Exhibit 99.9

EXECUTIVE SUMMARY
THIRD PARTY DUE DILIGENCE REVIEW

Overview

Maxwell Diligence Solutions, LLC (“MaxDiligence”), a third-party due diligence provider, performed the review described below on behalf of its client, Santander Bank, N.A. The review included a total of 1 newly originated residential mortgage loan, in connection with the securitization identified as SAN 2025-NQM3 (the “Securitization”). The review began on May 2024 and concluded on June 2024.

Scope of Review

Credit Review

MaxDiligence performed a “Credit Review” to verify compliance with guidelines in effect at the time of loan origination, or other guidelines provided by Client 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 included the following (collectively, the “Credit Review”):

Review Initial & Final Application

Check application for completeness. Determine whether the information in the preliminary Loan application, final application, and all credit documents is consistent or reconciled.

Validate Social Security/Taxpayer Identification number is valid

Compare data on final form 1003 with the data from verifications

Form is Complete, Signed, Dated, on or before loan consummation date, and NMLS is complete

Review AUS Decision and Approval Conditions

Underwriting decision is supported (manual underwrite credit conditions have been satisfied prior to closing the approved Loan package)

Validation of income calculations

Validation of assets/funds to close

Validation of DTI calculations

Validation of LTV calculations

Validation of payment shock calculations if applicable

Review Occupancy/Red Flags

Occupancy is supported

Red Flags adequately addressed

Verification of Borrower Original and Audit Credit Report (if applicable)

Validate names, social security number(s), and addresses

AKA’s investigated and cleared

Validate credit inquiries within 90 days have been properly addressed

Acceptable credit history and credit score requirements

Reviews Fraud Report to compare vs loan documentation:

Validates Social Security number and year issued

Verifies address information associated with the Borrower (s)

Confirms OFAC clearances

Reveals any potential bankruptcy filings

Review of Borrower Employment, Income, and Asset Information

Employment

Compare for conflicting information

ii.

Check dates for document expiration

iii.

Complete forms and documentation

iv.

Evaluate history and stability of employment

Income

Review employment and income by analyzing income documents and comparing against re-verification documents

ii.

W-2s and Paystubs, if applicable

iii.

Transcripts (as applicable) support income

iv.

Tax Returns and Profit and Loss Statements, as applicable

Bank Statements or other Alternate Income documents as required by the guidelines

vi.

Consistent/Continuing Employment, if applicable

Assets

Confirm adequate funds to cover required down payment and closing costs and reserves

ii.

Check dates for document expiration

iii.

Sufficient funds were sourced and seasoned

iv.

Gift funds verified and met guidelines

Review Sales Contract

Complete and executed

Earnest Money Deposit verified

Parties are consistent

Seller contributions are within guidelines

Hazard and Flood (if applicable)

Verify sufficient coverage

Verify coverage is for subject

Validate all premiums are included in DTI and any required upfront premium is paid

Mortgage Insurance (if applicable)

Certificate in file

Sufficient Coverage

Premium indicated and included in DTI

10.

Review Title Commitment/Policy

Vesting correct

Lien position

Legal description

Validate no encumbrances

11.

Review Closing Documents

Review security documents to ensure the Loan was closed in accordance with approval and with all required signatures and NMLS identifiers

Correct and complete instruments

Closing Disclosure

Right to Cancel (if applicable)

12.

Qualified Mortgage / Ability-to-Repay Review

Loans with application dates after January 10, 2014 are subject to the Qualified Mortgage (“QM”) rule and the Ability to Repay (“ATR”) rule under Regulation Z – the Truth in Lending Act. For these Loans, Service Provider will (a) Confirm that the originator/aggregator provided a QM designation, and (b) review the Loan for the eight (8) Key Underwriting Factors below that are required pursuant to the ATR rule.

	a.	Sections 1411 and 1412 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) amending TILA, as implemented by Regulation Z, 12 C.F.R. 1026.43, excluding investment properties, as set forth below:

The general Ability to Repay (ATR) underwriting standards (12 C.F.R. 1026.43(c)) as evaluated based on the applicable investor guidelines;

ii.

Refinancing of non-standard mortgages (12 C.F.R. 1026.43(d));

iii.

Qualified Mortgages (QM) (12 C.F.R. 1026.43(e) (including qualified mortgages as separately defined by the Department of Housing and Urban Development (24 C.F.R. 201 and 203 et seq.), and the Department of Veterans Affairs (38 C.F.R. Part 36 et seq.); and

iv.

Balloon-payment qualified mortgages made by certain creditors (12 C.F.R. 1026.43(f)).

Service Provider will review applicable mortgage loans for compliance with the ATR and QM rule requirements based upon each mortgage loan’s originator designation of QM, Non-QM, or exempt from ATR. (Service Provider determines the mortgage loan’s status under the ATR or QM rule requirements and assigns a due diligence mortgage loan designation. Generally, Service Provider notes as a material exception if the due diligence findings do not confirm the originator’s mortgage loan designation. Additionally, Service Provider notes if an originator mortgage loan designation was not provided.

Service Provider utilizes the following designations for applicable loans: QM designations: QM Safe-Harbor, Temporary QM, Non-QM, QM Rebuttal Presumption and ATR Designations: ATR Compliant, ATR Exempt and ATR Fail.

