EXECUTIVE SUMMARY


(1) Type of assets that were reviewed.
AMC Diligence, LLC (“AMC”) performed due diligence services as described below utilizing various scopes of review. All of these mortgage loans, which were originated by multiple parties, were purchased by an affiliate of FirstKey Mortgage, LLC (“Client”) in multiple bulk transactions and were reviewed by AMC on behalf of such party. The mortgage loans were reviewed via files imaged and provided by the Client or its designee for review.

(2) Sample size of the assets reviewed.
The diligence review (the “Review”) was conducted on a portion of the securitization mortgage loan population reviewed by AMC. The total population covered during the Review varied by mortgage loan scope. The Client may have utilized multiple third-party review (“TPR”) firms for the securitization and AMC did not review all of the mortgage loans in the securitization loan population for a specific scope of review.

The mortgage loan review sample was broken down into the following review scopes:

 ◾ “Compliance Review”:         
487 mortgage loans

◾ “Data Integrity Review”:           
487 mortgage loans

◾ “Modification Review”                 
120 mortgage loans

◾ “Collection Comment Review”:             
203 mortgage loans

◾ “Payment History Review”:          
522 mortgage loans

◾ “Title Review”:            
622 mortgage loans

Throughout the securitization process, the Client may have removed or added various mortgage loans from the securitization population for reasons that are unknown to AMC. AMC’s disclosures herein reflect findings on the securitization population (as known by AMC) as of the date hereof.

(3) Determination of the sample size and computation.
The Compliance Review was conducted consistent with the criteria for the NRSRO(s) identified in Item 3 of this Form ABS Due Diligence-15E.

(4) Quality or integrity of information or data about the assets: review and methodology.
AMC compared data fields on the bid tape provided by the Client to the data found in the actual file as captured during the Compliance Review. The scope of this review and the findings are detailed later in this document.

(5) Origination of the assets and conformity to stated underwriting or credit extension guidelines, standards, criteria or other requirements: review and methodology.
Not applicable.

(6) Value of collateral securing the assets: review and methodology.
Not applicable.

(7) Compliance of the originator of the assets with federal, state and local laws and regulations: review and methodology.
Please be advised that AMC did not make a determination as to whether the mortgage loans complied with federal, state or local laws, constitutional provisions, regulations or ordinances that are not expressly enumerated below. There can be no assurance that the Review uncovered all relevant factors relating to the origination of the mortgage loans, their compliance with applicable law and regulations and the original appraisals relating to the mortgaged properties or uncovered all relevant factors that could affect the future performance of the mortgage loans. Furthermore, the findings reached by AMC are dependent upon its receiving complete and accurate data regarding the mortgage loans from mortgage loan originators and other third parties upon which AMC is relying in reaching such findings.

Please be further advised that AMC does not employ personnel who are licensed to practice law in the various jurisdictions, and the findings set forth in the reports prepared by AMC do not constitute legal advice or opinions. They are recommendations or conclusions based on information provided to AMC. Information contained in any AMC report related to the applicable statute of limitations for certain claims may not be accurate or reflect the most recent controlling case law. Further, a particular court in a particular jurisdiction may extend, not enforce or otherwise allow claims beyond the statute of limitations identified in the report based on certain factors, including the facts and circumstances of an
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individual mortgage loan. All final decisions as to whether to purchase or enter into a transaction related to any individual mortgage loan or the mortgage loans in the aggregate, any investment strategy and any legal conclusions, including the potential liability related to the purchase or other transaction involving any such mortgage loan or mortgage loans, shall be made solely by the Client, or other agreed upon party, that has engaged AMC to prepare its reports pursuant to its instructions and guidelines. The Client, or other agreed upon party, acknowledges and agrees that the scoring models applied by AMC are designed to identify potential risk and the Client, or other agreed upon party, assumes sole responsibility for determining the suitability of the information for its particular use. AMC does not make any representation or warranty as to the value of any mortgage loan or mortgage loan’s collateral that has been reviewed by AMC.

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

FOR APPLICATION DATES BEFORE JANUARY 10, 2014 (289 Mortgage Loans)
(I) Federal Truth in Lending Act (“TILA”), as implemented by Regulation Z, 12 C.F.R. Part 1026, as set forth below:

 a)
Rescission (§1026.23):

i)
failure to provide the right of rescission notice;

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

iii)
errors in the right of rescission notice;

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

v)
failure to provide the three (3) business day rescission period; and

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

b)
TIL Disclosure (§§1026.17, 18 and 19) as applicable for loans with application dates prior to October 3, 2015:

i)
review and comparison of the initial and final TIL disclosures, and any re-disclosed TIL(s);

ii)
proper execution by all required parties;

iii)
principal and interest calculations, and proper completion of the interest rate and payment summary; and

iv)
timing of initial and re-disclosed TIL(s);

c)
Tolerances (§§1026.18, 22 and 23):

i)
inaccurate Annual Percentage Rate (APR) outside of applicable tolerance by comparing disclosed APR to re-calculated APR; and

ii)
inaccurate Finance Charge outside of applicable tolerance by comparing disclosed Finance Charge to re-calculated Finance Charge;

