639699 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | The file is missing a copy of the RESPA Homeownership Counseling List Disclosure. | Reviewer Comment (2022-09-06): accepted as is. |
2 | B | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639699 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis. Fee Amount of $ [Redacted]exceeds tolerance of $ [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Sufficient or excess cure was provided the Final CD to the borrower at Closing. | Reviewer Comment (2022-09-01): Sufficient Cure Provided At Closing |
09/01/2022 | 1 | A | NY | Primary | Purchase | Final CD evidences Cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639699 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted]. Compliant SubPrime Loan. | Reviewer Comment (2022-09-06): accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639699 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | The guideline requirement for reserves is [Redacted] months. | Reviewer Comment (2022-09-06): Received, Clearing. Seller Comment (2022-09-06): Comment from [Redacted] ([Redacted]): Per final CD, required cash to close $[Redacted], plus 6 months PITIA $[Redacted], total required $[Redacted] to close. We've verified the transaction activity of [Redacted] #[Redacted] at $[Redacted], which is sufficient to cover this transaction. Also, attached transaction page of [Redacted] #[Redacted] and appraisal paid receipt. |
09/06/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639700 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | File is missing a copy of List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-09-07): Accepted as is. |
2 | B | WA | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639700 | Credit | Asset | Asset Calculation / Analysis | Asset | Available for Closing is insufficient to cover Cash From Borrower. | Insufficient Assets to cover cash from borrower. File is missing a copy of account statement to verify Union bank account ending with " [Redacted]" and [Redacted] account ending with " [Redacted]". | Reviewer Comment (2022-09-07): Received, Clearing. Seller Comment (2022-09-07): Comment from [Redacted] ([Redacted]): Per final CD, required cash to close $[Redacted] plus 6 months PITIA $[Redacted], total required $[Redacted]to close. We've verified the transaction activities of [Redacted]#[Redacted] at $[Redacted] and [Redacted]#[Redacted] at $[Redacted], total asset $[Redacted], which is sufficient to cover this transaction. Also, attached EMD $[Redacted]k cashier check, $[Redacted]k & $[Redacted] deposit check, and bank statements reflecting large deposits and evidencing reserves. |
09/07/2022 | 1 | A | WA | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639700 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Insufficient assets to cover reserves. Provide assets documentation (account statement) for account number ending with " [Redacted]" and [Redacted]" | Reviewer Comment (2022-09-07): Received, Clearing. Seller Comment (2022-09-07): Comment from [Redacted] ([Redacted]): Per final CD, required cash to close $[Redacted], plus 6 months PITIA $[Redacted], total required $[Redacted]to close. We've verified the transaction activities of [Redacted]#[Redacted] at $[Redacted] and[Redacted] #[Redacted] at $[Redacted], total asset $[Redacted], which is sufficient to cover this transaction. Also, attached EMD $[Redacted]k cashier check, $[Redacted]k & $[Redacted] deposit check, and bank statements reflecting large deposits and evidencing reserves. |
09/07/2022 | 1 | A | WA | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639700 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Hazard coverage of $ [Redacted]is insufficient to cover the mortgage amount of $ [Redacted]with an estimated cost new of $ [Redacted]. Please provide a letter from the Insurer stating the maximum insurable amount and/or a replacement costs estimator from the insurer. | Reviewer Comment (2022-09-06): Received, Clearing. Seller Comment (2022-09-06): Comment from [Redacted] ([Redacted]): Dwelling coverage $[Redacted] is sufficient to cover the replacement cost $[Redacted] per attached RCE. |
09/06/2022 | 1 | A | WA | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639701 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Appraisal receipt is dated XXXX however the signature date is XXXX | Reviewer Comment (2022-09-12): Accepted as is. |
2 | B | FL | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639701 | Compliance | Compliance | Federal Compliance | Missing Required Data (other than HUD-1 or Note) | Payoff Statement Missing | Missing Payoff Statement: Unable to determine if a prepayment penalty was included in the pay-off which may impact high cost findings. | Reviewer Comment (2022-09-12): Accepted as is. |
2 | B | FL | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639701 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Finance Charge | TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXX disclosed an inaccurate Finance Charge on page 5 that does not match the actual Finance Charge for the loan (fee amounts included in Finance Charge calculation are based on Closing Disclosure dated XXXX. | The title - admin fee in the amount of $400 is not included in the total finance charges | Reviewer Comment (2022-09-27): SitusAMC received Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission. Seller Comment (2022-09-26): Comment from XXXX (XXXX): Please see attached for the PCCD, LOE, Proof of delivery, proof of refund and RTC. Reviewer Comment (2022-09-26): Cure documents are missing new RTC. Material disclosure exceptions require re-opening of rescission on all refinance transactions. Please provide copy of RTC and proof of receipt of RTC to test cure. Seller Comment (2022-09-26): Comment from XXXX (XXXX): Please see attached for the PCCD, LOE, Proof of delivery and proof of refund. Reviewer Comment (2022-09-15): Admin fee is not a factor in calculations. Fees indicate an amount of $12,817.84. Finance charge calculation on page 5 appears to be in error. Cure is required in the amount of $400. Seller Comment (2022-09-13): Comment from XXXX (XXXX): The Admin Fee was not included within the calculations because it is actually a discount given to the borrower by the title company. Please see attached pre-CD from the title company. Buyer Comment (2022-09-13): Comment from XXXX (XXXX): The Admin Fee was not included within the calculations because it is actually a discount given to the borrower by the title company. |
09/27/2022 | 2 | B | FL | Primary | Refinance - Cash-out - Other | TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission if Applicable | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639701 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | Per guidelines, P&L must be dated and signed on accounting firm’s letterhead and must include signer’s contact information. P&L for XXXX is not signed by CPA. | Reviewer Comment (2022-09-12): Received, Clearing. Seller Comment (2022-09-12): Comment from XXXX (XXXX): Please see attached P&L for XXXX including CPA's signed and date and contact. |
09/12/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639702 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee. Fee Amount of $ [Redacted]exceeds tolerance of $ [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | No COC or Cure was provided to Borrower for tolerance overages | Reviewer Comment (2022-09-01): Sufficient Cure Provided At Closing |
09/01/2022 | 1 | A | FL | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | A | A | A | A | A | A | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639705 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: File does not contain evidence that analysis of borrower's ability to repay was performed based on verified income, obligations, assets, and/or employment using PITI payment based on fully-indexed rate with fully-amortizing payment and taking into account payments on any simultaneously-closed loans. | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | NY | Primary | Refinance - Cash-out - Other | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639705 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | NY | Primary | Refinance - Cash-out - Other | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639705 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | NY | Primary | Refinance - Cash-out - Other | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639705 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Escrow Not Established) | New York Subprime Loan: Mandatory escrow account not established for the collection of property taxes and insurance. (Note: Does not apply to a subordinate lien when the taxes and insurance are escrowed through another home loan. It also does not apply if the borrower can demonstrate a record of [Redacted] months of timely payments of taxes and insurance on a previous home loan.) | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | NY | Primary | Refinance - Cash-out - Other | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639705 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted] Non-Compliant SubPrime Loan. | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | NY | Primary | Refinance - Cash-out - Other | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639705 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided) | New York Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan. | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | NY | Primary | Refinance - Cash-out - Other | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639705 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Total Property Costs Year 1 - October 2018 Test | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of [Redacted] on Final Closing Disclosure provided on [Redacted] not accurate. | All data is correct and matches the final CD. | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | NY | Primary | Refinance - Cash-out - Other | Letter of Explanation & Corrected Closing Disclosure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639705 | Compliance | Compliance | Federal Compliance | Missing Non-Required Data | (Missing Data) Last Rate Set Date | Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing. | Reviewer Comment (2022-08-30): Accepted as is. |
2 | B | NY | Primary | Refinance - Cash-out - Other | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639705 | Credit | Insurance | Insurance Documentation | Insurance | Hazard Insurance Error: Subject hazard insurance premium is missing from evidence of insurance. | Reviewer Comment (2022-08-30): Received, Clearing. Seller Comment (2022-08-30): Subject property is Co-operative. Per XXXX guidelines, it's not required HO6 but co-op master insurance for co-op. Therefore, no HO6 premium for this loan. |