With respect to QM (Safe Harbor and Higher-priced) designated mortgage loans, Service Provider reviews the mortgage loan to determine whether, based on available information in the mortgage loan file: (i) the mortgage loan contains risky mortgage loan features and terms (e.g. an interest only feature or negative amortization), (ii) the “points and fees” exceed the applicable QM threshold, (iii) the monthly payment was calculated appropriately, (iv) the creditor considered and verified income or assets at or before consummation, (v) the creditor appropriately considered debt obligations, alimony and child support, and (vi) at the time of consummation, if the debt-to-income ratio exceeds 43% (calculated in accordance with Appendix Q to Regulation Z). This portion of the Review includes a recalculation of all income and liabilities with attention to the appropriate documentation of each source.

If a mortgage loan was designated as QM, Service Provider reviews the mortgage loan to determine whether, based on available information in the mortgage loan file, if the mortgage loan satisfied (i), (ii) and (iii) in the preceding paragraph.

For each QM designated mortgage loan that satisfied the applicable requirements enumerated above, Service Provider then determines whether the mortgage loan is a Safe Harbor QM or QM Rebuttable Presumption by comparing the mortgage loan’s actual annual percentage rate, as recalculated, to the applicable average prime offer rate plus a certain applicable percentage. The Review also includes determining, as applicable, whether a mortgage loan is a qualified mortgage as defined by the Department of Housing and Urban Development (24 C.F.R. 201 and 203 et seq.), and the Department of Veterans Affairs (38 C.F.R. Part 36 et seq.).

For each QM designated mortgage loan that does not satisfy the applicable requirements enumerated above, Service Provider then determines whether the mortgage loan complies with the ATR rule consideration and verification requirements, as defined within the applicable underwriting guidelines, and provides a due diligence designation of Non-QM indicating compliant, ATR risk indicating it may not be compliant, or ATR Fail, indicating it is non-compliant.

	h.	Service Provider reviews the mortgage loan to determine whether, based on available information in the mortgage loan file, the creditor considered, as applicable, the following eight underwriting factors, and will verify such information using reasonably reliable third-party records, at or before consummation:

Income / Assets - Recalculate borrower(s)’s monthly gross income, and validate funds required to close and required reserves, to Confirm that the borrower has current or reasonably expected income or assets (other than the value of the property that secures the Loan) that the borrower will rely on to repay the Loan.

•

Review Loan documentation for required level of income and asset verifications.

ii.

Employment - Review file documentation for required level of employment

iii.

Monthly Mortgage Payment: Confirm that the correct program, qualifying rate, and terms were used to calculate projected monthly mortgage payment.

iv.

Simultaneous Loans - Ensure that all concurrent Loans were included in the debt-to-income ratio (“DTI”) calculation, to properly assess the ability to repay.

Mortgage-Related Obligations - Validate that the subject Loan monthly payment calculation includes principle, interest, taxes, and insurance (“PITI”), as well as other costs related to the property such as homeowners’ association (“HOA”) fees, private mortgage insurance (“PMI”), ground rental fees, etc.

vi.

Debts / Obligations - Validate monthly recurring non-mortgage-related liabilities

vii.

DTI / Residual Income - Validate debt-to-income ratio (DTI), or “residual income,” based upon all mortgage and non-mortgage obligations, calculated as a ratio of gross monthly income, based on documentation provided in the file.

viii.

Credit History - Review credit report for credit history and required credit depth, including any / all inquiries, and Determine a representative credit score from the credit report

Property Review

MaxDiligence performed a “Property Review,” which included the following:

Property Review

Review will include a review of the valuation materials utilized during the origination of the loan and in confirming the value of the underlying property. The review will include verifying the appraisal report:

	b.	On the appropriate GSE form:

All elements of appraisal are present

ii.

Ensure all applicable Loan documents match appraisal information

iii.

Property is acceptable collateral for Loan program

iv.

Completed by an appraiser that was actively licensed to perform the valuation

Completed such that the named client on the appraisal report is the lender or a related entity that is permitted to engage the lender per Title XI of FIRREA, or if the appraisal was performed for another lender, the file contains a transfer letter from the original lender

vi.

The original appraisal report is made and signed prior to the final approval of the mortgage loan application; Any revisions, if made known to MaxDiligence, to the original report are documented and dated completed and dated within the guideline’s restrictions,

vii.

The original appraisal is ‘As is' or Inspection received including all inspections, licenses, and certificates (including certificates of occupancy) to be made or issued with respect to all occupied portions of the mortgaged property and with respect to the use and occupancy of the same, have been made or obtained from the appropriate authorities.

viii.

Determine whether the appraised value is supported at or within 10% variance based on a third-party valuation product. If a third-party valuation product is in file but notes a variance above 10% or an inconclusive value, MaxDiligence will recommend a BPO or field review be ordered.

ix.

With regard to the use of comparable properties, review will (a) review the relative comparable data (gross and net adjustments, sale dates and distance from subject property) and ensure that such comparable properties are within standard appraisal guidelines; (b) confirm the property value and square footage of the subject property was bracketed by comparable properties, (c verify that comparable properties used are similar in size, style, and location to the subject, and (d) check for the reasonableness of adjustments when reconciling value between the subject property and comparable properties.