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

i)
points and fees threshold test;

ii)
APR threshold test;

iii)
prepayment penalty test; and

iv)
compliance with the disclosure requirements, limitation on terms and prohibited acts or practices in connection with a high-cost mortgage;

e)
Higher-priced Mortgage Loan (§1026.35):

i)
APR threshold test; and

ii)
compliance with the escrow account and appraisal requirements;

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

 a)
Good Faith Estimate (GFE) (§1024.7) as applicable for loans with application dates prior to October 3, 2015:

i)
confirm the presence of the current GFE form in effect at the time of origination;

ii)
verify GFE was provided to the borrower(s) within three (3) business days of application;

iii)
verify all sections of the GFE were accurately completed and that information was reflected in the appropriate locations;

iv)
determine whether a valid and properly documented changed circumstance accompanies any changes to loan terms and/or fees on any revised GFEs over the applicable tolerance(s); and

v)
confirm the presence of a settlement service provider list, as applicable.

b)
Final HUD-1/A Settlement Statement (HUD) (§1024.8) as applicable for loans with application dates prior to October 3, 2015:
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 i)
confirm current applicable HUD form was provided;

ii)
determination that the loan file contains the final HUD;

iii)
escrow deposit on the final HUD matches the initial escrow statement amount; and

iv)
verify all sections of the final HUD were accurately completed and that information was reflected in the appropriate locations.

c)
GFE and Final HUD Comparison (§1024.7) as applicable for loans with application dates prior to October 3, 2015:

i)
review changes disclosed on the last GFE provided to the borrower(s) to determine that such changes were within the allowed tolerances;

ii)
confirm loan terms and fees disclosed on the third page of the final HUD accurately reflect how such items were disclosed on the referenced GFE, page 2 of the final HUD and loan documents; and

iii)
review any documented cure of a tolerance violation to determine that the proper reimbursement was made and a revised HUD was provided at or within 30 days of settlement.

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

i)
confirm the presence of the Servicing Disclosure Statement form in the loan file;

ii)
verify the Servicing Disclosure Statement was provided to the borrower(s) within three (3) business days of application;

iii)
confirm the presence of the Special Information Booklet in the loan file or that the loan file contains documentary evidence that the disclosure was provided to the borrower;

iv)
confirm the Special Information Booklet was provided within three (3) business days of application;

v)
confirm the presence of the Affiliated Business Arrangement Disclosure in the loan file in the event the lender has affiliated business arrangements;

vi)
confirm the Affiliated Business Arrangement Disclosure was provided no later than three (3) business days of application;

vii)
confirm the Affiliated Business Arrangement Disclosure is executed; and

viii)
confirm the presence of the Initial Escrow Disclosure Statement in the loan file and proper timing.
(III) The disclosure requirements and prohibitions of Section 50(a)(6), Article XVI of the Texas Constitution and associated regulations;

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

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

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

 ◾
Initial application (1003);

◾
Final application (1003);

◾
Note;

◾
Appraisal;

◾
Sales contract;

◾
Title/Preliminary Title;

◾
Initial TIL;

◾
Final TIL;

◾
Final HUD-1;

◾
Initial and final GFE’s;

◾
Right of Rescission Disclosure;

◾
Mortgage/Deed of Trust;

◾
Mortgage Insurance;

◾
Tangible Net Benefit Disclosure;

◾
FACTA disclosures; and

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

FOR APPLICATION DATES ON OR AFTER JANUARY 10, 2014 (20 Mortgage Loans)
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For mortgage loans with application dates on or after January 10, 2014 additional compliance testing was applicable and conducted by AMC. Testing during this period included all items as referenced in the FOR APPLICATION DATES BEFORE JANUARY 10, 2014 section above plus:

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

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

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

ii)
review relevant document to determine if there was dual compensation; and

iii)
review the presence of the loan option disclosure and to determine if the Steering Safe Harbor provisions were satisfied.

(1)
Note: Where available, AMC reviewed the relevant documents in the loan file and, as necessary, attempted to obtain the loan originator compensation agreement and/or governing policies and procedures of the loan originator. In the absence of the loan originator compensation agreement and/or governing policies and procedures, AMC’s review was limited to formal general statements of entity compliance provided by the loan originator, if any. These statements, for example, were in the form of a letter signed by the seller correspondent/loan originator or representations in the mortgage loan purchase agreement between the Client and seller correspondent;

b)
Homeownership counseling (§1026.36):

i)
determine if the creditor obtained proof of homeownership counseling in connection with a loan to a first time homebuyer that contains a negative amortization feature;

c)
Mandatory Arbitration Clauses (§1026.36):

i)
determine if the terms of the loan require arbitration or any other non-judicial procedure to resolve any controversy or settle any claims arising out of the transaction;

d)
Prohibition on Financing Credit Insurance (§1026.36):

i)
determine if the creditor financed, directly or indirectly, any premiums or fees for credit insurance; and

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

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

ii)
verify the data against the NMLSR database, as available.