08/30/2022 | 1 | A | NY | Primary | Refinance - Cash-out - Other | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639706 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Verification appraisal was delivered to Borrower, however, the receipt date was not provided. | Reviewer Comment (2022-08-30): Received, Clearing. |
08/30/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639706 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted] % or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR [Redacted]. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-08-30): Received, Clearing. |
08/30/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639706 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three [Redacted] business days prior to consummation. | Verification appraisal was delivered to Borrower, however, the receipt date was not provided. | Reviewer Comment (2022-08-30): Received, Clearing. Seller Comment (2022-08-30): Please see attached for the appraisal delivery letter. |
08/30/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639706 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-08-31): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639706 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-08-31): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639706 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted] Non-Compliant SubPrime Loan. | Reviewer Comment (2022-08-31): Accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639706 | Credit | Title | General | Title | Final Title Policy Coverage is less than Original Loan Amount. | The final title report in file disclosed $ [Redacted]of title insurance coverage; however this is less than the loan amount of $ [Redacted]. | Reviewer Comment (2022-08-31): Received, Clearing. Seller Comment (2022-08-31): final title report with $[Redacted]K has been uploaded |
08/31/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639706 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Reviewer Comment (2022-08-31): Accepted as is. |
2 | B | NY | Primary | Purchase | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639709 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | FL | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639710 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | The file is missing a copy of the List of Homeownetship. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NJ | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639711 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | New York Subprime Disclosure not found in file | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639711 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted] Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639711 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639713 | Compliance | Compliance | State Compliance | State HPML | Maine HPML Threshold 2013 Test Compliant | Maine Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR [Redacted]%, or subject loan is a high-cost mortgage loan, contains negative amortization, or has an interest-only feature. Compliant Higher Priced Loan. | Reviewer Comment (2022-09-06): accepted as is. |
2 | B | ME | Primary | Purchase | Within 30 days of closing and prior to receiving any notice, notify borrower, make appropriate restitution and adjustments. (Narrow Defense - Requires CHD Approval) Within 60 days of closing and prior to receiving any notice, (1) provide Lender Attestation to SitusAMC attesting (a) lender has not received any notice from borrower regarding the failure and (b) the failure was not intentional and was a bona fide error notwithstanding procedures in place to prevent such loans from being made (specific details on how the higher-priced loan was made despite procredures to prevent); (2) notify the borrower and make appropriate restitution/adjustments to the loan; and (3) proof of mailing. |
C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639713 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Reviewer Comment (2022-09-06): Received, Clearing. Seller Comment (2022-09-06): Comment from [Redacted][Redacted]: Per final CD, required cash to close[Redacted], plus [Redacted]months PITIA[Redacted], total required[Redacted] to close. We've verified the transaction activity of [Redacted] #[Redacted]at [Redacted], which is sufficient to cover this transaction. Also, attached transaction page of [Redacted] #[Redacted], Appraisal paid receipt, and [Redacted][Redacted] cancelled check. |
09/06/2022 | 1 | A | ME | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639714 | Compliance | Compliance | Federal Compliance | TILA | ARM Disclosure Timing Test | TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application. | Evidence of earlier borrower receipt was not found in file. | Reviewer Comment (2022-08-30): Received, Clearing. Seller Comment (2022-08-30): Please see attached for the ARM Disclosure with borrower acknowledgement. |
08/30/2022 | 1 | A | NJ | Primary | Purchase | No Defined Cure | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639717 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $ [Redacted]exceeds tolerance of $ [Redacted]plus [Redacted]% or $ [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Ten Percent Fee Tolerance exceeded. Total amount of $ [Redacted]exceeds tolerance of $ [Redacted]plus [Redacted]% or $ [Redacted]. Excess cure in the amount of $ [Redacted]was provided to the borrower at Closing. | Reviewer Comment (2022-08-26): Sufficient Cure Provided At Closing |
08/26/2022 | 1 | A | NY | Primary | Purchase | Final CD evidences Cure | A | A | A | A | A | A | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639718 | Compliance | Compliance | Federal Compliance | TILA | CHARM Booklet Disclosure Status | TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower. | Reviewer Comment (2022-08-30): Received, Clearing. Seller Comment (2022-08-30): Please see attached for the CHARM booklet with borrower acknowledgment. |
08/30/2022 | 1 | A | NY | Primary | Purchase | No Defined Cure | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639719 | Compliance | Compliance | Federal Compliance | RESPA | RESPA - Initial Escrow Account statement Inaccurate | RESPA: Initial escrow account statement does not match charges on HUD-1/Final Closing Disclosure. | 2 | B | RI | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||||
| 438639719 | Compliance | Compliance | State Compliance | State Defect | Rhode Island Home Loan (Prohibited Acts and Practices Regarding High-Cost Home Loans Disclosure Not Provided) | Rhode Island Home Loan: Prohibited Acts and Practices Regarding High-Cost Home Loans disclosure not provided. | Reviewer Comment (2022-09-22): Disclosure received Seller Comment (2022-09-21): Comment from XXXX (XXXX): Please see attached for the prohibited acts-high cost disclosure. |
09/22/2022 | 1 | A | RI | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639719 | Compliance | Compliance | State Compliance | State Defect | Rhode Island Home Loan (High Cost Analysis Not In File) | Rhode Island Home Loan: Loan file did not contain record(s) documenting high-cost home loan analysis. | Reviewer Comment (2022-09-23): Received compliance report, added exception for post closing timing. Seller Comment (2022-09-23): Comment from XXXX (XXXX): See attached for our compliance report showing the pass on its analysis for high-cost. Reviewer Comment (2022-09-22): The RI Home Loan Protection Act requires that a high cost analysis be performed and documented for each and every loan file substantiating the “high cost loans” analysis performed during the transaction. It is not only required to be performed on high-cost loans, but not high-cost as well. The analysis on a non-high-cost loan would support the creditor’s determination on how the loan did not exceed the thresholds whereas an analysis on a high-cost loan would support how it did exceed the thresholds. The creditor must maintain on file and be in possession of documentation clearly identifying and substantiating the high cost calculation Buyer Comment (2022-09-21): Comment from XXXX (XXXX): This is only required when it is a high-cost loan and this loan isn't. Total loan amount is XXXX , threshold of 5% for points and fees not to be exceeded is $17,605 - points and fees for this file adds up to $9,112 which is lower. |
09/23/2022 | 1 | A | RI | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639719 | Compliance | Compliance | State Compliance | State Defect | Rhode Island Home Loan (Prohibited Acts and Practices Regarding Home Loans Disclosure Not Provided) | Rhode Island Home Loan: Prohibited Acts and Practices Regarding Home Loans disclosure not provided. | Reviewer Comment (2022-09-22): Disclosure received Seller Comment (2022-09-21): Comment from XXXX (XXXX): Please see attached for the prohibited acts disclosure. |
09/22/2022 | 1 | A | RI | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639719 | Compliance | Compliance | State Compliance | State Defect | Rhode Island High Cost Analysis Timing | Rhode Island Home Loan: High-cost Analysis not documented and substantiated prior to closing of the loan. | Received compliance report, added exception for post closing timing. | Reviewer Comment (2022-09-23): Received, Clearing. Seller Comment (2022-09-23): Comment from XXXX (XXXX): Please see attached for the compliance report ran at closing. |
09/23/2022 | 1 | A | RI | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639721 | Compliance | Compliance | Federal Compliance | Missing Non-Required Data | (Missing Data) Last Rate Set Date | Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NC | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639721 | Compliance | Compliance | Federal Compliance | TILA | NMLS - Missing Evidence of Initial Loan Application Date | Truth in Lending Act (NMLSR Dodd- Frank 2014): Unable to determine compliance with NMLSR timing requirements due to missing evidence of initial loan application date. | Reviewer Comment (2022-08-31): Received, Clearing. Seller Comment (2022-08-31): Please see attached for the initial 1003. Reviewer Comment (2022-08-31): Need initial application 1003. Seller Comment (2022-08-31): Please see attached for the initial LE. |
08/31/2022 | 1 | A | NC | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639721 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NC | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639721 | Compliance | Compliance | Federal Compliance | TILA | ARM Disclosure Timing Test | Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information. | Reviewer Comment (2022-08-31): Received, Clearing. Seller Comment (2022-08-31): Please see attached for initial 1003. Reviewer Comment (2022-08-31): Need initial application 1003. Seller Comment (2022-08-31): Please see attached for the ARM Disclosure. |
