Angel Oak Mortgage Trust I, LLC ABS-15G
Exhibit 99.16
EXECUTIVE
SUMMARY
Third Party Due Diligence Review
Overview
Consolidated Analytics, Inc (“Consolidated Analytics”), a third-party due diligence provider, performed the review described below on behalf of Angel Oak Mortgage Fund EU B LLC (the “Client”). The review included a total of 298 newly originated residential mortgage loans, in connection with the securitization identified as Angel Oak Mortgage Trust 2025-5 (the “Securitization”). The Review was conducted from August 2022 through March 2025 on mortgage loans originated between July 2022 and March 2025.
Scope of Review
Credit Review
Consolidated Analytics performed a “Credit Review” to verify compliance with guidelines in effect at the time of loan origination, or other guidelines provided by Clients prior to review, and ensure the characteristics used by the underwriter are supported by the file documentation; and determine whether any loans outside of those guidelines contain legitimate and approved exceptions with compensating factors.
The Credit Review attempted to confirm the following:
a. | QM or ATR Validation / Review of 8 Key Underwriting Factors |
i. | Income / Assets |
● | Validate borrower(s) monthly gross income |
● | Validate funds required to close, required reserves |
● | Review file documentation for required level of income and asset verifications |
ii. | Employment Status |
● | Review file documentation for required level of employment |
iii. | Monthly Mortgage Payment |
● | Confirm program, qualifying rate, terms |
iv. | Simultaneous Loans |
● | Validate all concurrent loans are included in the DTI to properly assess the ability to repay |
v. | Mortgage Related Obligations: PITI, HOA, PMI, etc. |
● | Validate subject loan monthly payment (PITI) and associated obligations |
vi. | Debts / Obligations |
● | Validate monthly recurring liabilities |
vii. | DTI and/or Residual Income |
● | Validate debt-to-income ratio (DTI) based upon income and debt documentation provided in the file |
● | Documentation meets Appendix Q requirements for QM Loans |
viii. | Credit History |
● | Review credit report for credit history and required credit depth including any / all inquiries |
● | Determine representative credit score from credit report |
b. | Validate loan-to-value (LTV) and combined loan-to-value |
c. | Review borrower’s occupancy |
d. | Validation through third party resource of the subject properties most recent twelve (12) month sales history |
e. | Confirm sufficient evidence in loan file, by reviewing the underwriter’s decision to approve the loan based upon the borrows income, debt, and credit history, to support borrower’s willingness and ability to repay the debt |
f. | Confirm that Final 1003 is sufficiently completed |
g. | Provide Audit 1008 with accurate data based on file documentation |
h. | Confirm Loan Approval conditions were met |
i. | Review condominium questionnaire to verify all information is complete, prepared by an authorized representative, and address any red flags that may deem condominium project ineligible |
j. | General QM for any loans originated under the GQM Rule |
i. | Pricing Thresholds: |
a. | Pricing for First Lien Loans: |
i. | 2.25% for a first-lien covered transaction with a loan amount greater than or equal to the applicable dollar amount threshold; and |
ii. | 3.5% for a first-lien covered transaction with a loan amount greater than or equal to the applicable dollar amount threshold; and |
iii. | 6.5% for a first-lien covered transaction with a loan amount less than the applicable dollar amount threshold. |
b. | Pricing for Subordinate Lien Loans: |
i. | 3.5% for a subordinate-lien covered transaction with a loan amount greater than or equal to the applicable dollar amount threshold; and |
ii. | 6.5% for a subordinate-lien covered transaction with a loan amount less than the applicable dollar amount threshold. |
c. | Pricing for Manufactured Homes: |
i. | 2.25% for a first-lien covered transaction secured by a manufactured home with a loan amount equal to or greater than the applicable dollar amount threshold; and |
ii. | 6.5% for a covered transaction secured by a manufactured home with a loan amount less than applicable dollar amount threshold. |
ii. | Consider Income and Assets: |