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

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

i)
confirm that the creditor provided the borrower a list of homeownership counseling organizations within three (3) business days of application; and

ii)
confirm that the list of homeownership counseling organizations was obtained no earlier than 30 days prior to when the list was provided to the loan applicant.

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

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

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

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

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

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

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

If a loan was designated as QM and identified as eligible for guarantee, purchase, or insurance by an applicable agency as permitted under the QM final rule, AMC reviews the loan to determine whether, based on available information in the loan file, the loan satisfied (i), (ii) and (iii) in the preceding paragraph and reviews the Automated Underwriting System output within the file to confirm agency eligibility.

For each QM designated loan that satisfied the applicable requirements enumerated above, AMC then determines whether the loan is a Safe Harbor QM or Higher Priced QM by comparing the loan’s actual annual percentage rate, as recalculated, to the applicable average prime offer rate plus a certain applicable percentage.

The Review also includes determining, as applicable, whether a loan is a qualified mortgage as defined by the Department of Housing and Urban Development (24 C.F.R. 201 and 203 et seq.) and the Department of Veterans Affairs (38 C.F.R. Part 36 et seq.).

For each QM designated loan that does not satisfy the applicable requirements enumerated above, AMC then determines whether the loan complies with the ATR rule consideration and verification requirements and provides a due diligence designation of Non-QM compliant or non-compliant.

General Ability to Repay
AMC reviews the loan to determine whether, based on available information in the mortgage loan file, the creditor considered, as applicable, the following eight underwriting factors and verified such information using reasonably reliable third-party records, at or before consummation: (i) the consumer's current or reasonably expected income or assets; (ii) if the creditor relied on income from the consumer's employment in determining repayment ability, the consumer's current employment status; (iii) the consumer's monthly payment; (iv) the consumer's monthly payment on any simultaneous loan that the creditor knows or has reason to know will be made; (v) the consumer's monthly payment for mortgage-related obligations; (vi) the consumer's current debt obligations, alimony, and child support; (vii) the consumer's monthly debt-to-income ratio or residual income; and (viii) the consumer's credit history. This portion of the Review also focuses on full recalculation of income and debts, as well as the documentation provided to support each item used in originator’s determination of the ability to repay.

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

AMC reviews loans to determine their conformity with the ATR/QM factors above, and is not rendering an independent assessment or opinion, warranting or representing that a loan will be deemed to conform to Safe Harbor, Rebuttable Presumption, ATR or other status based on any additional or revised factors that may be considered by legislative, regulatory, administrative or judicial authorities (“Authorities”). AMC does not represent or warrant that the factors for which it is reviewing the loans constitute all of the factors and/or criteria that Authorities may consider in determining the status of a loan. AMC’s review is based on information contained in the mortgage loan file at the time it is provided to AMC to review, and only reflects information as of that point in time.

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

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

i)
timing and content of the right to receive copy of appraisal disclosure;

ii)
charging of a fee for a copy of the appraisal or other written valuation;

iii)
timing of creditor providing a copy of each appraisal or other written valuation;

iv)
with respect to a borrower that has waived the three (3) business day disclosure requirement, confirm that the borrower has signed the waiver or other acknowledgment at least three (3) business days prior to
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consummation and (2) confirm that the lender has provided copies of appraisals and other written valuations at or prior to consummation.

(XI) FIRREA Review
AMC confirmed that the appraiser and the appraisal made by such appraiser both satisfied the requirements of Title XI of FIRREA. Specifically, AMC reviewed the appraisal for conformity to industry standards, including ensuring the appraisal was complete, that the comparables and adjustments were reasonable and that pictures were provided and were accurate. 

FOR APPLICATION DATES ON OR AFTER OCTOBER 3, 2015 (178 Mortgage Loans)
For mortgage loans with application dates on or after October 3, 2015 additional compliance testing was applicable and conducted by AMC. Testing during this period included all items as referenced in the FOR APPLICATION DATES BEFORE JANUARY 10, 2014 and FOR APPLICATION DATES ON OR AFTER JANUARY 10, 2014 sections above plus:

With regard to TILA-RESPA Integrated Disclosure (“TRID”) testing, AMC implemented the TRID scope of review referenced within the Regulatory Compliance section (XII) based on (i) the RMBS 3.0 TRID Compliance Review Scope published by the Structured Finance Industry Group (the "SFIG Compliance Review Scope") and (ii) outside counsel’s interpretations of the published regulations as of the date of review of each mortgage loan. AMC worked with outside counsel and continues to obtain updated interpretations relative to the informal guidance provided by the Consumer Financial Protection Bureau (“CFPB”) which has caused alterations in the review scope and severity of TRID related exceptions, including applicable cures. (This will continue as necessary as additional guidance becomes available, as well as any future rulemaking.) While AMC continues to make a good faith effort to identify material TRID exceptions and apply the appropriate grading, the implementation of new regulations (including TRID) that impact residential mortgages carries certain interpretive risk and continues to evolve, impacting the review scope and exception severity. AMC has worked closely with the NRSROs and Client to disclose, as mutually agreed upon by the parties, the relevant exceptions per AMC’s suggested review implementation as reviewed by outside counsel; however, no assurances can be provided and/or are given that AMC has included within its Review all areas that may represent risk to the securitization trust or that areas of risk identified by AMC will result in the potential level of risk indicated by an Event Level or NRSRO grade.

