Unique ID LoanID Seller Servicer Group Loan Exception Exception Exception Exception Detail Exception Information Amount of Compliance Factors Subject to Origination Statute of State Purpose at Occupancy Disposition Fitch Moody's DBRS S&P Date Date Cure Cured Cleared Issue Unable QM Status Seller Comments AMC Additional Comments
Loan ID Loan ID Exception Type Grade Underdisclosure Predatory Date Limitation Origination at 3 UAL State Exception Exception Exception Exception Reported Provided / with to
ID - Unable Date Origination Level Level Level Level by AMC Waived Cure Clear
to Test Grade Grade Grade Grade Doc
649208142 XXX XXX 1 29371225 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 2/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Rate/Term
649208142 XXX XXX 1 29371226 compliance 2 SAFE Act - Individual LO Unable to test Individual Loan Originator license status due to missing 2/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
NMLS license status not information. Rate/Term
approved
649208142 XXX XXX 1 29371227 compliance 2 SAFE Act - Individual LO Unable to test Loan Originator license due to missing information. Liability appears to be limited to originators/licensees. 2/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
not licensed at time of Rate/Term
application
649208142 XXX XXX 1 29371228 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 2/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Affiliated Business Disclosure to applicant within three (3) business days of application. implementing regulation, Regulation X, for these type of violations. Rate/Term
Arrangement Disclosure
Not Provided Within 3
Business Days of
Application
649208142 XXX XXX 1 29371229 compliance 2 (Missing Data) Unable to Original Lender was not able to be determined. Unable to determine if correct 2/XX/2013 2/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
determine if loan is a TILA rescission form was used. (H-8 Form was used and property is in the 2 nd, 5 Rate/Term
same lender refi (Circuit th, 7 th, 8 th, 9 th, 10 th, or District of Columbia)
2, 5, 7, 8, 9, 10 or DC)
649207386 XXX XXX 2 29371268 compliance 2 (Doc Error) Initial GFE 1/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
not provided Cash-out -
Debt
Consolidation
649207386 XXX XXX 2 29371269 compliance 2 Property Type Not (Missing Data) Property Type. If property type is other than single family 1/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Provided residence, state and federal testing may be impacted. Cash-out -
Debt
Consolidation
649207386 XXX XXX 2 29371270 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 1/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Affiliated Business Disclosure to applicant within three (3) business days of application. implementing regulation, Regulation X, for these type of violations. Cash-out -
Arrangement Disclosure Debt
Not Provided Within 3 Consolidation
Business Days of
Application
649207386 XXX XXX 2 29371271 compliance 2 RESPA Servicing RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 1/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Disclosure: Servicing Statement. implementing regulation, Regulation X, for these type of violations. Cash-out -
Disclosure Statement Debt
Missing Consolidation
649207386 XXX XXX 2 29371272 compliance 2 RESPA - Initial GFE RESPA: Initial GFE not provided to Borrower(s). RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 1/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Missing implementing regulation, Regulation X, for these type of violations. Cash-out -
Debt
Consolidation
649207386 XXX XXX 2 29371273 compliance 2 TIL-MDIA - Initial TIL Truth in Lending Act (Early TIL Disclosure): Initial TIL was not provided to the TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited as a defense to 1/XX/2013 1/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
Missing borrower. foreclosure. Assignee liability. Cash-out -
Debt
Consolidation
649207386 XXX XXX 2 29371274 compliance 2 (Missing Data) Unable to Original Lender was not able to be determined. Unable to determine if correct 1/XX/2013 1/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
determine if loan is a TILA rescission form was used. (H-8 Form was used and property is in the 2 nd, 5 Cash-out -
same lender refi (Circuit th, 7 th, 8 th, 9 th, 10 th, or District of Columbia) Debt
2, 5, 7, 8, 9, 10 or DC) Consolidation
649207386 XXX XXX 2 29371275 credit 3 Missing Valuation: Appraisal not provided. 1/XX/2013 CA Refinance - Primary No C C C C 7/XX/2023
Cash-out -
Debt
Consolidation
649208723 XXX XXX 1 29371291 compliance 2 RESPA (2010) - GFE column RESPA (2010) - GFE column on page 3 of Final HUD-1 does not match most recently RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 1/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
on HUD Comparison Chart disclosed GFE. implementing regulation, Regulation X, for these type of violations. Cash-out -
Inaccurate Debt
Consolidation
649208723 XXX XXX 1 29371292 compliance 2 TILA - Incorrect Right To Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing 1/XX/2014 1/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023
Cancel Form Used - H-8 Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses Cash-out -
Used on Same Lender form should have been used. the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that Debt
Refinance (Circuit 2, 5, creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for Consolidation
7, 8, 9, 10 or DC) refinances involving the same creditor.
649208738 XXX XXX 2 29371369 credit 3 Missing Document: Missing 11/XX/2013 CA Refinance - Investment No C C C C 7/XX/2023
Final 1003 Rate/Term
649208738 XXX XXX 2 29371370 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 11/XX/2013 CA Refinance - Investment No B B B B 7/XX/2023
Application Test an application date of 10/XX/2013 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date.
649206770 XXX XXX 1 29371421 credit 3 Missing Document: Missing 5/XX/2013 CA Purchase Investment No C C C C 7/XX/2023
Final 1003
649206770 XXX XXX 1 29371422 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 5/XX/2013 CA Purchase Investment No B B B B 7/XX/2023
Application Test an application date of 04/XX/2013 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
649207563 XXX XXX 2 29371429 credit 3 Missing Document: Missing No 8/XX/2012 CA Purchase Investment No C C C C 7/XX/2023
Final 1003
649207563 XXX XXX 2 29371430 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. No 8/XX/2012 CA Purchase Investment No B B B B 7/XX/2023
649207563 XXX XXX 2 29371431 compliance 3 Missing Final HUD-1: Missing Final HUD-1: HUD-1 Not Signed or Stamped used for any applicable No 8/XX/2012 CA Purchase Investment No D D D D 7/XX/2023
HUD-1 Not Signed or Federal, State or Local compliance testing.
Stamped Used For Fee
Testing Material
649207563 XXX XXX 2 29371432 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using No 8/XX/2012 CA Purchase Investment No B B B B 7/XX/2023
Application Test an application date of 07/XX/2012 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
649207470 XXX XXX 1 29371448 credit 3 Missing Document: Missing No 12/XX/2011 CA Purchase Investment No C C C C 7/XX/2023
Final 1003
649207470 XXX XXX 1 29371449 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. No 12/XX/2011 CA Purchase Investment No B B B B 7/XX/2023
649207470 XXX XXX 1 29371450 compliance 3 Missing Final HUD-1: Missing Final HUD-1: HUD-1 Not Signed or Stamped used for any applicable No 12/XX/2011 CA Purchase Investment No D D D D 7/XX/2023
HUD-1 Not Signed or Federal, State or Local compliance testing.
Stamped Used For Fee
Testing Material
649207470 XXX XXX 1 29371451 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using No 12/XX/2011 CA Purchase Investment No B B B B 7/XX/2023
Application Test an application date of 11/XX/2011 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
649209004 XXX XXX 1 29371456 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. Yes 3/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Cash-out -
Other
649209004 XXX XXX 1 29371457 compliance 3 Missing Final HUD-1: Missing Final HUD-1: Illegible HUD-1 used for any applicable Federal, State or HUD has significant legibility issues, please provide a Yes 3/XX/2013 CA Refinance - Primary No D D D D 7/XX/2023 2023/XX/XX: HUD provided is
Illegible HUD-1 Used For Local compliance testing. clearer copy to confirm fee capture is accurate. Cash-out - not for subject transaction.
Fee Testing Material Other
649209004 XXX XXX 1 29371458 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using Yes 3/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Application Test an application date of 02/XX/2013 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. Other
649209004 XXX XXX 1 29371459 compliance 2 SAFE Act - LO Company not Unable to test LO company NMLS license due to missing information. Liability appears to be limited to originators/licensees. Yes 3/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
licensed at time of Cash-out -
application Other
649209004 XXX XXX 1 29371460 compliance 2 SAFE Act - Individual LO Unable to test Individual Loan Originator license status due to missing Yes 3/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
NMLS license status not information. Cash-out -
approved Other
649209004 XXX XXX 1 29371461 compliance 2 SAFE Act - Individual LO Unable to test Loan Originator license due to missing information. Liability appears to be limited to originators/licensees. Yes 3/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
not licensed at time of Cash-out -
application Other
649209004 XXX XXX 1 29371462 compliance 2 SAFE Act - LO Company Unable to test LO company status due to missing information. Yes 3/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
NMLS license status not Cash-out -
approved Other
649209004 XXX XXX 1 29371463 compliance 2 Safe Act NMLS - Missing Secure and Fair Enforcement for Mortgage Licensing Act: Unable to determine Liability appears to be limited to originators/licensees. Yes 3/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Evidence of Initial Loan compliance with NMLSR timing requirements due to missing evidence of initial loan Cash-out -
Application Date application date. Other
649209004 XXX XXX 1 29371464 compliance 2 RESPA (2010) - GFE RESPA (2010): GFE does not provide minimum ten (10) business day availability RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or Yes 3/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Settlement charges Good for estimate of charges and terms for all other settlement charges. implementing regulation, Regulation X, for these type of violations. Cash-out -
Thru Date Less than 10 Other
Days
649209004 XXX XXX 1 29371465 compliance 2 RESPA (2010) - GFE column RESPA (2010) - GFE column on page 3 of Final HUD-1 does not match most recently RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or Yes 3/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
on HUD Comparison Chart disclosed GFE. implementing regulation, Regulation X, for these type of violations. Cash-out -
Inaccurate Other
649209004 XXX XXX 1 29371466 compliance 2 RESPA - Initial GFE Not Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or Yes 3/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Provided Within 3 Loan Application Date. implementing regulation, Regulation X, for these type of violations. Cash-out -
Business Days of Other
Application
649209004 XXX XXX 1 29371467 compliance 2 RESPA Servicing Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or Yes 3/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Disclosure: Servicing Loan Application Date. implementing regulation, Regulation X, for these type of violations. Cash-out -
Disclosure Statement Not Other
Provided Within 3
Business Days of
Application
649209004 XXX XXX 1 29371468 compliance 2 TIL-MDIA - Initial TIL Unable to determine compliance with timing requirements due to missing Initial TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited as a defense to Yes 3/XX/2013 3/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
Not Provided within 3 Loan Application Date. foreclosure. Assignee liability. Cash-out -
Business Days of Other
Application
649209004 XXX XXX 1 29371469 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" date on the TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Yes 3/XX/2013 3/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - Final TIL does not match the date on which the first regular periodic payment Assignee liability. Cash-out -
Maximum In First 5 Years will be due and the earliest date on which that rate may apply. Other
Change Date Inaccurate
(ARM loan)
649209004 XXX XXX 1 29371470 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" interest rate TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Yes 3/XX/2013 3/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - on the Final TIL does not match the maximum interest rate that may apply during Assignee liability. Cash-out -
Maximum In First 5 Years the first five (5) years of the loan. Other
Interest Rate Inaccurate
649209004 XXX XXX 1 29371471 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" total payment TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Yes 3/XX/2013 3/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - amount (PITI) on the Final TIL does not match the maximum total payment on the Assignee liability. Cash-out -
Maximum In First 5 Years loan during the first five (5) years for the loan. Other
Total Payment (PITI)
Inaccurate
649209004 XXX XXX 1 29371472 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum Ever" date on the Final TIL does TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Yes 3/XX/2013 3/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - not match the earliest date on which the maximum rate may apply. Assignee liability. Cash-out -
Maximum Ever Change Date Other
Inaccurate
649209004 XXX XXX 1 29371473 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "First Adjustment" date on the Final TIL TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Yes 3/XX/2013 3/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - does not match the first adjustment date for the loan. Assignee liability. Cash-out -
First Adjustment Change Other
Date Inaccurate
649209004 XXX XXX 1 29371474 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" interest payment TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Yes 3/XX/2013 3/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - on the Final TIL does not match the maximum interest payment that may apply Assignee liability. Cash-out -
Maximum In First 5 Years during the first five (5) years of the loan. Other
Interest Payment
Inaccurate
649209004 XXX XXX 1 29371475 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" principal TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Yes 3/XX/2013 3/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - payment on the Final TIL does not match the maximum principal payment that may Assignee liability. Cash-out -
Maximum In First 5 Years apply during the first five (5) years of the loan. Other
Principal Payment
Inaccurate
649209004 XXX XXX 1 29371476 compliance 2 ARM Disclosure Timing Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 3/XX/2013 3/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
Test application due to missing information. Cash-out -
Other
649209004 XXX XXX 1 29371477 compliance 2 TILA - Incorrect Right To Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing Yes 3/XX/2013 3/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Cancel Form Used - H-8 Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses Cash-out -
Used on Same Lender form should have been used. the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that Other
Refinance (Circuit 2, 5, creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for
7, 8, 9, 10 or DC) refinances involving the same creditor.
649209004 XXX XXX 1 29371478 credit 3 Missing Document: Missing Yes 3/XX/2013 CA Refinance - Primary No C C C C 7/XX/2023
Final 1003 Cash-out -
Other
649209004 XXX XXX 1 29371479 compliance 2 CHARM Booklet Disclosure Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 3/XX/2013 3/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
Timing Loan Application Date. Cash-out -
Other
649208722 XXX XXX 2 29371580 credit 3 Missing Document: Missing No 4/XX/2013 CA Purchase Primary No C C C C 7/XX/2023
Final 1003
649208722 XXX XXX 2 29371581 compliance 3 Missing Final HUD-1: Missing Final HUD-1: HUD-1 Not Signed or Stamped used for any applicable No 4/XX/2013 CA Purchase Primary No D D D D 7/XX/2023 2023/XX/XX: Final HUD- 2023/XX/XX: The cover letter
HUD-1 Not Signed or Federal, State or Local compliance testing. 1 was not stamped or mentioned does not meet the
Stamped Used For Fee signed, however it did requirements of a Final HUD-
Testing Material have a cover letter 1. How a particular escrow
that confirmed that company may or may not have
the enclosed Final HUD operated in accordance with
is the certified copy state standards is outside
which is likely how the scope of SAMC's review. A
that Escrow operated signed final HUD-1 has not
vs the been provided. Exception
stamp/signature. remains.
649208722 XXX XXX 2 29371582 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using No 4/XX/2013 CA Purchase Primary No B B B B 7/XX/2023
Application Test an application date of 03/XX/2013 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
649208722 XXX XXX 2 29371583 compliance 2 Federal LO Compensation Loan Originator Compensation: Dual compensation received from both a consumer and Assignee Liability: Civil actions that may be brought against a creditor may be maintained against No 4/XX/2013 4/XX/2016 CA Purchase Primary No B B B B 7/XX/2023
Dual Compensation Pre- person other than consumer. any assignee only if the violation is apparent on the face of the disclosure or other documents
Dodd Frank Test assigned, and where the assignment was involuntary. This civil liability may include $XXX in the
case of an individual transaction, or the lesser of $XXX or 1% of the creditor's net worth in the
case of a class action as well as actual damages, court costs, and attorneys' fees. For an anti-
steering violation, the creditor may also be liable in an amount equal to the sum of all finance
charges and fees paid by the consumer, unless the creditor demonstrates the failure to comply is not
material. Notwithstanding any other provision of law, when a creditor, assignee, or other holder or
anyone acting on behalf of the creditor, assignee, or holder, initiates a judicial or non-judicial
foreclosure of the residential mortgage loan, or any other action to collect the debt in connection
with such loan, a consumer may assert a violation as a matter of defense by recoupment or set off
without regard for the time limit on a private action for damages.
649208722 XXX XXX 2 29371584 compliance 2 SAFE Act - LO Company not Unable to test LO company NMLS license due to missing information. Liability appears to be limited to originators/licensees. No 4/XX/2013 CA Purchase Primary No B B B B 7/XX/2023
licensed at time of
application
649208722 XXX XXX 2 29371585 compliance 2 SAFE Act - Individual LO Unable to test Individual Loan Originator license status due to missing No 4/XX/2013 CA Purchase Primary No B B B B 7/XX/2023
NMLS license status not information.
approved
649208722 XXX XXX 2 29371586 compliance 2 SAFE Act - Individual LO Unable to test Loan Originator license due to missing information. Liability appears to be limited to originators/licensees. No 4/XX/2013 CA Purchase Primary No B B B B 7/XX/2023
not licensed at time of
application
649208722 XXX XXX 2 29371587 compliance 2 SAFE Act - LO Company Unable to test LO company status due to missing information. No 4/XX/2013 CA Purchase Primary No B B B B 7/XX/2023
NMLS license status not
approved
649208722 XXX XXX 2 29371588 compliance 2 Safe Act NMLS - Missing Secure and Fair Enforcement for Mortgage Licensing Act: Unable to determine Liability appears to be limited to originators/licensees. No 4/XX/2013 CA Purchase Primary No B B B B 7/XX/2023
Evidence of Initial Loan compliance with NMLSR timing requirements due to missing evidence of initial loan
Application Date application date.
649208722 XXX XXX 2 29371589 compliance 2 RESPA - Initial GFE Not Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or No 4/XX/2013 CA Purchase Primary No B B B B 7/XX/2023
Provided Within 3 Loan Application Date. implementing regulation, Regulation X, for these type of violations.
Business Days of
Application
649208722 XXX XXX 2 29371590 compliance 2 RESPA Disclosure - HUD RESPA Disclosure Rule: Creditor did not provide HUD Settlement Cost Booklet. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or No 4/XX/2013 CA Purchase Primary No B B B B 7/XX/2023
Settlement Cost Booklet implementing regulation, Regulation X, for these type of violations.
Missing
649208722 XXX XXX 2 29371591 compliance 2 RESPA Servicing Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or No 4/XX/2013 CA Purchase Primary No B B B B 7/XX/2023
Disclosure: Servicing Loan Application Date. implementing regulation, Regulation X, for these type of violations.
Disclosure Statement Not
Provided Within 3
Business Days of
Application
649208722 XXX XXX 2 29371592 compliance 2 TIL-MDIA - Initial TIL Unable to determine compliance with timing requirements due to missing Initial TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited as a defense to No 4/XX/2013 4/XX/2014 CA Purchase Primary No B B B B 7/XX/2023
Not Provided within 3 Loan Application Date. foreclosure. Assignee liability.
Business Days of
Application
649208722 XXX XXX 2 29371593 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum Ever" date on the Final TIL does TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. No 4/XX/2013 4/XX/2014 CA Purchase Primary No B B B B 7/XX/2023
Payment Summary Table - not match the earliest date on which the maximum rate may apply. Assignee liability.
Maximum Ever Change Date
Inaccurate
649208722 XXX XXX 2 29371594 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "First Adjustment" date on the Final TIL TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. No 4/XX/2013 4/XX/2014 CA Purchase Primary No B B B B 7/XX/2023
Payment Summary Table - does not match the first adjustment date for the loan. Assignee liability.
First Adjustment Change
Date Inaccurate
649208722 XXX XXX 2 29371595 compliance 2 ARM Disclosure Compliant TIL variable rate disclosure: ARM loan program disclosure does not match terms of TILA - subject to a 1 year SOL for affirmative claims under TILA No 4/XX/2013 4/XX/2014 CA Purchase Primary No B B B B 7/XX/2023
Test loan.
649208722 XXX XXX 2 29371596 compliance 2 ARM Disclosure Timing Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA No 4/XX/2013 4/XX/2014 CA Purchase Primary No B B B B 7/XX/2023
Test application due to missing information.
649208722 XXX XXX 2 29371597 compliance 2 CHARM Booklet Disclosure Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA No 4/XX/2013 4/XX/2014 CA Purchase Primary No B B B B 7/XX/2023
Timing Loan Application Date.
649209125 XXX XXX 2 29371911 credit 3 Missing Document: Missing 11/XX/2012 CA Purchase Primary No C C C C 7/XX/2023
Final 1003
649209125 XXX XXX 2 29371912 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 11/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
649209125 XXX XXX 2 29371913 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 11/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
Application Test an application date of 10/XX/2012 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
649209125 XXX XXX 2 29371914 compliance 2 SAFE Act - LO Company not Unable to test LO company NMLS license due to missing information. Liability appears to be limited to originators/licensees. 11/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
licensed at time of
application
649209125 XXX XXX 2 29371915 compliance 2 SAFE Act - Individual LO Unable to test Individual Loan Originator license status due to missing 11/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
NMLS license status not information.
approved
649209125 XXX XXX 2 29371916 compliance 2 SAFE Act - Individual LO Unable to test Loan Originator license due to missing information. Liability appears to be limited to originators/licensees. 11/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
not licensed at time of
application
649209125 XXX XXX 2 29371917 compliance 2 SAFE Act - LO Company Unable to test LO company status due to missing information. 11/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
NMLS license status not
approved
649209125 XXX XXX 2 29371918 compliance 2 Safe Act NMLS - Missing Secure and Fair Enforcement for Mortgage Licensing Act: Unable to determine Liability appears to be limited to originators/licensees. 11/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
Evidence of Initial Loan compliance with NMLSR timing requirements due to missing evidence of initial loan
Application Date application date.
649209125 XXX XXX 2 29371919 compliance 2 RESPA - Initial GFE Not Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 11/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
Provided Within 3 Loan Application Date. implementing regulation, Regulation X, for these type of violations.
Business Days of
Application
649209125 XXX XXX 2 29371920 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 11/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
Affiliated Business Business Arrangement Disclosure to applicant within three (3) business days of implementing regulation, Regulation X, for these type of violations.
Arrangement Disclosure application due to missing information.
Not Provided Within 3
Business Days of
Application
649209125 XXX XXX 2 29371921 compliance 2 RESPA Disclosure - HUD RESPA Disclosure Rule: Creditor did not provide HUD Settlement Cost Booklet. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 11/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
Settlement Cost Booklet implementing regulation, Regulation X, for these type of violations.
Missing
649209125 XXX XXX 2 29371922 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 11/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
Account Statement Missing implementing regulation, Regulation X, for these type of violations.
649209125 XXX XXX 2 29371923 compliance 2 RESPA Servicing Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 11/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
Disclosure: Servicing Loan Application Date. implementing regulation, Regulation X, for these type of violations.
Disclosure Statement Not
Provided Within 3
Business Days of
Application
649209125 XXX XXX 2 29371924 compliance 2 TIL-MDIA - Initial TIL Unable to determine compliance with timing requirements due to missing Initial TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited as a defense to 11/XX/2012 11/XX/2013 CA Purchase Primary No B B B B 7/XX/2023
Not Provided within 3 Loan Application Date. foreclosure. Assignee liability.
Business Days of
Application
649207006 XXX XXX 2 29371925 compliance 1 (Missing Doc) Incomplete Loan file does not contain any origination documentation. 2/XX/2006 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes 2023/XX/XX: Additional image
loan images/file Cash-out - package received.
Debt
Consolidation
649207006 XXX XXX 2 29371926 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 2/XX/2006 CA Refinance - Primary No B B B B 7/XX/2023
Application Test an application date of 02/XX/2006 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. Debt
Consolidation
649207347 XXX XXX 1 29371927 credit 3 Missing Document: Missing 3/XX/2013 CA Purchase Investment No C C C C 7/XX/2023
Final 1003
649207347 XXX XXX 1 29371928 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 3/XX/2013 CA Purchase Investment No B B B B 7/XX/2023
Application Test an application date of 03/XX/2013 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
649207347 XXX XXX 1 29371929 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 3/XX/2013 CA Purchase Investment No B B B B 7/XX/2023
649208064 XXX XXX 2 29371931 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization did not disclose the sign in fees of $XXX $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 4/XX/2005 4/XX/2008 CA Refinance - Primary No B B B B 7/XX/2023
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. and $XXX subordination recording fee of $XXX and title transactions. Unlimited as a defense to foreclosure. Assignee liability. Cash-out -
courier fee of $XXX as prepaid finance charges. HUD Other
disclosed prepaid interest fee as $XXX and itemization
disclosed as $XXX.
649208548 XXX XXX 2 29371936 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. Yes 4/XX/2007 CA Refinance - Primary No B B B B 7/XX/2023
Cash-out -
Debt
Consolidation
649208548 XXX XXX 2 29371937 compliance 3 Missing Final HUD-1: Missing Final HUD-1: HUD-1 Not Signed or Stamped used for any applicable Yes 4/XX/2007 CA Refinance - Primary No D D D D 7/XX/2023
HUD-1 Not Signed or Federal, State or Local compliance testing. Cash-out -
Stamped Used For Fee Debt
Testing Material Consolidation
649208548 XXX XXX 2 29371938 compliance 2 Property Type Not (Missing Data) Property Type. If property type is other than single family Yes 4/XX/2007 CA Refinance - Primary No B B B B 7/XX/2023
Provided residence, state and federal testing may be impacted. Cash-out -
Debt
Consolidation
649208548 XXX XXX 2 29371939 credit 3 Missing Valuation: Appraisal not provided. Yes 4/XX/2007 CA Refinance - Primary No C C C C 7/XX/2023
Cash-out -
Debt
Consolidation
649207779 XXX XXX 2 29371940 credit 3 Missing Document: Missing 12/XX/2013 CA Refinance - Primary No C C C C 7/XX/2023
Final 1003 Rate/Term
649207779 XXX XXX 2 29371941 credit 3 Missing Valuation: Appraisal not provided. 12/XX/2013 CA Refinance - Primary No C C C C 7/XX/2023
Rate/Term
649207779 XXX XXX 2 29371942 compliance 2 Possible Federal Loan Loan Originator Compensation: Anti-Steering - Unable to determine Safe Harbor Assignee Liability: Civil actions that may be brought against a creditor may be maintained against 12/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Originator Compensation - due to Anti-Steering Disclosure not provided to borrower. any assignee only if the violation is apparent on the face of the disclosure or other documents Rate/Term
Anti-Steering Disclosure assigned, except where the assignment was involuntary. This civil liability may include $XXX in the
Not Provided: Unable to case of an individual transaction, or the lesser of $XXX or 1% of the creditor's net worth in the
determine Anti-Steering case of a class action (effective 1/XX/14, this amount increases to the lesser of $XXX or 1%), as
compliance/Safe Harbor well as actual damages, court costs, and attorneys' fees. For an anti-steering violation, the
creditor may also be liable in an amount equal to the sum of all finance charges and fees paid by the
consumer, unless the creditor demonstrates the failure to comply is not material. Notwithstanding
any other provision of law, when a creditor, assignee, or other holder or anyone acting on behalf of
the creditor, assignee, or holder, initiates a judicial or nonjudicial foreclosure of the residential
mortgage loan, or any other action to collect the debt in connection with such loan, a consumer may
assert a violation as a matter of defense by recoupment or set off without regard for the time limit
on a private action for damages.
Effective 1/XX/2014 in addition to the aforementioned, the individual Loan Originator could be liable
for statutory damages. The maximum liability is the greater of actual damages or 3 times the loan
originator's compensation or gain, plus the cost to the consumer of the action. The Dodd-Frank Act
extended the statute of limitations on TILA violations to 3 years from the date of the violation.
649207779 XXX XXX 2 29371943 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 12/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Application Test an application date of 11/XX/2013 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date.
649207779 XXX XXX 2 29371944 compliance 2 Property Type Not (Missing Data) Property Type. If property type is other than single family 12/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Provided residence, state and federal testing may be impacted. Rate/Term
649207779 XXX XXX 2 29371945 compliance 2 SAFE Act - LO Company not Unable to test LO company NMLS license due to missing information. Liability appears to be limited to originators/licensees. 12/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
licensed at time of Rate/Term
application
649207779 XXX XXX 2 29371946 compliance 2 SAFE Act - Individual LO Unable to test Individual Loan Originator license status due to missing 12/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
NMLS license status not information. Rate/Term
approved
649207779 XXX XXX 2 29371947 compliance 2 SAFE Act - Individual LO Unable to test Loan Originator license due to missing information. Liability appears to be limited to originators/licensees. 12/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
not licensed at time of Rate/Term
application
649207779 XXX XXX 2 29371948 compliance 2 SAFE Act - LO Company Unable to test LO company status due to missing information. 12/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
NMLS license status not Rate/Term
approved
649207779 XXX XXX 2 29371949 compliance 2 Safe Act NMLS - Missing Secure and Fair Enforcement for Mortgage Licensing Act: Unable to determine Liability appears to be limited to originators/licensees. 12/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Evidence of Initial Loan compliance with NMLSR timing requirements due to missing evidence of initial loan Rate/Term
Application Date application date.
649207779 XXX XXX 2 29371950 compliance 2 RESPA - Initial GFE Not Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 12/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Provided Within 3 Loan Application Date. implementing regulation, Regulation X, for these type of violations. Rate/Term
Business Days of
Application
649207779 XXX XXX 2 29371951 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 12/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Account Statement Missing implementing regulation, Regulation X, for these type of violations. Rate/Term
649207779 XXX XXX 2 29371952 compliance 2 RESPA Servicing Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 12/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Disclosure: Servicing Loan Application Date. implementing regulation, Regulation X, for these type of violations. Rate/Term
Disclosure Statement Not
Provided Within 3
Business Days of
Application
649207779 XXX XXX 2 29371953 compliance 2 TIL-MDIA - Initial TIL Unable to determine compliance with timing requirements due to missing Initial TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited as a defense to 12/XX/2013 12/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
Not Provided within 3 Loan Application Date. foreclosure. Assignee liability. Rate/Term
Business Days of
Application
649207420 XXX XXX 2 29372002 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 7/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Cash-out -
Other
649207420 XXX XXX 2 29372003 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 7/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Application Test an application date of 06/XX/2013 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. Other
649207420 XXX XXX 2 29372004 compliance 2 SAFE Act - LO Company not Unable to test LO company NMLS license due to missing information. Liability appears to be limited to originators/licensees. 7/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
licensed at time of Cash-out -
application Other
649207420 XXX XXX 2 29372005 compliance 2 SAFE Act - Individual LO Unable to test Individual Loan Originator license status due to missing 7/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
NMLS license status not information. Cash-out -
approved Other
649207420 XXX XXX 2 29372006 compliance 2 SAFE Act - Individual LO Unable to test Loan Originator license due to missing information. Liability appears to be limited to originators/licensees. 7/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
not licensed at time of Cash-out -
application Other
649207420 XXX XXX 2 29372007 compliance 2 SAFE Act - LO Company Unable to test LO company status due to missing information. 7/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
NMLS license status not Cash-out -
approved Other
649207420 XXX XXX 2 29372008 compliance 2 Safe Act NMLS - Missing Secure and Fair Enforcement for Mortgage Licensing Act: Unable to determine Liability appears to be limited to originators/licensees. 7/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Evidence of Initial Loan compliance with NMLSR timing requirements due to missing evidence of initial loan Cash-out -
Application Date application date. Other
649207420 XXX XXX 2 29372009 compliance 2 RESPA (2010) - GFE RESPA (2010): GFE does not provide minimum ten (10) business day availability RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 7/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Settlement charges Good for estimate of charges and terms for all other settlement charges. implementing regulation, Regulation X, for these type of violations. Cash-out -
Thru Date Less than 10 Other
Days
649207420 XXX XXX 2 29372010 compliance 2 RESPA - Initial GFE Not Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 7/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Provided Within 3 Loan Application Date. implementing regulation, Regulation X, for these type of violations. Cash-out -
Business Days of Other
Application
649207420 XXX XXX 2 29372011 compliance 2 RESPA Servicing Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 7/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Disclosure: Servicing Loan Application Date. implementing regulation, Regulation X, for these type of violations. Cash-out -
Disclosure Statement Not Other
Provided Within 3
Business Days of
Application
649207420 XXX XXX 2 29372012 compliance 2 TIL-MDIA - Initial TIL Unable to determine compliance with timing requirements due to missing Initial TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited as a defense to 7/XX/2013 7/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
Not Provided within 3 Loan Application Date. foreclosure. Assignee liability. Cash-out -
Business Days of Other
Application
649207420 XXX XXX 2 29372013 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" date on the TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 7/XX/2013 7/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - Final TIL does not match the date on which the first regular periodic payment Assignee liability. Cash-out -
Maximum In First 5 Years will be due and the earliest date on which that rate may apply. Other
Change Date Inaccurate
(ARM loan)
649207420 XXX XXX 2 29372014 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" interest rate TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 7/XX/2013 7/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - on the Final TIL does not match the maximum interest rate that may apply during Assignee liability. Cash-out -
Maximum In First 5 Years the first five (5) years of the loan. Other
Interest Rate Inaccurate
649207420 XXX XXX 2 29372015 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" total payment TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 7/XX/2013 7/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - amount (PITI) on the Final TIL does not match the maximum total payment on the Assignee liability. Cash-out -
Maximum In First 5 Years loan during the first five (5) years for the loan. Other
Total Payment (PITI)
Inaccurate
649207420 XXX XXX 2 29372016 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum Ever" date on the Final TIL does TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 7/XX/2013 7/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - not match the earliest date on which the maximum rate may apply. Assignee liability. Cash-out -
Maximum Ever Change Date Other
Inaccurate
649207420 XXX XXX 2 29372017 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "First Adjustment" date on the Final TIL TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 7/XX/2013 7/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - does not match the first adjustment date for the loan. Assignee liability. Cash-out -
First Adjustment Change Other
Date Inaccurate
649207420 XXX XXX 2 29372018 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" interest payment TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 7/XX/2013 7/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - on the Final TIL does not match the maximum interest payment that may apply Assignee liability. Cash-out -
Maximum In First 5 Years during the first five (5) years of the loan. Other
Interest Payment
Inaccurate
649207420 XXX XXX 2 29372019 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" principal TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 7/XX/2013 7/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - payment on the Final TIL does not match the maximum principal payment that may Assignee liability. Cash-out -
Maximum In First 5 Years apply during the first five (5) years of the loan. Other
Principal Payment
Inaccurate
649207420 XXX XXX 2 29372020 compliance 2 ARM Disclosure Timing Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2013 7/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
Test application due to missing information. Cash-out -
Other
649207420 XXX XXX 2 29372021 compliance 2 CHARM Booklet Disclosure Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2013 7/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
Timing Loan Application Date. Cash-out -
Other
649207420 XXX XXX 2 29372022 credit 3 Missing Document: Missing 7/XX/2013 CA Refinance - Primary No C C C C 7/XX/2023
Final 1003 Cash-out -
Other
649208980 XXX XXX 1 29372187 compliance 1 (Missing Doc) Incomplete Loan file does not contain any origination documentation. 8/XX/2012 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes 2023/XX/XX: Additional image
loan images/file package received.
649208980 XXX XXX 1 29372188 compliance 2 SAFE Act - LO Company not Unable to test LO company NMLS license due to missing information. Liability appears to be limited to originators/licensees. 8/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
licensed at time of
application
649208980 XXX XXX 1 29372189 compliance 2 SAFE Act - LO Company Secure and Fair Enforcement for Mortgage Licensing Act: Loan Originator Liability appears to be limited to originators/licensees. 8/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
NMLS does not match NMLS Organization NMLS information on loan documents does not match NMLS.
649208980 XXX XXX 1 29372190 compliance 2 SAFE Act - Individual LO Unable to test Individual Loan Originator license status due to missing 8/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
NMLS license status not information.
approved
649208980 XXX XXX 1 29372191 compliance 2 SAFE Act - Individual LO Unable to test Loan Originator license due to missing information. Liability appears to be limited to originators/licensees. 8/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
not licensed at time of
application
649208980 XXX XXX 1 29372192 compliance 2 SAFE Act - LO Company Unable to test LO company status due to missing information. 8/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
NMLS license status not
approved
649208980 XXX XXX 1 29372193 compliance 2 SAFE Act - Individual LO Secure and Fair Enforcement for Mortgage Licensing Act: Individual Loan Liability appears to be limited to originators/licensees. 8/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
NMLS does not match NMLS Originator NMLSR information on loan documents does not match NMLSR.
649208980 XXX XXX 1 29372194 compliance 2 RESPA (2010) - GFE RESPA (2010): GFE does not provide minimum ten (10) business day availability RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 8/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
Settlement charges Good for estimate of charges and terms for all other settlement charges. implementing regulation, Regulation X, for these type of violations.
Thru Date Less than 10
Days
649208980 XXX XXX 1 29372195 compliance 2 RESPA (2010) - Written Unable to determine if the borrower received a list of service providers due to RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 8/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
Service Provider List missing information. implementing regulation, Regulation X, for these type of violations.
Missing
649208980 XXX XXX 1 29372196 compliance 2 RESPA Disclosure - HUD RESPA Disclosure Rule: Creditor did not provide HUD Settlement Cost Booklet. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 8/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
Settlement Cost Booklet implementing regulation, Regulation X, for these type of violations.
Missing
649208980 XXX XXX 1 29372197 compliance 2 RESPA Servicing Unable to determine Servicing Disclosure Statement was provided due to missing RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 8/XX/2012 CA Purchase Primary No B B B B 7/XX/2023
Disclosure: Servicing information. implementing regulation, Regulation X, for these type of violations.
Disclosure Statement
Missing
649208980 XXX XXX 1 29372198 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from The TIL Itemization disclosed an underwriting fee of $XXX $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 8/XX/2012 8/XX/2013 CA Purchase Primary No B B B B 7/XX/2023
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. and a loan tie in fee of $XXX which are not reflected on the transactions. Unlimited as a defense to foreclosure. Assignee liability.
hud. The TIL The TIL Itemization did not disclose a
settlement fee of $XXX and a tax service fee of $XXX as
prepaid finance charges. Prepaid interest was disclosed at
$XXX but reflected at $XXX on the hud.
649208778 XXX XXX 2 29372323 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX 5/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 5/XX/2023 Yes Non QM 2023/XX/XX: BPO provided
most recent valuation Disaster End Date: XX/XX/XXXX Rate/Term reflects no damage.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649208778 XXX XXX 2 29372324 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 5/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three (3) business days prior to consummation. Rate/Term
Business Days Prior to (Type:Primary/04/XX/2018)
Consummation
649208778 XXX XXX 2 29372325 compliance 2 Self-Employed Tax Return Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or Based on Application Date, more recent tax returns are 5/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Recency - ATR personal tax returns provided are not the most recent. Application Date due/missing. Self Employed Tax Returns - The business or Rate/Term
04/XX/2018, Most Recent Tax Return End Date 12/XX/2016, Tax Return Due Date personal tax returns provided are not the most recent.
03/XX/2018. (XXX XXX/S-Corp) Application Date 04/XX/2018, Most Recent Tax Return End Date
12/XX/2016, Tax Return Due Date 03/XX/2018.