○ | Consumer’s current or reasonably expected income or assets (other than the value of the dwelling that secures the loan; |
○ | The consumer’s debt obligations, alimony, child support; and |
○ | The monthly DTI or residual income. |
iii. | Verification of Income and Assets: |
a. | Verification in compliance with one of the “safe harbor” guidelines will meet the QM verification requirement. A creditor is allowed to “mix and match” provisions of the different guidelines rather than only apply one guideline per loan. |
The specific guidelines that the CFPB is designating for the safe harbor are: The GQM Rule provides that if the creditor verifies the consumer’s income or assets, debt obligations, alimony, child support, and monthly DTI or residual income by meeting the standards of certain specified third-party underwriting manuals, then a creditor is presumed to have complied with the verification requirement. These specified manuals are:
i. | Chapters B3-3 through B3-6 of the Fannie Mae Single Family Selling Guide, published June 3, 2020; |
ii. | Sections 5102 through 5500 of the Freddie Mac Single-Family Seller/Servicer Guide, published June 10, 2020; |
iii. | Sections II.A.1 and II.A.4-5 of the Federal Housing Administration’s Single Family Housing Policy Handbook, issued October 24, 2019; |
iv. | Chapter 4 of the U.S. Department of Veterans Affairs’ Lenders Handbook, revised February 22, 2019; |
v. | Chapter 4 of the U.S. Department of Agriculture’s Field Office Handbook for the Direct Single Family Housing Program, revised March 15, 2019; and |
vi. | Chapters 9 through 11 of the U.S. Department of Agriculture’s Handbook for the Single Family Guaranteed Loan Program, revised March 19, 2020. |
Compliance Review
Consolidated Analytics performed a “Compliance Review” to determine, as applicable, to the extent possible and subject to the caveats below, whether the loan complies with applicable regulatory requirements as noted below, each as amended, restated and/or replaced from time to time. The Compliance Review included the following:
a. | Test Loan Estimate(s) for accuracy and completeness as well as timing requirements as required by TRID Regulations |
b. | Test Closing Disclosure(s) for accuracy and completeness as well as timing requirements as required by TRID Regulations |
c. | Tolerance Testing |
i. | Compare Loan Estimate and Closing Disclosures |
ii. | Identify Tolerance Violations and applicable cost to cure |
d. | Comprehensive review of Closing Disclosure to determine transaction accuracy |
e. | Recalculation of APR and Finance Charge |
f. | Testing of: |
i. | Federal High Cost Mortgage provisions |
ii. | Federal Higher Priced Mortgage Loans provisions |
iii. | Local and/or State Anti-predatory and High Cost provisions |
iv. | HOEPA Points and Fees |
g. | Determine whether specified federal disclosures were provided timely based upon comparison of the application date to the dates on such disclosures |
i. | Service Provider List |
ii. | Home Ownership Counselling Disclosure |
iii. | ARM Disclosure |
h. | Compliance with QM as it relates to: |
i. | APR Test |
ii. | Points & Fees Test |
iii. | Prepayment Penalty Test |
iv. | Product Eligibility Testing |
i. | Notice of Right to Cancel (Rescission) Review |
i. | Confirm transaction date, expiration date, and disbursement date |
ii. | Confirm document is properly executed by all required parties to the transaction |
iii. | Confirm the correct Right of Rescission document was executed for the transaction type |
j. | Confirm through NMLS the loan originator and originating firm’s license status was active and properly disclosed on appropriate loan documents |
k. | Check the Loan participants against the exclusionary list provided by Clients or by the purchaser of the Loan(s) |
l. | Review closing documents to ensure that the Mortgage Loan information is complete, accurate, and consistent with other documents; Confirm collateral documents have been recorded or sent for recording |
The Compliance Review did not include any federal, state or local laws, constitutional provisions, regulations or ordinances that are not expressly enumerated above. Furthermore, the findings reached by Consolidated Analytics are dependent upon its receiving complete and accurate data regarding the loans from loan originators and other third parties upon which Consolidated Analytics is relying in reaching such findings.