Please be further advised that AMC does not employ personnel who are licensed to practice law in the various jurisdictions, and the findings set forth in the reports prepared by AMC do not constitute legal advice or opinions. They are recommendations or conclusions based on information provided to AMC. Information contained in any AMC report related to the applicable statute of limitations for certain claims may not be accurate or reflect the most recent controlling case law. Further, a particular court in a particular jurisdiction may extend, not enforce or otherwise allow claims beyond the statute of limitations identified in the report based on certain factors, including the facts and circumstances of an individual mortgage loan. All final decisions as to whether to purchase or enter into a transaction related to any individual mortgage loan or the mortgage loans in the aggregate, any investment strategy and any legal conclusions, including the potential liability related to the purchase or other transaction involving any such mortgage loan or mortgage loans, shall be made solely by the Client, or other agreed upon party, that has engaged AMC to prepare its reports pursuant to its instructions and guidelines. The Client, or other agreed upon party, acknowledges and agrees that the scoring models applied by AMC are designed to identify potential risk and the Client, or other agreed upon party, assumes sole responsibility for determining the suitability of the information for its particular use. AMC does not make any representation or warranty as to the value of any mortgage loan or mortgage loans collateral that has been reviewed by AMC.

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

(XII) Sections 1098 and 1100A of Dodd-Frank amending TILA and RESPA, as implemented by Regulation Z, 12 C.F.R. Part 1026, as set forth below (applicable only for mortgage loans with application dates on or after October 3, 2015):

 a)
Loan Estimate (LE) (§§1026.19 and 37):

i)
confirm the presence of LE for applications on or after October 3, 2015;

ii)
confirm the initial LE date indicates it was delivered or placed in the mail within three (3) business days of application;
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 iii)
confirm that certain sections of each LE determined to carry assignee liability were accurately completed and that information was reflected in the appropriate locations, which, in certain instances, was based solely on the information disclosed on the LE;

iv)
confirm the initial LE was delivered or placed in the mail not later than seven (7) business days prior to consummation of the transaction or such period was waived due to a bona fide financial emergency;

v)
confirm that any written estimate of terms or costs provided prior to receipt of a LE contained the required disclosures;

vi)
confirm that each revised LE is accompanied by valid written documentation explaining the reason for re-disclosure to allow for fee increases based on a valid change of circumstance and was timely provided within 3 business days of issuance;

vii)
confirm the presence and timely provision of a settlement service provider list (when consumer is given the opportunity to shop for services);

viii)
confirm borrower received LE not later than four (4) business days prior to consummation; and

ix)
confirm LE was not provided to the borrower on or after the date of the CD.

b)
Closing Disclosure (CD) (§§1026.19 and 38):

i)
confirm the presence of CD for applications on or after October 3, 2015;

ii)
confirm the borrower received CD at least three (3) business days prior to consummation or that such period was waived due to a bona fide financial emergency;

iii)
confirm that certain sections of each CD determined to carry assignee liability were accurately completed and that information was reflected in the appropriate locations, which, in certain instances, was based solely on the information disclosed on the CD;

iv)
confirm that a revised CD was received in a timely manner if the initial or any revised CD became inaccurate;

v)
identify tolerance violations based on the charges disclosed on the initial and interim LE’s, initial CD, and reflected on the final CD;

vi)
with respect to tolerance violations based on the disclosed charges on the LE and CD, confirm that the creditor cured the violations no later than 60 days after consummation or within 60 days of discovery; and

vii)
with respect to applicable exception remediation measures for numerical exceptions, confirm that a letter of explanation, as well as a refund as applicable, was delivered or placed in the mail no later than 60 days after discovery of the exception establishing the need for a revised CD or with respect to exception remediation measures for non-numerical exceptions and that a corrected CD was delivered or placed in the mail no later than 60 days after consummation. (In an attempt to establish a best practices approach to pre-securitization due diligence, as it applies to TILA RESPA Integrated Disclosure testing, the Structured Finance Industry Group (“SFIG”) has a working group that consists of industry participants including third party review providers and law firms who agreed to a standardized approach to remediation considerations. This approach is intended to be based on a reasoned legal analysis that expressly assumes that courts will interpret TRID in accordance with the principals of liability set forth in the letter to the MBA from Richard Cordray, the Director of the CFPB. No assurances can be provided that the courts in question will interpret TRID in accordance with the SFIG Compliance Review Scope.)

c)
Your Home Loan Toolkit (§1026.19):

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

ii)
confirm Your Home Loan Toolkit was delivered or placed in the mail not later than three (3) business days after receipt of application.