649208778 XXX XXX 2 29372326 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet Disclosure is missing. TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2018 5/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower. Rate/Term
649208778 XXX XXX 2 29372327 credit 3 Insufficient Coverage: HOI coverage provided is short $XXX. Please provide 5/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Hazard insurance coverage increased HOI coverage or RCE. Rate/Term
amount is insufficient.
649208778 XXX XXX 2 29372328 credit 3 REO Documents are Address: XXX, CA Insurance Verification, Statement, Tax Verification The following REO documents are required and missing: 5/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
missing. Statement, HOI and property tax verification. Rate/Term
649208778 XXX XXX 2 29372329 credit 3 REO Documents are Address: XXX, CA Insurance Verification, Statement, Tax Verification The following REO documents are required and missing: 5/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
missing. Statement, HOI and property tax verification. Rate/Term
649208778 XXX XXX 2 29372330 credit 3 REO Documents are Address: XXX, CA Insurance Verification, Statement, Tax Verification The following REO documents are required and missing: 5/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
missing. Statement, HOI and property tax verification. Rate/Term
649208778 XXX XXX 2 29372331 credit 3 REO Documents are Address: XXX, CA Insurance Verification, Tax Verification The following REO documents are required and missing: HOI 5/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
missing. and property tax verification. Rate/Term
649208778 XXX XXX 2 29372332 credit 3 REO Documents are Address: XXX, CA Insurance Verification, Tax Verification The following REO documents are required and missing: HOI 5/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
missing. and property tax verification. Rate/Term
649208778 XXX XXX 2 29372333 credit 3 REO Documents are Address: XXX, CA Insurance Verification, Tax Verification The following REO documents are required and missing: HOI 5/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
missing. and property tax verification. Rate/Term
649208778 XXX XXX 2 29372334 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM loan program disclosure located in file; however, it is TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2018 5/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Test borrower. not dated to determine that it was sent to borrower within 3 Rate/Term
business days of application date.
649208799 XXX XXX 1 29372388 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The Property is located in a FEMA disaster area. Provide a 9/XX/2016 CA Refinance - Investment No A A A A 7/XX/2023 5/XX/2023 Yes N/A 2023/XX/XX: BPO provided
most recent valuation Disaster End Date: XX/XX/XXXX post-disaster inspection verifying there were no damage. The Cash-out - reflecting no damage.
inspection is dated prior Disaster Name: XXX inspection must include exterior photos and the property Other
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX must be re-inspected on or after XX/XX/XXXX declared end
disaster. date.
649208799 XXX XXX 1 29372389 credit 3 Income Docs Missing: Borrower: XXX Third Party Verification Missing Third Party Verification 9/XX/2016 CA Refinance - Investment No C C C C 7/XX/2023 N/A 2023/XX/XX: Missing Third
Cash-out - Party Verification
Other
649208799 XXX XXX 1 29372390 compliance 2 Missing Document: Missing 1003 initial copy is missing in the file. 9/XX/2016 CA Refinance - Investment No B B B B 7/XX/2023 N/A 2023/XX/XX: Missing signed
Lender's Initial 1003 Cash-out - and dated initial
Other application.
649208799 XXX XXX 1 29372391 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Verification appraisal was delivered to borrower was not 9/XX/2016 CA Refinance - Investment No B B B B 7/XX/2023 N/A
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. provided. Cash-out -
Business Days Prior to (Type:Primary/07/XX/2016) Other
Consummation
649208799 XXX XXX 1 29372392 credit 3 Income documentation Missing third party verification. 9/XX/2016 CA Refinance - Investment No C C C C 7/XX/2023 N/A
requirements not met. Cash-out -
Other
649208799 XXX XXX 1 29372393 credit 3 REO Documents are Address: XXX, CA Insurance Verification, Tax Verification 9/XX/2016 CA Refinance - Investment No C C C C 7/XX/2023 N/A
missing. Cash-out -
Other
649207480 XXX XXX 1 29372554 credit 1 Missing Document: Rider - Missing signed 1-4 Family Rider. 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Signed document
1-4 Family not provided Cash-out - provided.
Other
649207480 XXX XXX 1 29372555 credit 1 Missing Document: Missing signed Security Instrument. 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Signed document
Security Instrument - Cash-out - provided.
Subject Lien not provided Other
649207480 XXX XXX 1 29372556 credit 3 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The Property is located in a FEMA disaster area. Provide a 12/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
most recent valuation Disaster End Date: XX/XX/XXXX post-disaster inspection verifying there were no damage. The Cash-out -
inspection is dated prior Disaster Name: XXX inspection must include exterior photos and the property Other
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX must be re-inspected on or after XX/XX/XXXX declared end
disaster. date.
649207480 XXX XXX 1 29372557 compliance 2 Missing Document: Missing Lender's Application 1003 is missing 12/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM 2023/XX/XX: Missing Initial
Lender's Initial 1003 Cash-out - signed/dated 1003.
Other
2023/XX/XX: Missing
Signed/dated Initial 1003.
2023/XX/XX: The file is still
missing a signed and dated
initial 1003.
649207480 XXX XXX 1 29372558 credit 1 Guideline Requirement: Calculated investor qualifying total debt ratio of 48.88023% exceeds Guideline Calculated the base income for the borrower from the 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Income documents
Investor qualifying total total debt ratio of 44.00000%. document available is lower than the Income qualified by the Cash-out - provided to support the
debt ratio discrepancy. Underwriter. Missing the Sch. C for 2017 to calculate the Other qualifying income.
income correctly.
649207480 XXX XXX 1 29372559 credit 1 Income Docs Missing: Borrower: XXX 1040 (2017), 1040 - Schedule C (2017), Balance Sheet, P&L Statement Borrower did not provide following document to calculate 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Income documents
Income - 1040 & Schedule C (2017), Transcript (2017), P&L Cash-out - provided to support the
2018, balance sheet 2018. Other qualifying income.
649207480 XXX XXX 1 29372560 compliance 1 QM Employment History - Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two Calculated the base income for the borrower from the 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Income documents
Current Employment years current employment. (XXX/12403757) document available is lower than the Income qualified by the Cash-out - provided to support the
Documentation lacks Date Underwriter. Documents were not provided to calculate Income Other qualifying income and
Info - 1040 & Schedule C (2017), Transcript (2017), P&L 2018, employment verification.
balance sheet 2018.
649207480 XXX XXX 1 29372561 compliance 3 Sole Proprietorship Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not Calculated the base income for the borrower from the 12/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM 2023/XX/XX: Agree with 2023/XX/XX: The tax returns
Income Documentation Test sufficient (Sole Proprietorship). (XXX XXX/Schedule C) document available is lower than the Income qualified by the Cash-out - error cite & that tax provided for 2016 and 2017
Underwriter. Documents were not provided to calculate Income Other returns are not are not signed at dated.
- 1040 & Schedule C (2017), Transcript (2017), P&L 2018, signed.
balance sheet 2018. 2023/XX/XX: Trailing docs did
not contain any docs to clear
this exception.
649207480 XXX XXX 1 29372562 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 12/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three (3) business days prior to consummation. Cash-out -
Business Days Prior to (Type:Primary/10/XX/2018) Other
Consummation
649207480 XXX XXX 1 29372563 compliance 1 ECOA Appraisal Disclosure ECOA - File does not evidence the consumer was provided with the right to receive Missing the initial disclosure or the initial loan estimate 12/XX/2018 12/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: LE provided.
- ECOA Status a copy of the Appraisal Disclosure. with this verbiage. Cash-out -
Other
649207480 XXX XXX 1 29372564 compliance 1 General Ability To Repay Ability-to-Repay (Dodd-Frank 2014): Unable to verify current Sole Proprietorship Calculated the base income for the borrower from the Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Income documents
Provision Employment - status using reasonably reliable third-party records. (XXX XXX/Schedule C) document available is lower than the Income qualified by the damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Cash-out - provided to support the
Schedule C Test Underwriter. Documents were not provided to calculate Income all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Other qualifying income and
- 1040 & Schedule C (2017), Transcript (2017), P&L 2018, to comply is not material). A private right of action may be brought before the end of the three- employment verification.
balance sheet 2018. year period beginning on the date of the occurrence of the violation. However, when a creditor,
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649207480 XXX XXX 1 29372565 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify Sole Proprietorship income Calculated the base income for the borrower from the Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Income documents
Provision Income and using reasonably reliable third-party records. (XXX XXX/Schedule C) document available is lower than the Income qualified by the damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Cash-out - provided to support the
Assets - Schedule C Underwriter. Documents were not provided to calculate Income all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Other qualifying income.
- 1040 & Schedule C (2017), Transcript (2017), P&L 2018, to comply is not material). A private right of action may be brought before the end of the three-
balance sheet 2018. year period beginning on the date of the occurrence of the violation. However, when a creditor,
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649207480 XXX XXX 1 29372566 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Calculated the base income for the borrower from the 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Income documents
Provision Investor guideline components, the loan is at ATR risk. document available is lower than the Income qualified by the Cash-out - provided to support the
Guidelines Underwriter. Documents were not provided to calculate Income Other qualifying income.
- 1040 & Schedule C (2017), Transcript (2017), P&L 2018,
balance sheet 2018.
649207480 XXX XXX 1 29372567 compliance 1 General ATR Provision Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Calculated the base income for the borrower from the 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Income documents
Investor and Non QM DTIs Lenders Guidelines and 1026.43(c)(5) of 48.88023% moderately exceeds the document available is lower than the Income qualified by the Cash-out - provided to support the
match and both moderately guideline maximum of 44.00%. (DTI Exception is eligible to be regraded with Underwriter. Documents were not provided to calculate Income Other qualifying income.
exceed Guidelines compensating factors.) - 1040 & Schedule C (2017), Transcript (2017), P&L 2018,
balance sheet 2018.
649207480 XXX XXX 1 29372569 compliance 3 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Originator Loan Designation of Safe Harbor QM does not match Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 12/XX/2018 CA Refinance - Primary No C C B B 7/XX/2023 Non QM 2023/XX/XX: Agree. 2023/XX/XX: EXCEPTION HISTORY
Match - QM QM does not match Due Diligence Loan Designation of Non QM. Due Diligence Loan Designation of ATR Fail due to missing firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - - Exception Detail was
the income documents. Other updated on 06/XX/2023 PRIOR
Exception Detail: Qualified
Mortgage (Dodd-Frank 2014):
Originator Loan Designation
of Safe Harbor QM does not
match Due Diligence Loan
Designation of ATR Fail.
2023/XX/XX: The tax returns
provided for 2016 and 2017
are not signed at dated.
2023/XX/XX: Trailing docs did
not contain any docs to clear
this exception.
649207480 XXX XXX 1 29372570 compliance 1 QM DTI Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and Calculated the base income for the borrower from the Although this issue is subject to a 3 year SOL for affirmative claims under TILA, AMC does not adjust 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Income documents
the images do not provide evidence loan is eligible for purchase, guarantee or document available is lower than the Income qualified by the grading taking into account TILA SOL for exceptions under ATR, given the potential for enhanced Cash-out - provided to support the
insurance by the appropriate agency. Underwriter. Documents were not provided to calculate Income damages when asserting an ability to repay defense in response to an action to collect a debt by Other qualifying income.
- 1040 & Schedule C (2017), Transcript (2017), P&L 2018, recoupment or set-off.
balance sheet 2018.
649207480 XXX XXX 1 29372571 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Creditor did not provide a copy of each valuation to RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 12/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
of Homeownership Organizations not provided to applicant within three (3) business days of applicant three (3) business days prior to consummation. implementing regulation, Regulation X, for these type of violations. Cash-out -
Counseling Organizations application. Provided date is 12/XX/2018 while Application date is Other
Not Provided Within 3 11/XX/2018
Business Days of
Application
649207480 XXX XXX 1 29372572 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure The post-closing closing disclosure dated 1/XX/19 reflects TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2018 12/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure Homeowners provided on 12/XX/2018 incorrectly disclosed whether Homeowners Insurance is escrows and the final closing disclosure dated 12/XX/18 Cash-out -
Insurance Included In included in escrow. (Final/12/XX/2018) reflects no escrows. Other
Escrow Test
649207480 XXX XXX 1 29372573 compliance 2 TILA-RESPA Integrated TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images Loan Estimate not provided TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2018 12/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure: application to evidence delivery to the Borrower(s). The earliest Closing Disclosure Cash-out -
date on or after provided in the loan file was used as the estimated baseline for Tolerance Other
10/XX/2015, no Loan Testing. Depending on the actual values on the initial Loan Estimate, a fee
Estimates in the Loan tolerance cure of up to $XXX may be required.
File
649207480 XXX XXX 1 29372574 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure The post-closing closing disclosure dated 1/XX/19 reflects TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2018 12/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure Property Taxes provided on 12/XX/2018 incorrectly disclosed whether property taxes are included escrows and the final closing disclosure dated 12/XX/18 Cash-out -
Included In Escrow in escrow. (Final/12/XX/2018) reflects no escrows. Other
649207480 XXX XXX 1 29372575 compliance 1 Right of Rescission Unable to conclusively determine date of consummation. Note date used as 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Signed, dated and
Timing - Note Date used transaction date for purposes of determining compliance with rescission timing Cash-out - notorized copy of the
as Transaction Date requirements Other security instrument was
provided.
649207480 XXX XXX 1 29372576 compliance 1 Income Method of Qualified Mortgage (Dodd-Frank 2014): The Method used to calculate the qualifying Calculated the base income for the borrower from the 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Income documents
Calculation monthly income is not supported by the earnings history/trend. (XXX XXX/Schedule document available is lower than the Income qualified by the Cash-out - provided to support the
C) Underwriter. Documents were not provided to calculate Income Other qualifying income.
- 1040 & Schedule C (2017), Transcript (2017), P&L 2018,
balance sheet 2018.
649207480 XXX XXX 1 29372577 compliance 1 Self Employed Financial Qualified Mortgage (Dodd-Frank 2014): Financial strength of self-employed Calculated the base income for the borrower from the 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Income documents
Strength business reflects annual earnings that significantly decline over the analysis document available is lower than the Income qualified by the Cash-out - provided to support the
period. (XXX XXX/Schedule C) Underwriter. Documents were not provided to calculate Income Other qualifying income.
- 1040 & Schedule C (2017), Transcript (2017), P&L 2018,
balance sheet 2018.
649207480 XXX XXX 1 29372578 compliance 1 Sole Proprietorship Qualified Mortgage (Dodd-Frank 2014): YTD P&L is dated before the quarter prior The file is still missing the signed and dated initial 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Sufficient income
Income Documentation - to creditor application date. YTD Date = 1/XX/2018 12:00:00 AM, Creditor application to verify timing of the P&L statement in the Cash-out - and employment documents
YTD P&L Application Date = 11/XX/2018 (Sole Proprietorship). (XXX XXX/Schedule C) file. Other provided.
649207358 XXX XXX 2 29372696 credit 3 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Post Disaster Inspection (PDI) document is missing. 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
most recent valuation Disaster End Date: XX/XX/XXXX
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207358 XXX XXX 2 29372697 credit 3 REO Documents are Insurance Verification, Statement, Tax Verification document 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
missing. missing for property address XXX, CA
649207358 XXX XXX 2 29372698 credit 3 REO Documents are Insurance Verification, Lease Agreement, Statement, Tax 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
missing. Verification document missing for property address XXX, AZ
649207358 XXX XXX 2 29372699 credit 3 REO Documents are Insurance Verification, Lease Agreement, Statement, Tax 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
missing. Verification document missing for property Address: XXX, NV
649207358 XXX XXX 2 29372700 credit 3 REO Documents are Insurance Verification, Lease Agreement, Statement, Tax 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
missing. Verification document missing for property Address: XXX, AZ:
649207358 XXX XXX 2 29372701 credit 3 REO Documents are Insurance Verification, Lease Agreement, Statement, Tax 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
missing. Verification document missing for property Address: XXX, AZ
649207358 XXX XXX 2 29372702 credit 3 Income Docs Missing: Borrower: XXX 1065 (2014), 1065 (2015), 1099-SSA (2014), 1099-SSA (2015), K-1 All income documentation is missing for all borrowers. 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A 2023/XX/XX: File is missing
(2014), K-1 (2015), VVOE - Employment Only, W-2 (2015), W-2 (2016) 2015/2014 signed/dated personal and business tax returns and all personal & business
K1's, year to date P&L's/Balance sheets, third party income documentation.
verification dated within 30 days prior to note date, all Condition remains.
income documentation for any additional income being used
and award letters. Unable to determine all borrowers' income
and business structure due to missing documentation.
649207358 XXX XXX 2 29372703 credit 3 Income Docs Missing: Borrower: XXX 1065 (2014), 1065 (2015), K-1 (2014), K-1 (2015), VVOE - Employment All income documentation is missing for all borrowers. 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A 2023/XX/XX: File is missing
Only 2015/2014 signed/dated personal and business tax returns and all personal & business
K1's, year to date P&L's/Balance sheets, third party income documentation.
verification dated within 30 days prior to note date, all Condition remains.
income documentation for any additional income being used
and award letters. Unable to determine all borrowers' income
and business structure due to missing documentation.
649207358 XXX XXX 2 29372704 credit 3 Income Docs Missing: Borrower: XXX 1065 (2014), 1065 (2015), K-1 (2014), K-1 (2015), VVOE - Employment All income documentation is missing for all borrowers. 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A 2023/XX/XX: File is missing
Only, W-2 (2014), W-2 (2015) 2015/2014 signed/dated personal and business tax returns and all personal & business
K1's, year to date P&L's/Balance sheets, third party income documentation.
verification dated within 30 days prior to note date, all Condition remains.
income documentation for any additional income being used
and award letters. Unable to determine all borrowers' income
and business structure due to missing documentation.
649207358 XXX XXX 2 29372705 credit 3 Income documentation All income documentation is missing for all borrowers. 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A 2023/XX/XX: File is missing
requirements not met. 2015/2014 signed/dated personal and business tax returns and all personal & business
K1's, year to date P&L's/Balance sheets, third party income documentation.
verification dated within 30 days prior to note date, all Condition remains.
income documentation for any additional income being used
and award letters. Unable to determine all borrowers' income
and business structure due to missing documentation.
649207358 XXX XXX 2 29372706 credit 3 REO Documents are Address: XXX, CA Insurance Verification, Lease Agreement, Tax Verification 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A 2023/XX/XX: EXCEPTION HISTORY
missing. - Exception Explanation was
updated on 09/XX/2023 PRIOR
Exception Explanation:
Insurance Verification, Lease
Agreement, Statement, Tax
Verification
649207358 XXX XXX 2 29372707 credit 3 REO Documents are Address: XXX, NV Insurance Verification, Lease Agreement, Statement, Tax 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
missing. Verification
649207358 XXX XXX 2 29372708 credit 3 REO Documents are Address: XXX, AZ Insurance Verification, Lease Agreement, Statement, Tax 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
missing. Verification
649207358 XXX XXX 2 29372709 credit 3 REO Documents are Address: XXX, AZ Insurance Verification, Lease Agreement, Statement, Tax 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
missing. Verification
649207358 XXX XXX 2 29372710 credit 3 REO Documents are Address: XXX, AZ Insurance Verification, Lease Agreement, Statement, Tax 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
missing. Verification
649207358 XXX XXX 2 29372711 credit 3 REO Documents are Address: XXX, CA Insurance Verification, Statement, Tax Verification 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
missing.
649207358 XXX XXX 2 29372712 credit 3 REO Documents are Address: XXX, CA Insurance Verification, Statement, Tax Verification 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
missing.
649207358 XXX XXX 2 29372713 credit 3 REO Documents are Address: XXX, NV Insurance Verification, Lease Agreement, Statement, Tax 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
missing. Verification
649207358 XXX XXX 2 29372714 credit 3 REO Documents are Address: XXX, CA Insurance Verification 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
missing.
649207358 XXX XXX 2 29372715 credit 3 REO Documents are Address: XXX, CA Insurance Verification, Statement, Tax Verification 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
missing.
649207358 XXX XXX 2 29372716 credit 3 Guideline Requirement: Calculated PITIA months reserves of 0.00 is less than Guideline PITIA months Borrower has insufficient assets to cover funds to close and 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
PITIA reserves months reserves of 48.00. extended reserves required.
discrepancy.
649207358 XXX XXX 2 29372717 credit 3 Asset documentation File is missing sufficient asset documentation to cover 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
requirements not met. funds to close and required extensive reserves due to
properties owned.
649207358 XXX XXX 2 29372718 credit 3 Aged document: Asset Financial Institution: XXX // Account Type: Individual Retirement Account (IRA) / Both accounts exceeds the 90 age of document reflected in 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
Account date is more than Account Number: XXX, Financial Institution: XXX // Account Type: Stocks / Account the lender guidelines.
90 days prior to Closing. Number: XXX
649207358 XXX XXX 2 29372719 credit 3 Available for Closing is Documented qualifying Assets for Closing of $XXX is less than Cash From Borrower Borrower's are missing sufficient asset documentation to 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
insufficient to cover $XXX. cover funds to close.
Cash From Borrower.
649207358 XXX XXX 2 29372720 credit 3 AUS/Guideline Findings: File is missing sufficient assets, all income documents for 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
All conditions were not all borrowers, REO supporting documentation.
met
649208804 XXX XXX 2 29372735 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Subject property was appraised on XX/XX/XXXX prior to the 6/XX/2020 CA Purchase Primary No A A A A 7/XX/2023 5/XX/2023 Yes Safe Harbor 2023/XX/XX: BPO provided
most recent valuation Disaster End Date: XX/XX/XXXX FEMA disaster ( XXX) dated XX/XX/XXXX through XX/XX/XXXX. QM reflecting no damage.
inspection is dated prior Disaster Name: XXX File is missing a property inspection dated after the
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX disaster, or the lender's Rep and Warranty attestation along
disaster. with visible confirmation that the subject property was not
damaged
649208804 XXX XXX 2 29372736 property 1 Loan is to be 6/XX/2020 CA Purchase Primary No A A A A 7/XX/2023 5/XX/2023 Yes Safe Harbor 2023/XX/XX: Client not
securitized. The only QM securitizing loan.
valuation provided was a
Drive by. It is
interpreted that this
Drive By was used in
lieu of URAR and that
this file is missing the
secondary valuation (GSE
COVID19)
649208804 XXX XXX 2 29372737 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is Date valuation provided to applicant is prior to the date 6/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Appraisal Provided Prior prior to the date when valuation was performed. Unable to determine compliance when valuation was performed. Unable to determine compliance QM
to Date Performed with appraisal timing requirements. (Type:Primary/05/XX/2020) with appraisal timing requirements
649208804 XXX XXX 2 29372738 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure Final Closing Disclosure provided on 06/XX/2020, page (5) TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 6/XX/2020 6/XX/2021 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Disclosure Contact provided on 06/XX/2020 did not disclose the required Lender Contact Information missing Lender contact name. QM
Information - Lender (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/06/XX/2020)
649208804 XXX XXX 2 29372739 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Loan Terms: Final Closing Disclosure provided on 06/XX/2020 TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. Assignee liability. 6/XX/2020 6/XX/2021 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Disclosure Payment on 06/XX/2020 with an increasing payment disclosed the frequency of adjustments with an increasing payment disclosed the frequency of QM
Adjusts Every that does not match the actual adjustment period for the loan. (Final/06/XX/2020) adjustments that does not match the actual adjustment period
for the loan
649208804 XXX XXX 2 29372740 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure not provided to Borrower(s) at least TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 6/XX/2020 6/XX/2021 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Disclosure Timing without at least three (3) business days prior to closing. (Initial/06/XX/2020) three (3) business days prior to closing QM
Waiver
649208804 XXX XXX 2 29372742 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Consumer Handbook on Adjustable Rate Mortgages, CHARM TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2020 6/XX/2021 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Status CHARM Booklet, not provided to the borrower. Booklet, was not provided to the borrower. QM
649207721 XXX XXX 2 29372765 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Verification appraisal was delivered to borrower was not 10/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Temporary
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. provided. Rate/Term SHQM
Business Days Prior to (Type:Primary/09/XX/2017) (GSE/Agency
Consummation Eligible)
649207721 XXX XXX 2 29372766 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 10/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Temporary
Account Statement Missing implementing regulation, Regulation X, for these type of violations. Rate/Term SHQM
(GSE/Agency
Eligible)
649207721 XXX XXX 2 29372767 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement 10/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 Temporary
is missing. Rate/Term SHQM
(GSE/Agency
Eligible)
649207721 XXX XXX 2 29372768 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Most Recent Valuation Inspection Date: XX/XX/XXXX 10/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 5/XX/2023 Yes Temporary 2023/XX/XX: BPO provided
most recent valuation Disaster End Date: XX/XX/XXXX Disaster End Date: XX/XX/XXXX Rate/Term SHQM reflecting no damage.
inspection is dated prior Disaster Name: XXX Disaster Name: XXX (GSE/Agency
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX Disaster Declaration Date: XX/XX/XXXX Eligible)
disaster.
649207721 XXX XXX 2 29372769 credit 3 File does not contain Valuation Type: Appraisal / Valuation Report Date: 09/XX/2017 Documentation certifying the subject property condo is 10/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 Temporary
documentation from warrantable is missing from the file. Rate/Term SHQM
lender/seller confirming (GSE/Agency
the condo is warrantable. Eligible)
649207721 XXX XXX 2 29372770 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Finance charge disclosed is $XXX. Calculated finance charge TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 10/XX/2017 10/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 Temporary
Disclosure Finance Charge provided on 10/XX/2017 disclosed an inaccurate Finance Charge on page 5 that does is $XXX. Variance is $XXX. Unable to determine the cause of Assignee liability. Rate/Term SHQM
not match the actual Finance Charge for the loan (fee amounts included in Finance the under disclosure due to missing the final itemization of (GSE/Agency
Charge calculation are based on Closing Disclosure dated 11/XX/2017). finance charges. TILA Material Disclosure Cure - Provide the Eligible)
(Final/10/XX/2017) following: Letter of Explanation, Proof of Delivery, Refund
check for underdisclosed amount, Corrected CD, and re-open
rescission if applicable.
649207721 XXX XXX 2 29372771 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 10/XX/2017 10/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Temporary
Disclosure Other Includes provided on 10/XX/2017 disclosed whether Homeowners insurance is included in Rate/Term SHQM
Insurance Costs escrow in incorrect section. Creditor disclosed insurance to consumer in "Other" (GSE/Agency
section where regulation requires disclosure under "Homeowner's Insurance" Eligible)
section of Projected Payments table. Disclosure requirement met, non-material
exception for incorrect format/placement. (Final/10/XX/2017)
649207325 XXX XXX 2 29372848 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Disclosed Finance Charges are $XXX. Calculated Finance TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 6/XX/2016 6/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Temporary
Disclosure Finance Charge provided on 06/XX/2016 disclosed an inaccurate Finance Charge on page 5 that does Charges are $XXX. There is a variance of -$XXX. Assignee liability. Limited Cash- SHQM
not match the actual Finance Charge for the loan (fee amounts included in Finance out GSE (GSE/Agency
Charge calculation are based on Closing Disclosure dated 06/XX/2016). Eligible)
(Final/XX/20/2016)
649207325 XXX XXX 2 29372850 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX 6/XX/2016 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Temporary 2023/XX/XX: BPO provided
most recent valuation Disaster End Date: XX/XX/XXXX Limited Cash- SHQM reflects no damage.
inspection is dated prior Disaster Name: XXX out GSE (GSE/Agency
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX Eligible)
disaster.
649207325 XXX XXX 2 29372851 credit 3 Missing Document: 6/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 Temporary
Occupancy Certificate not Limited Cash- SHQM
provided out GSE (GSE/Agency
Eligible)
649207912 XXX XXX 1 29373024 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX FEMA Disaster Issue: The most recent valuation inspection is 7/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 5/XX/2023 Yes Non QM 2023/XX/XX: BPO dated 5/XX/23
most recent valuation Disaster End Date: XX/XX/XXXX dated prior to the most recent FEMA disaster. Cash-out - showing no damage to property
inspection is dated prior Disaster Name: XXX Other has been received.
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207912 XXX XXX 1 29373025 property 3 Missing Document: Valuation Type: Appraisal / Valuation Report Date: 06/XX/2017 Appraisal was made subject to and 1004D is missing from loan 7/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Appraisal was made file Cash-out -
"subject to" and Form Other
1004D/442 was not
provided.
649207912 XXX XXX 1 29373026 credit 3 Aged document: Credit Credit Report: Original // Borrower: XXX, Credit Report: Original // Borrower: Latest credit report in the document file is dated 7/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Report is more than 90 XXX 04/XX/2017. Loan consummation date is 07/XX/2017. Cash-out -
days prior to the note Other
date.
649207912 XXX XXX 1 29373027 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Finance charge disclosed on Final Closing Disclosure as TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 7/XX/2017 7/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure Finance Charge provided on 07/XX/2017 disclosed an inaccurate Finance Charge on page 5 that does $XXX. Calculated Finance Charge is $XXX - a difference of Assignee liability. Cash-out -
not match the actual Finance Charge for the loan (fee amounts included in Finance $XXX. Other
Charge calculation are based on Closing Disclosure dated 07/XX/2017).
(Final/07/XX/2017)
649207912 XXX XXX 1 29373028 compliance 2 Missing Document: Missing Initial 1003 not executed by lender or loan officer. 7/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM 2023/XX/XX: Missing signed
Lender's Initial 1003 Cash-out - and dated initial
Other application.
649207734 XXX XXX 2 29373214 credit 3 Insufficient Coverage: HOI coverage is insufficient by $XXX Provide updated policy 8/XX/2019 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
Hazard insurance coverage reflecting minimum coverage of $XXX OR provide copy of QM
amount is insufficient. insurer's replacement cost estimate supporting current
coverage amount.
649207734 XXX XXX 2 29373215 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, The file was missing evidence the CHARM Booklet was provided TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2019 8/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor 2023/XX/XX: Missing CHARM
Status CHARM Booklet, not provided to the borrower. to borrower within 3 days of initial application. QM Booklet provided within 3
days of application.
649207734 XXX XXX 2 29373216 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. Initial escrow account statement was not provided to the RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 8/XX/2019 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Account Statement Missing borrower in loan file implementing regulation, Regulation X, for these type of violations. QM
649207734 XXX XXX 2 29373217 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 8/XX/2019 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three (3) business days prior to consummation. QM
Business Days Prior to (Type:Primary/08/XX/2019)
Consummation
649207734 XXX XXX 2 29373219 credit 3 Guideline Requirement: Calculated combined loan to value percentage of 89.87879% exceeds Guideline Per lender guides for the 2nd mortgage: Up to 89.90% TLTV is 8/XX/2019 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
Combined loan to value combined loan to value percentage of 80.00000%. allowed with a concurrent XXX 2nd with a minimum 730 credit QM
discrepancy. score (or 740 if required by XXX 1st Mortgage guidelines).
The 2nd mortgage was provided by XXX, not XXX as required
for the increased LTV.
649207209 XXX XXX 2 29373313 credit 3 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Property was not in FEMA disaster at the time of closing. 7/XX/2019 CA Refinance - Primary No C C C C 7/XX/2023 Safe Harbor
most recent valuation Disaster End Date: XX/XX/XXXX Disaster end date XX/XX/XXXX. Cash-out - QM
inspection is dated prior Disaster Name: XXX Other
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207209 XXX XXX 2 29373314 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure Final Closing Disclosure provided on 07/XX/2019 did not TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 7/XX/2019 7/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor
Disclosure Contact provided on 07/XX/2019 did not disclose the required Lender Contact Information disclose the required Lender Contact Information (Lender Cash-out - QM
Information - Lender (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/07/XX/2019) Name, Lender NMLS ID, Contact Name, Contact NMLS ID). Other
649207209 XXX XXX 2 29373315 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2019 7/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor
Test borrower within three (3) days of application. Cash-out - QM
Other
649207209 XXX XXX 2 29373316 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2019 7/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor
Timing CHARM Booklet, not provided to the borrower within three (3) days of application. Cash-out - QM
Other
649207660 XXX XXX 1 29373395 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet Disclosure is missing TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2017 9/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Non QM 2023/XX/XX: Missing CHARM
Status CHARM Booklet, not provided to the borrower. Booklet provided within 3
days of application.
649207660 XXX XXX 1 29373397 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Initial Closing Disclosure in file dated 9/XX/2017 is not TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2017 9/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Disclosure Timing without at least three (3) business days prior to closing. (Initial/09/XX/2017) signed or dated by borrowers. Applying 3 day mailbox rule,
Waiver CD received 9/XX/2017, which is less than 3 business days
prior to closing.
649207660 XXX XXX 1 29373398 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure Closing Disclosure provided on 09/XX/2017 on page 4 Will Not TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2017 9/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Disclosure Will Not Have provided on 09/XX/2017 incorrectly disclosed whether the loan will have an escrow Have Escrow - Reason not disclosed.
Escrow - Reason account. (Final/09/XX/2017)
649207660 XXX XXX 1 29373399 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement E-sign Consent Agreement is missing. 9/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 Non QM
is missing.
649207660 XXX XXX 1 29373400 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender Per the guidelines provided, 10/1 ARM loans are qualified at 9/XX/2017 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: After further
Provision Investor does not match the ATR payment calculation methods under 1026.43(c)(5). the Note rate, which does not match the ATR payment review, exception has been
Qualification Method not calculation methods under 1026.43(c)(5). cleared.
Matching ATR
649207660 XXX XXX 1 29373401 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Document provided to borrowers did not contain the list of RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 9/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Non QM
of Homeownership Homeownership Counseling Organizations to borrower. 10 approved agencies to determine it was dated within 10 implementing regulation, Regulation X, for these type of violations.
Counseling Organizations days of application date.
Missing
649207660 XXX XXX 1 29373402 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM loan program disclosure provided is not dated to TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2017 9/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Test borrower. determine that it was provided to borrowers within 3
business days of application.
649207660 XXX XXX 1 29373403 credit 1 Guideline Requirement: Calculated investor qualifying total debt ratio of 47.45478% exceeds Guideline Lender utilized $XXX monthly in bonus income; however, loan 9/XX/2017 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Bonus income
Investor qualifying total total debt ratio of 43.00000%. file is missing the required WVOE or prior end of year provided on W-2s. Cleared.
debt ratio discrepancy. paystubs to verify the bonus amounts for 2015 and 2016.
Removing the bonus income, DTI exceeds the guideline maximum
of 43%.
649207660 XXX XXX 1 29373404 compliance 1 Check Loan Designation Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Waterfall exception due to DTI exceeding the guideline Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 9/XX/2017 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Bonus income
Match - ATR Risk not match Due Diligence Loan Designation of ATR Risk. maximum of 43%. firm performing the loan level due diligence and to have the TPR firm confirm said designation. listed on W-2s. Cleared.
649207660 XXX XXX 1 29373405 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Waterfall exception due to DTI exceeding the guideline 9/XX/2017 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Bonus income
Provision Investor guideline components, the loan is at ATR risk. maximum of 43%. listed on W-2s. Cleared.
Guidelines
649207660 XXX XXX 1 29373406 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lender utilized $XXX monthly in bonus income; however, loan 9/XX/2017 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Bonuses provided
Provision Non QM DTI 1026.43(c)(5) of 48.67% significantly exceeds the guideline maximum of 43.00%. file is missing the required WVOE or prior end of year on W-2s. Cleared.
significantly exceeds (DTI Exception requires compelling compensating factors to consider regrading to paystubs to verify the bonus amounts for 2015 and 2016.
Guidelines EV2-B.) Removing the bonus income, DTI exceeds the guideline maximum
of 43%.
649208008 XXX XXX 1 29373422 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The property is located in FEMA Disaster Area. Provide a 10/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 5/XX/2023 Yes Safe Harbor 2023/XX/XX: BPO dated 5/XX/23
most recent valuation Disaster End Date: XX/XX/XXXX post-disaster inspection verifying there was no damage from QM showing no damage to property
inspection is dated prior Disaster Name: XXX XXX. The inspection must -include/exterior photos and the has been received.
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX property must be re-inspected on or after XX/XX/XXXX
disaster. declared end date.
649208008 XXX XXX 1 29373423 credit 3 Insufficient Coverage: HOI coverage is insufficient by $XXX. Coverage must be at 10/XX/2019 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
Hazard insurance coverage least the lessor of the Cost new from the appraisal or the QM
amount is insufficient. loan amount. Provide verification of policy with sufficient
coverage OR provide copy of insurer's replacement cost
estimate supporting current coverage amount.
649208008 XXX XXX 1 29373424 credit 2 1003 Error: Birth Date Borrower: XXX Birth date is not provided for the Borrower "XXX" 10/XX/2019 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
was not provided QM
649208008 XXX XXX 1 29373425 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Earlier receipt was not provided. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 10/XX/2019 10/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Disclosure Timing without at least three (3) business days prior to closing. (Initial/10/XX/2019) QM
Waiver
649207792 XXX XXX 2 29373470 property 3 Appraiser's license or Valuation Type: Appraisal / Valuation Report Date: 07/XX/2015 Appraiser's license or certification was not active at the 8/XX/2015 CA Refinance - Investment No C C C C 7/XX/2023 N/A
certification was not time of the appraisal. Rate/Term
active at the time of the
appraisal.
649207792 XXX XXX 2 29373471 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The property is located in FEMA Disaster Area. Provide a 8/XX/2015 CA Refinance - Investment No A A A A 7/XX/2023 5/XX/2023 Yes N/A 2023/XX/XX: BPO dated 5/XX/23
most recent valuation Disaster End Date: XX/XX/XXXX post-disaster inspection verifying there was no damage from Rate/Term showing no damage to property
inspection is dated prior Disaster Name: XXX disaster. The inspection must include exterior photos and has been received.
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX the property must be re-inspected on or after XX/XX/XXXX
disaster. declared end date.
649207792 XXX XXX 2 29373472 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Verification appraisal was delivered to borrower was not 8/XX/2015 CA Refinance - Investment No B B B B 7/XX/2023 N/A
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. provided. Rate/Term
Business Days Prior to (Type:Primary/07/XX/2015)
Consummation
649207792 XXX XXX 2 29373473 compliance 2 ECOA Appraisal - Right to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to The Right to Receive Copy of Appraisal Disclosure was not There is generally no Assignee Liability. 8/XX/2015 CA Refinance - Investment No B B B B 7/XX/2023 N/A
Receive Copy of Appraisal Receive a Copy" appraisal disclosure to applicant within three (3) business days provided to borrower within 3 days of initial application. Rate/Term
Disclosure Not Provided of application or determination of first lien status.