Valuation Review
Consolidated Analytics performed a “Valuation Review,” which included the following:
a. | Review original appraisal, determination that property is in “average” condition or better, or property requires cosmetic improvements (as defined by the appraiser) that do not affect habitability. Should an area of concern be identified with the condition of the property, Consolidated Analytics will alert Clients. |
b. | Review appraisal, determination that property is completely constructed and appraisal is on an “as is basis,” or property is identified as not completely constructed by originating appraiser. |
c. | Review and determine if the appraisal report was performed on appropriate GSE forms and if the appraiser indicated in the body of the subject appraisal that the appraisal conforms to USPAP standards. |
d. | Review and determine the relevance of the comparable properties and ensure that a rational and reliable value was provided and supported as of the effective date of the Origination Appraisal. |
e. | Review adjustments (line item, net and gross adjustments) to ensure they are reasonable. |
f. | Ensure that the appraisal conforms to the guidelines provided from the Clients. |
g. | Review appraisal to ensure all required documents were included. |
h. | Review location map provided within the appraisal for external obsolescence. |
i. | Ensure highest and best use and zoning complies with guidelines. |
j. | Confirm there are no marketability issues that affect the subject property. |
k. | Ensure subject property does not suffer any functional obsolescence. |
l. | Where applicable, determine if the file did not contain the appraisal or other valuation method and a review could not be performed. |
m. | Additional valuation products were not required when the CU score provided was 2.5 or below or the appraisal LCA risk score was eligible for Collateral Rep and Warranty relief. In the event the CU score was greater than 2.5 or the LCA score was not eligible for R&W relief, an additional valuation product was obtained to confirm value was supported within 10% tolerance. In some instances, based on guidance from the seller, CDA’s were ordered on loans that had an acceptable CU score or R&W eligibility. |
Consolidated Analytics applied a cascade methodology to determine if the original appraised value was reasonably supported when compared to an independent third party valuation product.
For loans reviewed in a post-close valuation review scenario (298 loans in total):
Two-hundred four (204) loans had CU scores of 2.5 or less or were eligible for Collateral Rep and Warranty relief.
Twenty-one (21) loans had an AVM, five (5) loans had Secondary Appraisals, and eighty-six (86) loans had a Desktop Review. Consolidated Analytics has independent access to the Desktop Reviews ordered by the Aggregator.
If a loan with an AVM or Desktop Review fell outside of a -10% tolerance, was inconclusive, or a PIW was present, then an additional valuation product was completed. There was one (1) instance of this.
Product totals may not sum due to multiple products for each loan
TAPE INTEGRITY REVIEW RESULTS SUMMARY
Of the 298 mortgage loans reviewed, one-hundred eighteen (118) unique mortgage loans (39.60% by loan count) had a total of two hundred sixty (260) tape discrepancies across fifteen (15) data fields. A blank or zero value on the data tape when an actual value was captured by Consolidated Analytics was not treated as a data variance.