(XIII) Document Review
AMC reviewed each mortgage loan file and verified if the following documents, if applicable, were included in the file and if the data on these documents was consistent (where applicable):

 ◾
Loan Estimates;

◾
Closing Disclosures; and

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

(8) Other: review and methodology.

Data Integrity Review: AMC compared data fields on the bid tape provided by the Client to the data found in the actual file as captured during the Compliance Review. The number of fields included and reviewed on a bid tape can vary by counterparty and by time period of transaction.

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Collection Comment Review: AMC performed a pre-acquisition review utilizing individual mortgage loan collection comments provided by the servicer in order to provide a brief summary outlining current performance status, the borrower’s ability to pay, relative future/current risk (including hardship, life changes, etc.), possible servicer remedies, loss mitigation efforts, and modifications.

Modification Review: AMC conducted a review of the modification, or modifications, contained within the mortgage loan file.
Payment History Review: AMC performed a review utilizing individual mortgage loan payment history reports provided by the servicer. Using the MBA methodology, AMC created a payment string using a look back period for each mortgage loan within the payment history population ranging from 24 to 68 months.

SAFE ACT Review: For applicable mortgage loans, AMC performed a SAFE ACT review by going to the NMLS site and verifying, if the information is available, if the broker (if applicable) and the originator were licensed at the time of mortgage loan origination. The NMLS site contains limited retroactive license information and may not have such information available for all originators. This review was completed based upon the information that was available and AMC does not represent or warranty as to the completeness or accuracy of information contained on the site.

Title Review
As requested by the Client, a title review was included in SitusAMC’s scope of review. To facilitate this review, the Client provided SitusAMC with identifying data on the population of mortgage loans. Data provided by the client, included mortgage loan and servicer identification numbers as well as subject property address, borrower names, origination date, original mortgage loan amount for the subject mortgage and title policies from origination as it relates to the subject mortgage. Using the data provided, SitusAMC ordered a current owner’s title search on these mortgage loans through a service provider. Upon receipt and review of the current owner’s title search results, SitusAMC identified whether the title search report revealed any liens and/or judgments which could affect the seniority of the subject mortgage, including potentially superior post origination liens and/or judgments as well as subject mortgage not of record. For the purposes of identifying potentially superior post-origination homeowners’ association (“HOA”) liens, the Client has vetted and approved for use a list of states prepared by outside counsel for which potentially superior post origination HOA liens may take priority over the subject mortgage. The states identified by the Client to be super lien states are AL, AK, CO, CT, DC, DE, FL, HI, IL, MA, MD, MN, MO, NV, NH, NJ, OR, PA, RI, TN, VA, VT, WA, and WV.  SitusAMC reviewed the title policies for all liens and/or judgments that were recorded before the recordation of the subject mortgage to determine if any identifiable liens and/or judgments were listed as an exception on schedule B of the applicable title policies.

The final review results reflected in the Overall Review Results Summary herein may include additional exceptions identified after AMC’s initial review was completed where loan level issues were identified by external parties as a result of separate, distinct quality control evaluation of the loan files. In such cases, any additional exceptions cited by any such quality control evaluation would either be reflected (i) as an open exception or (ii) remediated if required documentation and/or curative actions were provided to AMC. The exception totals reflected herein, and corresponding Exception Rating, include exceptions that were so subsequently identified, if any. Please note that only a limited number of loans, if any, reflected in the Review Results Summary were subject to such external quality control evaluations.

(9) Disclaimer.
Except as expressly enumerated above, please be advised that SitusAMC has not performed any review to determine whether the mortgage loans covered in this Report complied with federal, state or local laws, constitutional provisions, regulations, ordinances or any other laws or guidance, including, without limitation, licensing and general usury laws (“Applicable Law”).  Further, there can be no assurances that in performing the review and preparing this Report that SitusAMC has uncovered all relevant factors and potential issues relating to the origination of the mortgage loans, their compliance with Applicable Law, or the original appraisals relating to the mortgaged properties, or that SitusAMC has uncovered all relevant factors that could affect the future performance of the mortgage loans. Please note that the results set forth in this Report are dependent upon receipt of complete and accurate data regarding the mortgage loans from mortgage loan originators, sponsors, issuers, and other third parties upon which SitusAMC is relying in reaching such results.  Except as expressly stated herein, SitusAMC did not verify the data relied upon in performing its review and producing this Report.  In addition, the findings and conclusions set forth in this Report are provided on an “as is” basis and are based on available information and Applicable Law as of the date of this Report, and SitusAMC does not undertake
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any obligation to update or provide any revisions to this Report to reflect events, circumstances, changes in Applicable Law, or changes in expectations after the date this Report was issued. 