Other aspects of the review include (i) verifying that the address matched the mortgage note, ((ii) if requested, noting whether the property zip code was declared a FEMA disaster area after the valuation date and notifying the Client of same, (iii) confirming the appraisal report does not include any apparent environmental problems, (iv) confirming the appraisal notes the current use of the property is legal or legal non-conforming (grandfathered), (v) reviewing pictures to ensure (a) that the property is in average or better condition and any repairs are noted where required and (b) that the subject property is the one for which the valuation was ordered and that there are no negative external factors; and (vi) confirming that the value product that was used as part of the origination decision conforms with rating agency requirements.

If more than one valuation was provided, reviewer will confirm consistency among the valuation products and if there are discrepancies that could not be resolved, MaxDiligence will create an exception and work with the client on the next steps which may include ordering of additional valuation products such as collateral desktop analyses, broker’s price opinions, and full appraisals. If the property valuation products included in the review result in a variance of more than 10% then the client will be notified of such variance.

MaxDiligence will confirm to the extent possible, that the appraiser and the appraisal made by such appraiser both satisfied the requirements of Title XI of FIRREA. Specifically, MaxDiligence will review the appraisal for conformity to industry standards, including ensuring the appraisal was complete, that the comparable properties and adjustments were reasonable and that pictures were provided and were accurate.

In addition, MaxDiligence will access the ASC database to verify that the appraiser, and if applicable the appraiser’s supervisor, were licensed and in good standing at the time the appraisal was completed.

Compliance Review

MaxDiligence performed a “Compliance Review” below, which is applicable to Loans originated on or after October 3, 2015, which are subject to the TILA/RESPA Integrated Disclosure Rule (“TRID”).

With regard to TRID testing, MaxDiligence implemented the TRID scope of review referenced within the Regulatory Compliance section (III) based on on (i) the SFA RMBS TRID Grid 4.0 Compliance Review Scope published by the Structured Finance Association (formerly SFIG) (the "SFA RMBS Compliance Review Scope") and (ii) outside counsel’s interpretations of the published regulations as of the date of review of each mortgage loan. MaxDiligence worked with outside counsel and continues to obtain updated interpretations relative to the informal guidance provided by the Consumer Financial Protection Bureau (“CFPB”) which has caused alterations in the review scope and severity of TRID related exceptions, including applicable cures. (This will continue as necessary as additional guidance becomes available, as well as any future rulemaking.) While MaxDiligence continues to make a good faith effort to identify material TRID exceptions and apply the appropriate grading, the implementation of new regulations (including TRID) that impact residential mortgages carries certain interpretive risk and continues to evolve, impacting the review scope and exception severity.

Loan Estimates (“LEs”)

Review the Initial LE and confirm (i) the correct form was used; (ii) all sections of the Initial LE are completed; and (iii) the Initial LE accurately reflects the information provided to Service Provider

If there is a Revised LE, confirm (i) that there is a “valid reason” for the Revised LE; and (ii) that the Revised LE was issued within three (3) days of the change.

Determine which LE in the file is the “final binding” LE for the purpose of Tolerance Testing. A Revised LE that is issued after the CD, or that does not state a valid reason will not be used for the purposes of Tolerance Testing. All revised LEs issued to the consumer will be reviewed for accuracy of terms.

Confirm initial LE was delivered within three (3) Business Days from the application date, and at least seven (7) Business Days prior to the consummation date.

Confirm revised LE was delivered within three (3) Business Days from date of the “valid reason” giving rise to the Revised LE, and at least four (4) Business Days prior to the consummation date.

Confirm that certain sections of each LE determined to carry assignee liability were accurately completed and that information was reflected in the appropriate locations

Closing Disclosures (“CDs”)

Review the CD review and confirm (i) the correct form was used; (ii) all sections of the CD are completed; and (iii) the CD accurately reflects the information provided to Service Provider.

If a subsequent CD is issued, confirm (i) that there was a valid reason for the change; (ii) that the CD was issued within three (3) days of the change; and (iii) whether the reason for the change requires a new 3-day waiting period prior to the consummation date.

Confirm Initial CD, and any subsequent CD with material changes (i.e. changes that require a new waiting period), was received at least three (3) Business Days prior to the consummation date. With respect to applicable exception remediation measures for numerical exceptions, confirm that a letter of explanation, as well as a refund as applicable, was delivered or placed in the mail no later than 60 days after discovery of the exception establishing the need for a revised CD or with respect to exception remediation measures for non-numerical exceptions, that a corrected CD was delivered or placed in the mail no later than 60 days after consummation.

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

Rescission

Failure to provide the right of rescission notice;

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

errors in the right of rescission notice;

failure to provide the correct form of right of rescission notice;

failure to provide the three (3) Business Day rescission period; and

any material disclosure violation on a rescindable loan that gives rise to the right of rescission under TILA, which means the required disclosures of the annual percentage rate, the finance charge, the amount financed, the total of payments, the payment schedule, the HOEPA disclosures;

Tolerance Testing. Compare the fees disclosed in the final binding LE to those in the final CD, and confirm that final CD fees are within the permitted tolerances. Confirm the total of payments are considered accurate as defined by Regulation Z. Confirm Finance Charge tolerances are correct.