08/31/2022 | 1 | A | NC | Primary | Refinance - Cash-out - Other | No Defined Cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639721 | Compliance | Compliance | Federal Compliance | TILA | CHARM Booklet Disclosure Status | TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower. | The file is missing copies of the adjustable rate mortgage and the CHARM booklet | Reviewer Comment (2022-08-31): Received, Clearing. Seller Comment (2022-08-31): Please see attached for initial 1003. Reviewer Comment (2022-08-31): Need initial application 1003. Seller Comment (2022-08-31): Please see attached for the CHARM booklet. |
08/31/2022 | 1 | A | NC | Primary | Refinance - Cash-out - Other | No Defined Cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639721 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Courier / Express Mail / Messenger Fee. Fee Amount of $ [Redacted]exceeds tolerance of $ [Redacted]. Insufficient or no cure was provided to the borrower. | The borrower was not provided with a COC | Reviewer Comment (2022-09-01): [Redacted] received missing [Redacted], [Redacted] & [Redacted] LE's along with [Redacted]. Upon further review there was no tolerance violation. Seller Comment (2022-08-31): Please see attached for the SSPL. The provider for this service was not the one listed on the SSPL, therefore this fee is not subject to a tolerance limit. No cure required. |
09/01/2022 | 1 | A | NC | Primary | Refinance - Cash-out - Other | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639721 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Recording Service Fee. Fee Amount of $ [Redacted]exceeds tolerance of $ [Redacted]. Insufficient or no cure was provided to the borrower. | The borrower was not provided with a COC | Reviewer Comment (2022-09-01): [Redacted] received missing[Redacted], [Redacted] & [Redacted] LE's along with SSPL. Upon further review there was no tolerance violation. Seller Comment (2022-08-31): Please see attached for the SSPL. The provider for this service was not the one listed on the SSPL, therefore this fee is not subject to a tolerance limit. No cure required. |
09/01/2022 | 1 | A | NC | Primary | Refinance - Cash-out - Other | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639721 | Compliance | Compliance | Federal Compliance | TRID | TRID Appraisal Disclosure - ECOA Status | ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure. | The filie is missing a copy of the Right to Receive a copy of the appraisal document. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NC | Primary | Refinance - Cash-out - Other | Good faith redisclosure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639721 | Compliance | Compliance | Federal Compliance | TRID Defect | TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File | TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s). The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing. Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $ [Redacted]may be required. | The file is missing a copy of the LE | Reviewer Comment (2022-09-02): [Redacted] received LEs. Seller Comment (2022-08-31): Please see attached for the Loan Estimates to this file. |
09/02/2022 | 1 | A | NC | Primary | Refinance - Cash-out - Other | No Defined Cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639721 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Hazard coverage of $ [Redacted]is insufficient to cover the mortgage amount of $ [Redacted]. Please provide a letter from the Insurer stating the maximum insurable amount and/or a replacement costs estimator from the insurer. | Reviewer Comment (2022-08-31): Received, Clearing. Buyer Comment (2022-08-31): please clarify, our dwelling coverage $[Redacted]is greater than loan amount $[Redacted], why is it not sufficient? |
08/31/2022 | 1 | A | NC | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639721 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR [Redacted] Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-08-31): Received, Clearing. |
08/31/2022 | 1 | A | NC | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639721 | Compliance | Compliance | Federal Compliance | Missing Application Date | Missing Initial Loan Application Compliance Determined Application Date | No evidence of application date located in file. Compliance tests were run using an application date of [Redacted]. The source for this date is . | 6 month lookback. | Reviewer Comment (2022-08-31): Received, Clearing. |
08/31/2022 | 1 | A | NC | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639721 | Compliance | Compliance | State Compliance | State HPML | North Carolina Rate Spread Threshold Test Compliant | North Carolina Rate Spread Home Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR [Redacted]%. Compliant Rate Spread Home Loan. | Reviewer Comment (2022-08-31): Received, Clearing. |
08/31/2022 | 1 | A | NC | Primary | Refinance - Cash-out - Other | Within 90 days of closing and prior to institution of any action against the lender, (1) notify the borrower, and (2) make appropriate restitution at the option of the borrower to either (a) make the loan comply with prohibited acts and practices or (b) change the terms of the loan in a manner beneficial to the borrower so the loan is no longer rate spread. (Narrow Defense - Requires CHD Approval) Within 120 days of discovery , which compliance failure was not intentional and resulted from a bona fide error, creditor must: (1) provide Lender Attestation to AMC attesting the failure was not intentional and was a bona fide error notwithstanding procedures in place to prevent such loans from being made (specific details on how rate spread home loan was made despite procredures to prevent); (2) notify the borrower, and make appropriate restitution at the option of the borrower to either (a) make the loan comply with prohibited acts and practices or (b) change the terms of the loan in a manner beneficial to the borrower so the loan is no longer rate spread. |
C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639721 | Compliance | Compliance | Federal Compliance | TRID | TRID Appraisal Disclosure - HPML Status | HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure. | Missing appraisal disclosure. | Reviewer Comment (2022-08-31): Received, Clearing. Seller Comment (2022-08-31): Please see attached for the appraisal delivery letter. |
08/31/2022 | 1 | A | NC | Primary | Refinance - Cash-out - Other | Good faith redisclosure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639722 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $ [Redacted]exceeds tolerance of $ [Redacted]plus [Redacted]% or $ [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | [Redacted]% tolerance was exceeded. No valid COC provided, cure provided at closing. | Reviewer Comment (2022-09-06): Sufficient Cure Provided At Closing |
09/06/2022 | 1 | A | NY | Primary | Purchase | Final CD evidences Cure | A | A | A | A | A | A | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639723 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NH | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639725 | Compliance | Compliance | Federal Compliance | Missing Non-Required Data | (Missing Data) Last Rate Set Date | Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing. | Rate lock date was not provided | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NJ | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639725 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | The file is missing a copy of the documentation. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NJ | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639726 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639726 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639726 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639726 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Greater than 3 Year ARM Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted]%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639726 | Compliance | Compliance | Federal Compliance | Missing Non-Required Data | (Missing Data) Last Rate Set Date | Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639727 | Compliance | Compliance | Federal Compliance | FACTA | Federal FACTA Disclosure Timing Test | FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639727 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $ [Redacted]exceeds tolerance of $ [Redacted]plus [Redacted]% or $ [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-09-14): Sufficient Cure Provided At Closing |
09/14/2022 | 1 | A | NY | Primary | Purchase | Final CD evidences Cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639728 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Reviewer Comment (2022-09-07): Received, Clearing. Seller Comment (2022-09-07): Comment from [Redacted] ([Redacted]): Per final CD, required cash to close $[Redacted], plus [Redacted] months PITIA $[Redacted], total required $[Redacted] to close. We've verified the transaction activity of [Redacted]#[Redacted] at $[Redacted] and gift funds $[Redacted](attached gift letter, check, and donor's statement evidencing withdrawal), total asset $[Redacted], which is sufficient to cover this transaction. Also, attached appraisal fee paid receipt, [Redacted]#[Redacted] transaction page, and gift docs. |
09/07/2022 | 1 | A | NY | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639731 | Compliance | Compliance | Federal Compliance | Missing Disclosure | Notice of Special Flood Hazard Disclosure Not Provided Timely | FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing. | The notice of special Flood Hazard disclosure was provided on [Redacted] and the loan closed on [Redacted] | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NJ | Primary | Purchase | B | B | A | A | B | B | B | B | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639731 | Property | Property - Appraisal | Appraisal Reconciliation | Property - Appraisal | Appraisal is required to be in name of Lender | - | The guidelines require an Appraisal Transfer Letter with the letterhead of the original lender. Unable to locate in file... | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NJ | Primary | Purchase | B | B | A | A | B | B | B | B | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639732 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR [Redacted]%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-09-22): HPML was made compliant with a cure for the double appraisal charge. Buyer Comment (2022-09-21): Comment from XXXX (XXXX): Related condition has been cleared. Please clear this condition. |