Please be further advised that SitusAMC does not employ personnel who are licensed to practice law in the various jurisdictions covered in this Report, and the results set forth in this Report do not constitute legal advice or legal opinions whatsoever. The findings are recommendations or conclusions based on information provided to SitusAMC and are not statements of fact or legal conclusions. Information contained in the Report related to the applicable statute of limitations for certain claims may not be accurate or reflect the most recent controlling case law. Further, a particular court in a particular jurisdiction may extend, not enforce or otherwise allow claims beyond the statute of limitations identified in the Report based on certain factors, including the facts and circumstances of an individual mortgage loan.  The authorities administering the Applicable Law that was part of the review have broad discretionary powers which may permit such authorities, among other things, to withdraw exemptions accorded by statute or regulation, to impose additional requirements or to reach a conclusion that is not consistent with the results set forth in the Report. All decisions as to whether to issue, purchase, hold, sell or otherwise transact in securities backed by the mortgage loans reviewed in this Report, any investment strategy and any legal conclusions, including the potential liability related to the purchase or other transaction involving any such securities, shall be made solely by the parties to or investors in the transaction. The results set forth in this Report do not constitute tax or investment advice.  The scoring models in this Report are designed to identify potential risk in the securities backed by the mortgage loans reviewed, and each party or investor assumes sole responsibility for determining the suitability of the information for its particular use. SitusAMC does not make any representation or warranty (express or implied) as to the value of any mortgage loan or mortgage loan’s collateral that has been reviewed by SitusAMC.

Item 5. Summary of findings and conclusions of review
There were 487 mortgage loans in the final compliance population reviewed by AMC. After all documents were presented, under the applicable Fitch & Moody’s NRSRO grading criteria, 60 (12.32%) had an Overall grade of “A”, 369 (75.77%) had an Overall grade of “B”, 26 (5.34%) loans had exceptions that generated an Overall grade of “C”, and 32 (6.57%) had an Overall grade of “D”.  Of the 487 mortgage loans reviewed for compliance, 479 were reviewed by AMCD and 8 were reviewed by JCIII.

COMPLIANCE RESULTS SUMMARY (487 Mortgage Loans)
Pursuant to the applicable NRSRO criteria, AMC graded certain compliance exceptions as non-material based upon seasoning of the mortgage loans. Certain mortgage loans were seasoned beyond the applicable period under TILA in which affirmative claims could be brought by a consumer. The time period is not limited for claims, other than rescission, which may be raised as a defense to foreclosure. Information contained in any AMC report related to the applicable statute of limitations for certain claims may not be accurate or reflect the most recent controlling case law. Further, a particular court in a particular jurisdiction may extend, not enforce or otherwise allow claims beyond the statute of limitations identified in the report based on certain factors, including the facts and circumstances of an individual mortgage loan.

AMC Consolidated (487 Mortgage Loans)
Fitch & Moody’s Loan Grades
Compliance Grade
Loan Count
% of Loans
A
60
12.32%
B
369
75.77%
C
26
5.34%
D
32
6.57%
Total
487
100.00%
     

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AMC Diligence, LLC (479 Mortgage Loans)
Fitch & Moody’s Loan Grades
Compliance Grade
Loan Count
% of Loans
A
59
12.32%
B
362
75.57%
C
26
5.43%
D
32
6.68%
Total
479
100.00%
     
JCIII & Associates, LLC (8 Mortgage Loans)
Compliance Grade
Loan Count
% of Loans
A
1
12.50%
B
7
87.50%
C
0
0.00%
D
0
0.00%
Total
8
100.00%


EXCEPTION SUMMARY (487 Mortgage Loans)
The summaries below detail the exceptions from the Compliance Review that would have resulted in a “B”, “C”, or “D” grade for a given mortgage loan. Please note that exception grades of EV1, EV2, and EV3 may not result in a corresponding “B”, “C”, or “D” grade per relevant rating agency guidelines due to considerations including statute of limitations and specific characteristics of ratings by a given NRSRO. Also note that some mortgage loans may have multiple exceptions and, as a result, may have an exception or multiple exceptions in any one exception category.

AMC Diligence, LLC (479 Mortgage Loans)
The following exceptions were noted on the mortgage loans included in the Compliance Review performed by AMCD.
Exception Type
Fitch & Moody’s Final Exception Rating
Exception Category
Total
Compliance
D
Missing, Incorrect, or Incomplete HUD-1
30
Incomplete File
1
Missing, Incorrect, or Incomplete Note
1
Total Compliance Grade (D) Exceptions:
32
C
ATR/QM Defect
67
Missing Required Data (other than HUD-1 or Note)
1
Total Compliance Grade (C) Exceptions:
68
B
TILA
416
TRID Defect
235
RESPA
179
Missing Application Date
128
ECOA
105
Safe Act
72
FACTA
69
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TIL-MDIA
58
Missing, Incorrect, or Incomplete GFE
44
Missing, Incorrect, or Incomplete Final or Initial 1003
39
TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form
37
Missing Non-Required Data
28
Misc. State Level
20
ATR/QM Defect
16
Missing Disclosure
14
Missing, Incorrect, or Incomplete Final TIL
14
ATR/QM
13
LTV Test
8
State Defect
7
Missing Required Data (other than HUD-1 or Note)
6
Missing Required Data
6
Final TIL Estimated
4
Loan Package Documentation
3
State Late Charge
2
TRID
2
Federal HPML
2
Insurance
1
Total Compliance Grade (B) Exceptions:
1,528
Total Compliance Exceptions:
1,628