Subsequent Changes. Review the file to determine (i) whether there is evidence that certain changes or errors (per the regulation) were discovered subsequent to closing, (ii) and whether the Loan originator followed the prescribed cure. Test for evidence such as a copy of the refund check, or a corrected, post-consummation CD (“PCCD”), and iii) with respect to applicable exception remediation measures for numerical exceptions, confirm that a letter of explanation, as well as a refund as applicable, was delivered or placed in the mail no later than 60 days after discovery of the exception establishing the need for a revised CD or with respect to exception remediation measures for non-numerical exceptions, that a corrected CD was delivered or placed in the mail no later than 60 days after consummation.

Loan Toolkit (§1026.19):

Confirm the presence of Your Home Loan Toolkit in the mortgage loan file or that the mortgage loan file contains documentary evidence that the disclosure was provided to the borrower; and

Confirm Your Home Loan Toolkit was delivered or placed in the mail not later than three (3) Business Days after receipt of application.

TILA

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

Points and fees threshold test;

ii.

APR threshold test;

iii.

Prepayment penalty test; and

iv.

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

Higher-priced Mortgage Loan (§1026.35):

APR threshold test; and

ii.

Compliance with the escrow account and appraisal requirements.

With respect to brokered mortgage loans, the Prohibitions and Restrictions related to Loan Originator Compensation and Steering (§1026.36):

Review relevant documentation to determine if compensation to a Loan Originator was based on a term of the transaction;

ii.

Review relevant document to determine if there was dual compensation; and

iii.

Review the presence of the mortgage loan option disclosure and to determine if the Steering Safe Harbor provisions were satisfied.

•

Note: Where available, Service Provider reviewed the relevant documents in the mortgage loan file and, as necessary, attempted to obtain the mortgage loan originator compensation agreement and/or governing policies and procedures of the mortgage loan originator. In the absence of the mortgage loan originator compensation agreement and/or governing policies and procedures, Service Provider’s review was limited to formal general statements of entity compliance provided by the mortgage loan originator, if any. These statements, for example, were in the form of a letter signed by the seller correspondent/mortgage loan originator or representations in the mortgage loan purchase agreement between the Client and seller correspondent;

Homeownership counseling (§1026.36):

Determine if the creditor obtained proof of homeownership counseling in connection with a mortgage loan to a first-time homebuyer that contains a negative amortization feature.

Mandatory Arbitration Clauses (§1026.36):

Determine if the terms of the mortgage loan require arbitration or any other non-judicial procedure to resolve any controversy or settle any claims arising out of the transaction.

Prohibition on Financing Credit Insurance (§1026.36):

Determine if the creditor financed, directly or indirectly, any premiums or fees for credit insurance in jurisdictions where it is prohibited.

Nationwide Mortgage Licensing System (NMLS) & Registry ID on Loan Documents (§1026.36):

Review for presence of mortgage loan originator organization and individual mortgage loan originator name and NMLSR ID, as applicable, on the credit application, note or mortgage loan contract, security instrument, Loan Estimate and Closing Disclosure; and

ii.

Verify the data against the NMLSR database, as available.

RESPA:

Additional RESPA/Regulation X Disclosures and Requirements (§1024.6, 15, 17, 20, and 33):

Confirm the presence of the Servicing Disclosure Statement form in the mortgage loan file;

ii.

Verify the Servicing Disclosure Statement was provided to the borrower(s) within three (3) Business Days of application;

iii.

Confirm the presence of the Your Home Loan Toolkit/Special Information Booklet in the mortgage loan file or that the mortgage loan file contains documentary evidence that the disclosure was provided to the borrower;

iv.

Confirm the Your Home Loan Toolkit /Special Information Booklet was provided within three (3) Business Days of application;

Confirm the presence of the CHARM booklet when applicable;

vi.

Confirm that the CHARM booklet was issued within three (3) Business Days of application;

vii.

Confirm the presence of the Affiliated Business Arrangement Disclosure in the mortgage loan file in the event the lender has affiliated business arrangements;

viii.

Confirm the Affiliated Business Arrangement Disclosure was provided no later than three (3) Business Days of application;

ix.

Confirm the Affiliated Business Arrangement Disclosure is executed;

Confirm the presence of the Initial Escrow Disclosure Statement in the mortgage loan file and proper timing;

xi.

Confirm that the creditor provided the borrower a list of homeownership counselling organizations within three (3) Business Days of application; and

xii.

Confirm that the list of homeownership counselling organizations was obtained no earlier than 30 days prior to when the list was provided to the mortgage loan applicant.

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

Providing Appraisals and Other Valuations (12 C.F.R. 1002.14):


	i.	Timing and content of the right to receive copy of appraisal disclosure;

ii.

Charging of a fee for a copy of the appraisal or other written valuation;

iii.

Timing of creditor providing a copy of each appraisal or other written valuation; and

iv) With respect to a borrower that has waived the three (3) Business Day disclosure requirement, confirm that (a) the borrower has signed the waiver or other acknowledgment at least three (3) Business Days prior to consummation; and (b) that the lender has provided copies of appraisals and other written valuations at or prior to consummation.

10.

Other Provisions

Texas:

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

	b.	Fed/State/Local Predatory Lending:

The disclosure requirements and prohibitions of state, county and municipal laws and ordinances with respect to “high-cost” mortgage loans, “covered” mortgage loans, “higher-priced” mortgage loans, “home” mortgage loans or any other similarly designated mortgage loan as defined under such authorities, or subject to any other laws that were enacted to combat predatory lending, as may have been amended from time to time;

	c.	Prepay Penalties and Late Fees:

Federal and state specific late charge and prepayment penalty provisions.