Timely
649207792 XXX XXX 2 29373474 credit 3 REO Documents are Address: XXX, CA Statement Mortgage statement missing for XXX, CA. 8/XX/2015 CA Refinance - Investment No C C C C 7/XX/2023 N/A
missing. Rate/Term
649208398 XXX XXX 2 29373561 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of List of Homeownership Counseling Organizations is missing in RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 6/XX/2019 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
of Homeownership Homeownership Counseling Organizations to borrower. file implementing regulation, Regulation X, for these type of violations. QM
Counseling Organizations
Missing
649208398 XXX XXX 2 29373562 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The property is located in FEMA Disaster area. Provide a 6/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 5/XX/2023 Yes Safe Harbor 2023/XX/XX: BPO provided
most recent valuation Disaster End Date: XX/XX/XXXX post-disaster inspection verifying there was no damage. The QM reflecting no damage.
inspection is dated prior Disaster Name: XXX inspection must include exterior photos and the property
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX must be re-inspected on or after XX/XX/XXXX declared end
disaster. date.
649208398 XXX XXX 2 29373563 property 1 The loan is to be Valuation Type: Appraisal / Valuation Report Date: 06/XX/2019 The file is missing a copy of the secondary valuation 6/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 5/XX/2023 Yes Safe Harbor 2023/XX/XX: Client not
securitized and the required for securitization purposes. QM securitizing loan.
appraisal certification
was not included in the
provided valuation.
Securitization valuations
are required to be
FIRREA/USPAP compliant.
649207071 XXX XXX 2 29373627 compliance 1 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure not provided to Borrower(s) at least TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2019 4/XX/2020 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Initial CD
Disclosure Timing without at least three (3) business days prior to closing. (Final/04/XX/2019) three (3) business days prior to closing. provided.
Waiver
649207071 XXX XXX 2 29373629 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax No valid change of circumstance or cure provided for the Tax TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2019 4/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Tolerance Violation Service Fee (Life Of Loan). Fee Amount of $XXX exceeds tolerance of $XXX. Service Fee exceeding the allowed tolerance.
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (7580)
Provided
649207071 XXX XXX 2 29373630 credit 1 No evidence of fraud Credit Report: Original // Borrower: XXX, Credit Report: Original // Borrower: Fraud report is missing for both borrowers. 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Fraud report
report in file XXX provided.
649207071 XXX XXX 2 29373632 credit 1 Missing Document: Verification of Non-US Citizen status not provided for 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Permanent
Verification of Non-US borrower. Resident Alien Card provided.
Citizen Status not Cleared.
provided
649207071 XXX XXX 2 29373633 credit 1 FEMA Disaster Issue: Disaster Name: XXX 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received BPO.
Property is located in a Disaster Declaration Date: XX/XX/XXXX Condition cleared.
FEMA Disaster area and Disaster End Date: XX/XX/XXXX
has not been inspected.
649207071 XXX XXX 2 29373634 credit 1 Missing Document: Source Recent bank statement from the gift funds donor to support 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Evidence 2023/XX/XX: Gift was
of Funds/Deposit not ability to give gift funds was not provided. of gift funds from sufficiently documented per
provided donor in file via guidelines. Exception
cashiers checks that cleared.
reflects donor XXX as
the remitter.
Documentation for
evidence of donors
bank statement/ability
to give gift funds is
not a requirement.
649207071 XXX XXX 2 29373635 credit 1 Asset documentation Recent bank statement from the gift funds donor to support 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Check from donor
requirements not met. ability to give gift funds was not provided. provided to Escrow provided.
649207071 XXX XXX 2 29373636 compliance 1 Income/Asset Guideline Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to Recent bank statement from the gift funds donor to support 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Check from donor
Deficiency - ATR Impact income and/or asset doc requirements which could result in a risk to the ability to give gift funds was not provided. provided to Escrow provided.
borrower's ability to repay. (Exception is eligible to be regraded with
compensating factors.)
649207071 XXX XXX 2 29373637 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Recent bank statement from the gift funds donor to support 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Check from donor
Provision Investor guideline components, the loan is at ATR risk. ability to give gift funds was not provided. provided to Escrow provided.
Guidelines
649207071 XXX XXX 2 29373638 credit 1 Guideline Requirement: Appraisal number of units of does not match Guideline number of units of 1. A full appraisal report is required and is missing. 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Appraisal
Number of units provided. Cleared.
discrepancy.
649207071 XXX XXX 2 29373639 credit 3 Guideline Requirement: Appraisal property type of Single Family Detached does not match Guideline Appraisal reflects the subject as Single Family when Final 4/XX/2019 CA Purchase Primary No C C C C 7/XX/2023 Non QM 2023/XX/XX: The 1004 reflects
Property type property type of PUD. Title reflects it was a PUD and the Security Instrument the subject property as
discrepancy. contains a PUD Rider. Single Family Detached,
However the Security
Instrument indicated a
Planned Unit Development
accompanied by a Planned Unit
Development Rider.
2023/XX/XX: EXCEPTION HISTORY
- Exception Explanation was
updated on 08/XX/2023 PRIOR
Exception Explanation:
Appraisal property type of
does not match Guideline
property type of PUD.
649207071 XXX XXX 2 29373640 compliance 1 Due to lack of appraised A full appraisal report is required and is missing. 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Appraisal
value, compliance tests provided. Cleared.
requiring an LTV were run
off an assumed value of a
contract sales price or
original loan amount,
whichever applies.
649207071 XXX XXX 2 29373641 credit 1 AUS/Guideline Findings: A full appraisal report is required and is missing. 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Appraisal
All conditions were not provided. Cleared.
met
649207071 XXX XXX 2 29373642 credit 1 Missing Document: File is missing the borrower's most recent 12 month rental 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: 13 2023/XX/XX: Trailing
Verification of Rent history as required by lender guides. cancelled checks in documents reviewed unable to
(VOR) / Verification of file from borrowers clear.
Mortgage (VOM) not XXX account to cover
provided timely satisfactory 2023/XX/XX: 13 months
rent payment history cancelled checks provided in
covering March 2018 - order to meet rental history
Mach 2019. > 12 months documentation.
rent history
documented as
required.
649207071 XXX XXX 2 29373643 credit 1 Income Docs Missing: Borrower: XXX Course Transcripts, Diploma File is missing the required school documentation for the 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: 2023/XX/XX: Please provide
co-borrower. Transcripts are in College Diploma for XXX.
file for XXX covering
Summer and Fall 2016 2023/XX/XX: Trailing
as well as transcript documents reviewed unable to
in file for XXX that clear.
covers 1/XX/2017 when
program entered and 2023/XX/XX: Course
11/XX/2017 completion Transcripts were in file from
date when XXX was XXX and XXX. Transcripts
earned. from XXX reflect degree in
XXX. Exception cleared.
649207071 XXX XXX 2 29373644 credit 3 Missing Lender's Initial File is missing a fully executed initial application. 4/XX/2019 CA Purchase Primary No C C C C 7/XX/2023 Non QM
1003/Application.
649207071 XXX XXX 2 29373645 compliance 3 QM Employment History Qualified Mortgage (Dodd-Frank 2014): Employment history requirement not met. File is missing Diploma for Sean Dupuis. 4/XX/2019 CA Purchase Primary No C C C C 7/XX/2023 Non QM 2023/XX/XX: 2023/XX/XX: Trailing
(XXX/12402430) Transcripts are in documents reviewed unable to
file for XXX covering clear.
Summer and Fall 2016
as well as transcript 2023/XX/XX: Unable to clear
in file for XXX that due to discrepancy in
covers 1/XX/2017 when property type and missing
program entered and explanation for gap from
11/XX/2017 completion 11/XX/2017 to 3/XX/2018.
date when XXX was
earned.
649207071 XXX XXX 2 29373646 compliance 1 QM Employment History - Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two Required explanation for the co-borrower's gap greater than 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Provided Post
Current and/or Previous years employment history for current and/or prior employment. (XXX/12402429) 30 days from 11/XX/2017 to 3/XX/2018 was not found as Close. Clear
Employment Documentation required per Appendix Q.
lacks Date Info
649207071 XXX XXX 2 29373647 compliance 3 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor File is missing Diploma for CoBorrower. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 4/XX/2019 CA Purchase Primary No C C B B 7/XX/2023 Non QM 2023/XX/XX: 2023/XX/XX: Trailing
Match - QM QM does not match Due Diligence Loan Designation of Non QM. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Transcripts are in documents reviewed unable to
file for XXX covering clear.
Summer and Fall 2016
as well as transcript 2023/XX/XX: Unable to clear
in file for XXX that due to discrepancy in
covers 1/XX/2017 when property type and missing
program entered and explanation for gap from
11/XX/2017 completion 11/XX/2017 to 3/XX/2018.
date when XXX was
earned. 2023/XX/XX: EXCEPTION HISTORY
- Exception Detail was
updated on 08/XX/2023 PRIOR
Exception Detail: Qualified
Mortgage (Dodd-Frank 2014):
Originator Loan Designation
of Safe Harbor QM does not
match Due Diligence Loan
Designation of ATR Risk.
649207071 XXX XXX 2 29373648 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Earlier receipt of disclosure not provided. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2019 4/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Disclosure Timing without at least three (3) business days prior to closing. (Initial/04/XX/2019)
Waiver
649207957 XXX XXX 2 29373671 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Post Disaster Inspection Document Needed 9/XX/2017 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received BPO
most recent valuation Disaster End Date: XX/XX/XXXX confirming no damage.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207957 XXX XXX 2 29373672 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement E- Sign Consent Document Missing 9/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 Non QM
is missing.
649207957 XXX XXX 2 29373673 compliance 2 General Ability To Repay Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender The guidelines require 7/1 ARMS to be qualified using the 9/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Provision Investor does not match the ATR payment calculation methods under 1026.43(c)(5). Note rate, causing the loan to waterfall through the QM
Qualification Method not Testing.
Matching ATR
649208740 XXX XXX 2 29373692 compliance 2 Missing Document: Missing 12/XX/2014 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor 2023/XX/XX: Missing signed
Lender's Initial 1003 QM and dated initial
application.
649208740 XXX XXX 2 29373693 compliance 2 RESPA Disclosure - HUD RESPA Disclosure Rule: Creditor did not provide HUD Settlement Cost Booklet. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 12/XX/2014 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Settlement Cost Booklet implementing regulation, Regulation X, for these type of violations. QM
Missing
649208740 XXX XXX 2 29373694 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2014 12/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Status CHARM Booklet, not provided to the borrower. QM
649208740 XXX XXX 2 29373695 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each File is missing evidence the borrower received the appraisal 12/XX/2014 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. at least 3 business days prior to the closing date QM
Business Days Prior to (Type:Primary/12/XX/2014)
Consummation
649208740 XXX XXX 2 29373696 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum Ever" date on the Final TIL does TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 12/XX/2014 12/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Payment Summary Table - not match the earliest date on which the maximum rate may apply. Assignee liability. QM
Maximum Ever Change Date
Inaccurate
649208740 XXX XXX 2 29373697 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX 12/XX/2014 CA Purchase Primary No A A A A 7/XX/2023 5/XX/2023 Yes Safe Harbor 2023/XX/XX: BPO provided
most recent valuation Disaster End Date: XX/XX/XXXX QM reflects no damage.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649208740 XXX XXX 2 29373698 compliance 2 (Doc Error) GFE Error: GFE Date: 12/XX/2014 Changed Circumstance not provided for GFE dated 12/XX/2014 12/XX/2014 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Changed Circumstance not from GFE dated 11/XX/2014 QM
provided.
649207973 XXX XXX 1 29373740 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Verification appraisal was delivered to borrower within 3 12/XX/2016 WA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. days of closing was not provided. Cash-out - QM
Business Days Prior to (Type:Primary/10/XX/2016) Other
Consummation
649207973 XXX XXX 1 29373741 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of The file was missing a copy of the Homeownership Counseling RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 12/XX/2016 WA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor
of Homeownership Homeownership Counseling Organizations to borrower. disclosure or proof of the borrower's receipt within 3 days implementing regulation, Regulation X, for these type of violations. Cash-out - QM
Counseling Organizations of originator application date. Other
Missing
649207973 XXX XXX 1 29373742 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Finance charge is under disclosed by $XXX. Unable to TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 12/XX/2016 12/XX/2019 WA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor 2023/XX/XX: EXCEPTION HISTORY
Disclosure Finance Charge provided on 12/XX/2016 disclosed an inaccurate Finance Charge on page 5 that does determine the cause of the under disclosure due to missing Assignee liability. Cash-out - QM - Exception Detail was
not match the actual Finance Charge for the loan. The disclosed Finance Charge itemization of amount financed. Other updated on 08/XX/2023 PRIOR
in the amount of $XXX is under disclosed by $XXX compared to the calculated Exception Detail: TILA-RESPA
Finance Charge of $XXX which exceeds the $XXX threshold (fee amounts included in Integrated Disclosure - Loan
Finance Charge calculation are based on Closing Disclosure dated 01/XX/2017). Calculations: Final Closing
(Final/12/XX/2016) Disclosure provided on
12/XX/2016 disclosed an
inaccurate Finance Charge on
page 5 that does not match
the actual Finance Charge for
the loan (fee amounts
included in Finance Charge
calculation are based on
Closing Disclosure dated
01/XX/2017).
(Final/12/XX/2016)
649207973 XXX XXX 1 29373743 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2016 12/XX/2017 WA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor
Tolerance Violation SubEscrow Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no or no cure was provided to the borrower. Cash-out - QM
Without Sufficient Cure cure was provided to the borrower. (75201) Other
Provided
649207973 XXX XXX 1 29373744 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Document missing TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2016 12/XX/2017 WA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor 2023/XX/XX: Missing CHARM
Status CHARM Booklet, not provided to the borrower. Cash-out - QM Booklet provided within 3
Other days of application.
649207973 XXX XXX 1 29373745 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing Per calculated subsequent change frequency, the CD does not TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2016 12/XX/2017 WA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor
Disclosure AIR Table Disclosure provided on 12/XX/2016 disclosed a Subsequent Changes frequency that match the note changes. Cash-out - QM
Subsequent Change does not match the actual subsequent change frequency for the loan. Other
Frequency (Final/12/XX/2016)
649207973 XXX XXX 1 29373746 compliance 2 TRID Lender Credit TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender File is missing a valid change of circumstance and no TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2016 12/XX/2017 WA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor
Tolerance Violation Credits. Final Lender Credit of -$XXX is less than amount of binding Lender tolerance cure was provided. Cash-out - QM
Credit previously disclosed in the amount of -$XXX. (9300) Other
649207973 XXX XXX 1 29373747 credit 3 Income documentation File is missing a third party verification dated within 21 12/XX/2016 WA Refinance - Primary No C C C C 7/XX/2023 Safe Harbor 2023/XX/XX: Agree. 2023/XX/XX: Trailing
requirements not met. business days of the note date for borrower's business Cash-out - QM documents reviewed unable to
verifying dates of operation, in good standing at Other clear.
operational at closing.
2023/XX/XX: Verification of
Third Party SE employment not
found as required.
649207973 XXX XXX 1 29373748 compliance 1 S-Corp Income Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not Failure due to missing income docs. 12/XX/2016 WA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Safe Harbor 2023/XX/XX: Trailing
Documentation Test sufficient (S-Corp). (XXX XXX/S-Corp) Cash-out - QM documents reviewed unable to
Other clear.
2023/XX/XX: Upon further
review of the Trialing
documents, exception cleared.
649207973 XXX XXX 1 29373749 compliance 1 Income/Asset Guideline Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to Failure due to missing income docs. 12/XX/2016 WA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Safe Harbor 2023/XX/XX: The verification
Deficiency - ATR Impact income and/or asset doc requirements which could result in a risk to the Cash-out - QM of Self Employment should be
borrower's ability to repay. (Exception is eligible to be regraded with Other done within 21 days of the
compensating factors.) Note Date. Exception remains.
2023/XX/XX: Upon further
review of the Trialing
documents, exception cleared.
649207973 XXX XXX 1 29373750 compliance 1 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Failure due to missing income docs. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 12/XX/2016 WA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Safe Harbor 2023/XX/XX: Trailing
Match - QM QM does not match Due Diligence Loan Designation of ATR Risk. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - QM documents reviewed unable to
Other clear.
2023/XX/XX: Upon further
review of the Trialing
documents, exception cleared.
649207973 XXX XXX 1 29373751 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Failure due to missing income docs 12/XX/2016 WA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Safe Harbor 2023/XX/XX: Trailing
Provision Investor guideline components, the loan is at ATR risk. Cash-out - QM documents reviewed unable to
Guidelines Other clear.
2023/XX/XX: Upon further
review of the Trialing
documents, exception cleared.
649207973 XXX XXX 1 29373752 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 12/XX/2016 WA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor
Account Statement Missing implementing regulation, Regulation X, for these type of violations. Cash-out - QM
Other
649208444 XXX XXX 2 29373844 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 12/XX/2016 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three (3) business days prior to consummation. QM
Business Days Prior to (Type:Primary/12/XX/2016)
Consummation
649208444 XXX XXX 2 29373845 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. Initial escrow account statement disclosure is missing in RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 12/XX/2016 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Account Statement Missing file. implementing regulation, Regulation X, for these type of violations. QM
649208444 XXX XXX 2 29373846 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet Disclosure is missing in file. Please provide. TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2016 12/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Status CHARM Booklet, not provided to the borrower. QM
649208444 XXX XXX 2 29373848 credit 3 Missing Document: Purchase Contract is missing in file. Please provide. 12/XX/2016 CA Purchase Primary No D D D D 7/XX/2023 Safe Harbor
Purchase Agreement / QM
Sales Contract not
provided
649208444 XXX XXX 2 29373849 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Post Disaster Inspection report is missing in file. 12/XX/2016 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Received BPO
most recent valuation Disaster End Date: XX/XX/XXXX QM confirming no damage.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649208444 XXX XXX 2 29373850 credit 3 Guideline Requirement: Calculated loan to value percentage of 80.00000% exceeds Guideline loan to value Per lender guides, for an extended LTV of 80%, borrower must 12/XX/2016 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
Loan to value percentage of 75.00000%. have a 740 fico which they do not have. Max LTV is 75% per QM
discrepancy. lender guides.
649207512 XXX XXX 2 29373900 compliance 1 (Missing Doc) Incomplete Income, Assets, Note, Security instrument, LE, CD and 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Received majority
loan images/file Initial/Final 1003's are missing. QM of documentation. Updated
exceptions set for remaining
missing docs.
649207512 XXX XXX 2 29373901 compliance 1 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2019 4/XX/2020 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Provided
Test borrower. QM
649207512 XXX XXX 2 29373902 compliance 1 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2019 4/XX/2020 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Provided
Status CHARM Booklet, not provided to the borrower. QM
649207512 XXX XXX 2 29373903 credit 1 FEMA Disaster Issue: Disaster Name: XXX 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Appraisal
Property is located in a Disaster Declaration Date: XX/XX/XXXX QM provided.
FEMA Disaster area and Disaster End Date: XX/XX/XXXX
has not been inspected.
649207512 XXX XXX 2 29373904 credit 1 Insufficient Coverage: Hazard insurance coverage is insufficient and a Replacement 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: RCE provided.
Hazard insurance coverage Cost Estimator was not provided. In addition, the document QM Cleared.
amount is insufficient. provided is an estimate only.
649207512 XXX XXX 2 29373905 credit 1 No evidence of fraud Credit Report: Original // Borrower: XXX 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Fraud report
report in file QM provided. Cleared.
649207512 XXX XXX 2 29373906 credit 1 Missing Document: Flood 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Flood Certificate
Certificate not provided QM provided.
649207512 XXX XXX 2 29373908 credit 1 Missing Document: 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Appraisal
Appraisal not provided QM provided.
649207512 XXX XXX 2 29373909 credit 3 Missing Document: Drive 4/XX/2019 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
By not provided QM
649207512 XXX XXX 2 29373910 credit 1 REO Documents are Address: XXX, CA Lease Agreement 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Lease agreement
missing. QM provided.
649207512 XXX XXX 2 29373911 credit 1 Missing Document: Source File is missing a copy of the wire/check from the fiance to 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Wire provided.
of Funds/Deposit not the title company for the $XXX. QM Cleared.
provided
649207512 XXX XXX 2 29373912 compliance 1 Rental Income Qualified Mortgage (Dodd-Frank 2014): Rental income documentation requirement not File is missing evidence borrower has 75% equity in the 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Lease/appraisal
Documentation - 25% met for XXX. Lease Agreement not provided or % of gross rents used is greater departure residence. QM provided. Cleared.
Method than 75%. (XXX/25% Vacancy Method)
649207512 XXX XXX 2 29373913 compliance 1 Rental Income Vacating Qualified Mortgage (Dodd-Frank 2014): Analysis of Rental income requirement not Per lender guides, the following is required for borrower's 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Lease/appraisal
Primary met. Borrower's current address matches the REO property address. (XXX/25% departure residence: A copy of the fully executed Lease QM provided. Cleared.
Vacancy Method) Agreement and receipt of a security deposit from the Tenant
and deposit into the Borrower's account.
649207512 XXX XXX 2 29373914 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify Real Estate Owned income Lease Agreement is missing, evidence of borrower's receipt Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Lease/appraisal
Provision Income and (25% Method) using reasonably reliable third-party records. (XXX/25% Vacancy of the security deposit and proof borrower has 75% equity in damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of QM provided. Cleared.
Assets - REO 25% Method Method) the property. all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure
to comply is not material). A private right of action may be brought before the end of the three-
year period beginning on the date of the occurrence of the violation. However, when a creditor,
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649207512 XXX XXX 2 29373916 compliance 1 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Lender is using a lower amount for the real estate taxes on Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Lease/appraisal
Match - QM QM does not match Due Diligence Loan Designation of ATR Fail. the subject property. California properties require a 1.25% firm performing the loan level due diligence and to have the TPR firm confirm said designation. QM provided. Cleared.
calculation for real estate taxes. There is no evidence in
the file of lower real estate taxes which is causing the
excessive debt ratio.
649207512 XXX XXX 2 29373917 compliance 1 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Evidence of borrower's earlier receipt was not provided. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2019 4/XX/2020 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Provided
Disclosure Timing without at least three (3) business days prior to closing. (Final/04/XX/2019) QM
Waiver
649207512 XXX XXX 2 29373919 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Second Appraisal Fee was last disclosed as $XXX on LE but TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2019 4/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Tolerance Violation Appraisal Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no disclosed as $XXX on Final Closing Disclosure. File does not QM
Without Sufficient Cure cure was provided to the borrower. (7507) contain a valid COC for this fee, nor evidence of cure in
Provided file.
649207512 XXX XXX 2 29373920 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Tax Service Fee was last disclosed as $XXX on LE but TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2019 4/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Tolerance Violation Service Fee (Life Of Loan). Fee Amount of $XXX exceeds tolerance of $XXX. disclosed as $XXX on Final Closing Disclosure. File does not QM
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (7580) contain a valid COC for this fee, nor evidence of cure in
Provided file.
649207512 XXX XXX 2 29373921 credit 3 Verification(s) of Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: 4/XX/2019 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor 2023/XX/XX: Agree. 2023/XX/XX: VVOE within 10
employment is not within 09/XX/2018 QM business days not provided as
10 business days of the required. Exception remains.
Note.
649207512 XXX XXX 2 29373922 credit 1 Guideline Requirement: Calculated investor qualifying total debt ratio of 43.36064% exceeds Guideline Hazard Insurance premium utilized $XXX. Actual premium per 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 8/XX/2023 Yes Safe Harbor 2023/XX/XX: Disagree; 2023/XX/XX: DTI within
Investor qualifying total total debt ratio of 43.00000%. HOI is $XXX. QM the final DTI per the guidelines once Note Rate was
debt ratio discrepancy. final 1008 is 42.764% used in qualifying per
which consists of $XXX guidelines.
PITIA and $XXX all
other payments against
the calculated income
of $XXX.
649207512 XXX XXX 2 29373923 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Updated Guidelines used. Income documents Lease for rental 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Lease/appraisal
Provision Investor guideline components, the loan is at ATR risk. property not located in file. QM provided. Cleared.
Guidelines
649207512 XXX XXX 2 29373924 compliance 1 General ATR Provision Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lender is using a lower amount for the real estate taxes on 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Lease/appraisal
Investor and Non QM DTIs Lenders Guidelines and 1026.43(c)(5) of 43.36064% moderately exceeds the the subject property. California properties require a 1.25% QM provided. Cleared.
match and both moderately guideline maximum of 43.00%. (DTI Exception is eligible to be regraded with calculation for real estate taxes. There is no evidence in
exceed Guidelines compensating factors.) the file of lower real estate taxes which is causing the
excessive debt ratio.
649207512 XXX XXX 2 29373925 credit 1 Missing Document: Hazard File is missing the actual Hazard insurance policy. The 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: HOI Policy
Dec Page not provided documentation provided is an insurance estimate. QM provided. Cleared.
649207512 XXX XXX 2 29373926 compliance 1 (Missing Data) Last Rate Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario Rate lock is missing from the loan file. 4/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Rate lock
Set Date between Creditor Application Date and Transaction Date used to determine rate QM provided. Cleared.
used for testing.
649207512 XXX XXX 2 29373927 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM loan program disclosure not provided to the borrower TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2019 4/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Test borrower within three (3) days of application. within three (3) days of application. QM
649207512 XXX XXX 2 29373928 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Consumer Handbook on Adjustable Rate Mortgages, CHARM TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2019 4/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Timing CHARM Booklet, not provided to the borrower within three (3) days of application. Booklet, not provided to the borrower within three (3) days QM
of application.
649207512 XXX XXX 2 29373929 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy Proof of receipt of appraisal was not provided. There is generally no Assignee Liability. 4/XX/2019 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Appraisal Not Provided at of the appraisal at least three (3) business days prior to closing, and appraisal QM
or Before Closing (3-Day was not provided at or before closing. (Type:Primary/04/XX/2019)
Waiver In File)
649207512 XXX XXX 2 29373930 credit 3 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX 4/XX/2019 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor 2023/XX/XX: Disagree; 2023/XX/XX: An inspection is
most recent valuation Disaster End Date: XX/XX/XXXX QM UB guidelines did not required for properties in
inspection is dated prior Disaster Name: XXX require a re- which the most recent
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX inspection for this valuation inspection date is
disaster. property prior to loan prior to the Disaster
closing. Declaration End Date.
Inspection not found in order
to clear the exception.
649208196 XXX XXX 1 29373976 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Property inspection report is missing 9/XX/2017 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received BPO
most recent valuation Disaster End Date: XX/XX/XXXX confirming no damage.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649208196 XXX XXX 1 29373977 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Evidence of borrower's receipt of the appraisal is missing. 9/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation.
Business Days Prior to (Type:Primary/09/XX/2017)
Consummation
649208196 XXX XXX 1 29373978 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender 9/XX/2017 CA Purchase Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Cleared
Provision Investor does not match the ATR payment calculation methods under 1026.43(c)(5).
Qualification Method not
Matching ATR
649208196 XXX XXX 1 29373979 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure Lender Contact Information i not updated in final cd. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2017 9/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Disclosure Contact provided on 09/XX/2017 did not disclose the required Lender Contact Information
Information - Lender (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/09/XX/2017)
649208196 XXX XXX 1 29373981 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet is missing and evidence of borrower's receipt TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2017 9/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower. is missing.
649208196 XXX XXX 1 29373982 credit 3 Missing Document: Note - Note for 2nd mortgage is missing from the file. 9/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 Non QM
Subordinate Lien not
provided
649208196 XXX XXX 1 29373983 credit 3 Guideline Requirement: Calculated combined loan to value percentage of 98.71876% exceeds Guideline It appears the lender used the purchase price of the 9/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 Non QM
Combined loan to value combined loan to value percentage of 90.00000%. property versus the market value of the property which came
discrepancy. in lower.
649208196 XXX XXX 1 29373984 credit 3 Guideline Requirement: Calculated loan to value percentage of 87.84762% exceeds Guideline loan to value It appears the lender used the purchase price of the 9/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 Non QM
Loan to value percentage of 80.00000%. property versus the market value of the property which came
discrepancy. in lower.
649208196 XXX XXX 1 29373985 credit 3 REO Documents are Address: XXX, CA Tax Verification, Verification of Security Deposit File is missing tax cert and the security deposit for the 9/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 Non QM
missing. rent and evidence borrower deposited it into their bank
account.
649208231 XXX XXX 1 29374146 credit 3 Missing Document: Appraisal is not provided. 12/XX/2018 CA Refinance - Primary No D D D D 7/XX/2023 Non QM
Appraisal not provided Cash-out -
Home
Improvement
649208231 XXX XXX 1 29374147 credit 3 No evidence of fraud Credit Report: Original // Borrower: XXX, Credit Report: Original // Borrower: Fraud report is not provided. 12/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
report in file XXX Cash-out -
Home
Improvement
649208231 XXX XXX 1 29374149 credit 1 FEMA Disaster Issue: Disaster Name: XXX Post Disaster inspection report is not provided for Disaster 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: PDI provided,
Property is located in a Disaster Declaration Date: XX/XX/XXXX End date XX/XX/XXXX. Cash-out - exception cleared.
FEMA Disaster area and Disaster End Date: XX/XX/XXXX Home
has not been inspected. Improvement
649208231 XXX XXX 1 29374150 credit 3 Insufficient Coverage: Replacement Cost estimator is not provided. Hazard insurance 12/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Hazard insurance coverage coverage amount is insufficient. Cash-out -
amount is insufficient. Home
Improvement
649208231 XXX XXX 1 29374151 compliance 3 Self Employed Financial Qualified Mortgage (Dodd-Frank 2014): Financial strength of self-employed B1 is showing a continual decline in income. A letter of 12/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM 2023/XX/XX: B1 LOE 2023/XX/XX: Trailing docs did
Strength business reflects annual earnings that significantly decline over the analysis explanation was not provided. Cash-out - dated 11/XX/2018 for not contain any docs to clear
period. (XXX XXX/S-Corp) Home continual decline in this exception.
Improvement income provided under
MISC|Income LOE. 2016 2023/XX/XX: Trailing docs did
was a one off and 2017 not contain any docs to clear
was not a decline but this exception.
due to completion of
one off. 2018 P&L 2023/XX/XX: Exception was
supports increasing elevated. Here are the
trend. results: The requirements
under Appendix Q for
2023/XX/XX: Provided analyzing the self-employed
LOE addressing 2017 financial strength of a
income decline (tax business permit earnings that
strategy advised by are increasing or stable but
CPA), along with 2018 do not accept income that
YTD P&L supporting show a "significant decline"
income stabilized. over the analysis period.
While it is acknowledged the
2023/XX/XX: Disagree; term "significant decline" is
Provided LOE not defined with Appendix Q,
addressing 2017 income SitusAMC has used a 20%
decline (tax strategy decline as the benchmark in
advised by CPA), along our QM Appendix Q testing
with 2018 YTD P&L since the inception of the
supporting income rule back in 2013. While the
stabilized. 20% benchmark may appear
subjective (as would any
number given it's not
defined), the HUD Handbook
previously reflected
"significant decline," but
after Appendix Q rolled out
in 2013, HUD subsequently
updated to reference a "20%
decline" in place of
"significant decline" (see
snip below). SitusAMC also
implemented this 20%
threshold as the default
approach in order to have a
reasonable, established
threshold to meet the
"significant decline"
requirement under Appendix Q.
In terms of what
documentation can clear the
exception, if the declining
income was used in
qualifying, there is little
that can be done, post-close,
to clear or cure that action
and the exception is largely
considered uncurable.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649208231 XXX XXX 1 29374152 compliance 1 General Ability To Repay Ability-to-Repay (Dodd-Frank 2014): Unable to verify current S-Corp status due to File is missing a 3rd party verification for B1 dated within Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Trailing docs did
Provision Employment - S- most recent Tax Return end date is older than 120 days before Closing Date, and 20 business days prior to the note date verifying dates of damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Cash-out - not contain any docs to clear
Corp Test one of these docs is required yet missing: Audited/Third Party P&L, CPA Letter, operation and that business was in good standing and active all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Home this exception.
or other Third Party Verification. (XXX XXX/S-Corp) at the time of closing. to comply is not material). A private right of action may be brought before the end of the three- Improvement
year period beginning on the date of the occurrence of the violation. However, when a creditor, 2023/XX/XX: Received required
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial documentation. Condition
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter cleared.
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649208231 XXX XXX 1 29374153 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2018 12/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower. Cash-out -
Home
Improvement
649208231 XXX XXX 1 29374154 compliance 1 QM Employment History - Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two Failure due to missing third party verification dated within 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Trailing docs did
Current Employment years current employment. (XXX/12401905) 20 business days of note date. Cash-out - not contain any docs to clear
Documentation lacks Date Home this exception.
Info Improvement
2023/XX/XX: Received required
documentation. Condition
cleared.
649208231 XXX XXX 1 29374155 compliance 1 QM Employment History - Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two Failure due to missing VVOE dated within 10 business days 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Received required
Current Employment years current employment. (XXX/12401906) prior to note date for B2 Cash-out - documentation. Condition
Documentation lacks Date Home cleared.
Info Improvement
649208231 XXX XXX 1 29374157 compliance 3 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Failure due to missing income and asset documentation and Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 12/XX/2018 CA Refinance - Primary No C C B B 7/XX/2023 Non QM 2023/XX/XX: N/A; 2023/XX/XX: Exception remains
Match - QM QM does not match Due Diligence Loan Designation of Non QM. the appraisal. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - Duplicative Exception due to the third party
Home verification for XXX is not
Improvement 2023/XX/XX: Provided within 21 days of the note
LOE addressing 2017 date and the appraisal is
income decline (tax missing.
strategy advised by
CPA), along with 2018 2023/XX/XX: Trailing docs did
YTD P&L supporting not contain any docs to clear
income stabilized. this exception.
2023/XX/XX: Disagree; 2023/XX/XX: Exception was
Provided LOE elevated. Here are the
addressing 2017 income results: The requirements
decline (tax strategy under Appendix Q for
advised by CPA), along analyzing the self-employed
with 2018 YTD P&L financial strength of a
supporting income business permit earnings that
stabilized. are increasing or stable but
do not accept income that
show a "significant decline"
over the analysis period.
While it is acknowledged the
term "significant decline" is
not defined with Appendix Q,
SitusAMC has used a 20%
decline as the benchmark in
our QM Appendix Q testing
since the inception of the
rule back in 2013. While the
20% benchmark may appear
subjective (as would any
number given it's not
defined), the HUD Handbook
previously reflected
"significant decline," but
after Appendix Q rolled out
in 2013, HUD subsequently
updated to reference a "20%
decline" in place of
"significant decline" (see
snip below). SitusAMC also
implemented this 20%
threshold as the default
approach in order to have a
reasonable, established
threshold to meet the
"significant decline"
requirement under Appendix Q.
In terms of what
documentation can clear the
exception, if the declining
income was used in
qualifying, there is little
that can be done, post-close,
to clear or cure that action
and the exception is largely
considered uncurable.
2023/XX/XX: EXCEPTION HISTORY
- Exception Detail was
updated on 09/XX/2023 PRIOR
Exception Detail: Qualified
Mortgage (Dodd-Frank 2014):
Originator Loan Designation
of Safe Harbor QM does not
match Due Diligence Loan
Designation of ATR Fail.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649208231 XXX XXX 1 29374158 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify current Wages/W-2 employment VVOE is not provided for XXX - XXX employer. Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Received required
Provision Employment - W- status using reasonably reliable third-party records. (XXX XXX/Wages) damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Cash-out - documentation. Condition
2 all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Home cleared.
to comply is not material). A private right of action may be brought before the end of the three- Improvement
year period beginning on the date of the occurrence of the violation. However, when a creditor,
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649208231 XXX XXX 1 29374159 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Evidence of borrower's receipt of the initial CD was not TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2018 12/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure Timing without at least three (3) business days prior to closing. (Initial/12/XX/2018) provided. Cash-out -
Waiver Home
Improvement
649208231 XXX XXX 1 29374160 compliance 1 Self Employed YTD Qualified Mortgage (Dodd-Frank 2014): Self-employed qualifying income reflects a A letter of explanation for either the borrower or CPA 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: N/A; 2023/XX/XX: Used Year 1
declining earnings trend. (XXX XXX/S-Corp) regarding B1's continual decline in income was not provided. Cash-out - Duplicative Exception average.
Home
Improvement
649208231 XXX XXX 1 29374161 credit 1 Income Docs Missing: Borrower: XXX The Work Number - Employment Only Missing VOE for B2. 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Received required
Cash-out - documentation. Condition
Home cleared.
Improvement
649208231 XXX XXX 1 29374162 credit 1 Guideline Requirement: Calculated PITIA months reserves of is less than Guideline PITIA months reserves File is missing sufficient asset documentation to support 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Received required
PITIA reserves months of 9.00. the reserve requirement. Cash-out - documentation. Condition
discrepancy. Home cleared.
Improvement
649208231 XXX XXX 1 29374163 credit 1 Income documentation File is missing a third party verification for B1 dated with 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: XXX 2023/XX/XX: Trailing docs did
requirements not met. 20 business days prior to the note date verifying dates of Cash-out - Business Regitration not contain any docs to clear
operation and active at closing and a VVOE for B2 dated Home Certificate in file this exception.
within 10 business days prior to note date. Improvement under
Other_Income|Self 2023/XX/XX: Exception remains
Employment due to the third party
Verification 1 pg verification for XXX is not
with 6/XX/18 and within 21 days of the note
6/XX/19 expiration date and the appraisal is
dates. Appraisal in missing.
file under
Property_Appraisal 34 2023/XX/XX: Third party
pgs. verification provided dated
with 20 business days prior
to the note date.
649208231 XXX XXX 1 29374164 credit 1 Asset documentation File is missing sufficient assets for reserve requirements. 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 7/XX/2023 Yes Non QM 2023/XX/XX: Bank statements
requirements not met. Cash-out - were provided.
Home
Improvement
649208231 XXX XXX 1 29374165 compliance 1 Income/Asset Guideline Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to Failure due to missing income and asset documentation and 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: N/A; 2023/XX/XX: Exception remains
Deficiency - ATR Impact income and/or asset doc requirements which could result in a risk to the appraisal. Cash-out - Duplicative Exception due to the third party
borrower's ability to repay. (Exception is eligible to be regraded with Home verification for XXX is not
compensating factors.) Improvement within 21 days of the note
date and the appraisal is
missing.