09/22/2022 | 1 | A | OH | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639732 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Flipped Property - Borrower Charged for 2 Appraisals) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Flipped Property - Creditor improperly charged consumer for two (2) appraisals. | Reviewer Comment (2022-09-20): Provide evidence of the refund of the amount charged to the consumer for the second appraisal performed on the subject property. (Include a copy of the Refund Check, Proof of Delivery, and Cover Letter) received Buyer Comment (2022-09-20): Comment from XXXX (XXXX): The cure has been received by the borrower. Please clear this condition. |
09/20/2022 | 2 | B | OH | Primary | Purchase | Provide evidence of the refund of the amount charged to the consumer for the second appraisal performed on the subject property. (Include a copy of the Refund Check, Proof of Delivery, and Cover Letter) | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639732 | Compliance | Compliance | State Compliance | Misc. State Level | Ohio Consumer Sales Practices Act (Acknowledgement of Receipt of Home Mortgage Loan Information Document Not Received Timely) | Ohio Consumer Sales Practices Act: Acknowledgement of Receipt of Home Mortgage Loan Information Document not received by borrower within five (5) business days of application. | 2 | B | OH | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||||
| 438639732 | Compliance | Compliance | State Compliance | Misc. State Level | Ohio Consumer Sales Practices Act (Demand Feature) | Ohio Consumer Sales Practices Act: Mortgage loan contains an impermissible demand feature. | 2 | B | OH | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||||
| 438639732 | Compliance | Compliance | State Compliance | Misc. State Level | Ohio Consumer Sales Practices Act (Right Not To Close Disclosure Not Provided) | Ohio Consumer Sales Practices Act: Borrower not provided Right Not To Close Disclosure. | 2 | B | OH | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||||
| 438639736 | Compliance | Compliance | Federal Compliance | TILA | ARM Disclosure Timing Test | TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three ( [Redacted]) days of application. | Borrower signed the document at closing on [Redacted] | Reviewer Comment (2022-09-16): Received, cleared Seller Comment (2022-09-15): Comment from [Redacted] ([Redacted]): Please see attached for the COC LE with borrower acknowledgement for this program change. Timing requirements are met. Reviewer Comment (2022-09-02): The new document has no delivery date but was signed on [Redacted] which is still beyond the timing window. Please provide a delivery dated doc. Seller Comment (2022-09-02): Comment from [Redacted] ([Redacted]): Please see attached for the ARM disclosure. |
09/16/2022 | 1 | A | PA | Primary | Purchase | No Defined Cure | C | A | A | A | C | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639738 | Credit | Title | Document Error | Title | The Preliminary/Commitment does not reflect a coverage amount (no final title policy in file). Unable to determine if appropiate coverage is provided. | Reviewer Comment (2022-09-12): Received, cleared Seller Comment (2022-09-12): Comment from [Redacted] ([Redacted]): Please see attached final title |
09/12/2022 | 1 | A | MA | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639738 | Compliance | Compliance | State Compliance | State HPML | Massachusetts HPML Threshold Test Compliant | Massachusetts Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR [Redacted]% Compliant Higher Priced Loan. | Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR [Redacted]% | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MA | Primary | Purchase | No obvious cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639738 | Compliance | Compliance | State Compliance | Misc. State Level | Massachusetts Mortgage Lender and Broker Regulation (Ability to Repay not Verified) | Massachusetts Mortgage Lender and Broker Regulation: File does not contain evidence that analysis of borrower's ability to repay was performed based on verified income, obligations, assets, and/or employment using PITI payment based on fully indexed rate and fully amortizing payment, if applicable | Valid Association | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | MA | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639739 | Compliance | Compliance | Federal Compliance | FACTA | Federal FACTA Disclosure Timing Test | FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score. | Reviewer Comment (2022-09-19): Accepted as is. |
2 | B | NY | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639739 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Provision Increasing Rate After Default) | New York Subprime Loan: Mortgage loan contains a provision that increases interest rate after default. | Reviewer Comment (2022-09-19): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, modification of loan terms to remove the provision to increase the interest rate after default and proof of mailing. | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639739 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639739 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Greater than 3 Year ARM Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted]%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639739 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis. Fee Amount of $ [Redacted]exceeds tolerance of $ [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-08-29): Sufficient Cure Provided At Closing |
08/29/2022 | 1 | A | NY | Primary | Purchase | Final CD evidences Cure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639739 | Compliance | Compliance | Federal Compliance | TILA | ARM Disclosure Timing Test | TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application. | Reviewer Comment (2022-09-19): Received, Clearing. Seller Comment (2022-09-19): Comment from [Redacted] ([Redacted]): Please see attached for the accompanying COC CD regarding this change. Reviewer Comment (2022-09-02): Provided doc has no delivery date, but is signed[Redacted] which is outside of the allowable window. Please provide a delivery date. Seller Comment (2022-09-02): Comment from[Redacted] ([Redacted]): Please see attached for the ARM disclosure. |
09/19/2022 | 1 | A | NY | Primary | Purchase | No Defined Cure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639739 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided at Application but within Three Days) | New York Subprime Loan: Counseling Disclosure not provided to borrower at the time of application, but within [Redacted]days of application. | please provide document | Reviewer Comment (2022-09-19): Accepted as is. |
2 | B | NY | Primary | Purchase | No obvious cure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639740 | Credit | Legal / Regulatory / Compliance | Title / Lien Defect | Legal / Regulatory / Compliance | Final Title Policy is missing. No evidence of title in file. | The file was missing a copy of the title policy. | Reviewer Comment (2022-09-13): Received, Clearing. Seller Comment (2022-09-13): Comment from [Redacted]g ([Redacted]): Attached. Reviewer Comment (2022-09-12): Prelim or commitment will resolve exception level. Seller Comment (2022-09-12): Comment from [Redacted] ([Redacted]): Please see attached email chain. From the attorney, in this county, title policies take [Redacted] months after closing. |
09/13/2022 | 1 | A | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639740 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | New York subprime disclosure not provided to customer. | Reviewer Comment (2022-09-13): Accepted as is. |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639740 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Greater than 3 Year ARM Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted]. Non-Compliant SubPrime Loan. | New York subprime disclosure not provided to customer. | Reviewer Comment (2022-09-13): Accepted as is. |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639740 | Compliance | Compliance | Federal Compliance | Missing Non-Required Data | (Missing Data) Last Rate Set Date | Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing. | Reviewer Comment (2022-09-13): Accepted as is. |
2 | B | NY | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639741 | Credit | Loan Package Documentation | Application / Processing | Missing Document | Missing Document: Tax Certificate not provided | The file is missing a copy of the tax certificate. | Reviewer Comment (2022-09-08): Received, Clearing. Seller Comment (2022-09-08): Comment from [Redacted] ([Redacted]): We added the highlighted together which total to $[Redacted] for a monthly amount of $[Redacted] property tax. |
09/08/2022 | 1 | A | TX | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639741 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | The file is missing a copy of the List of Homeownership Counseling. | Reviewer Comment (2022-09-08): Accepted as is. |
2 | B | TX | Primary | Purchase | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639741 | Compliance | Compliance | Federal Compliance | TRID | TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $[Redacted]exceeds tolerance of [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Borrower was not provided with a COC. | Reviewer Comment (2022-09-01): Sufficient Cure Provided At Closing |
09/01/2022 | 1 | A | TX | Primary | Purchase | Final CD evidences Cure | C | B | C | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639742 | Credit | Title | Document Error | Title | The Preliminary title policy is within CA or NV and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided. | No policy amount mentioned on prelim policy | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | CA | Primary | Purchase | C | B | C | B | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639742 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Hazard Insurance coverage of $452,000.00 is insufficient to cover mortgage amount of XXXX. Please provide a letter from insurer stating the maximum insurable amount or replacement costs estimator from insurer | Reviewer Comment (2022-09-15): RCE received Seller Comment (2022-09-15): Comment from[Redacted] ([Redacted]): Dwelling coverage of $[Redacted] is sufficient to cover the replacement cost $[Redacted] per attached RCE. Reviewer Comment (2022-09-13): Other structures isn't part of the dwelling coverage. The appraisal rebuild is for the dwelling not other structures. Seller Comment (2022-09-13): Comment from [Redacted] ([Redacted]): Dwelling coverage $[Redacted] plus Other Structures $[Redacted], total coverage of $[Redacted] is sufficient to cover the Estimate of Cost-New $[Redacted] per attached appraisal page #[Redacted]. |