JCIII & Associates, LLC (8 Mortgage Loans)
The following exceptions were noted on the mortgage loans included in the Compliance Review performed by JCIII.

Exception Type
Final Exception Rating
Exception Category
Total
Compliance
B
RESPA
5
Missing, Incorrect, or Incomplete Initial TIL
3
Misc. State Level
2
Missing Disclosure
1
Missing, Incorrect, or Incomplete GFE
1
Total Compliance Grade (B) Exceptions:
12
Total Compliance Exceptions:
12

DATA INTEGRITY REVIEW RESULTS SUMMARY (487 Mortgage Loans)
AMC compared data fields on the bid tape provided by the Client to the data found in the actual file as captured during the Compliance Review. The number of fields included and reviewed on a bid tape can vary by counterparty and by the time period of the transaction. The information provided below is based upon the relevant data capture and bid tape elements for a specific transaction, as may be unique for that transaction, within the reviews that occurred to the associated mortgage loans that are included in the securitization population. Data discrepancies have been separated by mortgage loans reviewed by AMCD and mortgage loans reviewed by JCIII. Some mortgage loans may have multiple data discrepancies.

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The data for LTV, CLTV and DTI was taken directly from various documents in the mortgage loan files and was not recalculated for this review.

Please note that AMC did not track the number of fields that were checked on each mortgage loan for these data integrity elements as the data review was conducted during the acquisition of such assets and varied by transaction. AMC can confirm that not all fields would have been reviewed for all mortgage loans; however, mortgage loans within a similar transaction would have included a consistent data comparison for that transaction.

AMC Diligence, LLC (479 Mortgage Loans)
In total, data variances were found on 375 (78.29%) mortgage loans across 53 unique data fields in the AMCD sample.

Label
Delta(s)
% of Loans
Note Date
143
29.85%
Original P&I
71
14.82%
Representative FICO
52
10.86%
Property Type
51
10.65%
Amortization Term
43
8.98%
Investor: Qualifying Total Debt Ratio
38
7.93%
PMI Company
34
7.10%
Interest Rate Life Cap
33
6.89%
Street
32
6.68%
Refi Purpose
24
5.01%
Original LTV
22
4.59%
Doc Type
21
4.38%
Margin
21
4.38%
Purpose
21
4.38%
Index Type
19
3.97%
LTV Valuation Value
18
3.76%
Original Interest Rate
17
3.55%
Original CLTV
16
3.34%
Interest Rate Change Frequency
14
2.92%
Interest Rate Life Min
14
2.92%
Interest Rate Periodic Cap
14
2.92%
Maturity Date
14
2.92%
First Interest Rate Change Date
13
2.71%
Borrower Last Name
12
2.51%
Interest Rate Initial Maximum
12
2.51%
Interest Rate Initial Minimum
12
2.51%
Mortgage Type
12
2.51%
Payment Change Frequency
12
2.51%
Interest Rate Periodic Floor
10
2.09%
Original Term
10
2.09%
PMI Coverage %
10
2.09%
Interest Rate Initial Cap
9
1.88%
Interest Rate Life Max
9
1.88%
Zip
6
1.25%
Borrower Middle Name
5
1.04%
Occupancy
5
1.04%
Amortization Type
4
0.84%
Borrower First Name
4
0.84%
Borrower SSN
4
0.84%
Contract Sales Price
4
0.84%
Prepayment Penalty
4
0.84%
Coborrower Last Name
3
0.63%
Balloon Flag
2
0.42%
City
2
0.42%
Coborrower Middle Name
2
0.42%
Coborrower SSN
2
0.42%
First Payment Date
2
0.42%
Interest Rate Life Floor
2
0.42%
Original Loan Amount
2
0.42%
# of Units
1
0.21%
First Payment Change Date
1
0.21%
Originator Application Date
1
0.21%
Other Financing - Lien Position 2 - Current Balance
1
0.21%
Total
910
 

JCIII & Associates, LLC (8 Mortgage Loans)
In total, no data variances were found on the 8 mortgage loans in the JCIII sample.

COLLECTION COMMENT REVIEW SUMMARY (203 Mortgage Loans)
Of the mortgage loans subject to the collection comment review, 188 mortgage loans (92.61%) triggered an EV1 or EV2 exception level, and 15 mortgage loans (7.39%) triggered an EV3.