11.

Exclusions. Service Provider will not test:

Loan types that are excluded from compliance with TRID:

Technical formatting of disclosures.

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

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

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

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

Data Discrepancy

As part of the Credit, Valuation and Compliance Reviews, MaxDiligence captured data from the source documents and compared it to a data tape provided by Client. MaxDiligence provided Client a Data Discrepancy Report which shows the differences between the tape data and the data captured by MaxDiligence during the diligence process.

Of the 1 mortgage loans reviewed, 0 unique mortgage loans (by loan count) had a total of 0 different tape discrepancies across 0 data fields (some mortgage loans may have had more than one). A blank or zero value on the data tape when an actual value was captured by MaxDiligence was not treated as a data variance.

Summary of Results

OVERALL RESULTS SUMMARY

After giving consideration to the grading criteria of the relevant NRSROs, 100% of the loans received an Overall “A” grade.

Final Loan Grades

Overall Loan Results:
Event Grade	Loan Count	Percent of Loans
A	1	100.00%
B	0	0.00%
C	0	0.00%
D	0	0.00%
Total	1	100.00%

Credit Grade Summary
Event Grade	Loan Count	Percent of Loans
A	1	100.00%
B	0	0.00%
C	0	0.00%
D	0	0.00%
Total	1	100.00%

Property Grade Summary
Event Grade	Loan Count	Percent of Loans
A	1	100.00%
B	0	0.00%
C	0	0.00%
D	0	0.00%
Total	1	100.00%

Compliance Grade Summary
Event Grade	Loan Count	Percent of Loans
A	1	100.00%
B	0	0.00%
C	0	0.00%
D	0	0.00%
Total	1	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 Grade of “A”, a Compliance Grade of “B”, and a Valuation Grade of “A” would receive an overall Loan Grade of “B”).

Exception Type	Exception Level Grade	Exception Category	Total
Credit	A	Third Party Fraud Report not Provided	1
		*Total Credit Grade (A) Exceptions*	1
Property	A	Value - Value is supported within -10% of original appraisal amount	1
		*Total Valuation Grade (A) Exceptions*	1
Compliance	A	No Compliance Findings	1
		*Total Compliance (A) Exceptions*	1

Event Grade Definitions:

Final Loan Grade
A	Loan meets Credit, Compliance, and Valuation Guidelines
B	The loan substantially meets published Client/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.
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.

Property 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.
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.

Loan ID

Customer Loan ID

Seller Loan ID

Note Date

Original Loan Amount

Last Name

Property State

Occupancy

Purpose

Originator QM Status

TPR QM Status

Exception ID

Exception Number

Exception Date

Exception Type

Exception Subcategory

Exception

Exception Remedy

Rebuttal

TPR Response

Compensating Factors

Status Update Date

Finding Status

Initial Exception Grade

Final Exception Grade

Initial Loan Grade

Final Loan Grade

XXXXXX

400071708

XXXXXX

Primary Residence

Refinance

Non-QM: Lender documented all ATR UW factors

1710453

1 of 3

2024-05-20 20:17

Credit

Third Party Fraud Report not Provided

Missing third party fraud report.

Document Uploaded. - 06/05/2024

The fraud report has been provided. - 06/05/2024

2024-06-05 13:46

Resolved

XXXXXX

400071708

XXXXXX

Primary Residence

Refinance

Non-QM: Lender documented all ATR UW factors

1710534

2 of 3

2024-05-20 20:28

Property

Value - Value is supported within -10% of original appraisal amount

The appraised value was supported within -10% and all applicable appraisal guidelines were satisfied.

2024-05-20 20:28

Cleared

XXXXXX

400071708

XXXXXX

Primary Residence

Refinance

Non-QM: Lender documented all ATR UW factors

1722433

3 of 3

2024-05-22 17:23

Compliance

No Compliance Findings

The loan meets all applicable compliance guidelines.

2024-05-22 17:23

Cleared

Client	Santander Bank N.A.
Transaction	SAN 2025-NQM3
Date	05/19/2025

Loan ID

Customer Loan ID

Seller Loan ID

Note Date

Original Loan Amount

Initial Loan Rating

Final Loan Rating

Initial Credit Rating

Final Credit Rating

Initial Compliance Rating

Final Compliance Rating

Initial Valuation Rating

Final Valuation Rating

Initial Loan Grade (S&P)

Final Loan Grade (S&P)

Initial Credit Grade (S&P)

Final Credit Grade (S&P)

Initial Compliance Grade (S&P)

Final Compliance Grade (S&P)

Initial Valuation Grade (S&P)

Final Valuation Grade (S&P)

Initial Loan Grade (DBRS Morningstar)

Final Loan Grade (DBRS Morningstar)

Initial Credit Grade (DBRS Morningstar)

Final Credit Grade (DBRS Morningstar)

Initial Compliance Grade (DBRS Morningstar)

Final Compliance Grade (DBRS Morningstar)

Initial Valuation Grade (DBRS Morningstar)

Final Valuation Grade (DBRS Morningstar)

Initial Loan Grade (Fitch)

Final Loan Grade (Fitch)

Initial Credit Grade (Fitch)

Final Credit Grade (Fitch)

Initial Compliance Grade (Fitch)

Final Compliance Grade (Fitch)