2023/XX/XX: Third party
verification provided dated
with 20 business days prior
to the note date.
649208231 XXX XXX 1 29374166 credit 1 AUS/Guideline Findings: Failure due to missing income and asset documentation and 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Received required
All conditions were not the interior/exterior appraisal. Cash-out - documentation. Condition
met Home cleared.
Improvement
649208231 XXX XXX 1 29374167 compliance 3 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Failure due to missing income and asset docs. 12/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM 2023/XX/XX: N/A; 2023/XX/XX: Exception remains
Provision Investor guideline components, the loan is at ATR risk. Cash-out - Duplicative Exception due to the third party
Guidelines Home verification for XXX is not
Improvement 2023/XX/XX: Duplicate within 21 days of the note
and/or waterfall date and the appraisal is
exception missing.
2023/XX/XX: Appraisal was not
provided. Condition remains.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649207695 XXX XXX 2 29374375 compliance 3 Overtime Bonus 2Yr Calc Qualified Mortgage (Dodd-Frank 2014): Use of Overtime/Bonus income for less than Written verification of employment provided in loan file 4/XX/2017 WA Purchase Primary No C C C C 7/XX/2023 Non QM
two (2) years not justified or documented in writing. (XXX XXX/Bonus) reflects "see attached" but missing other page. Unable to
determine/verify prior year bonus income due to missing
documentation.
649207695 XXX XXX 2 29374376 compliance 3 Overtime Bonus Declining Qualified Mortgage (Dodd-Frank 2014): Use of continual decline in income for Written verification of employment provided in loan file 4/XX/2017 WA Purchase Primary No C C C C 7/XX/2023 Non QM
Overtime/Bonus not justified or documented. (XXX XXX/Bonus) reflects "see attached" but missing other page. Unable to
determine/verify prior year bonus income due to missing
documentation.
649207695 XXX XXX 2 29374377 compliance 3 Overtime Bonus Method of Qualified Mortgage (Dodd-Frank 2014): Significant income variation requires a Written verification of employment provided in loan file 4/XX/2017 WA Purchase Primary No C C C C 7/XX/2023 Non QM
Calculation period of more than two (2) years when calculating the average Overtime/Bonus reflects "see attached" but missing other page. Unable to
income. (XXX XXX/Bonus) determine/verify prior year bonus income due to missing
documentation.
649207695 XXX XXX 2 29374378 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Verification appraisal was delivered to borrower was not 4/XX/2017 WA Purchase Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. provided.
Business Days Prior to (Type:Primary/04/XX/2017)
Consummation
649207695 XXX XXX 2 29374379 compliance 2 General Ability To Repay Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender 4/XX/2017 WA Purchase Primary No B B B B 7/XX/2023 Non QM
Provision Investor does not match the ATR payment calculation methods under 1026.43(c)(5).
Qualification Method not
Matching ATR
649207695 XXX XXX 2 29374380 compliance 3 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Loan designation failure due to ATR failure. This exception Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 4/XX/2017 WA Purchase Primary No C C B B 7/XX/2023 Non QM
Match - QM QM does not match Due Diligence Loan Designation of Non QM. will be cleared once all ATR specific exception have been firm performing the loan level due diligence and to have the TPR firm confirm said designation.
cured/ cleared.
649207695 XXX XXX 2 29374381 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 4/XX/2017 WA Purchase Primary No B B B B 7/XX/2023 Non QM
Account Statement Missing implementing regulation, Regulation X, for these type of violations.
649207695 XXX XXX 2 29374382 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure dated 04/XX/2017 was not provided to TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2017 5/XX/2018 WA Purchase Primary No B B B B 7/XX/2023 Non QM
Disclosure Timing without at least three (3) business days prior to closing. (Initial/04/XX/2017) Borrower(s) at least three business days prior to closing
Waiver 04/XX/2017.
649207695 XXX XXX 2 29374384 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee was last disclosed as $XXX on LE but TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2017 5/XX/2018 WA Purchase Primary No B B B B 7/XX/2023 Non QM
Tolerance Violation Appraisal Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no disclosed as $XXX on Final Closing Disclosure. File does not
Without Sufficient Cure cure was provided to the borrower. (7506) contain a valid COC for this fee, nor evidence of cure in
Provided file. A copy of refund check, proof of delivery, and a copy
of the letter of explanation sent to the borrower disclosing
the changes made.
649207695 XXX XXX 2 29374385 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2017 5/XX/2018 WA Purchase Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower.
649207695 XXX XXX 2 29374386 compliance 3 QM DTI Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and The DTI of 43.17542% exceeds the QM maximum of 43.00% Although this issue is subject to a 3 year SOL for affirmative claims under TILA, AMC does not adjust 4/XX/2017 WA Purchase Primary No C C C C 7/XX/2023 Non QM
the images do not provide evidence loan is eligible for purchase, guarantee or grading taking into account TILA SOL for exceptions under ATR, given the potential for enhanced
insurance by the appropriate agency. damages when asserting an ability to repay defense in response to an action to collect a debt by
recoupment or set-off.
649207695 XXX XXX 2 29374387 compliance 2 Missing Document: Missing Initial 1003 in loan file is missing borrowers signature and 4/XX/2017 WA Purchase Primary No B B B B 7/XX/2023 Non QM
Lender's Initial 1003 date.
649207695 XXX XXX 2 29374388 credit 3 Available for Closing is Documented qualifying Assets for Closing of $XXX is less than Cash From Borrower Documented qualifying Assets for Closing of $XXX is less 4/XX/2017 WA Purchase Primary No C C C C 7/XX/2023 Non QM
insufficient to cover $XXX. than Cash From Borrower $XXX.
Cash From Borrower.
649209079 XXX XXX 1 29374483 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy There is generally no Assignee Liability. 5/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Appraisal Not Provided at of the appraisal at least three (3) business days prior to closing, and appraisal QM
or Before Closing (3-Day was not provided at or before closing. (Type:Primary/05/XX/2018)
Waiver In File)
649209079 XXX XXX 1 29374485 compliance 2 Missing Document: Missing File is missing signed/dated initial application 5/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Lender's Initial 1003 QM
649209079 XXX XXX 1 29374487 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement 5/XX/2018 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
is missing. QM
649209079 XXX XXX 1 29374488 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX 5/XX/2018 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: BPO provided. No
most recent valuation Disaster End Date: XX/XX/XXXX QM damage noted. Cleared.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649209079 XXX XXX 1 29374489 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 5/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Account Statement Missing implementing regulation, Regulation X, for these type of violations. QM
649208795 XXX XXX 2 29374508 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each 3/XX/2018 WA Purchase Investment No B B B B 7/XX/2023 N/A
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation.
Business Days Prior to (Type:Primary/02/XX/2018)
Consummation
649208795 XXX XXX 2 29374509 credit 3 Verification(s) of Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: 3/XX/2018 WA Purchase Investment No C C C C 7/XX/2023 N/A
employment is not within 05/XX/2005
10 business days of the
Note.
649208795 XXX XXX 2 29374510 credit 3 Verification(s) of Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: 3/XX/2018 WA Purchase Investment No C C C C 7/XX/2023 N/A
employment is not within 02/XX/2016
10 business days of the
Note.
649206910 XXX XXX 2 29374896 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement E-sign Consent Agreement is missing in the file. 12/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
is missing. Cash-out -
Other
649206910 XXX XXX 2 29374897 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Loan file is missing a Post-Disaster Inspection Report 12/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: BPO provided. No
most recent valuation Disaster End Date: XX/XX/XXXX Cash-out - damage noted. Cleared.
inspection is dated prior Disaster Name: XXX Other
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649206910 XXX XXX 2 29374898 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Evidence of disclosure receipt is not in file. TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2017 12/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649206910 XXX XXX 2 29374899 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the Evidence of disclosure receipt is not in file. TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2017 12/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Test borrower. Cash-out -
Other
649206910 XXX XXX 2 29374900 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Evidence of disclosure receipt is not in file. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 12/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
of Homeownership Homeownership Counseling Organizations to borrower. implementing regulation, Regulation X, for these type of violations. Cash-out -
Counseling Organizations Other
Missing
649206910 XXX XXX 2 29374901 compliance 3 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor The Originator Loan Designation is Safe Harbor QM. However, Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 12/XX/2017 CA Refinance - Primary No C C B B 7/XX/2023 Non QM
Match - QM QM does not match Due Diligence Loan Designation of Non QM. the loan is missing self employed income documentation which firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out -
resulted in a Due Diligence Loan Designation of Non QM. Other
649206910 XXX XXX 2 29374902 compliance 3 Self Employed Financial Qualified Mortgage (Dodd-Frank 2014): Financial strength of self-employed Letter of explanation in file addressing the decline from 12/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Strength business reflects annual earnings that significantly decline over the analysis one year to the other; however, it does not address why the Cash-out -
period. (XXX XXX/Schedule C) YTD figure is down even more. Without additional Other
information, the YTD average should have been utilized for
qualifying.
649206910 XXX XXX 2 29374903 compliance 3 Sole Proprietorship Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not Self-employed documentation is insufficient due to missing 12/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Income Documentation Test sufficient (Sole Proprietorship). (XXX XXX/Schedule C) signed and dated tax returns for both borrower and co- Cash-out -
borrower, and balance sheets. Other
649206910 XXX XXX 2 29374904 compliance 3 Sole Proprietorship Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not Self-employed documentation is insufficient due to missing 12/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Income Documentation Test sufficient (Sole Proprietorship). (XXX XXX/Schedule C) signed and dated tax returns for both borrower and co- Cash-out -
borrower, and balance sheets. Other
649206910 XXX XXX 2 29374905 compliance 2 Payoff Statement Missing Missing Payoff Statement: Unable to determine if a prepayment penalty was Mortgage payoff statement is not in file. 12/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
included in the pay-off which may impact high cost findings. Cash-out -
Other
649207979 XXX XXX 1 29375092 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX 3/XX/2015 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: BPO provided. No
most recent valuation Disaster End Date: XX/XX/XXXX Cash-out - damage noted. Cleared.
inspection is dated prior Disaster Name: XXX Debt
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX Consolidation
disaster.
649207979 XXX XXX 1 29375093 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 3/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three (3) business days prior to consummation. Cash-out -
Business Days Prior to (Type:Primary/02/XX/2015) Debt
Consummation Consolidation
649207979 XXX XXX 1 29375094 compliance 2 RESPA (2010) - GFE RESPA (2010): GFE does not provide minimum ten (10) business day availability GFE does not provide minimum ten (10) business day RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Settlement charges Good for estimate of charges and terms for all other settlement charges. availability for estimate of charges and terms for all other implementing regulation, Regulation X, for these type of violations. Cash-out -
Thru Date Less than 10 settlement charges Debt
Days Consolidation
649207979 XXX XXX 1 29375095 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" date on the The final TIL reflects the date as 03/XX/2015, however the TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 3/XX/2015 3/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Payment Summary Table - Final TIL does not match the date on which the first regular periodic payment calculated date is 04/XX/2015. Assignee liability. Cash-out -
Maximum In First 5 Years will be due and the earliest date on which that rate may apply. Debt
Change Date Inaccurate Consolidation
(ARM loan)
649207979 XXX XXX 1 29375096 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet is missing on file TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2015 3/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower. Cash-out -
Debt
Consolidation
649207979 XXX XXX 1 29375098 credit 3 Missing Document: Note - File is missing a copy of the 2nd mortgage note. 3/XX/2015 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Subordinate Lien not Cash-out -
provided Debt
Consolidation
649207979 XXX XXX 1 29375099 credit 2 Public Record Issue: Credit Report: Original // Public Record Type: Tax Liens / Balance: XXX Evidence this lien was satisfied or paid was not provided. 3/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Cash-out -
Debt
Consolidation
649208761 XXX XXX 2 29375100 credit 3 Final Title Policy The Final Title Policy Amount of $XXX is less than the note amount of $XXX based The Final Title Policy Amount of $XXX is less than the note 3/XX/2020 CA Refinance - Investment No C C C C 7/XX/2023 N/A
Coverage is less than on the Short Form in file. amount of $XXX based on the Short Form in file. There is a Rate/Term
Original Loan Amount. variance of ($XXX)
649208761 XXX XXX 2 29375101 credit 3 Income Docs Missing: Borrower: XXX Third Party Verification Income documentation requirements were not met. Due to 3/XX/2020 CA Refinance - Investment No C C C C 7/XX/2023 N/A
missing supporting income documentation of borrower(s) Rate/Term
Interest/Dividends and Capital Gains Income.
649208761 XXX XXX 2 29375102 credit 3 Aged document: Primary Valuation Type: Appraisal / Valuation Report Date: 10/XX/2019 Per, guidelines the Appraisal cannot be (120) days prior to 3/XX/2020 CA Refinance - Investment No C C C C 7/XX/2023 N/A
Valuation is older than the Note date. The Valuation Report date is 10/XX/2019 the Rate/Term
guidelines permit Note Date is 03/XX/2020.
649208761 XXX XXX 2 29375103 credit 3 REO Documents are Address: XXX, CA Insurance Verification Property XXX, is missing the real estate tax verification 3/XX/2020 CA Refinance - Investment No C C C C 7/XX/2023 N/A
missing. and insurance policy. Rate/Term
649208761 XXX XXX 2 29375104 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Most recent property inspection report dated XX/XX/XXXX is 3/XX/2020 CA Refinance - Investment No A A A A 7/XX/2023 6/XX/2023 Yes N/A 2023/XX/XX: BPO provided. No
most recent valuation Disaster End Date: XX/XX/XXXX after the FEMA disaster (XXX) dated XX/XX/XXXX but before Rate/Term damage noted. Cleared.
inspection is dated prior Disaster Name: XXX the disaster end date of XX/XX/XXXX. File is missing a
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX property inspection dated after the disaster declaration end
disaster. date, or the lender's Rep and Warranty attestation along
with visible confirmation that the subject property was not
damaged.
649208761 XXX XXX 2 29375105 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Valuations were not provided to borrower(s) (3) days prior 3/XX/2020 CA Refinance - Investment No B B B B 7/XX/2023 N/A
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. to loan consummation. Rate/Term
Business Days Prior to (Type:Primary/10/XX/2019)
Consummation
649208761 XXX XXX 2 29375106 credit 3 Income documentation Income documentation requirements were not met. Due to 3/XX/2020 CA Refinance - Investment No C C C C 7/XX/2023 N/A
requirements not met. missing supporting income documentation of borrower(s) Rate/Term
Interest/Dividends and Capital Gains Income.
649207686 XXX XXX 1 29375178 compliance 2 Missing Document: Missing The file was missing a copy of the Initial 1003. 4/XX/2015 CA Refinance - Investment No B B B B 7/XX/2023 N/A
Lender's Initial 1003 Cash-out -
Other
649207686 XXX XXX 1 29375179 compliance 2 ECOA Appraisal - Borrower ECOA Valuations Rule (Dodd-Frank 2014): Creditor improperly charged consumer for There is generally no Assignee Liability. 4/XX/2015 CA Refinance - Investment No B B B B 7/XX/2023 N/A
Was Charged for Appraisal copy of appraisal. Cash-out -
Other
649207686 XXX XXX 1 29375180 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Verification appraisal was delivered to borrower was not 4/XX/2015 CA Refinance - Investment No B B B B 7/XX/2023 N/A
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. provided. Cash-out -
Business Days Prior to (Type:Primary/11/XX/2014) Other
Consummation
649207686 XXX XXX 1 29375181 credit 3 File does not contain Valuation Type: Appraisal / Valuation Report Date: 11/XX/2014 4/XX/2015 CA Refinance - Investment No C C C C 7/XX/2023 N/A
documentation from Cash-out -
lender/seller confirming Other
the condo is warrantable.
649208498 XXX XXX 1 29375330 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Post closing disaster end date XX/XX/XXXX. 5/XX/2016 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Received BPO
most recent valuation Disaster End Date: XX/XX/XXXX QM confirming no damage.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649208498 XXX XXX 1 29375331 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Evidence of Borrower's receipt of each valuation three (3) 5/XX/2016 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. business days prior to consummation not provided. QM
Business Days Prior to (Type:Primary/05/XX/2016)
Consummation
649208498 XXX XXX 1 29375332 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 5/XX/2016 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Account Statement Missing implementing regulation, Regulation X, for these type of violations. QM
649208498 XXX XXX 1 29375333 compliance 2 TRID Final Closing TRID Final Closing Disclosure 05/XX/2016 on a first lien purchase transaction did No seller fees reported on seller CD or on Buyer's CD. 5/XX/2016 5/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Disclosure No Seller Paid not disclose any Seller paid fees/charges on page 2. (Points and Fees testing QM
Fees Primary Residence limited to Borrower paid fees.) (Final/05/XX/2016)
First Lien
649208498 XXX XXX 1 29375334 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for No valid cure or COC provided TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2016 5/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Tolerance Violation Appraisal Re-Inspection Fee. Fee Amount of $XXX exceeds tolerance of $XXX. QM
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (75103)
Provided
649208498 XXX XXX 1 29375335 compliance 2 Missing Document: Missing An initial application signed and dated by the borrowers not 5/XX/2016 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Lender's Initial 1003 provided. QM
649208206 XXX XXX 1 29375351 credit 3 File does not contain Valuation Type: Appraisal / Valuation Report Date: 07/XX/2015 7/XX/2015 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
documentation from QM
lender/seller confirming
the condo is warrantable.
649208206 XXX XXX 1 29375352 compliance 2 RESPA Disclosure - HUD RESPA Disclosure Rule: Creditor did not provide HUD Settlement Cost Booklet. HUD Settlement Cost Booklet not provided. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 7/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Settlement Cost Booklet implementing regulation, Regulation X, for these type of violations. QM
Missing
649208206 XXX XXX 1 29375353 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" date on the The "Maximum First Five Years" date on the Final TIL does TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 7/XX/2015 7/XX/2016 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Payment Summary Table - Final TIL does not match the date on which the first regular periodic payment not match the date on which the first regular periodic Assignee liability. QM
Maximum In First 5 Years will be due and the earliest date on which that rate may apply. payment will be due and the earliest date on which that rate
Change Date Inaccurate may apply.
(ARM loan)
649208206 XXX XXX 1 29375354 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Consumer Handbook on Adjustable Rate Mortgages, CHARM TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2015 7/XX/2016 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Status CHARM Booklet, not provided to the borrower. Booklet, not provided. QM
649208206 XXX XXX 1 29375355 credit 3 Missing Document: HOA 7/XX/2015 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
Questionnaire not QM
provided
649208206 XXX XXX 1 29375356 compliance 2 Missing Document: Missing 7/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Lender's Initial 1003 QM
649208206 XXX XXX 1 29375357 compliance 2 TILA NMLSR - Individual Truth in Lending Act (NMLSR Dodd- Frank 2014): Individual Loan Originator NMLSR XXX #XXX Loan Originator is not located in NMLS data base Assignee Liability: Civil actions that may be brought against a creditor may be maintained against 7/XX/2015 7/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Originator NMLS information on loan documents does not match NMLSR. any assignee only if the violation is apparent on the face of the disclosure or other documents QM
information on documents assigned, except where the assignment was voluntary. This civil liability may include $XXX in the
does not match NMLS case of an individual transaction, or the lesser of $XXX or 1% of the creditor's net worth in the
website case of a class action (effective 1/XX/14, this amount increases to the lesser of $XXX or 1%), as
well as actual damages, court costs, and attorneys' fees. For an anti-steering violation, the
creditor may also be liable in an amount equal to the sum of all finance charges and fees paid by the
consumer, unless the creditor demonstrates the failure to comply is not material. Notwithstanding
any other provision of law, when a creditor, assignee, or other holder or anyone acting on behalf of
the creditor, assignee, or holder, initiates a judicial or nonjudicial foreclosure of the residential
mortgage loan, or any other action to collect the debt in connection with such loan, a consumer may
assert a violation as a matter of defense by recoupment or set off without regard for the time limit
on a private action for damages.
Effective 1/XX/2014 in addition to the aforementioned, the individual Loan Originator could be liable
for statutory damages. The maximum liability is the greater of actual damages or 3 times the loan
originator's compensation or gain, plus the cost to the consumer of the action. The Dodd-Frank Act
extended the statute of limitations on TILA violations to 3 years from the date of the violation.
649209097 XXX XXX 2 29375366 credit 1 Missing Document: Missing The file is missing a copy of Final 1003 Application. 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received
Final 1003 Cash-out -
Other
649209097 XXX XXX 2 29375367 credit 1 Missing Document: The file is missing a copy of Appraisal Report 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received
Appraisal not provided Cash-out - appraisal.
Other
649209097 XXX XXX 2 29375368 credit 1 Missing Document: Flood The file is missing a copy of Flood Certificate Report. 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received flood
Certificate not provided Cash-out - cert.
Other
649209097 XXX XXX 2 29375369 credit 1 Missing Document: Credit The file is missing a copy of Credit Report 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received credit
Report not provided Cash-out - report.
Other
649209097 XXX XXX 2 29375370 credit 1 Missing Document: Fraud The file is missing a copy of Fraud Report 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received fraud
Report not provided Cash-out - report.
Other
649209097 XXX XXX 2 29375371 credit 1 Missing Document: The is missing a copy of Occupancy Certificate 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received
Occupancy Certificate not Cash-out -
provided Other
649209097 XXX XXX 2 29375372 credit 1 FEMA Disaster Issue: Disaster Name: XXX The property is located in a FEMA disaster area. Provide a 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received BPO
Property is located in a Disaster Declaration Date: XX/XX/XXXX post-disaster inspection verifying there was no damage. The Cash-out - confirming no damage.
FEMA Disaster area and Disaster End Date: XX/XX/XXXX inspection must include exterior photos and the property Other
has not been inspected. must be re-inspected on or after XX/XX/XXXX declared end
date.
649209097 XXX XXX 2 29375373 credit 1 AUS/Guideline Findings: The file is missing a copy of Credit and Fraud Report, 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Trailing docs did
All conditions were not required by guidelines, and the DTI ratio exceeds the Cash-out - not contain any docs to clear
met maximum allowed. Other this exception.
2023/XX/XX: Received required
documentation. Condition
cleared.
649209097 XXX XXX 2 29375374 credit 1 Income Docs Missing: Borrower: XXX 4506-T (2016), 4506-T (2017), VVOE - Employment Only, W-2 (2017) The file is missing a copy of 4506-T (2016), 4506-T (2017), 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: 4506T was
VVOE - Employment Only, W-2 (2017) Cash-out - provided. Condition remains
Other for missing VVOE.
2023/XX/XX: Received required
documentation. Condition
cleared.
649209097 XXX XXX 2 29375375 credit 1 No evidence of fraud Credit Report: Original // Borrower: XXX The file is missing a copy of Fraud Report 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received fraud
report in file Cash-out - report
Other
649209097 XXX XXX 2 29375376 credit 1 REO Documents are Address: XXX, CA Insurance Verification, Statement, Tax Verification The file is missing a copy of Hazard Insurance, Mortgage 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Trailing docs did
missing. Statement and Tax Certificate Cash-out - not contain any docs to clear
Other this exception.
2023/XX/XX: Received required
documentation. Condition
cleared.
649209097 XXX XXX 2 29375377 compliance 1 QM Employment History - Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two The file is missing the most recent W-2 and a VVOE to verify 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Received required
Current Employment years current employment. (XXX/12403215) the employment dates, causing the loan to waterfall through Cash-out - documentation. Condition
Documentation lacks Date the QM Testing. Other cleared.
Info
649209097 XXX XXX 2 29375378 compliance 3 Rental Income Qualified Mortgage (Dodd-Frank 2014): Rental income documentation requirement not QM requires a lease agreement, which is missing from the 12/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM 2023/XX/XX: Concur, 2023/XX/XX: No additional
Documentation - Schedule met for XXX. Lease Agreement and/or Tax Return not provided. (XXX/Schedule E) loan file, causing the loan to waterfall through the QM Cash-out - unable to locate lease documentation provided.
E Method Test Testing. Other for property which was Exception remains.
a self-rental to the
borrower's 100% owned
business and therefore
the rent is offset by
a rental expense for
the business.
649209097 XXX XXX 2 29375379 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 12/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Cash-out -
Other
649209097 XXX XXX 2 29375380 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify debt obligations using Unable to verify debt obligations using reasonably reliable Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received credit
Provision Credit History reasonably reliable third-party records. third-party records due to the missing credit report from damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Cash-out - report.
the loan file. all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Other
to comply is not material). A private right of action may be brought before the end of the three-
year period beginning on the date of the occurrence of the violation. However, when a creditor,
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649209097 XXX XXX 2 29375381 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify current Wages/W-2 employment The file is missing the most recent W-2 and a VVOE to verify Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Received required
Provision Employment - W- status using reasonably reliable third-party records. (XXX XXX/Wages) the employment dates, causing the loan to waterfall through damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Cash-out - documentation. Condition
2 the QM Testing. all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Other cleared.
to comply is not material). A private right of action may be brought before the end of the three-
year period beginning on the date of the occurrence of the violation. However, when a creditor,
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649209097 XXX XXX 2 29375382 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender The guidelines require 10/1 ARMS to be qualified using the 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Received required
Provision Investor does not match the ATR payment calculation methods under 1026.43(c)(5). Note rate, causing the loan to waterfall through the QM Cash-out - documentation. Condition
Qualification Method not Testing. Other cleared.
Matching ATR
649209097 XXX XXX 2 29375383 compliance 1 Income/Asset Guideline Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to Due to missing income documentation and origination credit 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Received credit
Deficiency - ATR Impact income and/or asset doc requirements which could result in a risk to the report the ability to repay is not supported, causing the Cash-out - report and 2017 W2; however,
borrower's ability to repay. (Exception is eligible to be regraded with loan to waterfall through the QM Testing. Other other income documentation
compensating factors.) remains missing (separate
exceptions for these items).
Finding remains open as not
all items yet received.
2023/XX/XX: Trailing docs did
not contain any docs to clear
this exception.
2023/XX/XX: Received required
documentation. Condition
cleared.
649209097 XXX XXX 2 29375385 compliance 3 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Due to missing income documentation and origination credit Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 12/XX/2018 CA Refinance - Primary No C C B B 7/XX/2023 Non QM 2023/XX/XX: Missing 2023/XX/XX: No additional
Match - QM QM does not match Due Diligence Loan Designation of Non QM. report the ability to repay is not supported, causing the firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - lease document per documentation provided.
loan to waterfall through the QM Testing. Other finding above. Exception remains.
2023/XX/XX: EXCEPTION HISTORY
- Exception Detail was
updated on 08/XX/2023 PRIOR
Exception Detail: Qualified
Mortgage (Dodd-Frank 2014):
Originator Loan Designation
of Safe Harbor QM does not
match Due Diligence Loan
Designation of ATR Fail.
649209097 XXX XXX 2 29375386 compliance 1 QM DTI Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and Due to missing income documentation and origination credit Although this issue is subject to a 3 year SOL for affirmative claims under TILA, AMC does not adjust 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Received required
the images do not provide evidence loan is eligible for purchase, guarantee or report the ability to repay is not supported, causing the grading taking into account TILA SOL for exceptions under ATR, given the potential for enhanced Cash-out - documentation. Condition
insurance by the appropriate agency. loan to waterfall through the QM Testing. damages when asserting an ability to repay defense in response to an action to collect a debt by Other cleared.
recoupment or set-off.
649209097 XXX XXX 2 29375387 compliance 1 QM Required Credit Report Qualified Mortgage (Dodd-Frank 2014): The loan file does not contain a Credit The credit report is missing from the loan file, causing the 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received credit
Not Provided to Evidence report to evidence the consumers outstanding liabilities. (XXX/12403215) loan to waterfall through the QM Testing. Cash-out - report.
Debts Other
649209097 XXX XXX 2 29375388 compliance 2 TILA-RESPA Integrated TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images Loan Estimate not provided within loan images to evidence TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2018 12/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure: application to evidence delivery to the Borrower(s). The earliest Closing Disclosure delivery to the Borrower(s). The earliest Closing Disclosure Cash-out -
date on or after provided in the loan file was used as the estimated baseline for Tolerance provided in the loan file was used as the estimated baseline Other
10/XX/2015, no Loan Testing. Depending on the actual values on the initial Loan Estimate, a fee for Tolerance Testing. Depending on the actual values on the
Estimates in the Loan tolerance cure of up to $XXX may be required. initial Loan Estimate, a fee tolerance cure of up to $XXX
File may be required.
649209097 XXX XXX 2 29375389 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM loan program disclosure not provided to the borrower. TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2018 12/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Test borrower. Cash-out -
Other
649209097 XXX XXX 2 29375390 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Consumer Handbook on Adjustable Rate Mortgages, CHARM TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2018 12/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM 2023/XX/XX: Missing CHARM
Status CHARM Booklet, not provided to the borrower. Booklet, not provided to the borrower. Cash-out - Booklet provided within 3
Other days of application.
649209097 XXX XXX 2 29375391 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure General Information: Final Closing Disclosure provided on TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2018 12/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure Product provided on 12/XX/2018 disclosed a Product that does not match the actual product 12/XX/2018 disclosed a Product that does not match the Cash-out -
Testing for the loan. Additional AIR/AP table failures could apply for loans with an actual product for the loan. Additional AIR/AP table Other
adjustable rate or adjustable payment with incorrect Product disclosure. failures could apply for loans with an adjustable rate or
(Final/12/XX/2018) adjustable payment with incorrect Product disclosure.
649209097 XXX XXX 2 29375392 credit 1 Income documentation Loan file is missing 2 year previous W-2's,and VVOE as 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Received required
requirements not met. required. Cash-out - documentation. Condition
Other cleared.
649209097 XXX XXX 2 29375393 credit 1 Verification(s) of Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: VVOE was not provided. 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Received required
employment is not within 12/XX/2002 Cash-out - documentation. Condition
10 business days of the Other cleared.
Note.
649209097 XXX XXX 2 29375394 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Loan file is missing 2 year previous W-2's,and VVOE as 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Received required
Provision Investor guideline components, the loan is at ATR risk. required. Cash-out - documentation. Condition
Guidelines Other cleared.
649209097 XXX XXX 2 29375395 credit 1 Guideline Requirement: Calculated investor qualifying total debt ratio of 46.59173% exceeds Guideline Guidelines allowed for a max DTI of 43.00%. Due to missing 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Received required
Investor qualifying total total debt ratio of 43.00000%. prior 2 years W-2's or 1040 tax returns, VVOE and Cash-out - documentation. Condition
debt ratio discrepancy. origination credit report, the calculated DTI 46.59173% Other cleared.
exceeds allowed DTI.
649209097 XXX XXX 2 29375396 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Guidelines allowed for a max DTI of 43.00%. Due to missing 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Received required
Provision Non QM DTI 1026.43(c)(5) of 49.68% significantly exceeds the guideline maximum of 43.00%. prior 2 years W-2's or 1040 tax returns, VVOE and Cash-out - documentation. Condition
significantly exceeds (DTI Exception requires compelling compensating factors to consider regrading to origination credit report, the calculated DTI 46.59173% Other cleared.
Guidelines EV2-B.) exceeds allowed DTI, causing the loan to waterfall through
the QM Testing.
649209097 XXX XXX 2 29375397 credit 1 Asset documentation The guidelines do not allow for cash proceeds to be used as 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Received required
requirements not met. verified assets. The borrower has no assets verified to Cash-out - documentation. Condition
meet the reserve requirement. Other cleared.
649209097 XXX XXX 2 29375398 credit 1 Guideline Requirement: Calculated PITIA months reserves of is less than Guideline PITIA months reserves The guidelines do not allow for cash proceeds to be used as 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Received required
PITIA reserves months of 6.00. verified assets. The borrower has no assets verified to Cash-out - documentation. Condition
discrepancy. meet the reserve requirement. Other cleared.
649209097 XXX XXX 2 29375399 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Nothing in the loan file to evidence delivery of the 12/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. appraisal to the borrower. Cash-out -
Business Days Prior to (Type:Primary/11/XX/2018) Other
Consummation
649209097 XXX XXX 2 29375400 credit 1 The verification of Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Received required
employment is required 12/XX/2002 Cash-out - documentation. Condition
and was not found in Other cleared.
file.
649208262 XXX XXX 1 29375531 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX 9/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes ATR Fail 2023/XX/XX: Received BPO
most recent valuation Disaster End Date: XX/XX/XXXX Rate/Term confirming no damage.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649208262 XXX XXX 1 29375532 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 9/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three (3) business days prior to consummation. Rate/Term
Business Days Prior to (Type:Secondary/06/XX/2017) (Type:Secondary/06/XX/2017)
Consummation
649208262 XXX XXX 1 29375533 compliance 3 Check Loan Designation Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Originator Loan Designation of Non QM does not match Due Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 9/XX/2017 CA Refinance - Primary No C C B B 7/XX/2023 ATR Fail 2023/XX/XX: agree. 2023/XX/XX: No new
Match - ATR not match Due Diligence Loan Designation of ATR Fail. Diligence Loan Designation of ATR Fail. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Rate/Term information/documentation
2023/XX/XX: Duplicate provided. Exception remains.
and/or waterfall
exception 2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649208262 XXX XXX 1 29375534 compliance 3 General Ability To Repay Ability-to-Repay (Dodd-Frank 2014): Unable to verify current K-1 (Less than 25% The file is missing the most recent signed and dated 1040 Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 9/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: agree. 2023/XX/XX: No new
Provision Employment - K- Ownership) status using reasonably reliable third-party records. (XXX/Schedule K- tax returns or most recent tax transcripts, causing the loan damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Rate/Term 2016 personal tax information/documentation
1 Less 25% 1 less than 25 Percent) to waterfall through the QM Testing. all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure returns are on provided. Exception remains.
to comply is not material). A private right of action may be brought before the end of the three- extension, as verified
year period beginning on the date of the occurrence of the violation. However, when a creditor, by extension in file 2023/XX/XX: Reviewed trailing
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial (1040s document documentation. Documents
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter uploaded 4/XX/2023 at necessary to clear the
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set- 5:40pm). However, conditions were not provided.
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages since 2016 business Exception remains.
for a valid claim brought in an original action, plus the costs to the consumer of the action. If returns and income
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set- were used to qualify,
off shall not exceed three years of finance charges and fees. An action to enforce a violation may the 2016 1040s should
also be brought by the appropriate state AGs. have been obtained -
or the 2014/2015
income should have
been documented and
used for qualifying.
2023/XX/XX: Duplicate
and/or waterfall
exception
649208262 XXX XXX 1 29375535 compliance 1 General Ability To Repay Ability-to-Repay (Dodd-Frank 2014): Unable to verify current Partnership status The file is missing third party verification, P&L statement Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 9/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Fail 2023/XX/XX: Borrower 2023/XX/XX: A cash flow of
Provision Employment - due to missing Tax Return/Transcript for the most recent year, and one of these and most recent transcript or signed/dated tax returns, damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Rate/Term is 20% owner of XXX, the Partnership owned at 20%
Partnership Test docs is required yet missing: Audited/Third Party P&L, CPA Letter, or other causing the loan to waterfall through the QM Testing. all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure therefore a P&L/BS by the borrower was utilized
Third Party Verification. (XXX XXX/Partnership) to comply is not material). A private right of action may be brought before the end of the three- and business tax in qualifying. Therefore,
year period beginning on the date of the occurrence of the violation. However, when a creditor, returns are not Third Party Verification,
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial requied. 2016 personal tax returns
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter (used 2016 business in
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set- 2023/XX/XX: Agree with qualifying), and P&L is
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages error for VOE and required.
for a valid claim brought in an original action, plus the costs to the consumer of the action. If mixing of years to
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set- qualify between 2023/XX/XX: Received required
off shall not exceed three years of finance charges and fees. An action to enforce a violation may personal and business documentation. Condition
also be brought by the appropriate state AGs. tax returns. 2016 cleared.
personal returns were
on extension. UB
guidelines (RLU-NA
section 302-2.1.3)
state Documentation
Requirements for self-
employed businesses:
when ownership in a
business is less than
25%, additional
verification &
documentation is not
required. Borrower is
not considered self-
employed when
ownership percentage
is less than 25%.
649208262 XXX XXX 1 29375536 compliance 1 General Ability To Repay Ability-to-Repay (Dodd-Frank 2014): Unable to verify current S-Corp status due to The file is missing third party verification, P&L statement Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 9/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Fail 2023/XX/XX: company 2023/XX/XX: An Upload
Provision Employment - S- missing Tax Return/Transcript for the most recent year, and one of these docs is and most recent transcript or signed/dated tax returns, damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Rate/Term website provided for indicated in lender's
Corp Test required yet missing: Audited/Third Party P&L, CPA Letter, or other Third Party causing the loan to waterfall through the QM Testing. all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure verification (uploaded rebuttal was not received.
Verification. (XXX XXX/S-Corp) to comply is not material). A private right of action may be brought before the end of the three- 4/XX/23 at 7:07am), Need 2016 signed and dated
year period beginning on the date of the occurrence of the violation. However, when a creditor, P&L/BS are in file personal tax returns (2016
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial (uploaded 4/XX/23 at business income used), third
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter 7:07am). Business party verification and P&L
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set- returns were not statement.
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages signed.
for a valid claim brought in an original action, plus the costs to the consumer of the action. If 2023/XX/XX: EXCEPTION HISTORY
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set- 2023/XX/XX: Uploaded: - Exception Detail was
off shall not exceed three years of finance charges and fees. An action to enforce a violation may Verbal VOE updated on 08/XX/2023 PRIOR
also be brought by the appropriate state AGs. IRS Tax Transcript Exception Detail: Ability-to-
Bank Statements Repay (Dodd-Frank 2014):
Business tax returns Unable to verify current S-
Personal tax returns Corp status due to most
Profit and Loss recent Tax Return end date is
older than 120 days before
2023/XX/XX: Provided: Closing Date, and one of
Verbal VOE these docs is required yet
IRS Tax Transcript missing: Audited/Third Party
Bank Statements P&L, CPA Letter, or other
Business tax returns Third Party Verification.
Personal tax returns (XXX XXX/S-Corp)
Profit and Loss
2023/XX/XX: Received required
documentation. Condition
cleared.