09/15/2022 | 1 | A | CA | Primary | Purchase | C | B | C | B | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639742 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $ [Redacted]exceeds tolerance of $ [Redacted]. Insufficient or no cure was provided to the borrower. | Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $ [Redacted]exceeds tolerance of $ [Redacted]. Sufficient $ [Redacted]cure was provided | Reviewer Comment (2022-09-19): [Redacted]: Suffcient cure provided at closing. Reviewer Comment (2022-09-13): [Redacted]: Cure provided at closing insufficient to cure for all the citing [ [Redacted] + T[Redacted] ] exception. Exception will be cleared on resolution of [Redacted]% Tolerance fee. Seller Comment (2022-09-12): Comment from [Redacted] ([Redacted]): Please see attached final CD. Sufficient lender credits were provided for this fee change. |
09/19/2022 | 1 | A | CA | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | B | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639742 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $ [Redacted]exceeds tolerance of [Redacted] Insufficient or no cure was provided to the borrower. | Ten Percent Fee Tolerance exceeded. Total amount of $ [Redacted]exceeds tolerance of [Redacted]. No cure was provided to the borrower. | Reviewer Comment (2022-09-19): [Redacted] received Letter of Explanation, Proof of Mailing, Copy of Refund Check, and Corrected PCCD. Seller Comment (2022-09-16): Comment from [Redacted] ([Redacted]): Please see attached for the PCCD, LOE, Proof of Delivery and Proof of Refund. Reviewer Comment (2022-09-13): [Redacted]: On review exception is due to addition [Redacted]e $[Redacted] and [Redacted] $[Redacted] in Section B (borrower did not shop for) in PCCD dated [Redacted]. Please provide cure. Cure consists of Corrected CD, LOE to borrower, proof of mailing and copy of refund check. Seller Comment (2022-09-12): Comment from [Redacted] ([Redacted]): Please see attached for the last disclosed LE and final CD. The fee amount of $[Redacted] actually decreased, not increased between LE's and CD's. No cure required. |
09/19/2022 | 2 | B | CA | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | B | C | B | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639743 | Credit | Credit | Miscellaneous | Guideline | Credit Exception: | The borrower was qualified with income from future employment however, the non-contingent employment contract was not obtained. | Reviewer Comment (2022-09-13): VVOE received, meets guidelines Seller Comment (2022-09-13): Comment from[Redacted] ([Redacted]): Please see attached WVOE confirming the anticipated start date [Redacted] along with Job Offer letter. Reviewer Comment (2022-09-08): Per [Redacted]- the offer or contract should be non-contingent. If conditions of employment exist, the lender must confirm prior to closing that all conditions of employment are satisfied either by verbal verification or written documentation. This confirmation must be noted in the mortgage loan file. Seller Comment (2022-09-08): Comment from [Redacted] ([Redacted]): Please see attached Job Offer Letter, it states the employment benefit and start date. Please clarifying. |
09/13/2022 | 1 | A | NJ | Primary | Purchase | C | A | C | A | A | A | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639744 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | The file is missing a copy of the List of Homeownership Counseling. | Reviewer Comment (2022-09-09): Accepted as is. |
2 | B | NC | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639744 | Compliance | Compliance | Federal Compliance | TILA | ARM Disclosure Timing Test | TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application. | ARM disclosure was not received in a timely matter | Reviewer Comment (2022-09-09): Received, Clearing. Seller Comment (2022-09-09): Comment from [Redacted] ([Redacted]): Please see attached for the ARM Disclosure for the [Redacted] ARM program provided within [Redacted]days of app date. Reviewer Comment (2022-09-08): Arm disclosure provided is dated [Redacted] which is not within three ([Redacted]) days of application. Seller Comment (2022-09-08): Comment from [Redacted] ([Redacted]): Please see attached for the ARM Disclosure. |
09/09/2022 | 1 | A | NC | Primary | Refinance - Cash-out - Other | No Defined Cure | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||
| 438639744 | Credit | Income / Employment | Income Documentation | Income / Employment | Income Docs Missing: | - | Reviewer Comment (2022-09-08): Received, Clearing. Seller Comment (2022-09-08): Comment from[Redacted] ([Redacted]): Please see attached VOE. |
09/08/2022 | 1 | A | NC | Primary | Refinance - Cash-out - Other | C | B | C | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639745 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $ [Redacted]exceeds tolerance of $ [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | No COC or Cure was provided to Borrower for tolerance overages | Reviewer Comment (2022-09-06): Sufficient Cure Provided At Closing |
09/06/2022 | 1 | A | FL | Primary | Purchase | Final CD evidences Cure | A | A | A | A | A | A | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639747 | Compliance | Compliance | Federal Compliance | Federal HPML | Federal HPML 2014 Non Compliant | Federal Higher-Priced Mortgage Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of APOR [Redacted]%. Non-Compliant Higher Priced Mortgage Loan. | Reviewer Comment (2022-09-01): Received, Clearing. |
09/01/2022 | 1 | A | FL | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639747 | Compliance | Compliance | Federal Compliance | Federal HPML | TIL Higher Priced Mortgage Loan Safe Harbor Test | TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied. | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | FL | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639747 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation | ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Creditor did not provide a copy of each valuation to the applicant valuation missing in file. | Reviewer Comment (2022-09-01): Received, Clearing. |
09/01/2022 | 1 | A | FL | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639747 | Compliance | Compliance | Federal Compliance | Federal HPML | (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer) | TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. | Creditor did not provide a copy of each valuation to the applicant valuation missing in file. | Reviewer Comment (2022-09-01): Received, Clearing. Seller Comment (2022-09-01): Please see attached for the appraisal delivery letter. |
09/01/2022 | 1 | A | FL | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639747 | Compliance | Compliance | Federal Compliance | ECOA | ECOA Appraisal - Appraisal Provided Prior to Date Performed | ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed. Unable to determine compliance with appraisal timing requirements. | Reviewer Comment (2022-09-01): Accepted as is. |
2 | B | FL | Primary | Purchase | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||||
| 438639748 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Non Escrowed Property Costs Year 1 Test | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on [Redacted] not accurate. | The final CD disclosed the Amount of Non-Escrowed Property Costs over Year 1 as $ [Redacted]on page 4; however the HOA dues total $ [Redacted]per year. Final CD reflects Estimated Taxes, Insurance & Assessments of $ [Redacted]monthly, correct amount is $ [Redacted]. Provide a post-close CD correcting the Escrow Account section on page 4 and Estimated Taxes, Insurance & Assessments on page 1; and a copy of the letter of explanation letter sent to the borrower disclosing the changes made. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NV | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639748 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Administration Fee. Fee Amount of $ [Redacted]exceeds tolerance of $ [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Fee disclosed was last disclosed as $ [Redacted]on LE but disclosed as $ [Redacted]on Final Closing Disclosure. File does not contain a valid COC for this fee, cure provided at closing |
Reviewer Comment (2022-08-29): Sufficient Cure Provided At Closing |
08/29/2022 | 1 | A | NV | Primary | Purchase | Final CD evidences Cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639749 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: Borrower's ability to repay not verified with reliable documentation. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639749 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided within Three Days of Application) | New York Subprime Loan: Counseling Disclosure not provided to borrower within three days of application. | Evidence of earlier borrower receipt was not found in file. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | |||||||||||||
| 438639749 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted]%. Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639749 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Amount of Non-Escrowed Property Costs over Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on [Redacted] not accurate. | The final CD disclosed the Amount of Non-Escrowed Property Costs over Year 1 as $ [Redacted]on page 4; however the HOA dues total $ [Redacted]per year. Final CD reflects Estimated Taxes, Insurance & Assessments of $ [Redacted]monthly, correct amount is $ [Redacted]. Provide a post-close CD correcting the Escrow Account section on page 4 and Estimated Taxes, Insurance & Assessments on page 1; and a copy of the letter of explanation letter sent to the borrower disclosing the changes made. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | |||||||||||||
| 438639751 | Compliance | Compliance | State Compliance | State HPML | (State HPML Provision) New York Subprime Loan (Ability to Repay not Verified) | New York Subprime Loan: Borrower's ability to repay not verified with reliable documentation. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639751 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided) | New York Subprime Loan: Counseling Disclosure not provided to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | No obvious cure | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | No | ||||||||||||||
| 438639751 | Compliance | Compliance | State Compliance | State HPML | (State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage) | New York Subprime Loan: Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | Provide the following: Letter of Explanation, corrected Mortgage (with required Legend), and proof of mailing. Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery. Best Practice would be to have signed and re-recorded Mortgage.). | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639751 | Compliance | Compliance | State Compliance | State HPML | New York Subprime Home Loan Threshold Fixed Non-Compliant | New York Subprime Loan: APR on subject loan of [Redacted]% or Final Disclosure APR of [Redacted]% is in excess of allowable threshold of Prime Mortgage Market Rate [Redacted] Non-Compliant SubPrime Loan. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | NY | Primary | Purchase | While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status. Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender. There is no time limit for which such restitution must be made. | B | B | A | A | B | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||||