Fields Reviewed | Discrepancy
Count |
Percentage |
Qualifying All Borrower Residual Income | 65 | 25.00% |
QM Qualifying Total Debt Income Ratio | 50 | 19.23% |
Qualifying Total Reserves Number of Months | 45 | 17.31% |
Property Type | 42 | 16.15% |
Months Reserves | 20 | 7.69% |
Calculated DSCR | 13 | 5.00% |
Qualifying FICO | 8 | 3.08% |
Application Date | 4 | 1.54% |
STR | 4 | 1.54% |
Gross Rent | 3 | 1.15% |
Prepayment Penalty | 2 | 0.77% |
Lock Term (Days) | 1 | 0.38% |
Loan Purpose | 1 | 0.38% |
Property Value | 1 | 0.38% |
Property Address | 1 | 0.38% |
Grand Total | 260 | 100.00% |
Summary of Results
OVERALL RESULTS SUMMARY
Final Loan Grades
Overall Loan Results: | |||
Event Grade | Loan Count | Original Principal Balance | Percent of Sample |
Event Grade A | 250 | $98,630,989.00 | 83.89% |
Event Grade B | 48 | $29,574,300.00 | 16.11% |
Event Grade C | 0 | $0.00 | 0.00% |
Event Grade D | 0 | $0.00 | 0.00% |
Total Sample | 298 | $128,205,289.00 | 100.00% |
Credit Results: | |||
Event Grade | Loan Count | Percent of Sample | |
Event Grade A | 267 | 89.60% | |
Event Grade B | 31 | 10.40% | |
Event Grade C | 0 | 0% | |
Event Grade D | 0 | 0% | |
Total Sample | 298 | 100.00% |
Compliance Results: | |||
Event Grade | Loan Count | Percent of Sample | |
Event Grade A | 275 | 92.28% | |
Event Grade B | 23 | 7.72% | |
Event Grade C | 0 | 0% | |
Event Grade D | 0 | 0% | |
Total Sample | 298 | 100.00% |
Valuation Results: | |||
Event Grade | Loan Count | Percent of Sample | |
Event Grade A | 297 | 99.66% | |
Event Grade B | 1 | 0.34% | |
Event Grade C | 0 | 0% | |
Event Grade D | 0 | 0% | |
Total Sample | 298 | 100.00% | |
Exception Category Summary
The table below summarizes the individual exceptions which carried an associated “A”, “B”, “C”, or “D” level exception grade. One loan may have carried more than one exception. In such cases, the exception with the lowest grade would drive the loan grade for that particular area of the review. The overall loan grade is the lowest grade for any one particular review scope (ex. a loan with a Compliance Grade of “B”, a Credit Grade of “A”, and a Property Grade of “A” would receive an overall Loan Grade of “B”).
Exception
Type |
Exception Level Grade |
Exception Category | Total |
|
A | No Credit Findings | 198 |
ATR: Current Employment Not Verified | 8 | ||
Entity Documentation - Missing or Defective | 5 | ||
Borrower 1 CPA Letter Missing | 5 | ||
Approval/Underwriting Summary Partially Provided | 4 | ||
Purchase Contract is Expired | 4 | ||
Title Insurance Missing or Defective | 3 | ||
Title Insurance Coverage - Inadequate Coverage | 3 | ||
Closing Protection Letter Missing or Defective | 3 | ||
Credit Report Aged | 3 | ||
Minimum Credit Score Requirement Not Met | 2 | ||
Housing History Does Not Meet Guideline Requirements | 2 | ||
Note Missing or Defective | 2 | ||
Asset Qualification Does Not Meet Guideline Requirements | 2 | ||
Income and Employment Do Not Meet Guidelines | 2 | ||
Approval/Underwriting Summary Not Provided | 2 | ||
ATR: Reasonable Income or Assets Not Considered | 2 |
Credit |
Hazard Insurance Effective Date is after the Disbursement Date | 2 | |
Audited DTI Exceeds Guideline DTI | 2 | ||
Hazard Insurance Missing or Defective | 2 | ||
Credit Report Missing or Defective | 2 | ||
Borrower 1 3rd Party VOE Prior to Close Missing | 1 | ||
Background Check Missing or Defective | 1 | ||
Qualifying DTI exceeds Guideline Maximum Allowable | 1 | ||
Borrower 1 Credit Report is Expired | 1 | ||
Mortgage Insurance Cert Missing | 1 | ||
Borrower 1 Gap Credit Report is Expired (Greater than 10 Days from Closing/Settlement Date) | 1 | ||
Borrower 1 Business Bank Statements Missing | 1 | ||
Guideline Seasoning not Met | 1 | ||
Title Coverage is Less than Subject Lien | 1 | ||
Borrower 1 Gap Credit Report is Missing | 1 | ||
Missing VOM or VOR | 1 | ||