649208262 XXX XXX 1 29375537 compliance 3 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify K-1 (Less than 25% The file is missing the most recent signed and dated 1040 Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 9/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: agree. 2023/XX/XX: No new
Provision Income and Ownership) income using reasonably reliable third-party records. (XXX/Schedule K- tax returns or most recent tax transcripts, causing the loan damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Rate/Term 2015 & 2014 1040s were information/documentation
Assets - K-1 Less 25% 1 less than 25 Percent) to waterfall through the QM Testing. all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure provided, but business provided. Exception remains.
to comply is not material). A private right of action may be brought before the end of the three- income was calculated
year period beginning on the date of the occurrence of the violation. However, when a creditor, using 2015 & 2016 K1s 2023/XX/XX: Reviewed trailing
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial and business returns. documentation. Documents
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter necessary to clear the
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set- 2023/XX/XX: Duplicate conditions were not provided.
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages and/or waterfall Exception remains.
for a valid claim brought in an original action, plus the costs to the consumer of the action. If exception
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649208262 XXX XXX 1 29375538 compliance 3 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify Partnership income using One of the following missing documents is required for this Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 9/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: agree. 2023/XX/XX: No new
Provision Income and reasonably reliable third-party records. (XXX XXX/Partnership) income source: 1) Most recent tax transcripts; 2) Most damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Rate/Term 2015 & 2014 1040s were information/documentation
Assets - Partnership recent signed, dated 1040s; 3) Audited YTD P&L; 4) Most all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure provided, but business provided. Exception remains.
recent Business tax transcripts; 5) Most recent signed, to comply is not material). A private right of action may be brought before the end of the three- income was calculated
dated business returns. year period beginning on the date of the occurrence of the violation. However, when a creditor, using 2015 & 2016 K1s 2023/XX/XX: Reviewed trailing
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial and business returns. documentation. Documents
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter necessary to clear the
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set- 2023/XX/XX: Duplicate conditions were not provided.
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages and/or waterfall Exception remains.
for a valid claim brought in an original action, plus the costs to the consumer of the action. If exception
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649208262 XXX XXX 1 29375539 compliance 3 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify S-Corp income using One of the following missing documents is required for this Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 9/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: agree. 2023/XX/XX: No new
Provision Income and reasonably reliable third-party records. (XXX XXX/S-Corp) income source: 1) Most recent tax transcripts; 2) Most damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Rate/Term 2015 & 2014 1040s were information/documentation
Assets - S-Corp recent signed, dated 1040s; 3) Audited YTD P&L; 4) Most all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure provided, but business provided. Exception remains.
recent Business tax transcripts; 5) Most recent signed, to comply is not material). A private right of action may be brought before the end of the three- income was calculated
dated 1120S returns for 2016. year period beginning on the date of the occurrence of the violation. However, when a creditor, using 2015 & 2016 K1s 2023/XX/XX: Reviewed trailing
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial and business returns. documentation. Documents
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter necessary to clear the
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set- 2023/XX/XX: Duplicate conditions were not provided.
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages and/or waterfall Exception remains.
for a valid claim brought in an original action, plus the costs to the consumer of the action. If exception
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649208262 XXX XXX 1 29375541 compliance 2 Self-Employed Tax Return Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or The file is missing returns for 2016. 9/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Recency - ATR personal tax returns provided are not the most recent. Application Date Rate/Term
05/XX/2017, Most Recent Tax Return End Date 12/XX/2015, Tax Return Due Date
04/XX/2017. (XXX XXX/Schedule C)
649208262 XXX XXX 1 29375542 compliance 1 Self-Employed Tax Return Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or The file is missing returns for 2016. 9/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Fail 2023/XX/XX: 2016 Tax returns
Recency - ATR personal tax returns provided are not the most recent. Application Date Rate/Term provided. Exception cleared.
05/XX/2017, Most Recent Tax Return End Date 12/XX/2015, Tax Return Due Date
03/XX/2017. (XXX XXX/S-Corp)
649208262 XXX XXX 1 29375544 credit 1 Guideline Requirement: Calculated investor qualifying total debt ratio of 45.45285% exceeds Guideline The qualifying income used by the lender is not supported by 9/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Fail 2023/XX/XX: In order 2023/XX/XX: EXCEPTION HISTORY
Investor qualifying total total debt ratio of 45.00000%. documentation in the loan file, resulting in a DTI ratio of Rate/Term to correctly calculate - Exception Explanation was
debt ratio discrepancy. 47.60362%, which exceeds the guideline maximum of 45%. the income, either updated on 08/XX/2023 PRIOR
2016 1040s or 2014 Exception Explanation:
K1s/business returns Calculated investor
would be required. qualifying total debt ratio
However, total of 47.60362% exceeds
combined income from Guideline total debt ratio of
2015 to 2016 did 45.00000%.
decrease by 11%
(within the 20% 2023/XX/XX: The borrower's
tolerance), therefore income was calculated at $XXX
it can be supported versus $XXX. Unable to
that the income used accurately calculate income
for qualifying is due to missing two years
acceptable. business returns for West
Valley Radiology. Calculated
2023/XX/XX: Agree with DTI is 47.6036% which is over
error for VOE and guideline of 45%.
mixing of years to
qualify between 2023/XX/XX: Received required
personal and business documentation. Condition
tax returns. 2016 cleared.
personal returns were
on extension. UB
guidelines (RLU-NA
section 302-2.1.3)
state Documentation
Requirements for self-
employed businesses:
when ownership in a
business is less than
25%, additional
verification &
documentation is not
required. Borrower is
not considered self-
employed when
ownership percentage
is less than 25%.
649208262 XXX XXX 1 29375545 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Based on the loan failing one or more guideline components, 9/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Fail 2023/XX/XX: agree. 2023/XX/XX: No new
Provision Investor guideline components, the loan is at ATR risk. the loan is at ATR risk. Rate/Term 2015 & 2014 1040s were information/documentation
Guidelines provided, but business provided. Exception remains.
income was calculated
using 2015 & 2016 K1s 2023/XX/XX: Reviewed trailing
and business returns. documentation. Documents
necessary to clear the
2023/XX/XX: Duplicate conditions were not provided.
and/or waterfall Exception remains.
exception
2023/XX/XX: Cleared with
documentation provided in the
Trailing documents
649208262 XXX XXX 1 29375546 compliance 1 General ATR Provision Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Missing two years of supporting income documentation. Unable 9/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Fail 2023/XX/XX: 2015 & 2023/XX/XX: No new
Investor and Non QM DTIs Lenders Guidelines and 1026.43(c)(5) of 59.61763% significantly exceeds the to verify income as documented in file Rate/Term 2014 1040s were information/documentation
match and both guideline maximum of 45.00%. (DTI Exception requires compelling compensating provided, but business provided. Exception remains.
significantly exceed factors to consider regrading to EV2-B.) income was calculated
Guidelines using 2015 & 2016 K1s 2023/XX/XX: Due to DTI
and business returns. decrease, exception cleared.
New exception set based on
the reduced DTI.
649208262 XXX XXX 1 29375547 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the Missing completed document with borrower signature to TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2017 9/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Test borrower. support in compliance Rate/Term
649208262 XXX XXX 1 29375548 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Missing completed document with borrower signature to TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2017 9/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Status CHARM Booklet, not provided to the borrower. support in compliance Rate/Term
649208262 XXX XXX 1 29375549 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Interest Only period for seven years. TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2017 9/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Disclosure Payment on 09/XX/2017 with an increasing payment disclosed the due date of the last Rate/Term
Interest Only Until payment of interest only that does not match the actual last payment for the
loan. (Final/09/XX/2017)
649208262 XXX XXX 1 29375550 compliance 1 General Ability To Repay Ability-to-Repay (Dodd-Frank 2014): Unable to verify current S-Corp status due to The file is missing third party verification, P&L statement Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 9/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Fail 2023/XX/XX: ownership 2023/XX/XX: A cash flow of
Provision Employment - S- missing Tax Return/Transcript for the most recent year, and one of these docs is and most recent transcript or signed/dated tax returns, damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Rate/Term is 20%, therefore not the Partnership owned at 20%
Corp Test required yet missing: Audited/Third Party P&L, CPA Letter, or other Third Party causing the loan to waterfall through the QM Testing. all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure considered to be self- by the borrower was utilized
Verification. (XXX XXX/S-Corp) to comply is not material). A private right of action may be brought before the end of the three- employed. Verbal VOE in qualifying. Therefore,
year period beginning on the date of the occurrence of the violation. However, when a creditor, is in the file Third Party Verification,
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial (uploaded 4/XX/23 at 2016 personal tax returns
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter 5:18am) (used 2016 business in
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set- qualifying), and P&L is
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages 2023/XX/XX: Disagree required.
for a valid claim brought in an original action, plus the costs to the consumer of the action. If with interpretation of
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set- ATR requirements. UB 2023/XX/XX: Received required
off shall not exceed three years of finance charges and fees. An action to enforce a violation may guidelines (RLU-NA documentation. Condition
also be brought by the appropriate state AGs. section 302-2.1.3) cleared.
state Documentation
Requirements for self-
employed businesses:
when ownership in a
business is less than
25%, additional
verification &
documentation is not
required. Borrower is
not considered self-
employed when
ownership percentage
is less than 25%.
Additionally, UB
guidelines do not
require business tax
return transcripts.
649208262 XXX XXX 1 29375551 compliance 1 General ATR Provision Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Due to DTI in excess of guidelines, loan is waterfalling to 9/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Fail 2023/XX/XX: Duplicate 2023/XX/XX: Received required
Investor and Non QM DTIs Lenders Guidelines and 1026.43(c)(5) of 45.45285% moderately exceeds the standard QM/ATR requirements. Rate/Term and/or waterfall documentation. Condition
match and both moderately guideline maximum of 45.00%. (DTI Exception is eligible to be regraded with exception cleared.
exceed Guidelines compensating factors.)
649208012 XXX XXX 1 29375577 compliance 2 Missing Document: Missing The Initial signed and dated 1003 is missing from the loan 3/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Lender's Initial 1003 file. Cash-out -
Other
649208012 XXX XXX 1 29375578 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The property is located in a FEMA disaster area. Provide a 3/XX/2016 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received BPO
most recent valuation Disaster End Date: XX/XX/XXXX post-disaster inspection verifying there was no damage. The Cash-out - confirming no damage.
inspection is dated prior Disaster Name: XXX inspection must include exterior photos and the property Other
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX must be re-inspected on or after XX/XX/XXXX declared end
disaster. date.
649208012 XXX XXX 1 29375579 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each The loan file does not contain evidence the Appraisal report 3/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. was provided to the Borrower at lease three days prior to Cash-out -
Business Days Prior to (Type:Primary/02/XX/2016) closing. Other
Consummation
649208012 XXX XXX 1 29375580 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each The loan file does not contain evidence the Appraisal report 3/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. was provided to the Borrower at lease three days prior to Cash-out -
Business Days Prior to (Type:Secondary/02/XX/2016) closing. Other
Consummation
649208012 XXX XXX 1 29375581 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Evidence the Borrower received the CHARM Booklet with three TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2016 3/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower. days of application date is missing from the loan file. Cash-out -
Other
649208012 XXX XXX 1 29375582 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) The Initial Closing Disclosure signed and dated at least TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 3/XX/2016 3/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure Timing without at least three (3) business days prior to closing. (Final/03/XX/2016) three days prior to closing is missing from the loan file. Cash-out -
Waiver Other
649208012 XXX XXX 1 29375583 credit 3 Insufficient Coverage: Hazard Insurance Coverage is insufficient, please provide 3/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Hazard insurance coverage evidence of a Replacement Cost Estimate. Cash-out -
amount is insufficient. Other
649208362 XXX XXX 2 29375725 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Subject property was appraised on XX/XX/XXXX prior to the 11/XX/2016 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes ATR Fail 2023/XX/XX: Received BPO
most recent valuation Disaster End Date: XX/XX/XXXX FEMA disaster XXX) dated XX/XX/XXXX through XX/XX/XXXX. File Cash-out - confirming no damage.
inspection is dated prior Disaster Name: XXX is missing a property inspection dated after the disaster, Other
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX or the lender's Rep and Warranty attestation along with
disaster. visible confirmation that the subject property was not
damaged.
649208362 XXX XXX 2 29375726 credit 3 Guideline Financial Institution: XXX // Account Type: Stocks / Account Number: XXX, File is missing 2 consecutive months' statements dated 11/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: unable to 2023/XX/XX: Trailing docs did
Issue:Insufficient asset Financial Institution: XXX // Account Type: Individual Retirement Account (IRA) / within 90 days of Note date for accounts ending in XXX, XXX, Cash-out - locate updated assets not contain any docs to clear
documentation. Account Number: XXX, Financial Institution: XXX // Account Type: Individual XXX, XXX, XXX, XXX, XXX, XXX. Other statements to clear this exception.
Retirement Account (IRA) / Account Number: XXX, Financial Institution: XXX // finding
Account Type: Individual Retirement Account (IRA) / Account Number: XXX, 2023/XX/XX: Lender is unable
Financial Institution: XXX // Account Type: Stocks / Account Number: XXX, 2023/XX/XX: Agree with to clear condition. Exception
Financial Institution: XXX // Account Type: Stocks / Account Number: XXX error remains open.
2023/XX/XX: Reviewed all
trailing documentation.
Documents necessary to clear
condition were not provided.
2023/XX/XX: No supporting
trailing documentation was
provided to clear this
exception. Exception remains.
649208362 XXX XXX 2 29375727 credit 3 REO Documents are Address: XXX, CA, Address: XXX, CA, Address: XXX, CA Insurance Verification Insurance verification document is missing in file for all 3 11/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: unable to 2023/XX/XX: Trailing docs did
missing. Insurance Verification additional REOs owned by borrowers. Cash-out - locate insurance not contain any docs to clear
Insurance Verification Other verification for the this exception.
properites in question
2023/XX/XX: Lender is unable
2023/XX/XX: Agree with to clear condition. Exception
error remains open.
2023/XX/XX: Reviewed all
trailing documentation.
Documents necessary to clear
condition were not provided.
2023/XX/XX: No supporting
trailing documentation was
provided to clear this
exception. Exception remains.
649208362 XXX XXX 2 29375728 compliance 3 Check Loan Designation Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Waterfall exception due to missing the required income and Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 11/XX/2016 CA Refinance - Primary No C C B B 7/XX/2023 ATR Fail 2023/XX/XX: Agree 2023/XX/XX: Lender is unable
Match - ATR not match Due Diligence Loan Designation of ATR Fail. asset documentation. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - to clear condition. Exception
Other 2023/XX/XX: Duplicate remains open.
and/or waterfall
exception 2023/XX/XX: Reviewed all
trailing documentation.
Documents necessary to clear
condition were not provided.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649208362 XXX XXX 2 29375729 compliance 3 General Ability To Repay Ability-to-Repay (Dodd-Frank 2014): Unable to verify current S-Corp status due to File is missing third party verification of this business, Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 11/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: unable to 2023/XX/XX: Trailing docs did
Provision Employment - S- most recent Tax Return end date is older than 120 days before Closing Date, and along with the 2 years' most recent 1120s, K-1s and YTD P&L damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Cash-out - locate not contain any docs to clear
Corp Test one of these docs is required yet missing: Audited/Third Party P&L, CPA Letter, statement. all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Other this exception.
or other Third Party Verification. (XXX/S-Corp) to comply is not material). A private right of action may be brought before the end of the three- 2023/XX/XX: Agree with
year period beginning on the date of the occurrence of the violation. However, when a creditor, error 2023/XX/XX: Lender is unable
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial to clear condition. Exception
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter remains open.
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages 2023/XX/XX: Reviewed all
for a valid claim brought in an original action, plus the costs to the consumer of the action. If trailing documentation.
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set- Documents necessary to clear
off shall not exceed three years of finance charges and fees. An action to enforce a violation may condition were not provided.
also be brought by the appropriate state AGs.
2023/XX/XX: No supporting
trailing documentation was
provided to clear this
exception. Exception remains.
649208362 XXX XXX 2 29375730 compliance 3 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify current Wages/W-2 employment File is missing verification of employment for borrower's Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 11/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: unable to 2023/XX/XX: Trailing docs did
Provision Employment - W- status using reasonably reliable third-party records. (XXX XXX/Wages) caregiver positions. damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Cash-out - locate not contain any docs to clear
2 all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Other this exception.
to comply is not material). A private right of action may be brought before the end of the three- 2023/XX/XX: Duplicate
year period beginning on the date of the occurrence of the violation. However, when a creditor, and/or waterfall 2023/XX/XX: Lender is unable
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial exception to clear condition. Exception
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter remains open.
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages 2023/XX/XX: Reviewed all
for a valid claim brought in an original action, plus the costs to the consumer of the action. If trailing documentation.
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set- Documents necessary to clear
off shall not exceed three years of finance charges and fees. An action to enforce a violation may condition were not provided.
also be brought by the appropriate state AGs.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649208362 XXX XXX 2 29375731 compliance 3 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify current Wages/W-2 employment File is missing verification of employment for borrower's Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 11/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: N/A; 2023/XX/XX: Trailing docs did
Provision Employment - W- status using reasonably reliable third-party records. (XXX XXX/Wages) caregiver positions. damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Cash-out - Duplicative Exception not contain any docs to clear
2 all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Other this exception.
to comply is not material). A private right of action may be brought before the end of the three- 2023/XX/XX: Duplicate
year period beginning on the date of the occurrence of the violation. However, when a creditor, and/or waterfall 2023/XX/XX: Lender is unable
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial exception to clear condition. Exception
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter remains open.
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages 2023/XX/XX: Reviewed all
for a valid claim brought in an original action, plus the costs to the consumer of the action. If trailing documentation.
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set- Documents necessary to clear
off shall not exceed three years of finance charges and fees. An action to enforce a violation may condition were not provided.
also be brought by the appropriate state AGs.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649208362 XXX XXX 2 29375732 compliance 3 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verity asset depletion income due Unable to verity asset depletion income due to, bank 11/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: N/A; 2023/XX/XX: Reviewed all
Provision Income and to, bank statement provided was dated more than 90 days prior to closing. statements provided are all dated more than 90 days prior to Cash-out - Duplicative Exception trailing documents. The
Assets - Asset Depletion (XXX/Asset Depletion) to the Note date. Please provide two consecutive months' Other documents to clear the ATR
Income statements for all accounts used, dated within 90 days of 2023/XX/XX: Duplicate exceptions were not among
Note date. and/or waterfall them. The ARM change notice
exception was among the docs.
2023/XX/XX: Trailing docs did
not contain any docs to clear
this exception.
2023/XX/XX: Lender is unable
to clear condition. Exception
remains open.
2023/XX/XX: Reviewed all
trailing documentation.
Documents necessary to clear
condition were not provided.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649208362 XXX XXX 2 29375734 compliance 2 Self-Employed Tax Return Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or Missing 2 years' most recent tax returns for co-borrower's 11/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail 2023/XX/XX: Trailing docs did
Recency - ATR personal tax returns provided are not the most recent. Application Date S-corp. Cash-out - not contain any docs to clear
07/XX/2016, Most Recent Tax Return End Date 12/XX/2014, Tax Return Due Date Other this exception.
03/XX/2016. (XXX/S-Corp)
2023/XX/XX: Reviewed all
trailing documentation.
Documents necessary to clear
condition were not provided.
649208362 XXX XXX 2 29375735 compliance 2 Self-Employed Tax Return Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or Missing 2 years' most recent tax returns for co-borrower's 11/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail 2023/XX/XX: Trailing docs did
Recency - ATR personal tax returns provided are not the most recent. Application Date S-corp. Cash-out - not contain any docs to clear
07/XX/2016, Most Recent Tax Return End Date 12/XX/2014, Tax Return Due Date Other this exception.
03/XX/2016. (XXX XXX/S-Corp)
2023/XX/XX: Reviewed all
trailing documentation.
Documents necessary to clear
condition were not provided.
649208362 XXX XXX 2 29375736 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Zero Percent Fee Tolerance exceeded for Credit Report Fee. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 11/XX/2016 11/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Tolerance Violation Report Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient Cash-out -
Without Sufficient Cure cure was provided to the borrower. (7520) or no cure was provided to the borrower. Other
Provided
649208362 XXX XXX 2 29375737 credit 3 The verification of Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: 11/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: note dated 2023/XX/XX: Trailing docs did
employment is required 01/XX/2008 Cash-out - 11/XX/2016, VOE for not contain any docs to clear
and was not found in Other XXX dated 11/XX/2016 this exception.
file.
2023/XX/XX: Provided 2023/XX/XX: Additional
VOE for XXX dated information for this employer
11/XX/2016. was not provided. Exception
remains open.
2023/XX/XX: Reviewed all
trailing documentation.
Documents necessary to clear
condition were not provided.
2023/XX/XX: No supporting
trailing documentation was
provided to clear this
exception. Exception remains.
649208362 XXX XXX 2 29375738 credit 3 The verification of Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: Missing verification of employment for borrower's XXX 11/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: unable to 2023/XX/XX: Trailing docs did
employment is required 01/XX/2008 positions. Cash-out - locate not contain any docs to clear
and was not found in Other this exception.
file. 2023/XX/XX: Agree with
error 2023/XX/XX: Lender is unable
to clear condition. Exception
remains open.
2023/XX/XX: Reviewed all
trailing documentation.
Documents necessary to clear
condition were not provided.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649208362 XXX XXX 2 29375739 compliance 3 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify current Wages/W-2 employment VOE for this employer was missing from the file. Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 11/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: W2/Paystub 2023/XX/XX: Trailing docs did
Provision Employment - W- status using reasonably reliable third-party records. (XXX XXX/Wages) damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Cash-out - in file and was used not contain any docs to clear
2 all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Other to calculate income this exception.
to comply is not material). A private right of action may be brought before the end of the three-
year period beginning on the date of the occurrence of the violation. However, when a creditor, 2023/XX/XX: Duplicate 2023/XX/XX: VVOE performed
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial and/or waterfall within ten days of the Note
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter exception was not provided. Exception
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set- remains open.
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If 2023/XX/XX: Reviewed all
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set- trailing documentation.
off shall not exceed three years of finance charges and fees. An action to enforce a violation may Documents necessary to clear
also be brought by the appropriate state AGs. condition were not provided.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649208362 XXX XXX 2 29375740 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM loan program disclosure provided is not signed or dated TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2016 11/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Test borrower. to determine it was delivered within 3 business days of Cash-out -
application. Other
649208362 XXX XXX 2 29375741 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2016 11/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649208362 XXX XXX 2 29375742 credit 3 Verification(s) of Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: Missing VVOE dated within 10 days of Note date for 11/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: unable to 2023/XX/XX: Trailing docs did
employment is not within 01/XX/2008 borrower's wage earner income used in income qualification. Cash-out - locate not contain any docs to clear
10 calendar days of the Other this exception.
Note. 2023/XX/XX: Agree with
error 2023/XX/XX: Lender is unable
to clear condition. Exception
remains open.
2023/XX/XX: Reviewed all
trailing documentation.
Documents necessary to clear
condition were not provided.
2023/XX/XX: No supporting
trailing documentation was
provided to clear this
exception. Exception remains.
649208362 XXX XXX 2 29375743 credit 3 Verification(s) of Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: Missing VVOE dated within 10 days of Note date for 11/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: unable to 2023/XX/XX: Trailing docs did
employment is not within 01/XX/2008 borrower's wage earner income used in income qualification. Cash-out - locate not contain any docs to clear
10 calendar days of the Other this exception.
Note. 2023/XX/XX: Duplicate
and/or waterfall 2023/XX/XX: Lender is unable
exception to clear condition. Exception
remains open.
2023/XX/XX: Reviewed all
trailing documentation.
Documents necessary to clear
condition were not provided.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649208362 XXX XXX 2 29375744 credit 1 Verification(s) of Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: Missing VVOE dated within 10 days of Note date for 11/XX/2016 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Fail 2023/XX/XX: note dated 2023/XX/XX: Trailing docs did
employment is not within 11/XX/2010 borrower's wage earner income used in income qualification. Cash-out - 11/XX/2016, VOE for not contain any docs to clear
10 calendar days of the Other Tony Wang dated this exception.
Note. 11/XX/2016
2023/XX/XX: VVOE located.
Exception is clear.
649208362 XXX XXX 2 29375745 credit 3 Verification(s) of Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: Missing VVOE dated within 10 days of Note date for 11/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: unable to 2023/XX/XX: Trailing docs did
employment is not within 11/XX/2011 borrower's wage earner income used in income qualification. Cash-out - locate not contain any docs to clear
10 calendar days of the Other this exception.
Note. 2023/XX/XX: Duplicate
and/or waterfall 2023/XX/XX: Lender is unable
exception to clear condition. Exception
remains open.
2023/XX/XX: Reviewed all
trailing documentation.
Documents necessary to clear
condition were not provided.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649208362 XXX XXX 2 29375746 credit 3 Income Docs Missing: Borrower: XXX 1120S (2014), 1120S (2015), K-1 (2014), K-1 (2015), P&L Statement File is missing the following income documentation for the 11/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: unable to 2023/XX/XX: Trailing docs did
co-borrower's 2 S-corp businesses: 2014 and 2015 1120s, Cash-out - locate not contain any docs to clear
2014 and 2015 K-1s and YTD P&L for both businesses. Other this exception.
2023/XX/XX: Agree with
error 2023/XX/XX: Lender is unable
to clear condition. Exception
remains open.
2023/XX/XX: Reviewed all
trailing documentation.
Documents necessary to clear
condition were not provided.
2023/XX/XX: No supporting
trailing documentation was
provided to clear this
exception. Exception remains.
649208663 XXX XXX 1 29376042 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 4/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three business days prior to consummation. Cash-out -
Business Days Prior to (Type:Primary/03/XX/2018) Other
Consummation
649208663 XXX XXX 1 29376043 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - No Cure found in file. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2018 4/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Tolerance Violation Recording Service Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Cash-out -
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (75197) Other
Provided
649208663 XXX XXX 1 29376044 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower. TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2018 4/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649208663 XXX XXX 1 29376045 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Adjustable Payment Table: Final Closing Final Closing Disclosure provided on 04/XX/2018 disclosed a TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2018 4/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure AP Table Disclosure provided on 04/XX/2018 disclosed a Maximum Payment amount and period Maximum Payment amount and period that does not match the Cash-out -
Maximum Payment that does not match the actual terms for the loan. (Final/04/XX/2018) actual terms for the Other
649208663 XXX XXX 1 29376046 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final Closing Disclosure provided on 04/XX/2018 with an TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2018 4/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure Payment Max on 04/XX/2018 with an increasing payment disclosed the earliest date of the increasing payment disclosed the earliest date of the Cash-out -
Amount In Year maximum possible amount of principal and interest that does not match the actual maximum possible amount of principal and interest that does Other
earliest date for the loan. (Final/04/XX/2018) not match the actual earliest date for the loan.
649208663 XXX XXX 1 29376047 compliance 2 General Ability To Repay Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender Updated Qualification Method of Greater of the fully indexed 4/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Provision Investor does not match the ATR payment calculation methods under 1026.43(c)(5). rate at the fully amortized payment or the note rate at Cash-out -
Qualification Method not fully amortized payment. Other
Matching ATR
649207248 XXX XXX 1 29376197 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement E-Sign Consent Agreement is not provided. 11/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
is missing. Cash-out -
Other
649207248 XXX XXX 1 29376198 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Post Disaster Inspection report is not provided for Disaster 11/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 5/XX/2023 Yes Non QM 2023/XX/XX: Received BPO.
most recent valuation Disaster End Date: XX/XX/XXXX End date XX/XX/XXXX. Cash-out - Condition cleared.
inspection is dated prior Disaster Name: XXX Other
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207248 XXX XXX 1 29376199 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Documentations acknowledging receipt of appraisal within 3 11/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. business days from closing not provided. Cash-out -
Business Days Prior to (Type:Primary/10/XX/2017) Other
Consummation
649207248 XXX XXX 1 29376200 compliance 2 General Ability To Repay Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender 11/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Provision Investor does not match the ATR payment calculation methods under 1026.43(c)(5). Cash-out -
Qualification Method not Other
Matching ATR
649207248 XXX XXX 1 29376201 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2017 11/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Test borrower. Cash-out -
Other
649207248 XXX XXX 1 29376202 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2017 11/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649207248 XXX XXX 1 29376203 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Acknowledgment date was 9/XX/2017 which is more than 3 days RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 11/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
of Homeownership Organizations not provided to applicant within three (3) business days of from Initial application date. implementing regulation, Regulation X, for these type of violations. Cash-out -
Counseling Organizations application. Other
Not Provided Within 3
Business Days of
Application
649207128 XXX XXX 1 29376279 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet is not provided to the borrower within three TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2018 6/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Timing CHARM Booklet, not provided to the borrower within three (3) days of application. (3) days of application, need proof when disclosure was Cash-out -
mailed to borrower. Other
649207128 XXX XXX 1 29376280 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Missing evidence the borrower was provided a copy of the 6/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. appraisal within three (3) business days prior to Cash-out -
Business Days Prior to (Type:Primary/06/XX/2018) consummation. Other
Consummation
649207128 XXX XXX 1 29376281 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure in file dated 06/XX/2018 is not signed, TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 6/XX/2018 6/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure Timing without at least three (3) business days prior to closing. (Initial/06/XX/2018) dated by borrowers and file is missing evidence when the Cash-out -
Waiver borrowers received a copy of the closing disclosure. Other
Therefore a received date is being calculated to 06/XX/2018.
649207128 XXX XXX 1 29376282 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM loan program disclosure was not provided to the borrower TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2018 6/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Test borrower within three (3) days of application. within three (3) days of application, need proof when Cash-out -
disclosure was mailed to borrower. Other
649207128 XXX XXX 1 29376283 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Most recent Valuation Date in file is XX/XX/XXXX which is 6/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: PDI provided,
most recent valuation Disaster End Date: XX/XX/XXXX prior to the Disaster Declaration XX/XX/XXXX. Cash-out - exception cleared.
inspection is dated prior Disaster Name: XXX Other
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207128 XXX XXX 1 29376284 credit 3 Insufficient Coverage: Hazard Policy in file reflects Dwelling Coverage of $XXX 6/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Hazard insurance coverage plus 100% Replacement Cost Coverage $XXX (used 80% of the Cash-out -
amount is insufficient. appraised value) leaving a Shortfall of $XXX. Other
649207710 XXX XXX 2 29376397 credit 1 REO Documents are Address: XXX, CA HOA Verification HOA Verification is missing for XXX, CA. 8/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Risk 2023/XX/XX: Agree with 2023/XX/XX: HOA document
missing. Rate/Term findings. The July located in file.
2019 HOA quarterly
statement from XXX is
in loan file. The
quarterly payment is
$XXX ($XXX annually).
The annual HOA dues
were not accounted for
in the schedule E
rental income analysis
for the property in
question. Adding the
annual payment of $XXX
would result in
monthly negative
cashflow of $XXX vs
$XXX revising the
total net rental
income from $XXX to
$XXX. Revised
qualifying income
would be $XXX. Revised
DTI would be 49.675%
consisting of $XXX
PITI payment against
revised income of
$XXX.
649207710 XXX XXX 2 29376398 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA Disaster area 8/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes ATR Risk 2023/XX/XX: PDI provided,
most recent valuation Disaster End Date: XX/XX/XXXX post-close. A post-disaster inspection verifying there was Rate/Term exception cleared.
inspection is dated prior Disaster Name: XXX no damage to the subject property is required.
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207710 XXX XXX 2 29376399 compliance 3 Check Loan Designation Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Originator Loan Designation of Non QM does not match Due Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 8/XX/2019 CA Refinance - Primary No C C B B 7/XX/2023 ATR Risk 2023/XX/XX: Although 2023/XX/XX: The guidelines
Match - ATR Risk not match Due Diligence Loan Designation of ATR Risk. Diligence Loan Designation due to DTI Discrepancy. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Rate/Term HOA dues were require the subject payment
errorneously excluded to use the greater of the
from debt service Note rate or the fully-
which causes indexed rate amortized over
excessived DTI, ATR is the remaining 23 years,
still met as borrowers resulting in a qualifying DTI
residual income is ratio of 52%. The DTI
$XXX per mos exceeds the maximum allowed
by more than 5% and is not
2023/XX/XX: Agree with eligible to be waived
error, but don't agree regraded.
with ATR impact based
on overall file risk & 2023/XX/XX: No supporting
quality. trailing documentation was
provided to clear this
exception. Exception remains.
649207710 XXX XXX 2 29376400 compliance 3 General ATR Provision Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Calculated DTI of 52.48% exceeds guideline limit of DTI 45%. 8/XX/2019 CA Refinance - Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/XX: Already 2023/XX/XX: The guidelines
Investor and Non QM DTIs Lenders Guidelines and 1026.43(c)(5) of 52.60415% significantly exceeds the Rate/Term addressed above. require the subject payment
match and both guideline maximum of 45.00%. (DTI Exception requires compelling compensating Justifications for DTI to use the greater of the
significantly exceed factors to consider regrading to EV2-B.) exception- Per final Note rate or the fully-
Guidelines 1008; Low LTV 25.255% indexed rate amortized over
and Liquidity, post the remaining 23 years,
close reserves equal resulting in a qualifying DTI
to 150 months PITI ratio of 52%. The DTI
exceeds the maximum allowed
2023/XX/XX: Agree with by more than 5% and is not
error, but don't agree eligible to be waived
with ATR impact based regraded.
on overall file risk &
quality. 2023/XX/XX: No supporting
trailing documentation was
provided to clear this
exception. Exception remains.
649207710 XXX XXX 2 29376401 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure not provided to Borrower(s) at least TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 8/XX/2019 8/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Disclosure Timing without at least three (3) business days prior to closing. (Initial/08/XX/2019) three (3) business days prior to closing. Rate/Term
Waiver
649207710 XXX XXX 2 29376402 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 8/XX/2019 8/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Tolerance Violation Appraisal Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no Amount of $XXX exceeds tolerance of $XXX. Rate/Term
Without Sufficient Cure cure was provided to the borrower. (7506)
Provided
649207710 XXX XXX 2 29376403 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Zero Percent Fee Tolerance exceeded for Credit Report Fee. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 8/XX/2019 8/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Tolerance Violation Report Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no Fee Amount of $XXX exceeds tolerance of $XXX. Rate/Term
Without Sufficient Cure cure was provided to the borrower. (7520)
Provided
649207710 XXX XXX 2 29376404 credit 3 Guideline Requirement: Calculated investor qualifying total debt ratio of 52.60415% exceeds Guideline Calculated DTI of 52.48% exceeds guideline limit of DTI 45%. 8/XX/2019 CA Refinance - Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/XX: N/A; 2023/XX/XX: The guidelines
Investor qualifying total total debt ratio of 45.00000%. Rate/Term Duplicative Exception require the subject payment
debt ratio discrepancy. to use the greater of the
2023/XX/XX: Agree with Note rate or the fully-
error, but don't agree indexed rate amortized over
with ATR impact based the remaining 23 years,
on overall file risk & resulting in a qualifying DTI
quality. ratio of 52%. The DTI
exceeds the maximum allowed
by more than 5% and is not
eligible to be waived
regraded.
2023/XX/XX: No supporting
trailing documentation was
provided to clear this
exception. Exception remains.
649207710 XXX XXX 2 29376405 compliance 3 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Loan has ATR failure due to DTI discrepancy. 8/XX/2019 CA Refinance - Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/XX: Already 2023/XX/XX: The guidelines
Provision Investor guideline components, the loan is at ATR risk. Rate/Term addressed above. require the subject payment
Guidelines Justifications for DTI to use the greater of the
exception- Per final Note rate or the fully-
1008; Low LTV XX.XX% indexed rate amortized over
and Liquidity, post the remaining 23 years,
close reserves equal resulting in a qualifying DTI
to 150 months PITI ratio of 52%. The DTI
exceeds the maximum allowed
2023/XX/XX: Agree with by more than 5% and is not
error, but don't agree eligible to be waived
with ATR impact based regraded.
on overall file risk &
quality. 2023/XX/XX: No supporting
trailing documentation was
provided to clear this
exception. Exception remains.
649208811 XXX XXX 2 29376422 credit 3 Income Docs Missing: Borrower: XXX 4506-T (2017) The file is missing a copy of the 4506-C (2016), 4506-T 3/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM 2023/XX/XX: Disagree. 2023/XX/XX: EXCEPTION HISTORY
(2017). Cash-out - 4506-T in file - Exception Explanation was
Other covering 2017 & 2016. updated on 06/XX/2023 PRIOR
Okay to use 4506-T for Exception Explanation: 4506-C
these years based on (2016), 4506-C (2017), 4506-T
file date in 2018, (2016), 4506-T (2017)
4506-C was not
required for 3rd party 2023/XX/XX: EXCEPTION HISTORY
IRS transcript - Exception Explanation was
requests until May 1 updated on 08/XX/2023 PRIOR
2021. Exception Explanation: 4506-C
(2016), 4506-C (2017), 4506-T
(2017)
2023/XX/XX: None of the 4506-
T document cover the year
2017.
649208811 XXX XXX 2 29376423 credit 1 Missing Document: The file is missing a copy of the Appraisal. 3/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Appraisal
Appraisal not provided Cash-out - provided
Other
649208811 XXX XXX 2 29376424 credit 1 FEMA Disaster Issue: Disaster Name: XXX Loan file is missing a post-disaster inspection report. 3/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: PDI provided,
Property is located in a Disaster Declaration Date: XX/XX/XXXX Cash-out - exception cleared.
FEMA Disaster area and Disaster End Date: XX/XX/XXXX Other
has not been inspected.
649208811 XXX XXX 2 29376425 compliance 1 TRID Closing Disclosure TILA-RESPA Integrated Disclosure: Closing Disclosure not provided or Closing Final CD has not been provided. The only CD in the file is a High Cost or Anti-Predatory Lending Testing impact, therefore no SOL considerations. 3/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Initial and final
Status Test Disclosure not provided prior to closing. Any applicable Federal, State or Local post closing CD issued 06/XX/2018. For TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to Cash-out - CDs were provided
compliance testing is unreliable or not performed. Loan is subject to high cost foreclosure. Assignee liability. Other
testing.