| 438639752 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Partial Payments | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] incorrectly disclosed whether the loan allows for Partial Payments. | Final Closing Disclosure provided on [Redacted] disclosed loan does not accept any Partial Payments | Reviewer Comment (2022-09-06): [Redacted]received PCCD. Seller Comment (2022-09-01): Please see attached PCCD with the correct partial payments section disclosed. |
09/06/2022 | 2 | B | CA | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Exempt from ATR | Exempt from ATR | Yes | ||||||||||||
| 438639754 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Credit | Guideline Requirement: Minimum Loan Amount discrepancy. | Note loan amount of ___ is less than Guideline minimum loan amount of ___. | Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. | SitusAMC | Reviewer Comment (2022-09-02): Pre Close exception to guides Seller Comment (2022-09-02): Comment from [Redacted] ([Redacted]): Please see attached exceptional approval for loan amount under $[Redacted]. The loan amount is ok on [Redacted]loan over $[Redacted]per attached 1008. |
09/02/2022 | 2 | B | GA | Investment | Refinance - Cash-out - Other | C | B | C | B | A | A | N/A | No | |||||||||||||||
| 438639756 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Articles of Organization/Formation not provided | Reviewer Comment (2022-08-25): Received, Clearing. Seller Comment (2022-08-25): Please see attached for the articles of organization. |
08/25/2022 | 1 | A | PA | Investment | Purchase | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438639760 | Credit | Missing Document | General | Missing Document | Missing Document: Verification of Non-US Citizen Status not provided | Reviewer Comment (2022-09-01): Received, Clearing. Seller Comment (2022-09-01): Permanent Resident card. |
09/01/2022 | 1 | A | PA | Investment | Purchase | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438639761 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Business Purpose Certificate not provided | Documentation is not needed | Reviewer Comment (2022-08-25): Received, Clearing. Seller Comment (2022-08-25): Please see attached for the Business Purpose Cert. |
08/25/2022 | 1 | A | MI | Investment | Purchase | C | A | C | A | A | A | N/A | No | |||||||||||||||||
| 438639767 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Business Purpose Certificate not provided | Reviewer Comment (2022-08-25): Received, Clearing. Seller Comment (2022-08-25): Please see attached for the Business Purpose Cert. |
08/25/2022 | 1 | A | NV | Investment | Purchase | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438639767 | Credit | Insurance | Insurance Documentation | Insurance | Hazard Insurance Error: Missing HO-6 policy, blanket hazard insurance policy provided does not contain unit interior coverage. | The file is missing a copy of the HO-6. | Reviewer Comment (2022-08-25): Received, Clearing. Seller Comment (2022-08-25): Please see attached HO6 with rental loss coverage and condo master insurance. And HO6 is optional from borrower when condo master insurance includes walls-in coverage. |
08/25/2022 | 1 | A | NV | Investment | Purchase | C | A | C | A | A | A | N/A | No | |||||||||||||||||
| 438639773 | Credit | Missing Document | General | Missing Document | Missing Document: Source of Funds/Deposit not provided | The file is missing source of the Earnest money deposit in the amount of $ [Redacted] | Reviewer Comment (2022-08-26): Received, Clearing. Seller Comment (2022-08-26): Please see attached for the wire request and bank activity statement. Reviewer Comment (2022-08-26): Per guides: Borrower must provide fully executed donor gift letter which w have, and: • Option 1: o donor's cancelled personal check, wire confirmation from the incoming or outgoing bank, or Official Bank/Certified Check (Official Bank check must have donor's name as Remitter), and; o borrower's bank statement evidencing deposit of donor's gift. OR • Option 2: o donor's non-negotiated check, and; o donor's bank statement evidencing withdrawal of the gift, and; o borrower's bank statement evidencing deposit of donor's gift. • Donor's XXXX Gift Letter must state donor's source of funds for the gift. Seller Comment (2022-08-26): Please see attached for the gift letter. |
08/26/2022 | 1 | A | MA | Investment | Purchase | C | A | C | A | A | A | N/A | No | |||||||||||||||||
| 438639780 | Credit | Insurance | Insurance Documentation | Insurance | Rent loss insurance is required on all properties and there is no evidence of this insurance in the file. | Reviewer Comment (2022-09-06): Received, Clearing. Seller Comment (2022-09-06): Comment from [Redacted] ([Redacted]): Please see attached insurance, the rental coverage is stated as "Actual Loss Sustained" meaning there is no month limit, and it will be covered up to what the claim would required, which meets our requirement of rent loss coverage. |
09/06/2022 | 1 | A | MA | Investment | Purchase | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438639781 | Credit | Insurance | Insurance Documentation | Insurance | Rent loss insurance is required on all properties and there is no evidence of this insurance in the file. | Hazard policy in file does not reflect rental loss coverage and guidelines require coverage equal or greater than [Redacted] months total gross rents. | Reviewer Comment (2022-08-30): Received, Clearing. Seller Comment (2022-08-30): Please see attached HOI with [Redacted]months rent loss coverage. |
08/30/2022 | 1 | A | NJ | Investment | Purchase | C | A | C | A | A | A | N/A | No | |||||||||||||||||
| 438639793 | Credit | Insurance | Insurance Analysis | Insurance | Hazard Insurance Policy expires within 90 days of the Note Date. | Hazard Insurance Policy Expiration Date ___, Note Date ___ | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | FL | Investment | Refinance - Cash-out - Other | C | B | C | B | A | A | N/A | No | ||||||||||||||||||
| 438639793 | Credit | Credit | Credit Documentation | Credit | There is no lease in place for the subject property and the absence of this document casts doubt on business purpose of loan. | Reviewer Comment (2022-09-08): Received lease agreement Seller Comment (2022-09-08): Comment from [Redacted] ([Redacted]): Please see attached lease agreement for subject property. |
09/08/2022 | 1 | A | FL | Investment | Refinance - Cash-out - Other | C | B | C | B | A | A | N/A | No | ||||||||||||||||||
| 438639793 | Credit | Insurance | Insurance Analysis | Insurance | Insufficient Coverage: Hazard insurance coverage amount is insufficient. | Reviewer Comment (2022-09-07): Received, Clearing. Seller Comment (2022-09-07): Comment from [Redacted] ([Redacted]): Dwelling coverage $[Redacted]is sufficient to cover the mortgage loan amount of $[Redacted]. |
09/07/2022 | 1 | A | FL | Investment | Refinance - Cash-out - Other | C | B | C | B | A | A | N/A | No | ||||||||||||||||||
| 438639798 | Credit | Credit | AUS Discrepancy / Guidelines Discrepancy | Guideline | Guideline Requirement: PITIA reserves months discrepancy. | Reviewer Comment (2022-08-30): Received, Clearing. Seller Comment (2022-08-30): Per final HUD 1, cash to close required $[Redacted]plus [Redacted]months PITIA reserves requirement of $[Redacted], total required $[Redacted]to close. We've verified assets from the transaction activities of [Redacted]#[Redacted]at $[Redacted]and [Redacted]#[Redacted]at $[Redacted]. Less $[Redacted]unsourced deposit and HOI premium $[Redacted]. Total asset $[Redacted]is sufficient to cover total required funds $[Redacted]to close. And UW didn't use the $[Redacted]in the qualifying funds as it was "unverifiable", and $[Redacted]was applied for HOI premium. So both $[Redacted]and $[Redacted]are excluded from the calculation of total asset. |
08/30/2022 | 1 | A | IL | Investment | Purchase | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438639800 | Credit | Loan Package Documentation | Application / Processing | Loan Package Documentation | Missing Document: Operating Agreement not provided | Reviewer Comment (2022-09-13): Received, Clearing. Seller Comment (2022-09-13): Comment from [Redacted] ([Redacted]): Please see attached Operating Agreement. |
09/13/2022 | 1 | A | FL | Investment | Refinance - Cash-out - Other | C | A | C | A | A | A | N/A | No | ||||||||||||||||||
| 438820964 | Credit | Title | General | Title | Title Policy Coverage is less than Original Loan Amount. | The Title Policy Amount of ___ is less than the note amount of ___ based on the ___ in file. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | CA | Investment | Refinance - Cash-out - Other | B | B | B | B | A | A | N/A | No | ||||||||||||||||||
| 438820946 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points. Fee Amount of $ [Redacted]exceeds tolerance of $ [Redacted]. Insufficient or no cure was provided to the borrower. | The discount points fee increased from the initial CD dated [Redacted] to the interim CD dated [Redacted]from [Redacted]. The file contains a rate lock extension; however, the date the extension was granted was [Redacted]which was not disclosed within 3 business days. | Reviewer Comment (2022-08-04): [Redacted]received CD and rate lock document dated [Redacted]. Seller Comment (2022-08-03): CS [Redacted] On [Redacted] pricing got better from $[Redacted]to $[Redacted]. Then on[Redacted] an additional [Redacted]day lock extension occurred that changed pricing to $[Redacted], which was disclosed on a CD on [Redacted](mailbox rule applied on [Redacted]). Please see attached. |
08/04/2022 | 1 | A | CA | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | A | A | A | C | A | A | A | Non QM | Non QM | No | ||||||||||||
| 438820946 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee. Fee Amount of $ [Redacted]exceeds tolerance of $ [Redacted]. Insufficient or no cure was provided to the borrower. | The lender provided a $ [Redacted]cure on the final CD; however, the cure was insufficient to cure all tolerance violations. | Reviewer Comment (2022-08-02): Cured on the Final CD. |
08/02/2022 | 1 | A | CA | Primary | Purchase | Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD | C | A | A | A | C | A | A | A | Non QM | Non QM | No | ||||||||||||
| 438820946 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee. Fee Amount of $ [Redacted]exceeds tolerance of $ [Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | SitusAMC: Suffcient cure provioded at closing. | Reviewer Comment (2022-08-04): Sufficient Cure Provided At Closing |