Borrower Contributions Do Not Met Guideline Minimum | 1 | ||
Citizenship Documentation Not Provided | 1 | ||
HO6 Master Insurance Policy is Missing | 1 | ||
Property Title Issue | 1 | ||
Borrower does not meet residual income requirement | 1 | ||
Purchase Contract is Incomplete | 1 | ||
Housing history does not meet guidelines | 1 | ||
Sales Contract Missing or Defective | 1 | ||
Borrower Employment Verification does not meet guidelines | 1 |
Title Document Missing | 1 | ||
Borrower Liabilities Verification Indicator is Partial | 1 | ||
Missing verification of taxes, insurance, and/or HOA fees for non-subject property | 1 | ||
All Interested Parties Not Checked with Exclusionary Lists | 1 | ||
Delinquent Credit History Does Not Meet Guideline Requirements | 1 | ||
Total Credit Grade (A) Exceptions: | 283 | ||
B | Audited Reserves are less than Guideline Required Reserves (Dollar Amount) | 6 | |
Housing History Does Not Meet Guideline Requirements | 5 | ||
Payment shock exceeds guideline | 4 | ||
Insufficient Assets for Reserves | 3 | ||
Delinquent Credit History Does Not Meet Guideline Requirements | 3 | ||
Excessive Cash-Out Refinance | 3 | ||
Borrower does not meet residual income requirement | 2 | ||
Excessive LTV Ratio | 2 | ||
Audited DTI Exceeds Guideline DTI | 2 | ||
Borrower 1 Gap Credit Report is Missing | 1 | ||
Underwriting LTV exceeds Guideline Maximum Allowable | 1 | ||
Underwriting CLTV exceeds Guideline Maximum Allowable | 1 | ||
Asset 4 Does Not Meet Guideline Requirements | 1 | ||
Borrower 1 Gap Credit Report is Expired (Greater than 10 Days from Closing/Settlement Date) | 1 | ||
Borrower Non-US Citizen Identification Document Missing | 1 | ||
Residual income does not meet guidelines. | 1 | ||
Guideline Seasoning not Met | 1 | ||
Underwriting FICO does not meet Guideline Minimum Required | 1 |
Borrower 2 Gap Credit Report is Missing | 1 | ||
Audited FICO is less than Guideline FICO | 1 | ||
Income and Employment Do Not Meet Guidelines | 1 | ||
Total Credit Grade (B) Exceptions: | 42 | ||
Compliance
|
A | No Compliance Findings | 77 |
Higher-Priced Mortgage Loan Test | 25 | ||
Evidence of Appraisal Delivery to Borrower not Provided or Late (12 CFR 1002.14(a)(1)) | 6 | ||
Missing Credit Score Disclosure (FACTA) | 5 | ||
NC Rate Spread Home Loan Test | 3 | ||
Higher-Priced Mortgage Loan Evidence of Appraisal Delivery to the Borrower Not Provided (12 CFR 1026.35(c)(6)) | 3 | ||
Missing Required Affiliated Business Disclosure | 2 | ||
TRID: Missing Loan Estimate | 2 | ||
Homeownership Counseling Disclosure Is Missing | 2 | ||
Charges That Cannot Increase Test | 2 | ||
OK HOEPA Higher-Priced Mortgage Loan Test | 1 | ||
Charges That In Total Cannot Increase More Than 10% Test | 1 | ||
RESPA Homeownership Counseling Organizations Disclosure Date Test | 1 | ||
MD COMAR Higher-Priced Mortgage Loan Test | 1 | ||
eSigned Documents Consent is Missing | 1 | ||
Initial Loan Estimate Delivery Date Test (from application) | 1 | ||
Total Compliance Grade (A) Exceptions: | 133 | ||
B | Charges That Cannot Increase Test | 13 | |
Charges That In Total Cannot Increase More Than 10% Test | 10 | ||
Higher-Priced Mortgage Loan | 1 |
|
Total Compliance Grade (B) Exceptions: | 24 | |
Property | A | No Property Findings | 120 |
Hazard Insurance Missing or Defective | 6 | ||
Appraisal Review - Missing | 5 | ||
Third Party Valuation Product Not Provided within 10% Tolerance | 4 | ||
Property Issue(s) are Present | 2 | ||
Appraisal Aged | 1 | ||
Subject property appraisal is not on an as-is basis (Primary Value) | 1 | ||
HOA Questionnaire is Missing | 1 | ||
Market Rent - Missing or Defective | 1 | ||
Total Property Grade (A) Exceptions: | 141 | ||
B | Ineligible Property – Square Footage | 1 | |
Total Property Grade (B) Exceptions: | 1 |
Event Grade Definitions
Final Loan Grade | |
A | Loan meets Credit, Compliance, and Valuation Guidelines |