649208811 XXX XXX 2 29376426 compliance 1 Right of Rescission Missing Final Closing Disclosure Received Date. Unable to determine compliance Final CD has not been provided. TILA ROR - 3yrs for rescindable transactions. 3/XX/2018 3/XX/2021 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Initial and final
Timing - Receipt Date with rescission timing requirements. Cash-out - CDs were provided
Missing Other
649208811 XXX XXX 2 29376427 compliance 1 Check Loan Designation Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Loan designation of ATR Fail is due to the missing income Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 3/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Signed copy of
Match - ATR not match Due Diligence Loan Designation of ATR Fail. documentation. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - the 2016 1120 was provided
Other
649208811 XXX XXX 2 29376428 compliance 1 General Ability To Repay Ability-to-Repay (Dodd-Frank 2014): Unable to verify current C-Corp status due to Audited/Third Party P&L, CPA Letter, or other Third Party Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 3/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Verification of
Provision Employment - C- missing Tax Return/Transcript for the most recent year, and one of these docs is Verification is required and missing. damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Cash-out - the business was provided
Corp 1120 Test required yet missing: Audited/Third Party P&L, CPA Letter, or other Third Party all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Other
Verification. (XXX XXX/C-Corp 1120) to comply is not material). A private right of action may be brought before the end of the three-
year period beginning on the date of the occurrence of the violation. However, when a creditor,
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649208811 XXX XXX 2 29376429 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify C Corp income using Audited/Third Party P&L, CPA Letter, or other Third Party Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 3/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Signed copy of
Provision Income and reasonably reliable third-party records. (XXX XXX/C-Corp 1120) Verification is required and missing. damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Cash-out - the 2016 1120 was provided
Assets - C Corporation all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Other
1120 to comply is not material). A private right of action may be brought before the end of the three-
year period beginning on the date of the occurrence of the violation. However, when a creditor,
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649208811 XXX XXX 2 29376431 credit 3 Guideline Requirement: Calculated combined loan to value percentage of 81.47668% exceeds Guideline Subject mortgage $XXX plus 2nd mortgage $XXX = $XXX. 3/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Combined loan to value combined loan to value percentage of 80.00000%. Appraisal missing, LTV calculated with $XXX value = 81.476%. Cash-out -
discrepancy. Other
649208811 XXX XXX 2 29376432 compliance 1 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy Proof of appraisal delivery was not provided There is generally no Assignee Liability. 3/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Appraisal was
Appraisal Not Provided at of the appraisal at least three (3) business days prior to closing, and appraisal Cash-out - provided to the borrower per
or Before Closing (3-Day was not provided at or before closing. (Type:Primary/09/XX/2017) Other the conversation log
Waiver In File)
649208811 XXX XXX 2 29376433 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Fee increased with the 03//XX/2018 CD without a valid CIC or TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 3/XX/2018 3/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Tolerance Violation Appraisal Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no cure at close Cash-out -
Without Sufficient Cure cure was provided to the borrower. (7507) Other
Provided
649208811 XXX XXX 2 29376434 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement Initial 03/XX/2018 CD was electronically provided to the 3/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
is missing. borrower per the Conversation Log but proof of receipt was Cash-out -
not found Other
649209242 XXX XXX 2 29376706 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Yes 11/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received BPO.
most recent valuation Disaster End Date: XX/XX/XXXX Cash-out - Condition cleared.
inspection is dated prior Disaster Name: XXX Other
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649209242 XXX XXX 2 29376707 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 11/XX/2018 12/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649209242 XXX XXX 2 29376708 credit 1 Missing Document: Flood Yes 11/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Exception
Certificate not provided Cash-out - cleared.
Other
649209242 XXX XXX 2 29376709 credit 1 Missing Document: Credit Yes 11/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received
Report not provided Cash-out -
Other
649209242 XXX XXX 2 29376710 credit 1 Missing Document: Yes 11/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Exception
Occupancy Certificate not Cash-out - cleared.
provided Other
649209242 XXX XXX 2 29376711 compliance 3 Missing Document: Note - Yes 11/XX/2018 CA Refinance - Primary No D D D D 7/XX/2023 Non QM
Subject Lien not provided Cash-out -
Other
649209242 XXX XXX 2 29376712 credit 3 Insufficient Coverage: HOI coverage is insufficient by $XXX. Provide updated Yes 11/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Hazard insurance coverage policy reflecting minimum coverage of $XXX OR Provide copy Cash-out -
amount is insufficient. of insurer's replacement cost estimate supporting current Other
coverage amount.
649209242 XXX XXX 2 29376713 credit 1 Income Docs Missing: Borrower: XXX 4506-T (2016), 4506-T (2017), Award Letter / Continuance Letter, Yes 11/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Exception
Paystubs, W-2 (2016), W-2 (2017) Cash-out - cleared.
Other
649209242 XXX XXX 2 29376714 credit 1 Guideline Financial Institution: XXX // Account Type: Stocks / Account Number: XXX Guidelines require 2 months asset statements, only one month Yes 11/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Exception
Issue:Insufficient asset provided in file. Cash-out - cleared.
documentation. Other
649209242 XXX XXX 2 29376715 compliance 1 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. Yes 11/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: FACTA disclosure
Cash-out - received
Other
649209242 XXX XXX 2 29376716 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or Yes 11/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Account Statement Missing implementing regulation, Regulation X, for these type of violations. Cash-out -
Other
649209242 XXX XXX 2 29376717 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify alternate income source Missing income documentation for retirement income. Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory Yes 11/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Exception
Provision Income and using reasonably reliable third-party records. (XXX XXX/Social Security) damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Cash-out - cleared.
Assets - Other Income Doc all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Other
Source Null to comply is not material). A private right of action may be brought before the end of the three-
year period beginning on the date of the occurrence of the violation. However, when a creditor,
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649209242 XXX XXX 2 29376718 compliance 1 Check Loan Designation Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Due to missing income and asset documentation. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR Yes 11/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: All missing
Match - ATR not match Due Diligence Loan Designation of ATR Fail. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - income and asset
Other documentation has been
received.
649209242 XXX XXX 2 29376719 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify debt obligations using Credit report missing in loan file Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory Yes 11/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Credit report
Provision Credit History reasonably reliable third-party records. damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Cash-out - received
all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Other
to comply is not material). A private right of action may be brought before the end of the three-
year period beginning on the date of the occurrence of the violation. However, when a creditor,
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649209242 XXX XXX 2 29376720 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify income due to, missing W- Missing income documentation for all income sources used to Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory Yes 11/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Exception
Provision Income and 2, Paystub, LES, ETS or WVOE. (XXX XXX/Wages) qualify. damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Cash-out - cleared.
Assets - Wages all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Other
to comply is not material). A private right of action may be brought before the end of the three-
year period beginning on the date of the occurrence of the violation. However, when a creditor,
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649209242 XXX XXX 2 29376722 compliance 1 TRID Closing Disclosure TILA-RESPA Integrated Disclosure: Closing Disclosure not provided or Closing No CD's in file are executed by the borrower to determine High Cost or Anti-Predatory Lending Testing impact, therefore no SOL considerations. Yes 11/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Final CD was
Status Test Disclosure not provided prior to closing. Any applicable Federal, State or Local received date. For TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to Cash-out - provided.
compliance testing is unreliable or not performed. Loan is subject to high cost foreclosure. Assignee liability. Other
testing.
649209242 XXX XXX 2 29376723 compliance 1 Right of Rescission Missing Final Closing Disclosure Received Date. Unable to determine compliance No CD's in file are executed by the borrower to determine TILA ROR - 3yrs for rescindable transactions. Yes 11/XX/2018 12/XX/2021 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Final CD was
Timing - Receipt Date with rescission timing requirements. received date. Cash-out - provided.
Missing Other
649209242 XXX XXX 2 29376724 property 3 Missing Document: Valuation Type: Appraisal / Valuation Report Date: 10/XX/2018 Yes 11/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Appraisal was made Cash-out -
"subject to" and Form Other
1004D/442 was not
provided.
649209242 XXX XXX 2 29376725 compliance 2 ARM Disclosure Timing Unable to determine if ARM disclosure was provided within three (3) days of ARM Disclosure in the file does not contain a date provided. TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 11/XX/2018 12/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Test application due to missing information. Cash-out -
Other
649209242 XXX XXX 2 29376726 compliance 2 ECOA Appraisal Disclosure ECOA - File does not evidence the consumer was provided with the right to receive Evidence of borrower's earlier receipt of the disclosure was Yes 11/XX/2018 12/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
- ECOA Timing a copy of the Appraisal Disclosure within 3 days of the loan application date. not provided. Cash-out -
Other
649209242 XXX XXX 2 29376727 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling The Fraud Report reflects an application date of 10/XX/2018, RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or Yes 11/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
of Homeownership Organizations not provided to applicant within three (3) business days of disclosure not provided within 3 business days of implementing regulation, Regulation X, for these type of violations. Cash-out -
Counseling Organizations application. application. Other
Not Provided Within 3
Business Days of
Application
649209242 XXX XXX 2 29376728 compliance 2 TRID Loan Estimate Timing TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the The Fraud Report reflects an application date of 10/XX/2018, TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. Yes 11/XX/2018 12/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
mail to Borrower(s) within three (3) business days of application. disclosure not provided within 3 business days of Cash-out -
(Initial/10/XX/2018) application. Other
649209242 XXX XXX 2 29376729 credit 1 Asset documentation File is missing required bank statements as required by Yes 11/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Exception
requirements not met. lender guides to support required reserves. Cash-out - cleared.
Other
649209242 XXX XXX 2 29376730 credit 1 Income documentation File is missing required income documents as listed in Yes 11/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Exception
requirements not met. lender guides. Cash-out - cleared.
Other
649209242 XXX XXX 2 29376731 compliance 1 Income/Asset Guideline Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to File is missing critical documentation to complete DD Yes 11/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Exception
Deficiency - ATR Impact income and/or asset doc requirements which could result in a risk to the review: credit report, current paystubs, most recent 2 years Cash-out - cleared.
borrower's ability to repay. (Exception is eligible to be regraded with W2's, bank statements, award letter and 4506's. Other
compensating factors.)
649209242 XXX XXX 2 29376732 credit 1 AUS/Guideline Findings: File is missing critical documentation to complete DD Yes 11/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Exception
All conditions were not review: credit report, current paystubs, most recent 2 years Cash-out - cleared.
met W2's, bank statements, award letter and 4506's. Other
649209242 XXX XXX 2 29376733 compliance 2 Missing Document: Missing File is missing a fully executed initial application Yes 11/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Lender's Initial 1003 Cash-out -
Other
649209242 XXX XXX 2 29376734 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Guidelines provided do not address all 8 Failure due to missing income and asset documentation and Yes 11/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: All missing
Provision Investor factors of ATR. the subject note. Cash-out - income and asset
Guidelines Do Not Address Other documentation has been
8 ATR Factors received.
649209242 XXX XXX 2 29376735 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Failure due to missing income and asset documentation and Yes 11/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Credit report
Provision Investor guideline components, the loan is at ATR risk. subject note. Cash-out - received
Guidelines Other
649209242 XXX XXX 2 29376737 compliance 1 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 11/XX/2018 12/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Final CD was
Test borrower within three (3) days of application. Cash-out - provided.
Other
649209242 XXX XXX 2 29376738 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing Page 4 shows minimum rate of 2.25%, loan rate is 4.50%. TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. Yes 11/XX/2018 12/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure AIR Table Disclosure provided on 11/XX/2018 disclosed a Minimum Interest Rate that does not Cash-out -
Minimum Interest Rate match the actual minimum interest rate for the loan. (Final/11/XX/2018) Other
649209242 XXX XXX 2 29376739 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Page 1 shows minimum payment of $XXX and calculated payment TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Yes 11/XX/2018 12/XX/2021 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure Projected P&I provided on 11/XX/2018 disclosed a periodic principal and interest payment for is $XXX. Assignee liability. Cash-out -
Min Payment Adjustable payment stream 3 that does not match the actual payment for the loan. Other
Rate Subsequent Payments (ProjSeq:3/2211341)
649209242 XXX XXX 2 29376740 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Page 1 shows minimum payment of $XXX and calculated payment TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Yes 11/XX/2018 12/XX/2021 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure Projected P&I provided on 11/XX/2018 disclosed a periodic principal and interest payment for is $XXX. Assignee liability. Cash-out -
Min Payment Adjustable payment stream 4 that does not match the actual payment for the loan. Other
Rate Subsequent Payments (ProjSeq:4/2211342)
649207099 XXX XXX 2 29376770 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA Disaster area 9/XX/2014 CA Refinance - Investment No A A A A 7/XX/2023 6/XX/2023 Yes N/A 2023/XX/XX: BPO provided. No
most recent valuation Disaster End Date: XX/XX/XXXX post-close. A post-disaster inspection verifying there was Rate/Term damage noted. Cleared.
inspection is dated prior Disaster Name: XXX no damage to the subject property is required.
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207099 XXX XXX 2 29376771 credit 3 File does not contain Valuation Type: Appraisal / Valuation Report Date: 09/XX/2014 Condo Warranty is missing in file 9/XX/2014 CA Refinance - Investment No C C C C 7/XX/2023 N/A
documentation from Rate/Term
lender/seller confirming
the condo is warrantable.
649207099 XXX XXX 2 29376772 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 9/XX/2014 CA Refinance - Investment No B B B B 7/XX/2023 N/A
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three (3) business days prior to consummation. Rate/Term
Business Days Prior to (Type:Primary/XX/20/2014)
Consummation
649207099 XXX XXX 2 29376773 compliance 2 Missing Document: Missing File is missing a signed and dated Initial 1003 loan 9/XX/2014 CA Refinance - Investment No B B B B 7/XX/2023 N/A 2023/XX/XX: Missing Initial
Lender's Initial 1003 application. Rate/Term signed/dated 1003.
2023/XX/XX: Missing
Signed/dated Initial 1003.
649208860 XXX XXX 2 29376778 credit 1 FEMA Disaster Issue: Disaster Name: XXX The subject property is located in a FEMA disaster area. A 11/XX/2018 CA Refinance - Investment No A A A A 7/XX/2023 6/XX/2023 Yes N/A 2023/XX/XX: BPO provided. No
Property is located in a Disaster Declaration Date: XX/XX/XXXX post disaster inspection verifying there was no damage to Rate/Term damage noted. Cleared.
FEMA Disaster area and Disaster End Date: XX/XX/XXXX the subject property is required.
has not been inspected.
649208860 XXX XXX 2 29376779 credit 3 Missing Document: Missing Final 1003 missing. 11/XX/2018 CA Refinance - Investment No C C C C 7/XX/2023 N/A
Final 1003 Rate/Term
649208860 XXX XXX 2 29376780 compliance 2 Missing Document: Missing Lenders Initial 1003 missing. 11/XX/2018 CA Refinance - Investment No B B B B 7/XX/2023 N/A 2023/XX/XX: Missing Initial
Lender's Initial 1003 Rate/Term signed/dated 1003.
2023/XX/XX: Missing
Signed/dated Initial 1003.
649208860 XXX XXX 2 29376781 credit 3 Missing Document: Credit 11/XX/2018 CA Refinance - Investment No D D D D 7/XX/2023 N/A
Report not provided Rate/Term
649208860 XXX XXX 2 29376782 credit 3 Missing Document: Flood 11/XX/2018 CA Refinance - Investment No C C C C 7/XX/2023 N/A
Certificate not provided Rate/Term
649208860 XXX XXX 2 29376783 credit 3 Missing Document: 11/XX/2018 CA Refinance - Investment No C C C C 7/XX/2023 N/A
Occupancy Certificate not Rate/Term
provided
649208860 XXX XXX 2 29376784 credit 3 Missing Document: 11/XX/2018 CA Refinance - Investment No D D D D 7/XX/2023 N/A
Appraisal not provided Rate/Term
649208860 XXX XXX 2 29376785 credit 3 Income Docs Missing: Borrower: XXX Award Letter / Continuance Letter, Balance Sheet, P&L Statement, 11/XX/2018 CA Refinance - Investment No C C C C 7/XX/2023 N/A
Third Party Verification Rate/Term
649208860 XXX XXX 2 29376786 compliance 2 ECOA Appraisal - Right to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Creditor did not provide a copy of each valuation to There is generally no Assignee Liability. 11/XX/2018 CA Refinance - Investment No B B B B 7/XX/2023 N/A
Receive Copy of Appraisal Receive a Copy" appraisal disclosure to applicant within three (3) business days applicant three (3) business days prior to consummation. Rate/Term
Disclosure Not Provided of application or determination of first lien status.
Timely
649208860 XXX XXX 2 29376787 credit 3 Guideline Requirement: Calculated investor qualifying total debt ratio of 72.02250% exceeds Guideline Calculated investor qualifying total debt ratio of 72.02250% 11/XX/2018 CA Refinance - Investment No C C C C 7/XX/2023 N/A
Investor qualifying total total debt ratio of 45.00000%. exceeds Guideline total debt ratio of 45.00000%. Capital Rate/Term
debt ratio discrepancy. losses must be deducted from qualifying income.
649208860 XXX XXX 2 29376788 credit 3 AUS/Guideline Findings: File is missing credit report, appraisal and income 11/XX/2018 CA Refinance - Investment No C C C C 7/XX/2023 N/A
All conditions were not documentation. Rate/Term
met
649208860 XXX XXX 2 29376789 credit 3 Income documentation Failure due to missing income documentation. 11/XX/2018 CA Refinance - Investment No C C C C 7/XX/2023 N/A
requirements not met. Rate/Term
649208714 XXX XXX 2 29376841 compliance 1 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 10/XX/2016 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Risk 2023/XX/XX: Received required
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three (3) business days prior to consummation. Cash-out - documentation//clarification
Business Days Prior to (Type:Primary/09/XX/2016) Other Condition cleared.
Consummation
649208714 XXX XXX 2 29376842 compliance 2 (Fed HPML Provision) Federal Higher-Priced Mortgage Loan (2013): Mandatory escrow account not Mandatory escrow account not established on 1st lien TILA HPML - subject to a 1 year SOL for affirmative claims under TILA, Unlimited as a defense to 10/XX/2016 10/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk 2023/XX/XX: Fed HPML 2023/XX/XX: HPML requirements
Federal Higher-Priced established on 1st lien mortgage loan. mortgage loan. foreclosure. Assignee liability. Cash-out - Provision was were added under Section 35
Mortgage Loan (1st Lien, Other effective Feb 2021, of TILA and applicable to
Escrow Not Established) loan closed prior closed-end loans secured by
principal dwelliong for
2023/XX/XX: Agree with applications taken on or
error after October 1, 2009. Loan
was originations after this
date and exception is valid.
The requirement for
establishment of escrow
account was a requirements of
the implementation of the
HPML regulation.
2023/XX/XX: No documentation
was provided in trailing docs
to clear this condition.
2023/XX/XX: No supporting
trailing documentation was
provided to clear this
exception. Exception remains.
649208714 XXX XXX 2 29376843 compliance 2 Federal HPML 2014 Non Federal Higher-Priced Mortgage Loan: APR on subject loan of X.XX% or Final APR on subject loan of X.XX% or Final Disclosure APR of TILA HPML - subject to a 1 year SOL for affirmative claims under TILA, Unlimited as a defense to 10/XX/2016 10/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk 2023/XX/XX: Compliance 2023/XX/XX: File contains no
Compliant Disclosure APR of X.XX% is equal to or greater than the threshold of X.XX% + X.XX% is equal to or greater than the threshold of APOR foreclosure. Assignee liability. Cash-out - Eagle uploaded 4/XX/23 compliance report to
1.5%, or X.XX%. Non-Compliant Higher Priced Mortgage Loan. 3.25% + 1.5%, or 4.75000%. Non-Compliant Higher Priced Other at 8:14am under Misc determine lenders APR
Mortgage Loan with a change of circumstance in file. reflects a passing calculations. Condition
High Cost test (dated remains.
10-18 at 9:44 am). All
closing docs reference 2023/XX/XX: Reviewed trailing
final APR X.XX% documentation. Documents
necessary to clear the
2023/XX/XX: Provided conditions were not provided.
Compliance Eagle Exception remains.
report to support
passing High Cost
test. Closing docs
support final APR
X.XX%
649208714 XXX XXX 2 29376844 compliance 1 (Fed HPML Provision) TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of Creditor did not provide a copy of each valuation to TILA HPML - subject to a 1 year SOL for affirmative claims under TILA, Unlimited as a defense to 10/XX/2016 10/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Risk 2023/XX/XX: Notepad 2023/XX/XX: Received required
Federal Higher-Priced each valuation to applicant three (3) business days prior to consummation. applicant three (3) business days prior to consummation. foreclosure. Assignee liability. Cash-out - entry dated 9/XX/16 documentation//clarification
Mortgage Loan (Timing of (Type:Primary/09/XX/2016) Other indicates appraisal Condition cleared.
Appraisal to Consumer) and Property Valuation
Document Disclaimer
were mailed to
borrowers
649208714 XXX XXX 2 29376846 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM disclosure is not contains the document date. TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2016 10/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Test borrower. Cash-out -
Other
649208714 XXX XXX 2 29376847 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower. TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2016 10/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649208714 XXX XXX 2 29376848 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Loan Calculations: Final Closing Disclosure provided on TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 10/XX/2016 10/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Disclosure Amount provided on 10/XX/2016 disclosed an Amount Financed that was not within tolerance 10/XX/2016 disclosed an Amount Financed that was not within Assignee liability. Cash-out -
Financed of the actual amount financed for the loan. (Final/10/XX/2016) tolerance of the actual amount financed for the loan. Other
649208714 XXX XXX 2 29376849 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: APR of X.XX% on Final Loan Calculations: APR of X.XX% on Final Closing Disclosure TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 10/XX/2016 10/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Disclosure APR Irregular Closing Disclosure provided on 10/XX/2016 is under-disclosed from the calculated provided on 10/XX/2016 is under-disclosed from the Assignee liability. Cash-out -
Transaction APR of X.XX% outside of 0.250% tolerance. (Final/10/XX/2016) calculated APR of X.XX% outside of 0.250% tolerance. Other
649208714 XXX XXX 2 29376850 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Loan Calculations: Final Closing Disclosure provided on TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 10/XX/2016 10/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Disclosure Finance Charge provided on 10/XX/2016 disclosed an inaccurate Finance Charge on page 5 that does 10/XX/2016 disclosed an inaccurate Finance Charge on page 5 Assignee liability. Cash-out -
not match the actual Finance Charge for the loan (fee amounts included in Finance that does not match the actual Finance Charge for the loan Other
Charge calculation are based on Closing Disclosure dated 10/XX/2016). (fee amounts included in Finance Charge calculation are
(Final/10/XX/2016) based on Closing Disclosure dated 10/XX/2016).
649208714 XXX XXX 2 29376851 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Loan Calculations: Final Closing Disclosure provided on TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 10/XX/2016 10/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Disclosure Total Of provided on 10/XX/2016 disclosed an inaccurate Total of Payments on page 5 that 10/XX/2016 disclosed an inaccurate Total of Payments on page Assignee liability. Cash-out -
Payments does not match the actual total of payments for the loan (fee amounts included in 5 that does not match the actual total of payments for the Other
TOP calculation are based on Closing Disclosure dated 10/XX/2016). The disclosed loan (fee amounts included in TOP calculation are based on
Total of Payments in the amount of $XXX is under disclosed by $XXX compared to Closing Disclosure dated 10/XX/2016). The disclosed Total of
the calculated total of payments of $XXX which exceeds the $XXX per month Payments in the amount of $XXX is under disclosed by $XXX
threshold. (Final/10/XX/2016) compared to the calculated total of payments of $XXX which
exceeds the $XXX per month threshold.
649208714 XXX XXX 2 29376853 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The property is located in FEMA Disaster area. Provide a 10/XX/2016 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes ATR Risk 2023/XX/XX: BPO provided. No
most recent valuation Disaster End Date: XX/XX/XXXX post-disaster inspection verifying there was no damage. The Cash-out - damage noted. Cleared.
inspection is dated prior Disaster Name: XXX inspection must include exterior photos and the property Other
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX must be re-inspected on or after XX/XX/XXXX declared end
disaster. date.
649208714 XXX XXX 2 29376854 compliance 2 Missing Document: Missing Lender's Initial 1003 is not provided in the file. 10/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Lender's Initial 1003 Cash-out -
Other
649208714 XXX XXX 2 29376855 credit 3 Missing Document: Note - 10/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 ATR Risk
Subordinate Lien not Cash-out -
provided Other
649208714 XXX XXX 2 29376856 compliance 3 Check Loan Designation Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does The DTI exceeds the maximum allowable of 44% which resulted Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 10/XX/2016 CA Refinance - Primary No C C B B 7/XX/2023 ATR Risk 2023/XX/XX: N/A; 2023/XX/XX: Based on lender
Match - ATR Risk not match Due Diligence Loan Designation of ATR Risk. in a calculated Due Diligence Loan Designation of ATR Risk. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - Duplicative Exception guides, the qualifying method
Other is 10/1 IO ARM - The
2023/XX/XX: Duplicate qualifying rate is the
and/or waterfall greater of the note rate plus
exception 2% or the fully-indexed rate.
The qualifying payment is the
payment based on the
qualifying rate amortized
over 30 years (the number of
years remaining after the
interest-only period ends).
This calculation is causing
the DTI discrepancy. In
addition, the 2nd mortgage
documentation is missing. The
1008 reflects the 2nd
mortgage was closed at $XXXk.
2023/XX/XX: No documentation
was provided in trailing docs
to clear this condition.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649208714 XXX XXX 2 29376857 compliance 3 General ATR Provision Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the The DTI exceeds the maximum allowable of 44%. 10/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/XX: 1008 dated 2023/XX/XX: Based on lender
Investor and Non QM DTIs Lenders Guidelines and 1026.43(c)(5) of 49.87821% significantly exceeds the Cash-out - 10/XX/16 indicates a guides, the qualifying method
match and both guideline maximum of 44.00%. (DTI Exception requires compelling compensating Other counter was accepted is 10/1 IO ARM - The
significantly exceed factors to consider regrading to EV2-B.) lowering 2nd TD and qualifying rate is the
Guidelines final DTI under 44%. greater of the note rate plus
1008 DTI 43.141% using 2% or the fully-indexed rate.
income of $XXX PITIA The qualifying payment is the
of $XXX and other payment based on the
debts of $XXX qualifying rate amortized
over 30 years (the number of
2023/XX/XX: Duplicate years remaining after the
and/or waterfall interest-only period ends).
exception This calculation is causing
the DTI discrepancy.
2023/XX/XX: No documentation
was provided in trailing docs
to clear this condition.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649208714 XXX XXX 2 29376858 credit 3 Guideline Requirement: Calculated investor qualifying total debt ratio of 49.87821% exceeds Guideline The DTI exceeds the maximum allowable of 44%. 10/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/XX: N/A; 2023/XX/XX: Based on lender
Investor qualifying total total debt ratio of 44.00000%. Cash-out - Duplicative Exception guides, the qualifying method
debt ratio discrepancy. Other is 10/1 IO ARM - The
2023/XX/XX: Duplicate qualifying rate is the
and/or waterfall greater of the note rate plus
exception 2% or the fully-indexed rate.
The qualifying payment is the
payment based on the
qualifying rate amortized
over 30 years (the number of
years remaining after the
interest-only period ends).
This calculation is causing
the DTI discrepancy.
2023/XX/XX: No documentation
was provided in trailing docs
to clear this condition.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649208714 XXX XXX 2 29376859 compliance 3 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more The DTI exceeds the maximum allowable of 44%. 10/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/XX: N/A; 2023/XX/XX: Based on lender
Provision Investor guideline components, the loan is at ATR risk. Cash-out - Duplicative Exception guides, the qualifying method
Guidelines Other is 10/1 IO ARM - The
2023/XX/XX: Duplicate qualifying rate is the
and/or waterfall greater of the note rate plus
exception 2% or the fully-indexed rate.
The qualifying payment is the
payment based on the
qualifying rate amortized
over 30 years (the number of
years remaining after the
interest-only period ends).
This calculation is causing
the DTI discrepancy.
2023/XX/XX: No documentation
was provided in trailing docs
to clear this condition.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649207868 XXX XXX 1 29376871 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 3/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three (3) business days prior to consummation. Rate/Term
Business Days Prior to (Type:Primary/02/XX/2017)
Consummation
649207868 XXX XXX 1 29376872 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The property is located in FEMA Disaster area. Provide a 3/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: BPO provided. No
most recent valuation Disaster End Date: XX/XX/XXXX post-disaster inspection verifying there was no damage. The Rate/Term damage noted. Cleared.
inspection is dated prior Disaster Name: XXX inspection must include exterior photos and the property
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX must be re-inspected on or after XX/XX/XXXX declared end
disaster. date.
649208356 XXX XXX 1 29376879 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Post Inspection Disaster Report is required. 7/XX/2014 CA Refinance - Investment No A A A A 7/XX/2023 6/XX/2023 Yes N/A 2023/XX/XX: BPO provided. No
most recent valuation Disaster End Date: XX/XX/XXXX Rate/Term damage noted. Cleared.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649208356 XXX XXX 1 29376880 credit 3 Insufficient Coverage: HOI coverage provided is short $XXX. Increased coverage or 7/XX/2014 CA Refinance - Investment No C C C C 7/XX/2023 N/A
Hazard insurance coverage Replacement Cost Estimator is required. Rate/Term
amount is insufficient.
649208356 XXX XXX 1 29376881 compliance 2 Missing Document: Missing Signed and Dated Lender's Initial 1003 is missing. 7/XX/2014 CA Refinance - Investment No B B B B 7/XX/2023 N/A
Lender's Initial 1003 Rate/Term
649208356 XXX XXX 1 29376882 credit 3 Income documentation VVOE provided for Borrower 2's wage income is dated more 7/XX/2014 CA Refinance - Investment No C C C C 7/XX/2023 N/A
requirements not met. than 10 business days prior to the Note date. Rate/Term
649208356 XXX XXX 1 29376883 credit 3 Verification(s) of Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: VVOE provided for Borrower 2's wage income is dated more 7/XX/2014 CA Refinance - Investment No C C C C 7/XX/2023 N/A
employment is not within 09/XX/1989 than 10 business days prior to the Note date. Rate/Term
10 business days of the
Note.
649208045 XXX XXX 1 29376963 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX 11/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: BPO provided. No
most recent valuation Disaster End Date: XX/XX/XXXX Cash-out - damage noted. Cleared.
inspection is dated prior Disaster Name: XXX Debt
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX Consolidation
disaster.
649208045 XXX XXX 1 29376964 credit 3 File does not contain Valuation Type: Appraisal / Valuation Report Date: 11/XX/2017 File does not contain documentation from Lender confirming 11/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
documentation from the condo is warrantable. Cash-out -
lender/seller confirming Debt
the condo is warrantable. Consolidation
649208045 XXX XXX 1 29376965 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2017 11/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower. Cash-out -
Debt
Consolidation
649208045 XXX XXX 1 29376966 compliance 2 TRID Ten Percent TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Missing valid Change of Circumstance for increased fee(s). 11/XX/2017 11/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Tolerance Violation amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no Final Closing Disclosure does not disclose a Lender cure Cash-out -
Without Sufficient Cure cure was provided to the borrower. (0) credit sufficient to cure $XXX tolerance amount. Debt
Provided Consolidation
649208045 XXX XXX 1 29376967 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Adjustable Payment Table: Final Closing Adjustable Payment Table: Final Closing Disclosure provided TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 11/XX/2017 11/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM 2023/XX/XX: The loan terms
Disclosure AP Table Disclosure provided on 11/XX/2017 disclosed a Maximum Payment amount and period on 11/XX/2017 disclosed a Maximum Payment amount and period Cash-out - indicate maximum interest
Maximum Payment that does not match the actual terms for the loan. (Final/11/XX/2017) that does not match the actual terms for the loan hence Debt rate and payment amount can
please provide revised cd Consolidation be reached in year 13,
however page one indicates
payment would not reach
maximum until year 14. Cure
is required. PCCD, LOE,
reopening of rescission and
proof of delivery.
649208045 XXX XXX 1 29376968 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final Closing Disclosure provided on 11/XX/2017 with an TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. Assignee liability. 11/XX/2017 11/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM 2023/XX/XX: The loan terms
Disclosure Payment Max on 11/XX/2017 with an increasing payment disclosed the earliest date of the increasing payment disclosed the earliest date of the Cash-out - indicate maximum interest
Amount In Year maximum possible amount of principal and interest that does not match the actual maximum possible amount of principal and interest that does Debt rate and payment amount can
earliest date for the loan. (Final/11/XX/2017) not match the actual earliest date for the loan hence please Consolidation be reached in year 13,
provide valid change of circumstance or revised document to however page one indicates
cure this issue payment would not reach
maximum until year 14. Cure
is required. PCCD, LOE,
reopening of rescission and
proof of delivery.
649208045 XXX XXX 1 29376969 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each 11/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. Cash-out -
Business Days Prior to (Type:Primary/11/XX/2017) Debt
Consummation Consolidation
649208045 XXX XXX 1 29376970 compliance 2 ARM Disclosure Timing Unable to determine if ARM disclosure was provided within three (3) days of ARM Disclosire does not disclose a provide date or received TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2017 11/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Test application due to missing information. date. Cash-out -
Debt
Consolidation
649208045 XXX XXX 1 29376971 compliance 2 TRID Revised Loan TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on or after the Revised Loan Estimate dated 11/XX/2017 (#2) provided to TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 11/XX/2017 11/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Estimate Issue and date the Closing Disclosure was provided. (The Revised Loan Estimate was received Borrower(s) on 11/XX/2017 after Initial Closing Disclosure Cash-out -
Received Date > Closing on or after the Closing Disclosure.) (Interim/11/XX/2017) dated 7/XX/2017. Revised Loan Estimate is not signed by Debt
Disclosure Issue and Borrower. Consolidation
Received Date
649208045 XXX XXX 1 29376972 compliance 2 TRID Revised Loan TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on or after the Revised Loan Estimate dated 11/XX/2017 (#1) provided to TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 11/XX/2017 11/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Estimate Issue and date the Closing Disclosure was provided. (The Revised Loan Estimate was received Borrower(s) on 11/XX/2017 after Initial Closing Disclosure Cash-out -
Received Date > Closing on or after the Closing Disclosure.) (Interim/11/XX/2017) dated 7/XX/2017. Revised Loan Estimate is not signed by Debt
Disclosure Issue and Borrower. Consolidation
Received Date
649208045 XXX XXX 1 29376973 compliance 2 TRID Revised Loan TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on or after the Revised Loan Estimate dated 11/XX/2017 (#1) provided to TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 11/XX/2017 11/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Estimate Issue and date the Closing Disclosure was provided. (The Revised Loan Estimate was received Borrower(s) on 11/XX/2017 after Initial Closing Disclosure Cash-out -
Received Date > Closing on or after the Closing Disclosure.) (Interim/11/XX/2017) dated 7/XX/2017. Revised Loan Estimate is not signed by Debt
Disclosure Issue and Borrower. Consolidation
Received Date
649208045 XXX XXX 1 29376974 compliance 2 TRID Revised Loan TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on or after the Initial Loan Estimate dated 10/XX/2017 signed by Borrower(s) TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 11/XX/2017 11/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Estimate Issue and date the Closing Disclosure was provided. (The Revised Loan Estimate was received on 10/XX/2017 after Initial Closing Disclosure dated Cash-out -
Received Date > Closing on or after the Closing Disclosure.) (Initial/10/XX/2017) 7/XX/2017. Debt
Disclosure Issue and Consolidation
Received Date
649209036 XXX XXX 2 29377057 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Subject property was appraised on XX/XX/XXXX prior to the 1/XX/2016 CA Purchase Investment No A A A A 7/XX/2023 6/XX/2023 Yes N/A 2023/XX/XX: BPO provided. No
most recent valuation Disaster End Date: XX/XX/XXXX FEMA disaster (XXX) dated XX/XX/XXXX through XX/XX/XXXX. damage noted. Cleared.
inspection is dated prior Disaster Name: XXX File is missing a property inspection dated after the
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX disaster, or the lender's Rep and Warranty attestation along
disaster. with visible confirmation that the subject property was not
damaged.
649209036 XXX XXX 2 29377058 credit 3 Initial Rate Lock rate Initial Rate Lock rate document is missing. 1/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
date is not documented in
file.
649209036 XXX XXX 2 29377059 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 1/XX/2016 CA Purchase Investment No B B B B 7/XX/2023 N/A
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three (3) business days prior to consummation.
Business Days Prior to (Type:Primary/01/XX/2016)
Consummation
649208209 XXX XXX 1 29377077 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA disaster area. A 3/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: BPO provided. No
most recent valuation Disaster End Date: XX/XX/XXXX post disaster inspection verifying there was no damage to Cash-out - damage noted. Cleared.
inspection is dated prior Disaster Name: XXX the subject property is required. Home
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX Improvement
disaster.
649208209 XXX XXX 1 29377078 credit 1 Missing Document: Fraud Fraud Report missing in file. 3/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received
Report not provided Cash-out -
Home
Improvement
649208209 XXX XXX 1 29377079 credit 1 Missing Document: Hazard Hazard Insurance Policy missing in file. 3/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received
Insurance Policy not Cash-out -
provided Home
Improvement
649208209 XXX XXX 1 29377080 credit 1 Missing Document: Credit Credit Report missing in file. 3/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received
Report not provided Cash-out -
Home
Improvement
649208209 XXX XXX 1 29377081 credit 1 No evidence of fraud Credit Report: Original // Borrower: XXX Credit and Fraud Report missing in file. 3/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received
report in file Cash-out -
Home
Improvement
649208209 XXX XXX 1 29377082 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement E-Sign Consent Agreement missing in file. 3/XX/2019 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
is missing. Cash-out -
Home
Improvement
649208209 XXX XXX 1 29377083 compliance 1 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 3/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: FACTA provided.
Cash-out -
Home
Improvement
649208209 XXX XXX 1 29377084 compliance 1 Check Loan Designation Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Originator Loan Designation of Non QM does not match Due Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 3/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Credit report and
Match - ATR not match Due Diligence Loan Designation of ATR Fail. Diligence Loan Designation of ATR Fail is due to file is firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - WVOE provided.
missing credit report and income documentation for bonus Home
income. Improvement
649208209 XXX XXX 1 29377085 compliance 1 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the Missing ARM loan program disclosure. TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2019 3/XX/2020 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: ARM disclosure
Test borrower. Cash-out - provided; however, see
Home updated exception as it was
Improvement not provided within 3
business days of application.
649208209 XXX XXX 1 29377086 compliance 1 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Missing CHARM Booklet. TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2019 3/XX/2020 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Missing CHARM
Status CHARM Booklet, not provided to the borrower. Cash-out - Booklet provided within 3
Home days of application.
Improvement
2023/XX/XX: CHARM disclosure
provided; however, see
updated exception as it was
not provided within 3
business days of application.