08/04/2022 | 1 | A | CA | Primary | Purchase | Final CD evidences Cure | C | A | A | A | C | A | A | A | Non QM | Non QM | No | ||||||||||||
| 438820945 | Credit | Loan Package Documentation | Application / Processing | Missing Document | Missing Document: AUS not provided | The loan was represented as Safe Harbor QM (APOR) which requires an AUS per guidelines. | The qualifying DTI on the loan is at least 10% less than the guideline maximum. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has verified disposable income of at least $2500.00. The representative FICO score exceeds the guideline minimum by at least 40 points. |
[Redacted] FICO | SitusAMC SitusAMC SitusAMC SitusAMC,Aggregator |
Reviewer Comment (2022-08-04): Exception set based on client purchase criteria; client acknowledged as the loan meets the seller guidelines. |
08/04/2022 | 2 | B | TX | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||
| 438820945 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Due to failing QM Points and Fees. | Reviewer Comment (2022-06-21): Lender restated the loan designation as Non-QM. |
06/21/2022 | 1 | A | TX | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||
| 438820945 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | QM Points and Fees 2021 | Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of [Redacted]% is in excess of the allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an allowable total of $[Redacted](an overage of [Redacted] | QM Points and Fees include Discount Points of $[Redacted], Funding fee of $[Redacted]and Processing Fee of $[Redacted]. No evidence of par rate was found in the file. | Reviewer Comment (2022-06-21): Lender restated the loan designation as Non-QM. |
06/21/2022 | 1 | A | TX | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||
| 438820945 | Compliance | Compliance | Federal Compliance | GSE | Fannie Mae 2014 - 3% Points and Fees | Fannie Mae 2014 [Redacted]% Points and Fees Test. Points and Fees on subject loan of [Redacted]% is in excess of the investor allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an investor allowable total of $[Redacted](an overage of [Redacted] | Lender restated the loan designation as Non-QM. | 2 | B | TX | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||||
| 438820945 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - General Ability to Repay | Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not match. However, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. | Lender restated the loan designation as Non-QM. | 2 | B | TX | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||||
| 438820948 | Credit | Loan Package Documentation | Application / Processing | Missing Document | Missing Document: AUS not provided | The representative FICO score exceeds the guideline minimum by at least 40 points. Borrowers made a down payment from their own funds on this purchase transaction of at least 5% and $5,000.00. Borrower's monthly reserves have been verified and exceed the amount required based on the guidelines by at least 4 months. Borrower has worked in the same position for more than 3 years. Borrower has verified disposable income of at least $2500.00. The qualifying DTI on the loan is at least 10% less than the guideline maximum. |
[Redacted]% DTI | SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC SitusAMC,Aggregator |
Reviewer Comment (2022-08-04): Exception set based on client purchase criteria; client acknowledged as the loan meets the seller guidelines. |
08/04/2022 | 2 | B | CA | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||
| 438820948 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Bank Statement Income | General QM: Unable to verify bank statement income using reasonably reliable third-party records. | Reviewer Comment (2022-06-21): Lender restated the loan designation as Non-QM. |
06/21/2022 | 1 | A | CA | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||||
| 438820948 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Lender presented the file as Safe Harbor QM (APOR) however designation is coming through as QM (APOR) fail. | Reviewer Comment (2022-06-21): Lender restated the loan designation as Non-QM. |
06/21/2022 | 1 | A | CA | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | ||||||||||||
| 438820948 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Restated Loan Designation Match - General Ability to Repay | Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not match. However, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. | Lender restated the loan designation as Non-QM. | 2 | B | CA | Primary | Purchase | C | B | C | B | C | B | A | A | Safe Harbor QM (APOR) | Non QM | No | |||||||||||||||
| 438820947 | Compliance | Compliance | Federal Compliance | GSE | Fannie Mae 2014 - 3% Points and Fees | Fannie Mae 2014 [Redacted]% Points and Fees Test. Points and Fees on subject loan of [Redacted]% is in excess of the investor allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an investor allowable total of $[Redacted](an overage of [Redacted] | 2 | B | FL | Primary | Purchase | B | B | A | A | B | B | A | A | Non QM | Non QM | No | ||||||||||||||||
| 438820947 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Final CD discloses a Lender cure credit | Reviewer Comment (2022-08-01): Sufficient Cure Provided At Closing |
08/01/2022 | 1 | A | FL | Primary | Purchase | Final CD evidences Cure | B | B | A | A | B | B | A | A | Non QM | Non QM | No | ||||||||||||
| 438820953 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Non Escrowed Property Costs Year 1 Test | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year [Redacted] of [Redacted]on Final Closing Disclosure provided on [Redacted] not accurate. | Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on not accurate | 2 | B | TX | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | B | B | A | A | B | B | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820956 | Credit | Title | Document Error | Title | The Preliminary title policy is within CA or NV and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided. | The Preliminary title policy does not states a coverage amount | Reviewer Comment (2022-08-10): Received supplemental report reflecting the insurance lender will be UWM in the amount of $[Redacted]. Unable to determine if that is the coverage amount or the loan amount. Please provide final title. Seller Comment (2022-08-10): [Redacted] XXXX please see attached document. |
2 | B | CA | Second Home | Purchase | B | B | B | B | A | A | A | A | Non QM | Non QM | No | |||||||||||||||
| 438820956 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Sufficient or excess cure was provided to the borrower at Closing | Reviewer Comment (2022-08-01): Sufficient Cure Provided At Closing |
08/01/2022 | 1 | A | CA | Second Home | Purchase | Final CD evidences Cure | B | B | B | B | A | A | A | A | Non QM | Non QM | No | ||||||||||||
| 438820957 | Credit | Title | Document Error | Title | The Preliminary title policy is within CA or NV and does not reflect a coverage amount (no final title policy in file). Unable to determine if appropriate coverage is provided. | The Preliminary title policy does not states a coverage amount | Reviewer Comment (2022-08-03): Received copy of the title policy with sufficient coverage. |
08/03/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | B | A | B | A | A | A | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820957 | Credit | Legal / Regulatory / Compliance | Title / Lien Defect | Title | Title Policy is Preliminary or Commitment, and not a Final Title Policy. | Reviewer Comment (2022-08-03): Received copy of the title policy with sufficient coverage. |
08/03/2022 | 1 | A | CA | Primary | Refinance - Rate/Term | B | A | B | A | A | A | A | A | Non QM | Non QM | No | |||||||||||||||
| 438820951 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Escrowed Property Costs Year 1 Includes More Than 13 months of Costs - October 2018 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] disclosed an Amount of Escrowed Property Costs over Year 1 that includes more than [Redacted]months of costs. | Tax cert in file supports Annual taxes of $[Redacted]which equates to $[Redacted]monthly, however Final CD reflects $[Redacted]monthly or $[Redacted]annually with no supporting documentation | Reviewer Comment (2022-08-04): [Redacted]received lender tax calculation and supporting document. Seller Comment (2022-08-03): [Redacted]: Please see the attached title closing invoice that shows the [Redacted]quarter property taxes as $[Redacted]. The original tax assessment showed [Redacted]annual tax amount as $[Redacted], however it also included a statement that the [Redacted]second half taxes would increase to reflect the change in assessed value, so the $[Redacted]quarterly amount would be used for the quarters going forward to equal an annual amount of $[Redacted]annually. |
08/04/2022 | 1 | A | NJ | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Non QM | Non QM | No | ||||||||||||
| 438820951 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Estimated Escrow Payment Over Disclosed | TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [Redacted] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. | Tax cert in file supports Annual taxes of $[Redacted]which equates to $[Redacted]monthly, however Final CD reflects $[Redacted]monthly or $[Redacted]annually with no supporting documentation | Reviewer Comment (2022-08-04): [Redacted]received lender tax calculation and supporting document. |
08/04/2022 | 1 | A | NJ | Primary | Purchase | TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, and Corrected CD | C | B | A | A | C | B | A | A | Non QM | Non QM | No | ||||||||||||
| 438820951 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Have Escrow - Monthly Escrow Payment Underdisclosed | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted] disclosed the Monthly Escrow Payment that does not match the actual escrow payment for the loan. | Tax cert in file supports Annual taxes of $[Redacted]which equates to $[Redacted]monthly, however Final CD reflects $[Redacted]monthly or $[Redacted]annually with no supporting documentation | Reviewer Comment (2022-08-04): [Redacted]received lender tax calculation and supporting document. Seller Comment (2022-08-03): [Redacted]: Please see the attached title closing invoice that shows the [Redacted]quarter property taxes as $[Redacted]. The original tax assessment showed [Redacted]annual tax amount as $[Redacted], however it also included a statement that the [Redacted]second half taxes would increase to reflect the change in assessed value, so the $[Redacted]quarterly amount would be used for the quarters going forward to equal an annual amount of $[Redacted]annually. |