Initial Valuation Grade (Fitch)

Final Valuation Grade (Fitch)

Initial Loan Grade (Kroll)

Final Loan Grade (Kroll)

Initial Credit Grade (Kroll)

Final Credit Grade (Kroll)

Initial Compliance Grade (Kroll)

Final Compliance Grade (Kroll)

Initial Valuation Grade (Kroll)

Final Valuation Grade (Kroll)

Initial Loan Grade (Moody's)

Final Loan Grade (Moody's)

Initial Credit Grade (Moody's)

Final Credit Grade (Moody's)

Initial Compliance Grade (Moody's)

Final Compliance Grade (Moody's)

Initial Valuation Grade (Moody's)

Final Valuation Grade (Moody's)

XXXXXX

400071708

XXXXXX

Loan ID

Seller Loan ID

Investor Loan ID

Note Date

Original Loan Amount

Sales Price

Total Adjusted Prior Purchase Price

Primary Appraised Value

Primary Appraisal Date

Primary Appraisal Type

Value for LTV

LTV

CLTV

Loan Reviewed Property Value

Loan Reviewed Variance Amount

Loan Reviewed Variance Percent

Loan Reviewed Product Type

Loan Post-Close Reviewed Property Value

Loan Post-Close Reviewed Variance Amount

Loan Post-Close Reviewed Variance Percent

Loan Post-Close Reviewed Product Type

Second Appraisal Value

Second Appraisal Variance Amount

Second Appraisal Variance Percent

Second Appraisal Date

Second Appraisal Type

AVM Appraised Value

AVM Variance Amount

AVM Variance Percent

AVM Confidence Score

FSD Score

AVM Company Name

AVM Product Name

AVM Appraisal Date

Desk Review Appraised Value

Desk Review Variance Amount

Desk Review Variance Percent

Desk Review Company

Desk Review Risk Score

Desk Review Appraisal Date

Desk Top Appraised Value

Desk Top Variance Amount

Desk Top Variance Percent

Desk Top Company

Desk Top Appraisal Date

BPO Appraised Value

BPO Variance Amount

BPO Variance Percent

BPO Company

BPO Appraisal Date

Field Review Appraised Value

Field Review Variance Amount

Field Review Variance Percent

Field Review Company

Field Review Appraisal Date

2055 Appraised Value

2055 Variance Amount

2055 Variance Percent

2055 Company

2055 Appraisal Date

AVE/CMA Appraised Value

AVE/CMA Variance Amount

AVE/CMA Variance Percent

AVE/CMA Company

AVE/CMA Appraisal Date

Completion Report (1004D) Date

Other Appraised Value

Other Variance Amount

Other Variance Percent

Other Appraisal Date

Updated Appraised Value

Updated Variance Amount

Updated Variance Percent

Updated Company

Updated Appraisal Date

Updated Appraisal Type

Loan Collateral Advisor Risk Score

Loan Collateral Advisor Risk Score Date

Is Eligible for Rep and Warrant Relief per Loan Collateral Advisor?

Collateral Underwriter Risk Score

Collateral Underwriter Risk Score Date

XXXXXX

400071708

XXXXXX

1004 URAR

XXXXXX

69.9

XXXXXX

.00

.0000

Collateral Underwriter (CU)

XXXXXX

Loan ID

Seller Loan ID

Investor Loan ID

Loan Program

Guideline Product Name

Originator Name

Originating Entity CDFI Flag

Guideline Name

Guideline Author

Guideline Date

Guideline Version

Application Date

TILA Status

TRID

GSE

Verified Safe Harbor Flag

Verified Safe Harbor Reference Document

QM Regulation Failures

ATR QM Total Points and Fees Audit

Loan Regulation Benchmark Date

Benchmark Rate

AUS Decision System

Rating Result

Property Inspection Waiver (PIW)

Calculated APR

HUD 1 Page 1 Credits Total

Verified Qualifying Rate

Originator Qualifying Rate

Qualifying P&I

Default Interest Rate Present

Default Interest Rate

Annual Property Tax

Monthly Property Tax

Annual Insurance Costs

Monthly Insurance Cost

Annual HOA Costs

Monthly HOA Costs

Monthly Other Costs

PITIA

Residual Income

HOA Questionnaire Flag

HOA Name

HOA Address State

HOA Fee Amount

HOA Next Due Date

HOA Payment Frequency

Originator DTI

TPR Verified DTI

QM DTI

Is Borrower Non Occupant

Is Co Borrower Non Occupant

Co Borrower 2 Asset Verification Level

Co Borrower 3 Asset Verification Level

Co Borrower 2 Income Verification Level

Co Borrower 3 Income Verification Level

Co Borrower 2 Employment Verification Level

Co Borrower 3 Employment Verification Level

Borrower Employment Indicator

Co Borrower Employment Indicator

Co Borrower 2 Employment Indicator

Co Borrower 3 Employment Indicator

Co Borrower 2 Length of Employment

Co Borrower 3 Length of Employment

Document Level

Borrower Years of W2s/1099

CoBorrower Years of W2s/1099

Borrower Months of Paystubs Verified

Co Borrower Months of Paystubs Verified

Borrower Employment Gap Letter

Borrower Months of Employment Gap

Co Borrower Employment Gap Letter

Co Borrower Months of Employment Gap

Borrower Years of Personal Tax Returns

Borrower Years of Business Tax Returns

CoBorrower Years of Personal Tax Returns

CoBorrower Years of Business Tax Returns

Years of 4506T

Years of Tax Transcripts

Borrower Award/Offer Letter

Co Borrower Award/Offer Letter

Asset Depletion Flag

Partial Asset Depletion Flag

Asset Depletion Months Amortized

Asset Utilization Flag (No DTI)