649208209 XXX XXX 1 29377087 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify debt obligations using Missing credit report. Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 3/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Credit report and
Provision Credit History reasonably reliable third-party records. damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Cash-out - WVOE provided.
all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Home
to comply is not material). A private right of action may be brought before the end of the three- Improvement
year period beginning on the date of the occurrence of the violation. However, when a creditor,
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649208209 XXX XXX 1 29377089 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. Missing Initial escrow account statement. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Account Statement Missing implementing regulation, Regulation X, for these type of violations. Cash-out -
Home
Improvement
649208209 XXX XXX 1 29377090 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Missing List of Homeownership Counseling Organizations. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
of Homeownership Homeownership Counseling Organizations to borrower. implementing regulation, Regulation X, for these type of violations. Cash-out -
Counseling Organizations Home
Missing Improvement
649208209 XXX XXX 1 29377091 credit 1 Guideline Requirement: Representative FICO score of is less than Guideline representative FICO score of Credit Report is missing in file. 3/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Credit report
Representative FICO score 700. Cash-out - received.
discrepancy. Home
Improvement
649208209 XXX XXX 1 29377092 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Credit Report Fee was last disclosed as $XXX on LE, but TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 3/XX/2019 3/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Tolerance Violation Report Re-Issue Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient disclosed as $XXX on Final Closing Disclosure. File does not Cash-out -
Without Sufficient Cure or no cure was provided to the borrower. (75117) contain a valid COC for this fee, nor evidence of cure in Home
Provided file. Improvement
649208209 XXX XXX 1 29377093 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Final Closing Disclosure not provided to Borrower(s) at TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 3/XX/2019 3/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure Timing without at least three (3) business days prior to closing. (Final/03/XX/2019) least three (3) business days prior to closing. Cash-out -
Waiver Home
Improvement
649208209 XXX XXX 1 29377094 credit 1 Income documentation Bonus is used for income, file is missing a 2 year history 3/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received WVOE
requirements not met. for bonus income. File contains prior year W2 ad YTD Cash-out - with 2 year prior bonus
paystub. Home income.
Improvement
649208209 XXX XXX 1 29377095 compliance 1 Income/Asset Guideline Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to Bonus is used for income, file is missing a 2 year history 3/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Credit report and
Deficiency - ATR Impact income and/or asset doc requirements which could result in a risk to the for bonus income. File contains prior year W2 ad YTD Cash-out - WVOE provided.
borrower's ability to repay. (Exception is eligible to be regraded with paystub. Home
compensating factors.) Improvement
649208209 XXX XXX 1 29377096 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Bonus is used for income, file is missing a 2 year history 3/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Credit report and
Provision Investor guideline components, the loan is at ATR risk. for bonus income. File contains prior year W2 ad YTD Cash-out - WVOE received.
Guidelines paystub. Home
Improvement
649208209 XXX XXX 1 29377097 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2019 3/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Test borrower within three (3) days of application. Cash-out -
Home
Improvement
649208209 XXX XXX 1 29377098 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2019 3/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Timing CHARM Booklet, not provided to the borrower within three (3) days of application. Cash-out -
Home
Improvement
649207112 XXX XXX 1 29377220 compliance 2 Missing Document: Missing Initial 1003 not signed and dated. 7/XX/2015 WA Purchase Primary No B B B B 7/XX/2023 Non QM
Lender's Initial 1003
649207112 XXX XXX 1 29377221 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet missing on file TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2015 7/XX/2016 WA Purchase Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower.
649207112 XXX XXX 1 29377222 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 7/XX/2015 WA Purchase Primary No B B B B 7/XX/2023 Non QM
Account Statement Missing implementing regulation, Regulation X, for these type of violations.
649207112 XXX XXX 1 29377223 compliance 2 RESPA Disclosure - HUD RESPA Disclosure Rule: Creditor did not provide HUD Settlement Cost Booklet. HUD Settlement Cost Booklet missing on file RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 7/XX/2015 WA Purchase Primary No B B B B 7/XX/2023 Non QM
Settlement Cost Booklet implementing regulation, Regulation X, for these type of violations.
Missing
649207112 XXX XXX 1 29377224 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" date on the The note indicates the first payment is due 09/XX/2015. The TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 7/XX/2015 7/XX/2016 WA Purchase Primary No B B B B 7/XX/2023 Non QM
Payment Summary Table - Final TIL does not match the date on which the first regular periodic payment final TIL indicates the first payment is due 07/XX/2015. Assignee liability.
Maximum In First 5 Years will be due and the earliest date on which that rate may apply.
Change Date Inaccurate
(ARM loan)
649207112 XXX XXX 1 29377225 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "First Adjustment" amount of taxes and The TIL has an estimated escrow payment of $XXX. The actual TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 7/XX/2015 7/XX/2016 WA Purchase Primary No B B B B 7/XX/2023 Non QM
Payment Summary Table - insurance, including any mortgage insurance, on the Final TIL does not match the estimated escrow payment is $XXX. Assignee liability.
First Adjustment Taxes escrow payment that may apply during the first rate adjustment of the loan.
and Insurance Inaccurate
649207112 XXX XXX 1 29377226 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "First Adjustment" total payment amount The TIL has an estimated escrow payment of $XXX. The actual TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 7/XX/2015 7/XX/2016 WA Purchase Primary No B B B B 7/XX/2023 Non QM
Payment Summary Table - (PITI) on the Final TIL does not match the total payment amount that may apply estimated escrow payment is $XXX. The amount is $XXX Assignee liability.
First Adjustment Total during the first rate adjustment of the loan. difference.
Payment (PITI) Inaccurate
649207112 XXX XXX 1 29377227 credit 3 Insufficient Coverage: 7/XX/2015 WA Purchase Primary No C C C C 7/XX/2023 Non QM
Hazard insurance coverage
amount is insufficient.
649208489 XXX XXX 1 29400328 compliance 3 (Missing Doc) Incomplete File is missing the following items: Initial/Final fully UTD 2/XX/2019 CA Refinance - Primary No D D D D 7/XX/2023 2023/XX/XX: Disagree; 2023/XX/XX: File remains
loan images/file executed applications, Loan Estimates, Closing Disclosures, Rate/Term DocVelocity shows 286 substantially incomplete with
Note for subject Lien, appraisal, 2017/2016 K1's being used documents retained for most significant items
for income, 2017/2016 signed/dated personal tax returns and this loan file. missing being 2 yrs 1040s
transcripts, 2017/2016 signed/dated business returns on any including all schedules,
income being used, leases for all properties, Expense appraisal, HOI, all documents
documentation for all real estate owned. related to the expenses for
the REO properties (leases,
tax stmts, HOI stmts and
mortgage stmts), all Loan
Estimates and Closing
Disclosures. This list is
not all inclusive, but
includes some of the most
significant pieces still
missing. Finding remains
open.
649208610 XXX XXX 1 31492364 compliance 2 TRID Ten Percent TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Ten Percent Fee Tolerance exceeded. Total amount of $XXX 3/XX/2023 3/XX/2024 CA Purchase Primary No B B B B 8/XX/2024 HUD Safe
Tolerance Violation amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or Harbor QM
Without Sufficient Cure cure was provided to the borrower. (0) no cure was provided to the borrower.
Provided
649208610 XXX XXX 1 31492365 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Flood Zero Percent Fee Tolerance exceeded for Flood Certification TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 3/XX/2023 3/XX/2024 CA Purchase Primary No B B B B 8/XX/2024 HUD Safe
Tolerance Violation Certification (Initial Fee). Fee Amount of $XXX exceeds tolerance of $XXX. (Initial Fee). Fee Amount of $XXX exceeds tolerance of $XXX. Harbor QM
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (7531) Insufficient or no cure was provided to the borrower.
Provided
649208610 XXX XXX 1 31502060 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each No evidence in the file that the borrower received a copy of 3/XX/2023 CA Purchase Primary No B B B B 8/XX/2024 HUD Safe
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. the appraisal. Harbor QM
Business Days Prior to (Type:Primary/02/XX/2023)
Consummation
649207802 XXX XXX 2 31464073 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure not provided to Borrower within three TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 3/XX/2022 3/XX/2023 IL Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Disclosure Timing without at least three (3) business days prior to closing. (Initial/03/XX/2022) business days prior to closing. QM (APOR)
Waiver
649207701 XXX XXX 1 31461140 compliance 2 (Missing Data) Last Rate Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario 10/XX/2022 FL Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Set Date between Creditor Application Date and Transaction Date used to determine rate QM (APOR)
used for testing.
649207701 XXX XXX 1 XXX compliance 1 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Waterfall due to AUS provided states incorrect information. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 10/XX/2022 FL Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: 9/4- 2024/XX/XX: Updated LP
Match - QM QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Risk. Calculated investor qualifying total debt ratio of 49.68343% firm performing the loan level due diligence and to have the TPR firm confirm said designation. QM (APOR) Appeal: Uploading LPA provided. Exception is clear.
exceeds AUS total debt ratio of 21.00000%. Calculated DTI with correct DTI
with information provided on AUS is 49.68343%. However DTI reflected. TC
stated on AUS is 21%. A corrected AUS is required.
649207701 XXX XXX 1 31461143 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Creditor did not provide List of Homeownership Counseling RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 10/XX/2022 FL Purchase Primary No B B B B 8/XX/2024 Safe Harbor
of Homeownership Homeownership Counseling Organizations to borrower. Organizations to borrower. implementing regulation, Regulation X, for these type of violations. QM (APOR)
Counseling Organizations
Missing
649207701 XXX XXX 1 31461145 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Zero Percent Fee Tolerance exceeded for Loan Discount TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 10/XX/2022 10/XX/2023 FL Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or Points. Fee Amount of $XXX exceeds tolerance of $XXX. No QM (APOR)
Without Sufficient Cure no cure was provided to the borrower. (7200) valid changed circumstance was provided. No cure was
Provided provided to the Borrower.
649207701 XXX XXX 1 31461146 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Zero Percent Fee Tolerance exceeded for Appraisal Re- TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 10/XX/2022 10/XX/2023 FL Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Appraisal Re-Inspection Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Inspection Fee. Fee Amount of $XXX exceeds tolerance of QM (APOR)
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (75103) $XXX. No valid changed circumstance was provided. No cure
Provided was provided to the Borrower.
649207701 XXX XXX 1 31462056 compliance 1 General QM Provision General QM: Based on the loan failing one or more guideline components, the loan Waterfall due to AUS provided states incorrect information. 10/XX/2022 FL Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: 9/4- 2024/XX/XX: Updated LP
Investor Guidelines is at QM risk. Calculated investor qualifying total debt ratio of 49.68343% QM (APOR) Appeal: Uploading LPA provided. Exception is clear.
Violation exceeds AUS total debt ratio of 21.00000%. Calculated DTI with correct DTI
with information provided on AUS is 49.68343%. However DTI reflected. Please see
stated on AUS is 21%. A corrected AUS is required. exception ID XXX XXX
649207701 XXX XXX 1 31516192 credit 1 AUS Findings: Investor Calculated investor qualifying total debt ratio of 49.68343% exceeds AUS total Calculated investor qualifying total debt ratio of 49.68343% 10/XX/2022 FL Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Updated LP
qualifying total debt debt ratio of 21.00000%. exceeds AUS total debt ratio of 21.00000%. Calculated DTI QM (APOR) provided. Exception is clear.
ratio discrepancy. with information provided on AUS is 49.68343%. However DTI
stated on AUS is 21%. A corrected AUS is required.
649207701 XXX XXX 1 31516201 compliance 1 General QM Provision General QM: The DTI calculated in accordance with the Lenders Guidelines and Calculated investor qualifying total debt ratio of 49.68343% 10/XX/2022 FL Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: 9/4- 2024/XX/XX: Updated LP
Investor and QM DTIs 1026.43(e) of 49.68343% significantly exceeds the guideline maximum of 24.00%. exceeds AUS total debt ratio of 21.00000%. Calculated DTI QM (APOR) Appeal: Uploading LPA provided. Exception is clear.
match and both (DTI Exception requires compelling compensating factors to consider regrading to with information provided on AUS is 49.68343%. However DTI with correct DTI
significantly exceed EV2-B.) stated on AUS is 21%. A corrected AUS is required. reflected. Please see
Guidelines exception ID XXX XXX
649209175 XXX XXX 2 31452413 compliance 2 Missing Document: Missing 5/XX/2023 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Lender's Initial 1003 QM (APOR)
649209175 XXX XXX 2 31454010 property 3 Appraiser's license or Valuation Type: Appraisal / Valuation Report Date: 04/XX/2023 The initial appraisal was completed prior to the license 5/XX/2023 NY Purchase Primary No C C C C 8/XX/2024 Safe Harbor
certification was not expiration date. There was no change in value from the QM (APOR)
active at the time of the initial to the final appraisal.
appraisal.
649209175 XXX XXX 2 31454254 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each 5/XX/2023 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. QM (APOR)
Business Days Prior to (Type:Primary/04/XX/2023)
Consummation
649209175 XXX XXX 2 31454255 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each 5/XX/2023 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. QM (APOR)
Business Days Prior to (Client:5048/01/XX/2023)
Consummation
649209175 XXX XXX 2 31454271 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan No valid COC provided, nor evidence of cure in file. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2023 5/XX/2024 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or QM (APOR)
Without Sufficient Cure no cure was provided to the borrower. (7200)
Provided
649209175 XXX XXX 2 31454272 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for No valid COC provided, nor evidence of cure in file. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2023 5/XX/2024 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Appraisal Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no QM (APOR)
Without Sufficient Cure cure was provided to the borrower. (7308)
Provided
649209175 XXX XXX 2 31454273 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit No valid COC provided, nor evidence of cure in file. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2023 5/XX/2024 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Report Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no QM (APOR)
Without Sufficient Cure cure was provided to the borrower. (7520)
Provided
649209250 XXX XXX 2 31466065 credit 1 Missing Document: AUS not AUS is missing 5/XX/2023 CA Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Exception
provided Cash-out - QM (APOR) cleared. Final AUS
Other submission has been provided.
649209250 XXX XXX 2 31466098 compliance 1 General QM Provision General QM: Unable to verity income due to, missing W-2, Paystub, LES, ETS or Failure due to AUS missing and agency salable being No. 5/XX/2023 CA Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: 9/3-Loan 2024/XX/XX: Unable to
Income and Assets - Wages WVOE. (XXX XXX/Wages) Cash-out - QM (APOR) approved under digital determine loan requirements
Other refinance program. AUS due to missing final LP
verifies and no findings.
documentation
required. However WVOE 2024/XX/XX: Exception
in file. XXX cleared. Final AUS
submission was provided.
2024/XX/XX: 9/6-LPA
findings. XXX
649209250 XXX XXX 2 31466102 compliance 1 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Failure due to Aus missing and agency salable being No. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 5/XX/2023 CA Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: 9/3-Loan 2024/XX/XX: Unable to
Match - QM QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - QM (APOR) approved under digital determine loan requirements
Other refinance program. AUS due to missing final LP
verifies and no findings.
documentation
required. However WVOE 2024/XX/XX: Exception
in file. XXX cleared. Final AUS
submission was provided.
2024/XX/XX: 9/6--
Appeal: Re-uploading
LP findings. XXX
649209250 XXX XXX 2 31466103 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee was last disclosed as $XXX on Loan Estimate TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2023 5/XX/2024 CA Refinance - Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Appraisal Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no but disclosed as $XXX on Final Closing Disclosure. File does Cash-out - QM (APOR)
Without Sufficient Cure cure was provided to the borrower. (7506) not contain a valid Change of circumstance for this fee, nor Other
Provided evidence of cure in file.
649209250 XXX XXX 2 31515292 credit 1 AUS/Guideline Findings: Aus is missing. 5/XX/2023 CA Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Exception
All conditions were not Cash-out - QM (APOR) cleared. Final AUS
met Other submission has been provided.
649208903 XXX XXX 1 31521759 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 1/XX/2023 FL Refinance - Primary No B B B B 8/XX/2024 Safe Harbor
Cash-out - QM (APOR)
Other
649208903 XXX XXX 1 31521761 compliance 1 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Waterfall due to DTI variance Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 1/XX/2023 FL Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Appealed, 2024/XX/XX: Received Updated
Match - QM QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Risk. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - QM (APOR) providing correct LP. AUS & captured the DTI field
Other XXX correctly. Exception cleared.
2024/XX/XX: See LP
approval.
649208903 XXX XXX 1 31521762 compliance 1 General QM Provision General QM: The DTI calculated in accordance with the Lenders Guidelines and Field Value DTI is higher than Tape value due to Lender used 1/XX/2023 FL Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: See doc 2024/XX/XX: Received Updated
Investor and QM DTIs 1026.43(e) of 34.56089% moderately exceeds the guideline maximum of 30.00%. (DTI lower consumer debt than verified by audit Cash-out - QM (APOR) used to appeal AUS & captured the DTI field
match and both moderately Exception is eligible to be regraded with compensating factors.) Other exception id 31521761. correctly. Exception cleared.
exceed Guidelines
649208903 XXX XXX 1 31521763 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee was last disclosed as $XXX on LE but disclosed TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 1/XX/2023 1/XX/2024 FL Refinance - Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Appraisal Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no as $XXX on Final Closing Disclosure. File does not contain a Cash-out - QM (APOR)
Without Sufficient Cure cure was provided to the borrower. (7308) valid COC for this fee, nor evidence of cure in file. Other
Provided Provide a post-close CD disclosing the tolerance cure to
include $XXX a copy of refund check, proof of delivery, and
a copy of the letter of explanation sent to the borrower
disclosing the changes made.
649208903 XXX XXX 1 31521765 compliance 1 Incorrect Right To Cancel Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing 1/XX/2023 1/XX/2026 FL Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: 9.3.24 2024/XX/XX: Correction to
Form Used - H-9 Used on Model Form for a refinance by a creditor that is not considered the original risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses Cash-out - QM (APOR) Appeal attached SOM of previous comments: The form
Non Same Lender Refinance creditor. The H-9 form was used, the H-8 form should have been used. the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that Other XXX loan XX0547 Note H8 was utilized for subject
creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for which was paid in full transaction, but form H9
refinances involving the same creditor. 12.16.22 plus borrower should have been used. The
2 is new to our Note original lender on the
date 1.6.23. The CD preliminary title is XXX and
shows no mortgage was the lender on the Note is XXX
paid at closing, home
was free and clear. 2024/XX/XX: Incorrect
Model Form H-8 is exception. The form H8 was
correctly used, kindly utilized for subject
review, rescind or transaction, but form H9
advise, thank you.gs. should have been used. The
original lender on the
2024/XX/XX: The H8 preliminary title is XXX and
form was executed by the lender on the Note is XXX
borrower. PA
649208903 XXX XXX 1 31521767 credit 1 AUS Findings: Investor Calculated investor qualifying total debt ratio of 34.56089% exceeds AUS total Field Value DTI is higher than Tape value due to Lender used 1/XX/2023 FL Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: See doc 2024/XX/XX: Received Updated
qualifying total debt debt ratio of 27.00000%. lower consumer debt than verified by audit Cash-out - QM (APOR) used to appeal AUS & captured the DTI field
ratio discrepancy. Other exception id 31521761. correctly. Exception cleared.
649208903 XXX XXX 1 31521777 compliance 1 General QM Provision General QM: Based on the loan failing one or more guideline components, the loan Waterfall due to DTI variance 1/XX/2023 FL Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: See doc 2024/XX/XX: Received Updated
Investor Guidelines is at QM risk. Cash-out - QM (APOR) used to appeal AUS & captured the DTI field
Violation Other exception id 31521761. correctly. Exception cleared.
649208250 XXX XXX 1 31465954 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. Creditor did not provide FACTA Credit Score Disclosure There is no Assignee Liability. 12/XX/2022 TX Refinance - Primary No B B B B 8/XX/2024 Safe Harbor
Cash-out - QM (APOR)
Other
649208250 XXX XXX 1 31465960 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2022 12/XX/2023 TX Refinance - Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Appraisal Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no Amount of $XXX exceeds tolerance of $XXX. Insufficient or no Cash-out - QM (APOR)
Without Sufficient Cure cure was provided to the borrower. (7308) cure was provided to the borrower. Other
Provided
649208250 XXX XXX 1 31465991 credit 2 Evidence of Taxpayer Evidence of Taxpayer Consent is Missing 12/XX/2022 TX Refinance - Primary No B B B B 8/XX/2024 Safe Harbor
Consent is Missing, and Cash-out - QM (APOR)
Taxpayer documentation is Other
present.
649207411 XXX XXX 2 31493926 credit 3 FHA - Informed Consumer Disclosure: FHA - Informed Consumer Choice Disclosure (Government Documents) FHA - Informed Consumer Choice Disclosure not provided to 9/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 HUD Safe
Choice Disclosure was not borrower within 3 business days of the loan application. Harbor QM
provided to borrower Document was signed on 03/XX/2022.
within 3 business days of
the loan application.
649207411 XXX XXX 2 31493958 credit 3 Missing Document: 9/XX/2022 OH Purchase Primary No D D D D 8/XX/2024 HUD Safe
Purchase Agreement / Harbor QM
Sales Contract not
provided
649207411 XXX XXX 2 31493979 credit 2 FHA - Real Estate Disclosure: FHA - Real Estate Certification (Government Documents) Provided Date: FHA - Real Estate Certification is not provided in the file 9/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 HUD Safe
Certification was 06/XX/2024; Consummation Date: 09/XX/2022 Harbor QM
provided at or after
closing.
649207411 XXX XXX 2 31494070 credit 3 Missing Document: Loan was originated as FHA. A required Verification of 9/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 HUD Safe
Verification of Identification document was not provided. Harbor QM
Identification not
provided
649207411 XXX XXX 2 31494076 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 9/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 HUD Safe
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three business days prior to consummation. A Harbor QM
Business Days Prior to (Type:Primary/03/XX/2022) signed and dated appraisal delivery waiver was not provided.
Consummation
649207411 XXX XXX 2 31494079 compliance 2 Ohio Consumer Sales Ohio Consumer Sales Practices Act: Acknowledgement of Receipt of Home Mortgage Acknowledgement of Receipt of Home Mortgage Loan Information The Consumer Sales Practices Act (CSPA) generally does not provide for assignee liability. The Act 9/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 HUD Safe
Practices Act Loan Information Document not retained by lender. Document not retained by lender. provides that no claim or defense may be asserted under the Act by the Attorney General or any Harbor QM
(Acknowledgement of consumer against a purchaser or assignee of a mortgage loan for value for any action under the
Receipt of Home Mortgage statute unless: (a) the violation was committed by the purchaser or assignee; or (b) the assignee or
Loan Information Document purchaser is affiliated by common control with the seller of the loan at the time the loan was
Not Retained by Lender) purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant injunctions, and levy monetary
fines. Additionally, the CSPA provides borrowers with a private right of action. Therefore, it is
possible that any action commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law as part of the
private right of action, a court could reform the loan terms which could impact purchasers.
Therefore, if the seller cannot be compelled to repurchase the loan, the assignee could face
exposure.
649207411 XXX XXX 2 31494080 compliance 2 Ohio Consumer Sales Ohio Consumer Sales Practices Act: Borrower not provided Right Not To Close Right Not To Close Disclosure was not provided. "The Consumer Sales Practices Act (CSPA) generally does not provide for assignee liability. The Act 9/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 HUD Safe
Practices Act (Right Not Disclosure. provides that no claim or defense may be asserted under the Act by the Attorney General or any Harbor QM
To Close Disclosure Not consumer against a purchaser or assignee of a mortgage loan for value for any action under the
Provided) statute unless: (a) the violation was committed by the purchaser or assignee; or (b) the assignee or
purchaser is affiliated by common control with the seller of the loan at the time the loan was
purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant injunctions, and levy monetary
fines. Additionally, the CSPA provides borrowers with a private right of action. Therefore, it is
possible that any action commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law as part of the
private right of action, a court could reform the loan terms which could impact purchasers.
Therefore, if the seller cannot be compelled to repurchase the loan, the assignee could face
exposure."
649207411 XXX XXX 2 31494083 compliance 2 TRID Ten Percent TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Ten Percent Fee Tolerance exceeded. Total amount of $XXX 9/XX/2022 9/XX/2023 OH Purchase Primary No B B B B 8/XX/2024 HUD Safe
Tolerance Violation amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no exceeds tolerance of $XXX plus 10% or $XXX. No valid changed Harbor QM
Without Sufficient Cure cure was provided to the borrower. (0) circumstance was provided.
Provided Insufficient cure provided for all closing costs above the
legal limit.
649207411 XXX XXX 2 31494084 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Zero Percent Fee Tolerance exceeded for Appraisal Re- TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2022 9/XX/2023 OH Purchase Primary No B B B B 8/XX/2024 HUD Safe
Tolerance Violation Appraisal Re-Inspection Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Inspection Fee. Fee Amount of $XXX exceeds tolerance of Harbor QM
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (75103) $XXX. No valid changed circumstance was provided.
Provided Insufficient cure provided for all closing costs above the
legal limit.
649207411 XXX XXX 2 31494085 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Mortgage Insurance Premium. Fee Amount of $XXX exceeds TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2022 9/XX/2023 OH Purchase Primary No B B B B 8/XX/2024 HUD Safe
Tolerance Violation Mortgage Insurance Premium. Fee Amount of $XXX exceeds tolerance of $XXX. tolerance of $XXX.No valid changed circumstance was Harbor QM
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (7591) provided. Insufficient cure provided for all closing costs
Provided above the legal limit.
649207411 XXX XXX 2 31494165 credit 2 Loan has been identified Mortgage Type: FHA 9/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 HUD Safe
as FHA/VA/USDA Harbor QM
649207411 XXX XXX 2 31501453 credit 2 FHA - Initial HUD Disclosure: FHA - Initial HUD Addendum to the Loan Application 92900-A 9/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 HUD Safe
Addendum to the Loan (Government Documents) Harbor QM
Application 92900-A was
not provided within three
days of the application
date.
649207411 XXX XXX 2 31501477 credit 3 Important Notice to Disclosure: FHA - Important Notice to Homebuyer (92900-B) (Government Documents) 9/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 HUD Safe
Homebuyer (92900-B) is Harbor QM
missing.
649207411 XXX XXX 2 31501523 credit 3 FHA - Final HUD Addendum Disclosure: FHA - Final HUD Addendum to the Loan Application 92900-A (Government FHA - Final HUD Addendum to the Loan Application 92900-A 9/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 HUD Safe
to the Loan Application Documents) (Government Documents): FHA - Final HUD Addendum to the Loan Harbor QM
92900-A is not compliant. Application 92900-A is not compliant. To be compliant,
borrower(s) signature(s) MUST be on both Part IV and Part V
of Page 2, along with a signature on Page 4. The DE
Signature and CHUMS ID is required for a Manual Underwrite.
The lender MUST sign page 1 and 4.
649208246 XXX XXX 1 31522137 credit 3 Insufficient Coverage: HOI coverage is insufficient by $XXX. Provide updated 11/XX/2021 CO Refinance - Investment No C C C C 8/XX/2024 N/A
Hazard insurance coverage policy reflecting minimum coverage of $XXX OR provide copy Rate/Term
amount is insufficient. of insurer's replacement cost estimate supporting current
coverage amount.
649208246 XXX XXX 1 31523968 credit 3 Missing Valuation: Valuation Type: Appraisal / Valuation Report Date: <empty> Appraisal is missing 11/XX/2021 CO Refinance - Investment No C C C C 8/XX/2024 N/A
Rate/Term
649208246 XXX XXX 1 31523986 credit 3 AUS/Guideline Findings: The most recent AUS required an appraisal. However, the 11/XX/2021 CO Refinance - Investment No C C C C 8/XX/2024 N/A
All conditions were not appraisal provided is dated two months after closing and Rate/Term
met pages are cutoff at the bottom. The value is not shown on
the appraisal.
649208246 XXX XXX 1 31524042 credit 3 Missing Document: The AUS required an appraisal. The appraisal provided is 11/XX/2021 CO Refinance - Investment No D D D D 8/XX/2024 N/A
Appraisal not provided dated two months post closing and the value is not legible Rate/Term
on the document.
649208781 XXX XXX 1 31492187 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 9/XX/2021 GA Purchase Primary No B B B B 8/XX/2024 Safe Harbor
QM (APOR)
649207224 XXX XXX 2 31466841 compliance 2 (Missing Data) Last Rate Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario Rate lock agreement not provided 9/XX/2021 PA Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Set Date between Creditor Application Date and Transaction Date used to determine rate QM (APOR)
used for testing.
649207224 XXX XXX 2 31515472 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each No proof in file that the appraisal was provided to the 9/XX/2021 PA Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. borrower QM (APOR)
Business Days Prior to (Type:Primary/09/XX/2021)
Consummation
649208441 XXX XXX 1 31492119 credit 3 Insufficient Coverage: Hazard insurance coverage is short $XXX provide policy 12/XX/2021 UT Purchase Primary No C C C C 8/XX/2024 Safe Harbor
Hazard insurance coverage reflecting sufficient coverage or replacement cost QM (APOR)
amount is insufficient. estimator.
649208144 XXX XXX 2 31469808 compliance 2 Missing Document: Missing 8/XX/2021 IL Refinance - Primary No B B B B 8/XX/2024 Temporary
Lender's Initial 1003 Rate/Term SHQM
(GSE/Agency
Eligible)
649208144 XXX XXX 2 31470190 credit 3 REO Documents are Address: XXX, IL HOA Verification 8/XX/2021 IL Refinance - Primary No C C C C 8/XX/2024 Temporary
missing. Rate/Term SHQM
(GSE/Agency
Eligible)
649208144 XXX XXX 2 31470535 compliance 2 TRID Lender Credit TILA-RESPA Integrated Disclosure:Zero Percent Fee Tolerance exceeded for Lender No valid COC provided, nor evidence of cure in file. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 8/XX/2021 8/XX/2022 IL Refinance - Primary No B B B B 8/XX/2024 Temporary
Tolerance Violation Credits. Final Lender Credit of -$XXX exceeds tolerance of -$XXX. Insufficient Rate/Term SHQM
Without Sufficient Cure or no cure was provided to the borrower. (9300) (GSE/Agency
Provided Eligible)
649206783 XXX XXX 1 31470652 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 10/XX/2021 GA Refinance - Primary No B B B B 8/XX/2024 Non QM
Cash-out -
Other
649206783 XXX XXX 1 31498909 compliance 1 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor The loan failed QM APR testing which caused the loan to Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 10/XX/2021 GA Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Non QM 2024/XX/XX: Designation has
Match - QM QM (APOR) does not match Due Diligence Loan Designation of Non QM. default test as Non QM. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - been restated.
Other
649206783 XXX XXX 1 31498910 compliance 1 QM (APOR) Threshold Fail Qualified Mortgage: QM APR on subject loan of X.XX% is equal to or greater than 10/XX/2021 GA Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Non QM 2024/XX/XX: Designation has
the threshold of 4.50000%. Cash-out - been restated.
Other
649206783 XXX XXX 1 31667572 compliance 2 Check Restated Loan Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not Designation has been restated. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 10/XX/2021 GA Refinance - Primary No B B A A 9/XX/2024 Non QM
Designation Match - match. However, the updated Loan Designation of Non QM matches the Due Diligence firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out -
General Ability to Repay Loan Designation of Non QM. Other
649207247 XXX XXX 2 31466939 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 11/XX/2021 CA Refinance - Primary No B B B B 8/XX/2024 Safe Harbor
Rate/Term QM (APOR)
649207247 XXX XXX 2 31516296 credit 3 Un-audited P&L Statement Borrower: XXX // Employment Type: Employment / Income Type: S-Corp (>= 25%) / 11/XX/2021 CA Refinance - Primary No C C C C 8/XX/2024 Safe Harbor
provided. Average Start Date: 06/XX/2018 Rate/Term QM (APOR)
monthly deposits on the
business Account
statements do not support
the average monthly
income on the YTD P&L
Statement. (GSE COVID-
19)
649207532 XXX XXX 1 31493102 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 9/XX/2021 IN Refinance - Primary Yes B B B B 8/XX/2024 HUD Safe
Cash-out - Harbor QM
Other
649207532 XXX XXX 1 31493104 compliance 2 TRID Lender Credit TILA-RESPA Integrated Disclosure:Zero Percent Fee Tolerance exceeded for Lender Valid Change Circumstance not provided TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2021 9/XX/2022 IN Refinance - Primary Yes B B B B 8/XX/2024 HUD Safe
Tolerance Violation Credits. Final Lender Credit of -$XXX exceeds tolerance of -$XXX. Insufficient Cash-out - Harbor QM
Without Sufficient Cure or no cure was provided to the borrower. (9300) Other
Provided
649207532 XXX XXX 1 31502331 credit 2 Loan has been identified Mortgage Type: FHA 9/XX/2021 IN Refinance - Primary Yes B B B B 8/XX/2024 HUD Safe
as FHA/VA/USDA Cash-out - Harbor QM
Other
649207156 XXX XXX 1 31494697 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. FACTAdisclosure is missing. There is no Assignee Liability. 10/XX/2021 IN Refinance - Primary Yes B B B B 8/XX/2024 Safe Harbor
Cash-out - QM (APOR)
Other
649207156 XXX XXX 1 31494700 compliance 1 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor DTI exceeds the DU maximum allowable of 49.20% which caused Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 10/XX/2021 IN Refinance - Primary Yes A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Exception
Match - QM QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Risk. the loan to test as QM (APOR) risk. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - QM (APOR) cleared.
Other
649207156 XXX XXX 1 31494701 compliance 1 General QM Provision General QM: The DTI calculated in accordance with the Lenders Guidelines and The final AUS reflects DTI of 49.20% but the DTI reflected 10/XX/2021 IN Refinance - Primary Yes A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: 9.XX.24 2024/XX/XX: Exception
Investor and QM DTIs 1026.43(e) of 53.90309% moderately exceeds the guideline maximum of 50.00%. (DTI on the 1008 is 52.469% which close to the calculated amount Cash-out - QM (APOR) Appeal attached Final cleared.
match and both moderately Exception is eligible to be regraded with compensating factors.) of 53.90%. Other DU#10-
exceed Guidelines approve/ineligible -
DTI -52.47%- page 38-
of XXX in AMC. - Final
1008 p17of XXX- shows
52.47% kindly advise
XXX.
649207156 XXX XXX 1 31494703 credit 1 AUS Findings: Investor Calculated investor qualifying total debt ratio of 53.90309% exceeds AUS total The final AUS reflects DTI of 49.20% but the DTI reflected 10/XX/2021 IN Refinance - Primary Yes A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: 9.XX.24 2024/XX/XX: Exception
qualifying total debt debt ratio of 49.20000%. on the 1008 is 52.469% which close to the calculated amount Cash-out - QM (APOR) Appeal attached Final remains, AUS provided with
ratio discrepancy. of 53.90%. Other DU#10- submission date of 01/XX/2022
approve/ineligible - which is more than 2 months
DTI -52.47%- page 38- old from disbursement date
ofXXX in AMC. - Final 10/XX/2021 guideline states
1008 p17ofXXX- shows acceptable to use an AUS
52.47% kindly advise dated within one month post
XXX. close.
2024/XX/XX: Exception
cleared.
649207156 XXX XXX 1 31494707 compliance 1 General QM Provision General QM: Based on the loan failing one or more guideline components, the loan The final AUS reflects DTI of 49.20% but the DTI reflected 10/XX/2021 IN Refinance - Primary Yes A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Exception
Investor Guidelines is at QM risk. on the 1008 is 52.469% which close to the calculated amount Cash-out - QM (APOR) cleared.
Violation of 53.90%. Other
649207872 XXX XXX 1 31469811 compliance 1 ECOA Appraisal Disclosure ECOA - File does not evidence the consumer was provided with the right to receive File does not evidence the consumer was provided with the 2/XX/2024 2/XX/2025 GA Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: SitusAMC receive
- ECOA Timing a copy of the Appraisal Disclosure within 3 days of the loan application date. right to receive a copy of the Appraisal Disclosure within 3 QM (APOR) documentation of application
days of the loan application date. date.
649207872 XXX XXX 1 31469815 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Creditor did not provide List of Homeownership Counseling RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 2/XX/2024 GA Purchase Primary No B B B B 8/XX/2024 Safe Harbor
of Homeownership Homeownership Counseling Organizations to borrower. Organizations to borrower. implementing regulation, Regulation X, for these type of violations. QM (APOR)
Counseling Organizations
Missing
649207872 XXX XXX 1 31469823 compliance 1 TRID Loan Estimate Timing TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the Loan Estimate not delivered or placed in the mail to TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 2/XX/2024 2/XX/2025 GA Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: 8/XX/24 2024/XX/XX: Provided
mail to Borrower(s) within three (3) business days of application. Borrower(s) within three (3) business days of application. QM (APOR) Appeal: The applications contain all 6
(Initial/01/XX/2024) application effective pieces of application data
date is 1/XX/24 that require the issuance of
instead of 11/XX/23. an LE. TRID Grid 4.0,
Please see the Additional Considerations,
attached screenshot Row 36: All references to the
showing the property "Application" or Application
ID date did not occur Date" in this document
until 1/XX/24. Thus, pertains to an application as
the LE issue date of defined under
1/XX is within the 1026.2(a)(3):(3) (i)
required parameter. Application means the
The LE Required date submission of a consumer's
is the date the six financial information for the
pieces of information purposes of obtaining an
are captured and the extension of credit.(ii) For
LE is required to be transactions subject to
sent within 3 general {section} 1026.19(e), (f), or
business days. XXX (g) of this part, an
application consists of the
2024/XX/XX: 9/XX/24 submission of the consumer's
Appeal: Please see name, the consumer's income,
the included the consumer's social
screenshots confirming security number to obtain a
the receipt date of credit report, the property
the sales contract address, an estimate of the
(1/XX/24) and thus the value of the property, and
formal confirmation of the mortgage loan amount
the property address sought.1. In general. An
(TRID application date application means the
vs credit application submission of a consumer's
date). XXX MX Loan financial information for
Journal Notes confirm purposes of obtaining an
receipt on 1/XX/24 extension of credit. For
after hours, and the transactions subject to
XXX Enterprise Image {section} 1026.19(e), (f), or
Viewer (EIV) confirms (g) of this part, the term
it being loaded to the consists of the consumer's
system on 1/XX/24. name, the consumer's income,
XXX the consumer's social
security number to obtain a
credit report, the property
address, an estimate of the
value of the property, and
the mortgage loan amount
sought. This definition does
not prevent a creditor from
collecting whatever
additional information it
deems necessary in connection
with the request for the
extension of credit. However,
once a creditor has received
these six pieces of
information, it has an
application for purposes of
the requirements of
Regulation Z. A submission
may be in written or
electronic format and
includes a written record of
an oral application.