08/04/2022 | 1 | A | NJ | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Non QM | Non QM | No | ||||||||||||
| 438820951 | Compliance | Compliance | Federal Compliance | GSE | Fannie Mae 2014 - 3% Points and Fees | Fannie Mae 2014 [Redacted]% Points and Fees Test. Points and Fees on subject loan of [Redacted]% is in excess of the investor allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an investor allowable total of [Redacted] | Fannie Mae 2014 [Redacted]% Points and Fees Test. Points and Fees on subject loan of [Redacted]% is in excess of the investor allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an investor allowable total of $[Redacted](an overage of [Redacted]. | 2 | B | NJ | Primary | Purchase | C | B | A | A | C | B | A | A | Non QM | Non QM | No | |||||||||||||||
| 438820951 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Escrowed Property Costs Year 1 - October 2018 Testing | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on [Redacted] not accurate. | SitusAMC received proof of tax calculation and supporting document. However, the approval reflected on the 1008 transmittal only reflect tax and insurance qualified at $[Redacted]which does not match to the CD cost of $[Redacted] | 2 | B | NJ | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820950 | Compliance | Compliance | Federal Compliance | GSE | Fannie Mae 2014 - 3% Points and Fees | Fannie Mae 2014 [Redacted]% Points and Fees Test. Points and Fees on subject loan of [Redacted]% is in excess of the investor allowable maximum of [Redacted]% of the Federal Total Loan Amount. Points and Fees total $[Redacted]on a Federal Total Loan Amount of $[Redacted]vs. an investor allowable total of $[Redacted](an overage of [Redacted] | Fees exceed [Redacted]%. | 2 | B | FL | Primary | Purchase | B | B | A | A | B | B | A | A | Non QM | Non QM | No | |||||||||||||||
| 438820968 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM - Missing Investor Guideline Qualifying Total Debt Ratio | Unable to complete QM testing due to missing investor guideline qualifying total debt ratio. | Reviewer Comment (2022-08-31): Restated. Buyer Comment (2022-08-31): Being restated to NQM - No Ratio program |
08/31/2022 | 1 | A | AR | Primary | Purchase | C | B | A | A | C | B | A | A | Non QM | ATR Risk | No | ||||||||||||||
| 438820968 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General QM Provision Income and Assets - DTI | General QM: No debt to income ratio (or a negative or zero ratio) was provided to demonstrate ability to repay. | Reviewer Comment (2022-08-31): Restated. Buyer Comment (2022-08-31): Being restated to NQM - No Ratio program |
08/31/2022 | 1 | A | AR | Primary | Purchase | C | B | A | A | C | B | A | A | Non QM | ATR Risk | No | ||||||||||||||
| 438820968 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - QM | Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. | Verified Loan Designation of Safe Harbor QM | Reviewer Comment (2022-08-31): Restated. Buyer Comment (2022-08-31): Loan is a No Ratio program - please restate to NQM as it can't pass QM testing without the debt ratios |
08/31/2022 | 1 | A | AR | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | A | A | C | B | A | A | Non QM | ATR Risk | Yes | ||||||||||||
| 438820968 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Will Not Have Escrow - Reason | TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [Redacted]incorrectly disclosed whether the loan will have an escrow account. | Final Closing Disclosure did not state if escrows were declined or lender does not provide | Reviewer Comment (2022-09-07): [Redacted] received LOE and corrected closing disclosure. Reviewer Comment (2022-09-07): Exception cleared in error. Reviewer Comment (2022-09-07): Received, Clearing. Seller Comment (2022-09-07): Comment from [Redacted]l ([Redacted]): Uploaded attached PCCD provided to complete the No Escrow section on CD page [Redacted]to reflect the Escrow Waiver on file and the LOX. |
09/07/2022 | 2 | B | AR | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | C | B | A | A | C | B | A | A | Non QM | ATR Risk | Yes | ||||||||||||
| 438820968 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General Ability To Repay - Missing Investor Guideline Qualifying Total Debt Ratio | Unable to complete ATR testing due to missing investor guideline qualifying total debt ratio. | Reviewer Comment (2022-08-31): Clearing. |
08/31/2022 | 1 | A | AR | Primary | Purchase | C | B | A | A | C | B | A | A | Non QM | ATR Risk | No | ||||||||||||||
| 438820968 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | General Ability To Repay Provision Income and Assets - No DTI Provided | Ability to Repay (Dodd-Frank 2014): No debt to income ratio (or a negative or zero ratio) was provided to demonstrate ability to repay. | Reviewer Comment (2022-08-31): Clearing. |
08/31/2022 | 1 | A | AR | Primary | Purchase | C | B | A | A | C | B | A | A | Non QM | ATR Risk | No | ||||||||||||||
| 438820968 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - ATR | Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Fail. | Restated. | Reviewer Comment (2022-08-31): Clearing. |
08/31/2022 | 1 | A | AR | Primary | Purchase | Lender to provide updated ATR/QM status | C | B | A | A | C | B | A | A | Non QM | ATR Risk | Yes | ||||||||||||
| 438820968 | Compliance | Compliance | Federal Compliance | ATR/QM | NonQM ATR | Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied. | Restated. | Reviewer Comment (2022-08-31): Clearing. |
08/31/2022 | 1 | A | AR | Primary | Purchase | C | B | A | A | C | B | A | A | Non QM | ATR Risk | No | |||||||||||||
| 438820968 | Compliance | Compliance | Federal Compliance | ATR/QM Defect | Check Loan Designation Match - ATR Risk | Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk. | Reviewer Comment (2022-09-19): Accepted as is. Reviewer Comment (2022-09-08): Regraded to [Redacted] due to asset qualifier loan. Buyer Comment (2022-09-07): Comment from [Redacted] ([Redacted]): restate to ATR Risk to downgrade to a [Redacted] |
2 | B | AR | Primary | Purchase | Lender to provide updated ATR/QM Loan Designation | C | B | A | A | C | B | A | A | Non QM | ATR Risk | Yes | ||||||||||||||
| 438820968 | Compliance | Compliance | Federal Compliance | ATR/QM | General Ability To Repay Provision Asset Qualification Loan | Ability to Repay (Dodd-Frank 2014): It is questionable whether this loan meets ATR requirements. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | AR | Primary | Purchase | C | B | A | A | C | B | A | A | Non QM | ATR Risk | No | |||||||||||||||
| 438820969 | Compliance | Compliance | Federal Compliance | Missing Disclosure | Acknowledgement of Borrower Receipt of Notice of Special Flood Hazard Disclosure Missing | FDPA Notification Rule: Creditor did not retain record of borrower's receipt of Notice of Special Flood Hazard Disclosure. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | TX | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Non QM | Non QM | No | |||||||||||||||
| 438820969 | Compliance | Compliance | Federal Compliance | RESPA | RESPA Disclosure - List of Homeownership Counseling Organizations Missing | RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | TX | Primary | Refinance - Cash-out - Other | B | B | A | A | B | B | A | A | Non QM | Non QM | No | |||||||||||||||
| 438820969 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure did not disclose Amount of Non-Escrowed Property Costs over Year 1 | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted] on Final Closing Disclosure provided on [Redacted] not accurate. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | TX | Primary | Refinance - Cash-out - Other | Letter of Explanation & Corrected Closing Disclosure | B | B | A | A | B | B | A | A | Non QM | Non QM | Yes | ||||||||||||||
| 438820969 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Escrowed Property Costs Year 1 - October 2018 Testing | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Escrowed Property Costs over Year 1 of [Redacted]on Final Closing Disclosure provided on [Redacted] not accurate. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | TX | Primary | Refinance - Cash-out - Other | Letter of Explanation & Corrected Closing Disclosure | B | B | A | A | B | B | A | A | Non QM | Non QM | Yes | ||||||||||||||
| 438820969 | Compliance | Compliance | State Compliance | Misc. State Level | (TX50(a)(6)) Texas Cash-out Loan (T-42 Endorsement Not Obtained) | Unable to determine whether the loan contains a [Redacted] Endorsement due to missing information. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | TX | Primary | Refinance - Cash-out - Other | The endorsements would be required at the time of original title policy issuance, there is not an obvious remediation | B | B | A | A | B | B | A | A | Non QM | Non QM | No | ||||||||||||||
| 438820969 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | SitusAMC cure provided at closing. | Reviewer Comment (2022-09-07): [Redacted]Cure Provided At Closing |
09/07/2022 | 1 | A | TX | Primary | Refinance - Cash-out - Other | Final CD evidences Cure | B | B | A | A | B | B | A | A | Non QM | Non QM | Yes | ||||||||||||
| 438820963 | Credit | Title | General | Title | Title Policy Coverage is less than Original Loan Amount. | The Title Policy Amount of ___ is less than the note amount of ___ based on the ___ in file. | The file is missing a copy of the updated title policy with the correct loan amount. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | CA | Investment | Refinance - Cash-out - Other | B | B | B | B | A | A | N/A | No | |||||||||||||||||
| 438820970 | Compliance | Compliance | Federal Compliance | TRID | TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing | TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $[Redacted]exceeds tolerance of $[Redacted]. Sufficient or excess cure was provided to the borrower at Closing. | Reviewer Comment (2022-09-01): Sufficient Cure Provided At Closing |
09/01/2022 | 1 | A | NJ | Primary | Purchase | Final CD evidences Cure | A | A | A | A | A | A | A | A | Safe Harbor QM (APOR) | Safe Harbor QM (APOR) | Yes | |||||||||||||
| 438820971 | Compliance | Compliance | Federal Compliance | FACTA | Federal FACTA Disclosure Timing Test | FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | TX | Primary | Purchase | B | B | A | A | B | B | A | A | Non QM | Non QM | No | |||||||||||||||
| 438820971 | Compliance | Compliance | Federal Compliance | TRID Defect | TRID Final Closing Disclosure Non Escrowed Property Costs Year 1 Test | TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of [Redacted] on Final Closing Disclosure provided on [Redacted] not accurate. | Reviewer Comment (2022-09-19): Accepted as is |
2 | B | TX | Primary | Purchase | Letter of Explanation & Corrected Closing Disclosure | B | B | A | A | B | B | A | A | Non QM | Non QM | Yes |