Borrower Bank Statements Flag

Borrower Bank Statement Summary/Lender Worksheet

Borrower Number of Personal Bank Statements

Borrower Number of Business Bank Statements

CoBorrower Bank Statements Flag

Co Borrower Bank Statement Summary/Lender Worksheet

CoBorrower Number of Personal Bank Statements

CoBorrower Number of Business Bank Statements

Percent of Income From Statements

Borrower Business Ownership %

CoBorrower Business Ownership %

Bespoke Eligible Assets

Borrower P&L Type

Borrower Number of Months P&L

Borrower P&L Prepared By

CoBorrower P&L Type

CoBorrower P&L Prepared By

CoBorrower Number of Months P&L

Borrower CPA Letter Flag

# of Months CPA verified income

CoBorrower CPA Letter Flag

CoBorrower # of Months CPA verified income

Borrower WVOE Flag

Borrower # of Months Employment Validated WVOE

Borrower # of Months Income Validated WVOE

Borrower WVOE Form Type

CoBorrower WVOE Flag

CoBorrower # of Months WVOE

CoBorrower # of Months Income Validated WVOE

CoBorrower WVOE Form Type

DSCR Flag

TPR DSCR

Originator DSCR

Expense Letter

Income Doc Detail

Tax Return Doc Details

Property Address

Property City

Property State

Property Zip

Property County

Original Credit Report Date

Borrower 1 Credit Report Date

Borrower 2 Credit Report Date

Borrower 3 Credit Report Date

Borrower 4 Credit Report Date

Qualifying Credit Score

Third Wage Earner Original FICO Equifax

Third Wage Earner Original FICO Experian

Third Wage Earner Original FICO Transunion

Fourth Wage Earner Original FICO Equifax

Fourth Wage Earner Original FICO Experian

Fourth Wage Earner Original FICO Transunion

Most Recent Co Borrower 2 FICO

Most Recent Co Borrower 3 FICO

Updated Credit Report Flag

Updated Credit Report Date

Updated FICO Method

Primary Wage Earner Updated FICO Equifax

Primary Wage Earner Updated FICO Experian

Primary Wage Earner Updated FICO Transunion

Secondary Wage Earner Updated FICO Equifax

Secondary Wage Earner Updated FICO Experian

Secondary Wage Earner Updated FICO Transunion

Third Wage Earner Updated FICO Equifax

Third Wage Earner Updated FICO Experian

Third Wage Earner Updated FICO Transunion

Fourth Wage Earner Updated FICO Equifax

Fourth Wage Earner Updated FICO Experian

Fourth Wage Earner Updated FICO Transunion

Updated Primary Borrower FICO

Updated Co Borrower FICO

Updated Co Borrower 2 FICO

Updated Co Borrower 3 FICO

Updated Qualifying FICO

Most Recent Bankruptcy Type

Most Recent Bankruptcy Filing Date

Most Recent Bankruptcy Discharge Date

Number of Bankruptcy Events

Months Bankruptcy 7 11

Months Bankruptcy 13

Most Recent Deed in Lieu Date

Number of Deed in Lieu Events

Months Deed in Lieu

Most Recent Short Sale Date

Number of Short Sale Events

Months Short Sale (or Pre FC)

Most Recent Foreclosure Date

Number of Foreclosure Events

Months Foreclosure

Prior Mortgage/Rent Lates 30d in 0-12m

Prior Mortgage/Rent Lates 60d in 0-12m

Prior Mortgage/Rent Lates 90d in 0-12m

Prior Mortgage/Rent Lates 120d+ in 0-12m

Prior Mortgage/Rent Lates 30d in 13-24m

Prior Mortgage/Rent Lates 60d in 13-24m

Prior Mortgage/Rent Lates 90d in 13-24m

Prior Mortgage/Rent Lates 120d+ in 13-24m

Prior Mortgage/Rent Late 30d in 24m

Prior Mortgage/Rent Late 60d in 24m

Prior Mortgage/Rent Late 90d in 24m

Has ACH

Is Equity Shared Loan

Subordinate Lien Type

Subordinate Lien Max Draw Amount (HELOC)

Is Shared Appreciation Mortgage

Borrower Originator Citizenship Designation

Borrower Verified Citizenship Designation

Borrower Individual Tax Identification Number (ITIN)?

Borrower Photo Identification Type

Borrower Photo Identification Other Type

Borrower Photo ID State of Issuance

Borrower Photo ID Country of Issuance

Borrower Photo ID Expiration Date

Borrower Passport Country of Origin

Borrower Passport Expiration Date

Borrower Non-US Citizen Identification Document

Borrower Date of Resident Since/Valid Date

Borrower Non-US Document Expiration Date

Co Borrower Originator Citizenship Designation

Co Borrower Verified Citizenship Designation

Co Borrower Individual Tax Identification Number (ITIN)?