B | The loan substantially meets published Clients/Seller guidelines and/or eligibility in the validation of income, assets, or credit, is in material compliance with all applicable laws and regulations, and the value and valuation methodology is supported and substantially meets published guidelines. |
C | The loan does not meet the published guidelines and/or violates one material law or regulation, and/or the value and valuation methodology is not supported or did not meet published guidelines. |
D | Loan is missing documentation to perform a sufficient review. |
Credit Event Grades | |
A | The loan meets the published guidelines without any exceptions. The employment, income, assets and occupancy are supported and justifiable. The borrower’s willingness and ability to repay the loan is documented and reasonable. |
B | The loan substantially meets the published guidelines but reasonable compensating factors were considered and documented for exceeding published guidelines. The employment, income, assets and occupancy are supported and justifiable. The borrower’s willingness and ability to repay the loan is documented and reasonable. |
C | The loan does not substantially meet the published guidelines. There are not sufficient compensating factors that justify exceeding the published guidelines. The employment, income, assets or occupancy are not supported and justifiable. The borrower’s willingness and ability to repay the loan were not documented or are unreasonable. |
D | There was not sufficient documentation to perform a review or the credit file was not furnished. |
Compliance Event Grades | |
A | The loan is in compliance with all applicable laws and regulations. The legal documents accurately reflect the agreed upon loan terms and are executed by all applicable parties. |
B | The loan is in material compliance with all applicable laws and regulations. The legal documents accurately reflect the agreed upon loan terms and are executed by all applicable parties. Clients review required. |
C | The loan violates one material law or regulation. The material disclosures are absent or the legal documents do not accurately reflect the agreed upon loan terms or all required applicants did not execute the documents. |
D | There was not sufficient documentation to perform a review or the required legal documents were not furnished. |
Valuation Event Grades | |
A | The value is supported within 10% of the original appraisal by the AVM or there are other supporting documents in the originators loan file package (CDA, Field Review or Second Appraisal). The appraisal was performed on an “as-is” basis and the property is complete and habitable at origination. The appraiser was appropriately licensed and used GSE approved forms. |
B | The value is not supported within 10% of the original appraisal by the AVM and there are no other valuation support documents in the loan file provided by the Seller. The valuation methodology substantially meets the published guidelines but reasonable compensating factors were considered and documented for exceeding guidelines. The appraisal was performed on an “as-is” basis and the property is complete and habitable. The appraiser was appropriately licensed and used GSE approved forms. |
Valuation Event Grades | |
C | The value is not supported within 10% of the original appraisal. The valuation methodology did not meet the published guidelines and there were not sufficient compensating factors for exceeding published guidelines. The property is in below “average” condition or the property is not complete or requires significant repairs. The appraisal was not performed on an “as is” basis. The appraiser was not appropriately licensed or did not use GSE approved forms. |
D | The file was missing the appraisal or there was not sufficient valuation documentation to perform a review. |