Servicing Review Grade
Loan Count
% of Loans
1
184
90.64%
2
4
1.97%
3
15
7.39%
Total
203
100.00%

PAYMENT HISTORY REVIEW SUMMARY (522 Mortgage Loans)
A Payment History Review was completed on 522 mortgage loans. Of the 522 mortgage loans subjected to the Payment History Review, all 522 mortgage loans (100.00%) had complete pay history strings. Of the mortgage loans reviewed, 403 mortgage loans (77.20%) did not show a delinquency within the look back period and 119 mortgage loans (22.80%) showed at least one delinquency within the look back period.

Of the 522 mortgage loans reviewed, all 522 mortgage loans (100.00%) were reviewed with cut-off dates ranging from June 30, 2015 to July 31, 2024. The 522 mortgage loans (100.00%) were reviewed with look back periods ranging from twenty-four to sixty-eight months.

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Category
Loan Count
% of Loans
No Delinquency, No Missing Data
403
77.20%
Delinquency, No Missing Data
119
22.80%
No Delinquency, At Least One Month Missing
0
0.00%
Delinquency, At Least One Month Missing
0
0.00%
Total
522
100.00%

Lookback
Loan Count
% of Loans
Twenty-Four (24) Months
291
55.75%
Thirty-Six (36) Months
229
43.87%
Forty-Nine (49) Months
1
0.19%
Sixty-Eight (68) Months
1
0.19%
Total
522
100.00%

TAX AND TITLE REVIEW SUMMARY
SitusAMC Diligence, LLC Review (622 Mortgage Loans)
As part of the due diligence services, the Client provided SitusAMC with identifying data on 622 mortgage loans.  There were 32 mortgage loans that were determined to have critical findings based on the scope of reviews set forth herein.  These 32 mortgage loans had senior lien encumbrances recorded before the recordation of the subject mortgage, and all 32 mortgage files contained title evidence with no exceptions that explicitly preclude coverage to sufficiently mitigate the lien priority issue.  SitusAMC determined from a review of the current owner’s title search there were no critical exceptions on the remaining 590 mortgage loans.

ADDITIONAL SUMMARY (AMC Population – 479 Mortgage Loans)
Some % of Loans may not add to 100% due to rounding
Amortization Type
Loan Count
% of Loans
Fixed
210
43.84%
Adjustable
269
56.16%
Total
479
100.00%
     
Lien Position
Loan Count
% of Loans
1
477
99.58%
2
2
0.42%
Total
479
100.00%

Loan Purpose
Loan Count
% of Loans
Cash Out: Debt Consolidation
51
10.65%
Cash Out: Home Improvement/Renovation
9
1.88%
Cash Out: Other
104
21.71%
Limited Cash-Out
2
0.42%
Purchase
199
41.54%
Rate/Term Refinance
108
22.55%
Construction to Permanent
1
0.21%
Refinance- UTD
2
0.42%
Unavailable
3
0.63%
Total
479
100.00%

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Original Term
Loan Count
% of Loans
121-180 Months
16
3.34%
181-240 Months
5
1.04%
241-360 Months
434
90.61%
361+ Months
24
5.01%
Total
479
100.00%

Property Type
Loan Count
% of Loans
Single Family Detached
261
54.49%
Co-op
4
0.84%
Condo, Low Rise
54
11.27%
Condo, Mid Rise
7
1.46%
Condo, High Rise
7
1.46%
PUD
61
12.73%
Townhouse
1
0.21%
Manufactured Housing
4
0.84%
1 Family Attached
10
2.09%
2 Family
27
5.64%
3 Family
14
2.92%
4 Family
7
1.46%
PUD Attached
6
1.25%
Raw Land/Other
10
2.09%
Unavailable
6
1.25%
Total
479
100.00%

Occupancy
Loan Count
% of Loans
Primary
408
85.18%
Investment
55
11.48%
Second Home
13
2.71%
Unknown
3
0.63%
Total
479
100.00%

ADDITIONAL SUMMARY (JCIII Population - 8 Mortgage Loans)
Some % of Loans may not add to 100% due to rounding
Amortization Type
Loan Count
% of Loans
Fixed
1
12.50%
Adjustable
7
87.50%
Total
8
100.00%
   
 
Lien Position
Loan Count
% of Loans
First
8
100.00%
Total
8
100.00%
   
 
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Loan Purpose
Loan Count
% of Loans
Cashout Refi
2
25.00%
Purchase
5
62.50%
Rate/Term Refi
1
12.50%
Total
8
100.00%
   
 
Original Term
Loan Count
% of Loans
241-360 Months
7
87.50%
Unavailable
1
12.50%
Total
8
100.00%
   
 
Property Type
Loan Count
% of Loans
Single Family
5
62.50%
PUD Detached
2
25.00%
Low Rise Condo (<5 Floors)
1
12.50%
Total
8
100.00%
   
 
Occupancy
Loan Count
% of Loans
Primary
8
100.00%
Total
8
100.00%

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