Co Borrower Photo Identification Type

Co Borrower Photo Identification Other Type

Co Borrower Photo ID State of Issuance

Co Borrower Photo ID Country of Issuance

Co Borrower Photo ID Expiration Date

Co Borrower Passport Country of Origin

Co Borrower Passport Expiration Date

Co Borrower Non-US Citizen Identification Document

Co Borrower Date of Resident Since/Valid Date

Co Borrower Non-US Document Expiration Date

Co Borrower 2 Originator Citizenship Designation

Co Borrower 2 Verified Citizenship Designation

Co Borrower 2 Individual Tax Identification Number (ITIN)?

Co Borrower 2 Photo Identification Type

Co Borrower 2 Photo Identification Other Type

Co Borrower 2 Photo ID State of Issuance

Co Borrower 2 Photo ID Country of Issuance

Co Borrower 2 Photo ID Expiration Date

Co Borrower 2 Passport Country of Origin

Co Borrower 2 Passport Expiration Date

Co Borrower 2 Non-US Citizen Identification Document

Co Borrower 2 Date of Resident Since/Valid Date

Co Borrower 2 Non-US Document Expiration Date

Co Borrower 3 Originator Citizenship Designation

Co Borrower 3 Verified Citizenship Designation

Co Borrower 3 Individual Tax Identification Number (ITIN)?

Co Borrower 3 Photo Identification Type

Co Borrower 3 Photo Identification Other Type

Co Borrower 3 Photo ID State of Issuance

Co Borrower 3 Photo ID Country of Issuance

Co Borrower 3 Photo ID Expiration Date

Co Borrower 3 Passport Country of Origin

Co Borrower 3 Passport Expiration Date

Co Borrower 3 Non-US Citizen Identification Document

Co Borrower 3 Date of Resident Since/Valid Date

Co Borrower 3 Non-US Document Expiration Date

Property Rights

Leasehold Lease Expiration Date

Buydown Flag

Assumable Mortgage Flag

Foreign National Alternative Credit Documentation

Liquid / Cash Reserves (ASF)

Months Liquid Reserves

Total Assets Available for Reserves

Months Reserves

Blanket Mortgage Flag

Qualifying HCLTV

Condo Warrantability Flag

E-Note Flag

O&E in lieu of Title Insurance

Business Purpose Flag

Borrower Note Executed As

Co Borrower Note Executed As

Co Borrower 2 Note Executed As

Co Borrower 3 Note Executed As

Borrower1 SSN

Borrower2 SSN

Borrower 3 SSN

Borrower 4 SSN

First Time Homebuyer

Number of Units

Maturity Date

Note Type

Loan Type

Refinance Purpose

Borrower 1 Mailing Street Address

Borrower 1 Mailing City

Borrower 1 Mailing State

Borrower 1 Mailing Zip Code

Borrower 2 Mailing Street Address

Borrower 2 Mailing City

Borrower 2 Mailing State

Borrower 2 Mailing Zip Code

Borrower 3 Mailing Street

Borrower 3 Mailing City

Borrower 3 Mailing State

Borrower 3 Mailing Zip

Borrower 4 Mailing Street

Borrower 4 Mailing City

Borrower 4 Mailing Zip

Borrower 4 Mailing State

Prepay Penalty Calculation Description

Borrower 1 First Name

Borrower 1 Last Name

Borrower 2 First Name

Borrower 2 Last Name

Borrower 3 First Name

Borrower 3 Last Name

Borrower 4 First Name

Borrower 4 Last Name

Borrower 1 Employer

Borrower 1 Position

Borrower 2 Employer

Borrower 2 Position

Borrower 3 Employer

Borrower 3 Position

Borrower 4 Employer

Borrower 4 Position

First Time Investor

Borrower 1 Years in Industry

Borrower 2 Years in Industry

Borrower 3 Years in Industry

Borrower 4 Years in Industry

Borrower 1 ITIN

Borrower 2 ITIN

Borrower 3 ITIN

Borrower 4 ITIN

XXXXXX

400071708

30 Year Fixed

P&L Only

XXXXXX

Loan Eligibiity Guidelines

XXXXXX

Non-QM: Lender documented all ATR UW factors

Yes

N/A

APOR Threshold

.00

XXXXXX

6.950%

Manual Underwriting

9.198%

8.750%

XXXXXX

N/A

XXXXXX

$0.00

27.85%

27.70%

Self-Employed

Not Employed

1YR Business P&L

N/A

Yes

N/A

0.00%

100.00%

Third-Party Prepared (Unaudited)

XXXXXX

N/A

Yes

N/A

0.0

Borrower - SESoleProprietor - CPA Letter Verified, YTD Profit And Loss Verified, 2 YRS Executed 4506T Verified - 2022, 2023, 2024 || Co Borrower

Borrower - 2 YRS Executed 4506T Verified - 2022, 2023, 2024 || Co Borrower

XXXXXX

668

0.0

Unknown

Permanent Resident Alien

Permanent Non-US Citizen

N/A

Other

N/A

United States

XXXXXX

Work Visa

XXXXXX

US Citizen

N/A

Real ID Driver's License

XXXXXX

United States

XXXXXX

N/A

Fee Simple

N/A

.00

0.0

XXXXXX

103.0

69.9

N/A

Borrower As Individual

N/A

XXXXXX

false

XXXXXX

Fixed

Conventional

Cash Out - Other

XXXXXX

No Prepayment Penalty

XXXXXX

Owner

N/A