2024/XX/XX: SitusAMC receive
documentation of application
date.
649207872 XXX XXX 1 31469929 credit 3 Final Title Policy is Title Evidence is Missing. 2/XX/2024 GA Purchase Primary No C C C C 8/XX/2024 Safe Harbor
missing. No evidence of QM (APOR)
title in file.
649207872 XXX XXX 1 31469942 credit 3 Missing Document: Flood Flood Certificate is missing. 2/XX/2024 GA Purchase Primary No C C C C 8/XX/2024 Safe Harbor
Certificate not provided QM (APOR)
649207872 XXX XXX 1 31469945 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) is missing. 2/XX/2024 GA Purchase Primary No C C C C 8/XX/2024 Safe Harbor
Mortgage Insurance QM (APOR)
Certificate (MIC) not
provided
649207872 XXX XXX 1 31469955 compliance 2 Missing Document: Missing 1003 Initial - Lender's is missing. 2/XX/2024 GA Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Lender's Initial 1003 QM (APOR)
649207872 XXX XXX 1 31502321 credit 3 Hazard Insurance Error: HO-6 or Walls-In insurance was captured on the final CD, but 2/XX/2024 GA Purchase Primary No C C C C 8/XX/2024 Safe Harbor
Missing HO-6 policy, was not provided in file. QM (APOR)
blanket hazard insurance
policy provided does not
contain unit interior
coverage.
649206921 XXX XXX 1 31476241 credit 3 REO Documents are Address: XXX, NY Tax Verification Tax Verification is missing for investment property. 2/XX/2020 CA Purchase Primary No C C C C 8/XX/2024 Safe Harbor
missing. QM
649206950 XXX XXX 2 31492025 credit 3 Borrower(s) is not a U.S. Borrower: XXX, Borrower: XXX Employment Authorization, Resident Alien Card, Passport and 12/XX/2020 CA Purchase Primary No C C C C 8/XX/2024 Safe Harbor
Citizen, and the VISA missing in loan file. QM
guideline required
documentation was not
provided.
649206950 XXX XXX 2 31492026 credit 3 Missing Document: Employment Authorization, Resident Alien Card, Passport and 12/XX/2020 CA Purchase Primary No C C C C 8/XX/2024 Safe Harbor
Verification of Non-US VISA missing in loan file. QM
Citizen Status not
provided
649207658 XXX XXX 2 31492208 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is The file is missing documentation verifying the borrowers 11/XX/2019 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Appraisal Provided Prior prior to the date when valuation was performed. Unable to determine compliance received a copy of the appraisal within 3 business days of Rate/Term SHQM
to Date Performed with appraisal timing requirements. (Type:Primary/10/XX/2019) closing. (GSE/Agency
Eligible)
649207658 XXX XXX 2 31492211 compliance 2 TRID Revised Loan TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on 11/XX/2019 Revised Loan Estimate provided on 11/XX/2019 not received by TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 11/XX/2019 11/XX/2020 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Estimate Timing Before not received by borrower at least four (4) business days prior to closing. borrower within timeframe of 4 days. It was signed on Rate/Term SHQM
Closing (Interim/11/XX/2019) 11/XX/2019. (GSE/Agency
Eligible)
649208368 XXX XXX 2 31521594 credit 3 This loan closed during Financial Institution: XXX // Account Type: Savings / Account Number: XXX Note Bank Statements are within 60 days prior to the Note Date of 6/XX/2021 MA Purchase Primary Yes C C C C 8/XX/2024 Temporary
the COVID-19 affected Date: 06/XX/2021; Notary Date: 06/XX/2021 06/XX/2021. SHQM
timeframe. Asset Account (GSE/Agency
date is more than 60 days Eligible)
prior to the Note date or
notary date.
649208368 XXX XXX 2 31521780 credit 3 Insufficient Coverage: Situs AMC uses Fannie Mae's definition of acceptable 6/XX/2021 MA Purchase Primary Yes C C C C 8/XX/2024 Temporary
Hazard insurance coverage coverage. Fannie Mae requires coverage equal to the lesser SHQM
amount is insufficient. of the following: (GSE/Agency
100% of the insurable value of the improvements, as Eligible)
established by the property insurer; or the unpaid principal
balance of the mortgage, as long as it at least equals the
minimum amount-80% of the insurable value of the
improvements-required to compensate for damage or loss on a
replacement cost basis. If it does not, then coverage that
does provide the minimum required amount must be obtained.
There is a shortfall of $XXX.
649208368 XXX XXX 2 31521825 compliance 2 (Missing Data) Last Rate Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario Rate Set Date is missing. 6/XX/2021 MA Purchase Primary Yes B B B B 8/XX/2024 Temporary
Set Date between Creditor Application Date and Transaction Date used to determine rate SHQM
used for testing. (GSE/Agency
Eligible)
649208368 XXX XXX 2 31521827 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Home Home Inspection Fee increased from $XXX to $XXX, an increase TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 6/XX/2021 6/XX/2022 MA Purchase Primary Yes B B B B 8/XX/2024 Temporary
Tolerance Violation Inspection Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or of $XXX, without a valid Changed Circumstance form in file. SHQM
Without Sufficient Cure no cure was provided to the borrower. (7708) No cure provided. (GSE/Agency
Provided Eligible)
649208368 XXX XXX 2 31522543 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy Borrowers signed Waiver on 05/XX/2021. There is generally no Assignee Liability. 6/XX/2021 MA Purchase Primary Yes B B B B 8/XX/2024 Temporary
Appraisal Not Provided at of the appraisal at least three (3) business days prior to closing, and appraisal SHQM
or Before Closing (3-Day was not provided at or before closing. (Type:Primary/06/XX/2021) (GSE/Agency
Waiver In File) Eligible)
649208140 XXX XXX 1 31492239 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 1/XX/2020 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three business days prior to consummation. Rate/Term SHQM
Business Days Prior to (Type:Primary/12/XX/2019) (GSE/Agency
Consummation Eligible)
649208140 XXX XXX 1 31492241 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 1/XX/2020 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Affiliated Business Disclosure to applicant within three (3) business days of application. Disclosure to applicant within three business days of implementing regulation, Regulation X, for these type of violations. Rate/Term SHQM
Arrangement Disclosure application. (GSE/Agency
Not Provided Within 3 Eligible)
Business Days of
Application
649208140 XXX XXX 1 31492242 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Disclosures: Non Escrowed Property Costs Loan Disclosures: Non Escrowed Property Costs over Year 1 of TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 1/XX/2020 1/XX/2021 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Disclosure Non Escrow over Year 1 of on Final Closing Disclosure provided on 01/XX/2020 are on Final Closing Disclosure provided on 01/XX/2020 are Rate/Term SHQM
Costs Year 1 underdisclosed. (Final/01/XX/2020) underdisclosed. (GSE/Agency
Underdisclosed - October Eligible)
2018
649208140 XXX XXX 1 31492249 credit 3 Insufficient Coverage: Hazard Insurance Coverage Amount is insufficient by $XXX. 1/XX/2020 NY Refinance - Primary No C C C C 8/XX/2024 Temporary
Hazard insurance coverage Rate/Term SHQM
amount is insufficient. (GSE/Agency
Eligible)
649206819 XXX XXX 1 31493669 credit 3 Missing Document: Fraud 2/XX/2020 FL Purchase Primary No C C C C 8/XX/2024 Temporary
Report not provided SHQM
(GSE/Agency
Eligible)
649207574 XXX XXX 1 31492554 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure not provided to Borrower(s) at least TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2019 9/XX/2020 WA Refinance - Primary No B B B B 8/XX/2024 Temporary
Disclosure Timing without at least three (3) business days prior to closing. (Final/09/XX/2019) three (3) business days prior to closing. (Final/09/XX/2019) Cash-out - SHQM
Waiver Other (GSE/Agency
Eligible)
649209086 XXX XXX 2 31492394 compliance 2 TRID Closing Disclosure TILA-RESPA Integrated Disclosure: Closing Disclosure estimated to be provided on Date issued not completed on Closing Disclosure. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 4/XX/2019 4/XX/2022 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Issue Date Not Provided 04/XX/2019 did not disclose the actual Date Issued. Unable to conclusively Assignee liability. Rate/Term SHQM
determine Final Closing disclosure to use to test for compliance with applicable (GSE/Agency
TRID timing requirements, TRID fee tolerance testing or accuracy of disclosures Eligible)
at or before consummation due to missing Issue Date. Tested using an estimated
Date Issued based on best information available. (Interim/04/XX/2019)
649209086 XXX XXX 2 31492396 compliance 2 TRID Closing Disclosure TILA-RESPA Integrated Disclosure: Closing Disclosure estimated to be provided on Date issued not completed on Closing Disclosure. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 4/XX/2019 4/XX/2022 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Issue Date Not Provided 04/XX/2019 did not disclose the actual Date Issued. Unable to conclusively Assignee liability. Rate/Term SHQM
determine Final Closing disclosure to use to test for compliance with applicable (GSE/Agency
TRID timing requirements, TRID fee tolerance testing or accuracy of disclosures Eligible)
at or before consummation due to missing Issue Date. Tested using an estimated
Date Issued based on best information available. (Initial/04/XX/2019)
649209086 XXX XXX 2 31492397 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Finance Charge disclosed is $XXX. Calculated finance charge TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 4/XX/2019 4/XX/2022 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Disclosure Amount provided on 04/XX/2019 disclosed an Amount Financed disclosed an inaccurate is $XXX Variance of $XXX. Assignee liability. Rate/Term SHQM
Financed Test Amount Financed. The disclosed Amount Financed in the amount of $XXX is over (GSE/Agency
disclosed by $XXX compared to the calculated Amount Financed of $XXX and the Eligible)
disclosed Finance Charge is not accurate within applicable tolerances for Amount
Financed to be considered accurate (fee amounts included in Amount Financed and
Finance Charge calculations are based on Closing Disclosure dated 04/XX/2019).
(Final/04/XX/2019)
649209086 XXX XXX 2 31492399 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Finance Charge disclosed is $XXX. Calculated finance charge TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 4/XX/2019 4/XX/2022 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Disclosure Finance Charge provided on 04/XX/2019 disclosed an inaccurate Finance Charge on page 5 that does is $XXX Variance of $XXX. Assignee liability. Rate/Term SHQM
not match the actual Finance Charge for the loan. The disclosed Finance Charge (GSE/Agency
in the amount of $XXX is under disclosed by $XXX compared to the calculated Eligible)
Finance Charge of $XXX which exceeds the $XXX threshold (fee amounts included in
Finance Charge calculation are based on Closing Disclosure dated 04/XX/2019).
(Final/04/XX/2019)
649209086 XXX XXX 2 31492400 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Proof of earlier delivery not found in file. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2019 4/XX/2020 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Disclosure Timing without at least three (3) business days prior to closing. (Initial/04/XX/2019) Rate/Term SHQM
Waiver (GSE/Agency
Eligible)
649209086 XXX XXX 2 31492402 compliance 2 TRID Interim Closing TILA-RESPA Integrated Disclosure - Corrected Closing Disclosure provided on or Proof of delivery not found in file. TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2019 4/XX/2020 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Disclosure Timing Test after 04/XX/2019 contains a change in APR and was not received by borrower at Rate/Term SHQM
least three (3) business days prior to consummation (GSE/Agency
Eligible)
649209086 XXX XXX 2 31492403 compliance 2 TRID Lender Credit TILA-RESPA Integrated Disclosure:Zero Percent Fee Tolerance exceeded for Lender Lender Credit was last disclosed as -$XXX on LE but TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2019 4/XX/2020 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Tolerance Violation Credits. Final Lender Credit of -$XXX exceeds tolerance of -$XXX. Insufficient disclosed as- $XXX on Final Closing Disclosure. File does Rate/Term SHQM
Without Sufficient Cure or no cure was provided to the borrower. (9300) not contain a valid Change of Circumstance for this fee, nor (GSE/Agency
Provided evidence of cure in file. Eligible)
649209086 XXX XXX 2 31492405 compliance 2 TRID Revised Loan TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on or after the Loan Estimate provided after the date of Closing Disclousre. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2019 4/XX/2020 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Estimate Issue and date the Closing Disclosure was provided. (The Revised Loan Estimate was received Rate/Term SHQM
Received Date > Closing on or after the Closing Disclosure.) (Interim/04/XX/2019) (GSE/Agency
Disclosure Issue and Eligible)
Received Date
649209086 XXX XXX 2 31492406 compliance 2 TRID Revised Loan TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on 04/XX/2019 Proof of receipt not in file. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2019 4/XX/2020 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Estimate Timing Before not received by borrower at least four (4) business days prior to closing. Rate/Term SHQM
Closing (Interim/04/XX/2019) (GSE/Agency
Eligible)
649209086 XXX XXX 2 31492407 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Service Service Charge Fee was not disclosed on Loan Estimate. File TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2019 4/XX/2020 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Tolerance Violation Charges. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no cure does not contain a valid Change of Circumstance for this Rate/Term SHQM
Without Sufficient Cure was provided to the borrower. (7527) fee, nor evidence of cure. (GSE/Agency
Provided Eligible)
649209086 XXX XXX 2 31501649 credit 3 Missing Document: Note - 4/XX/2019 NY Refinance - Primary No C C C C 8/XX/2024 Temporary
Subordinate Lien not Rate/Term SHQM
provided (GSE/Agency
Eligible)
649207614 XXX XXX 2 31473798 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 11/XX/2023 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor
QM (APOR)
649207614 XXX XXX 2 31473801 compliance 1 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 11/XX/2023 OH Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Exception
Affiliated Business Disclosure to applicant within three (3) business days of application. Disclosure to applicant within three business days of implementing regulation, Regulation X, for these type of violations. QM (APOR) cleared.
Arrangement Disclosure application.
Not Provided Within 3
Business Days of
Application
649207614 XXX XXX 2 31473802 compliance 1 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling List of Homeownership Counseling Organizations not provided RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 11/XX/2023 OH Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Exception
of Homeownership Organizations not provided to applicant within three (3) business days of to applicant within three business days of application. implementing regulation, Regulation X, for these type of violations. QM (APOR) cleared.
Counseling Organizations application.
Not Provided Within 3
Business Days of
Application
649207614 XXX XXX 2 31473803 compliance 2 Ohio Consumer Sales Ohio Consumer Sales Practices Act: Acknowledgement of Receipt of Home Mortgage Acknowledgement of Receipt of Home Mortgage Loan Information The Consumer Sales Practices Act (CSPA) generally does not provide for assignee liability. The Act 11/XX/2023 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Practices Act Loan Information Document not retained by lender. Document not retained by lender. provides that no claim or defense may be asserted under the Act by the Attorney General or any QM (APOR)
(Acknowledgement of consumer against a purchaser or assignee of a mortgage loan for value for any action under the
Receipt of Home Mortgage statute unless: (a) the violation was committed by the purchaser or assignee; or (b) the assignee or
Loan Information Document purchaser is affiliated by common control with the seller of the loan at the time the loan was
Not Retained by Lender) purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant injunctions, and levy monetary
fines. Additionally, the CSPA provides borrowers with a private right of action. Therefore, it is
possible that any action commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law as part of the
private right of action, a court could reform the loan terms which could impact purchasers.
Therefore, if the seller cannot be compelled to repurchase the loan, the assignee could face
exposure.
649207614 XXX XXX 2 31473804 compliance 2 Ohio Consumer Sales Ohio Consumer Sales Practices Act: Borrower not provided Right Not To Close Right not to close disclosure not provided to borrower. "The Consumer Sales Practices Act (CSPA) generally does not provide for assignee liability. The Act 11/XX/2023 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Practices Act (Right Not Disclosure. provides that no claim or defense may be asserted under the Act by the Attorney General or any QM (APOR)
To Close Disclosure Not consumer against a purchaser or assignee of a mortgage loan for value for any action under the
Provided) statute unless: (a) the violation was committed by the purchaser or assignee; or (b) the assignee or
purchaser is affiliated by common control with the seller of the loan at the time the loan was
purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant injunctions, and levy monetary
fines. Additionally, the CSPA provides borrowers with a private right of action. Therefore, it is
possible that any action commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law as part of the
private right of action, a court could reform the loan terms which could impact purchasers.
Therefore, if the seller cannot be compelled to repurchase the loan, the assignee could face
exposure."
649207614 XXX XXX 2 31473805 compliance 1 TRID Loan Estimate Timing TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the Loan Estimate is not signed and dated for 10/XX/2023. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 11/XX/2023 11/XX/2024 OH Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Appeal - 2024/XX/XX: Application in
mail to Borrower(s) within three (3) business days of application. QM (APOR) Please see attached file contains all 6 pieces of
(Initial/10/XX/2023) system screen shots required information and loan
provide verification ID number matching final CD,
of electronic delivery to issue an LE. The
/ receipt within three application is dated 9/XX.
(3) business days of Please provide initial LE for
application. (Initial testing of documentation.
10/XX/2023). - XXX
2024/XX/XX: SitusAMC received
2024/XX/XX: Appeal - lender certification and
The estimated property screen prints confirming
value of XXX also the application date with receipt
(6th piece of info) of 6 pieces of information
was not received on supported by contract and
this purchase prior pre-approval
transaction until the information.
Lender received the
sales contract on
10/XX/23, see also
D0136. - XXX
2024/XX/XX: Appeal -
Property address,
section 4 not
available on the
9/XX/23 application
see document print
date 9/XX/23. See the
9/XX/23 application
with actual issue /
print date of 10/XX/23
application with
property address, 6th
piece of information.
The print date
specified can be
located on the lower
portion of the page in
the middle. - XXX
649207614 XXX XXX 2 31473824 compliance 1 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax Fee was last disclosed as $XXX on Loan TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 11/XX/2023 11/XX/2024 OH Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Appeal - 2024/XX/XX: SituAMC received
Tolerance Violation Transfer Tax. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no Estimate but disclosed as $XXX on Final Closing Disclosure. QM (APOR) Please see attached snips for timeline of
Without Sufficient Cure cure was provided to the borrower. (8304) File does not contain a valid Change of circumstance for screen shots provide disclosure of fee however,
Provided this fee, nor evidence of cure in file. verification of Change the reason for adding the
of Circumstance vie $XXX fee was not provided as
electronic delivery to to what changed circumstance
borrower for required occurred (as defined under
fees change to include 1026.19(e)(4)(A)-(F) that
the $XXX Transfer Tax resulted in an increase in
Fee. - XXX closing costs.
2024/XX/XX: Appeal - 2024/XX/XX: Change took place
Per loan data fees on 11/8. Any VCC must have a
changed due to the reason for the change.
change in loan amount, SitusAMC is unable to accept
points and sales a statement of change without
price. Lender paid a supporting reason for the
Transfer tax went down change in fees. A change in
resulting in an pricing, rate, loan amount,
increase in the borrower requested changes,
narrower paid Transfer any changes must include a
tax. The change in reason for the change that
loan amount is a valid the lender did not know, or
reason to revise loan could not have known about at
fees. - XXX initial disclosure. Please
provide VCC for changes in
2024/XX/XX: Appeal - transaction, that include
VCC date 11/XX/23 - explanation of reason for
Lender received e-mail change.
from borrower that XXX
was to be removed from 2024/XX/XX: SitusAMC received
the title. See also VCC dated 11/XX/24 for adding
the purchase contract fee due to removed title only
available in file XXX borrower from vesting.
as updated 11/XX/23. -
XXX
649207614 XXX XXX 2 31505937 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is Delivery of appraisal not provided to the borrower within 3 11/XX/2023 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Appraisal Provided Prior prior to the date when valuation was performed. Unable to determine compliance days prior to closing. QM (APOR)
to Date Performed with appraisal timing requirements. (Type:Primary/10/XX/2023)
649206773 XXX XXX 1 29371234 credit 3 Initial Rate Lock rate 3/XX/2013 CA Refinance - Primary No C C C C 7/XX/2023
date is not documented in Cash-out -
file. Debt
Consolidation
649206773 XXX XXX 1 29371235 compliance 2 (Missing Data) Last Rate Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario 3/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Set Date between Creditor Application Date and Transaction Date used to determine rate Cash-out -
used for testing. Debt
Consolidation
649206773 XXX XXX 1 29371236 compliance 2 SAFE Act - Individual LO Truth in Lending Act (NMLSR Dodd- Frank 2014): Individual Loan Originator not 3/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
NMLS license status not licensed to conduct loan origination activities. Cash-out -
approved Debt
Consolidation
649206773 XXX XXX 1 29371237 compliance 2 RESPA (2010) - GFE RESPA (2010): GFE does not provide minimum ten (10) business day availability RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Settlement charges Good for estimate of charges and terms for all other settlement charges. implementing regulation, Regulation X, for these type of violations. Cash-out -
Thru Date Less than 10 Debt
Days Consolidation
649206773 XXX XXX 1 29371238 compliance 2 SAFE Act - LO Company Truth in Lending Act (NMLSR Dodd- Frank 2014): Loan Originator Organization not 3/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
NMLS license status not licensed to conduct loan origination activities. Cash-out -
approved Debt
Consolidation
649206773 XXX XXX 1 29371239 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization only disclosed the prepaid interest fee of $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 3/XX/2013 3/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. $XXX as prepaid finance charges. transactions. Unlimited as a defense to foreclosure. Assignee liability. Cash-out -
Debt
Consolidation
649208102 XXX XXX 1 29371249 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 9/XX/2013 9/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. itemization of amount financed. Under disclosure appears to transactions. Unlimited as a defense to foreclosure. Assignee liability. Cash-out -
be fee related. Debt
Consolidation
649208102 XXX XXX 1 29371250 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 9/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Missing Signature on Arrangement Disclosure. implementing regulation, Regulation X, for these type of violations. Cash-out -
Affiliated Business Debt
Arrangement Disclosure Consolidation
649208102 XXX XXX 1 29371251 compliance 2 TILA - Incorrect Right To Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing 9/XX/2013 9/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Cancel Form Used - H-8 Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses Cash-out -
Used on Same Lender form should have been used. the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that Debt
Refinance (Circuit 2, 5, creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for Consolidation
7, 8, 9, 10 or DC) refinances involving the same creditor.
649207362 XXX XXX 1 29371280 compliance 3 Missing Final HUD-1: Missing Final HUD-1: Estimated HUD-1 used for any applicable Federal, State or No 3/XX/2011 CA Refinance - Investment No D D D D 7/XX/2023
Estimated HUD-1 Used For Local compliance testing. Cash-out -
Fee Testing Material Debt
Consolidation
649208404 XXX XXX 2 29371281 compliance 2 RESPA (2010) - GFE column RESPA (2010) - GFE column on page 3 of Final HUD-1 does not match most recently RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
on HUD Comparison Chart disclosed GFE. implementing regulation, Regulation X, for these type of violations. Rate/Term
Inaccurate
649208404 XXX XXX 2 29371282 compliance 2 RESPA (2010) - Loan RESPA (2010): Loan Amount on Final GFE does not match Note. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Amount on Final GFE implementing regulation, Regulation X, for these type of violations. Rate/Term
Inaccurate
649208404 XXX XXX 2 29371283 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Affiliated Business Disclosure to applicant within three (3) business days of application. implementing regulation, Regulation X, for these type of violations. Rate/Term
Arrangement Disclosure
Not Provided Within 3
Business Days of
Application
649208404 XXX XXX 2 29371284 compliance 2 RESPA Servicing RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Disclosure: Servicing Statement to applicant within three (3) business days of application. implementing regulation, Regulation X, for these type of violations. Rate/Term
Disclosure Statement Not
Provided Within 3
Business Days of
Application
649207210 XXX XXX 1 29371328 credit 3 Missing Document: Missing 2/XX/2013 CA Purchase Investment No C C C C 7/XX/2023
Final 1003
649207210 XXX XXX 1 29371329 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 2/XX/2013 CA Purchase Investment No B B B B 7/XX/2023
649207210 XXX XXX 1 29371330 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 2/XX/2013 CA Purchase Investment No B B B B 7/XX/2023
Application Test an application date of 01/XX/2013 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
649209169 XXX XXX 1 29371371 compliance 2 Possible Federal Loan Loan Originator Compensation: Anti-Steering - Unable to determine Safe Harbor Assignee Liability: Civil actions that may be brought against a creditor may be maintained against 9/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Originator Compensation - due to Anti-Steering Disclosure not provided to borrower. any assignee only if the violation is apparent on the face of the disclosure or other documents Cash-out -
Anti-Steering Disclosure assigned, except where the assignment was involuntary. This civil liability may include $XXX in the Debt
Not Provided: Unable to case of an individual transaction, or the lesser of $XXX or 1% of the creditor's net worth in the Consolidation
determine Anti-Steering case of a class action (effective 1/XX/14, this amount increases to the lesser of $XXX or 1%), as
compliance/Safe Harbor well as actual damages, court costs, and attorneys' fees. For an anti-steering violation, the
creditor may also be liable in an amount equal to the sum of all finance charges and fees paid by the
consumer, unless the creditor demonstrates the failure to comply is not material. Notwithstanding
any other provision of law, when a creditor, assignee, or other holder or anyone acting on behalf of
the creditor, assignee, or holder, initiates a judicial or nonjudicial foreclosure of the residential
mortgage loan, or any other action to collect the debt in connection with such loan, a consumer may
assert a violation as a matter of defense by recoupment or set off without regard for the time limit
on a private action for damages.
Effective 1/XX/2014 in addition to the aforementioned, the individual Loan Originator could be liable
for statutory damages. The maximum liability is the greater of actual damages or 3 times the loan
originator's compensation or gain, plus the cost to the consumer of the action. The Dodd-Frank Act
extended the statute of limitations on TILA violations to 3 years from the date of the violation.
649209169 XXX XXX 1 29371372 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 9/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Application Test an application date of 08/XX/2013 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. Debt
Consolidation
649209169 XXX XXX 1 29371373 compliance 2 Federal LO Compensation Loan Originator Compensation: Dual compensation received from both a consumer and Assignee Liability: Civil actions that may be brought against a creditor may be maintained against 9/XX/2013 9/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Dual Compensation Pre- person other than consumer. any assignee only if the violation is apparent on the face of the disclosure or other documents Cash-out -
Dodd Frank Test assigned, and where the assignment was involuntary. This civil liability may include $XXX in the Debt
case of an individual transaction, or the lesser of $XXX or 1% of the creditor's net worth in the Consolidation
case of a class action as well as actual damages, court costs, and attorneys' fees. For an anti-
steering violation, the creditor may also be liable in an amount equal to the sum of all finance
charges and fees paid by the consumer, unless the creditor demonstrates the failure to comply is not
material. Notwithstanding any other provision of law, when a creditor, assignee, or other holder or
anyone acting on behalf of the creditor, assignee, or holder, initiates a judicial or non-judicial
foreclosure of the residential mortgage loan, or any other action to collect the debt in connection
with such loan, a consumer may assert a violation as a matter of defense by recoupment or set off
without regard for the time limit on a private action for damages.
649209169 XXX XXX 1 29371374 compliance 2 Safe Act NMLS - Missing Secure and Fair Enforcement for Mortgage Licensing Act: Unable to determine Liability appears to be limited to originators/licensees. 9/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Evidence of Initial Loan compliance with NMLSR timing requirements due to missing evidence of initial loan Cash-out -
Application Date application date. Debt
Consolidation
649209169 XXX XXX 1 29371375 compliance 2 RESPA - Initial GFE Not Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 9/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Provided Within 3 Loan Application Date. implementing regulation, Regulation X, for these type of violations. Cash-out -
Business Days of Debt
Application Consolidation
649209169 XXX XXX 1 29371376 compliance 2 RESPA Servicing Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 9/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Disclosure: Servicing Loan Application Date. implementing regulation, Regulation X, for these type of violations. Cash-out -
Disclosure Statement Not Debt
Provided Within 3 Consolidation
Business Days of
Application
649209169 XXX XXX 1 29371377 compliance 2 TIL-MDIA - Initial TIL Unable to determine compliance with timing requirements due to missing Initial TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited as a defense to 9/XX/2013 9/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
Not Provided within 3 Loan Application Date. foreclosure. Assignee liability. Cash-out -
Business Days of Debt
Application Consolidation
649209169 XXX XXX 1 29371378 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum Ever" date on the Final TIL does TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 9/XX/2013 9/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - not match the earliest date on which the maximum rate may apply. Assignee liability. Cash-out -
Maximum Ever Change Date Debt
Inaccurate Consolidation
649209169 XXX XXX 1 29371379 compliance 2 ARM Disclosure Timing Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2013 9/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
Test application due to missing information. Cash-out -
Debt
Consolidation
649209169 XXX XXX 1 29371380 compliance 2 CHARM Booklet Disclosure Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2013 9/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
Timing Loan Application Date. Cash-out -
Debt
Consolidation
649209169 XXX XXX 1 29371381 credit 3 Missing Document: Missing 9/XX/2013 CA Refinance - Primary No C C C C 7/XX/2023
Final 1003 Cash-out -
Debt
Consolidation
649209169 XXX XXX 1 29371382 compliance 2 SAFE Act - LO Company not Unable to test LO company NMLS license due to missing information. Liability appears to be limited to originators/licensees. 9/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
licensed at time of Cash-out -
application Debt
Consolidation
649209169 XXX XXX 1 29371383 compliance 2 SAFE Act - Individual LO Unable to test Individual Loan Originator license status due to missing 9/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
NMLS license status not information. Cash-out -
approved Debt
Consolidation
649209169 XXX XXX 1 29371384 compliance 2 SAFE Act - Individual LO Unable to test Loan Originator license due to missing information. Liability appears to be limited to originators/licensees. 9/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
not licensed at time of Cash-out -
application Debt
Consolidation
649209169 XXX XXX 1 29371385 compliance 2 SAFE Act - LO Company Unable to test LO company status due to missing information. 9/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
NMLS license status not Cash-out -
approved Debt
Consolidation
649207962 XXX XXX 2 29371737 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 5/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Cash-out -
Debt
Consolidation
649207962 XXX XXX 2 29371738 compliance 2 RESPA (2010) - GFE RESPA (2010): GFE does not provide minimum ten (10) business day availability RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 5/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Settlement charges Good for estimate of charges and terms for all other settlement charges. implementing regulation, Regulation X, for these type of violations. Cash-out -
Thru Date Less than 10 Debt
Days Consolidation
649207962 XXX XXX 2 29371739 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 5/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Account Statement Missing implementing regulation, Regulation X, for these type of violations. Cash-out -
Debt
Consolidation
649207962 XXX XXX 2 29371740 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum Ever" date on the Final TIL does TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 5/XX/2013 5/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - not match the earliest date on which the maximum rate may apply. Assignee liability. Cash-out -
Maximum Ever Change Date Debt
Inaccurate Consolidation
649207962 XXX XXX 2 29371741 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "First Adjustment" date on the Final TIL TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 5/XX/2013 5/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - does not match the first adjustment date for the loan. Assignee liability. Cash-out -
First Adjustment Change Debt
Date Inaccurate Consolidation
649207962 XXX XXX 2 29371742 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "First Adjustment" amount of taxes and TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 5/XX/2013 5/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - insurance, including any mortgage insurance, on the Final TIL does not match the Assignee liability. Cash-out -
First Adjustment Taxes escrow payment that may apply during the first rate adjustment of the loan. Debt
and Insurance Inaccurate Consolidation
649207962 XXX XXX 2 29371743 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "First Adjustment" total payment amount TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 5/XX/2013 5/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - (PITI) on the Final TIL does not match the total payment amount that may apply Assignee liability. Cash-out -
First Adjustment Total during the first rate adjustment of the loan. Debt
Payment (PITI) Inaccurate Consolidation
649207962 XXX XXX 2 29371744 credit 3 Missing Document: Missing 5/XX/2013 CA Refinance - Primary No C C C C 7/XX/2023
Final 1003 Cash-out -
Debt
Consolidation
649207962 XXX XXX 2 29371745 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 5/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Application Test an application date of 04/XX/2013 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. Debt
Consolidation
649207962 XXX XXX 2 29371746 compliance 2 SAFE Act - LO Company not Unable to test LO company NMLS license due to missing information. Liability appears to be limited to originators/licensees. 5/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
licensed at time of Cash-out -
application Debt
Consolidation
649207962 XXX XXX 2 29371747 compliance 2 SAFE Act - Individual LO Unable to test Individual Loan Originator license status due to missing 5/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
NMLS license status not information. Cash-out -
approved Debt
Consolidation
649207962 XXX XXX 2 29371748 compliance 2 SAFE Act - Individual LO Unable to test Loan Originator license due to missing information. Liability appears to be limited to originators/licensees. 5/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
not licensed at time of Cash-out -
application Debt
Consolidation
649207962 XXX XXX 2 29371749 compliance 2 SAFE Act - LO Company Unable to test LO company status due to missing information. 5/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
NMLS license status not Cash-out -
approved Debt
Consolidation
649207962 XXX XXX 2 29371750 compliance 2 Safe Act NMLS - Missing Secure and Fair Enforcement for Mortgage Licensing Act: Unable to determine Liability appears to be limited to originators/licensees. 5/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Evidence of Initial Loan compliance with NMLSR timing requirements due to missing evidence of initial loan Cash-out -
Application Date application date. Debt
Consolidation
649207962 XXX XXX 2 29371751 compliance 2 RESPA - Initial GFE Not Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 5/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Provided Within 3 Loan Application Date. implementing regulation, Regulation X, for these type of violations. Cash-out -
Business Days of Debt
Application Consolidation
649207962 XXX XXX 2 29371752 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 5/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Affiliated Business Business Arrangement Disclosure to applicant within three (3) business days of implementing regulation, Regulation X, for these type of violations. Cash-out -
Arrangement Disclosure application due to missing information. Debt
Not Provided Within 3 Consolidation
Business Days of
Application
649207962 XXX XXX 2 29371753 compliance 2 RESPA Servicing Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 5/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Disclosure: Servicing Loan Application Date. implementing regulation, Regulation X, for these type of violations. Cash-out -
Disclosure Statement Not Debt
Provided Within 3 Consolidation
Business Days of
Application
649207962 XXX XXX 2 29371754 compliance 2 TIL-MDIA - Initial TIL Unable to determine compliance with timing requirements due to missing Initial TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited as a defense to 5/XX/2013 5/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
Not Provided within 3 Loan Application Date. foreclosure. Assignee liability. Cash-out -
Business Days of Debt
Application Consolidation
649207962 XXX XXX 2 29371755 compliance 2 ARM Disclosure Timing Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2013 5/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
Test application due to missing information. Cash-out -
Debt
Consolidation
649207962 XXX XXX 2 29371756 compliance 2 CHARM Booklet Disclosure Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2013 5/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
Timing Loan Application Date. Cash-out -
Debt
Consolidation
649208943 XXX XXX 2 29371650 credit 3 Missing Document: Missing 6/XX/2013 CA Refinance - Primary No C C C C 7/XX/2023
Final 1003 Rate/Term
649208943 XXX XXX 2 29371651 compliance 2 Possible Federal Loan Loan Originator Compensation: Anti-Steering - Unable to determine Safe Harbor Assignee Liability: Civil actions that may be brought against a creditor may be maintained against 6/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Originator Compensation - due to Anti-Steering Disclosure not provided to borrower. any assignee only if the violation is apparent on the face of the disclosure or other documents Rate/Term
Anti-Steering Disclosure assigned, except where the assignment was involuntary. This civil liability may include $XXX in the
Not Provided: Unable to case of an individual transaction, or the lesser of $XXX or 1% of the creditor's net worth in the
determine Anti-Steering case of a class action (effective 1/XX/14, this amount increases to the lesser of $XXX or 1%), as
compliance/Safe Harbor well as actual damages, court costs, and attorneys' fees. For an anti-steering violation, the
creditor may also be liable in an amount equal to the sum of all finance charges and fees paid by the
consumer, unless the creditor demonstrates the failure to comply is not material. Notwithstanding
any other provision of law, when a creditor, assignee, or other holder or anyone acting on behalf of
the creditor, assignee, or holder, initiates a judicial or nonjudicial foreclosure of the residential
mortgage loan, or any other action to collect the debt in connection with such loan, a consumer may
assert a violation as a matter of defense by recoupment or set off without regard for the time limit
on a private action for damages.
Effective 1/XX/2014 in addition to the aforementioned, the individual Loan Originator could be liable
for statutory damages. The maximum liability is the greater of actual damages or 3 times the loan
originator's compensation or gain, plus the cost to the consumer of the action. The Dodd-Frank Act
extended the statute of limitations on TILA violations to 3 years from the date of the violation.
649208943 XXX XXX 2 29371652 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 6/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Rate/Term
649208943 XXX XXX 2 29371653 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 6/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Application Test an application date of 05/XX/2013 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date.
649208943 XXX XXX 2 29371654 compliance 2 Federal LO Compensation Loan Originator Compensation: Dual compensation received from both a consumer and Assignee Liability: Civil actions that may be brought against a creditor may be maintained against 6/XX/2013 6/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Dual Compensation Pre- person other than consumer. any assignee only if the violation is apparent on the face of the disclosure or other documents Rate/Term
Dodd Frank Test assigned, and where the assignment was involuntary. This civil liability may include $XXX in the
case of an individual transaction, or the lesser of $XXX or 1% of the creditor's net worth in the
case of a class action as well as actual damages, court costs, and attorneys' fees. For an anti-
steering violation, the creditor may also be liable in an amount equal to the sum of all finance
charges and fees paid by the consumer, unless the creditor demonstrates the failure to comply is not
material. Notwithstanding any other provision of law, when a creditor, assignee, or other holder or
anyone acting on behalf of the creditor, assignee, or holder, initiates a judicial or non-judicial
foreclosure of the residential mortgage loan, or any other action to collect the debt in connection
with such loan, a consumer may assert a violation as a matter of defense by recoupment or set off
without regard for the time limit on a private action for damages.
649208943 XXX XXX 2 29371655 compliance 2 SAFE Act - LO Company not Unable to test LO company NMLS license due to missing information. Liability appears to be limited to originators/licensees. 6/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
licensed at time of Rate/Term
application
649208943 XXX XXX 2 29371656 compliance 2 SAFE Act - Individual LO Unable to test Individual Loan Originator license status due to missing 6/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
NMLS license status not information. Rate/Term
approved
649208943 XXX XXX 2 29371657 compliance 2 SAFE Act - Individual LO Unable to test Loan Originator license due to missing information. Liability appears to be limited to originators/licensees. 6/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
not licensed at time of Rate/Term
application
649208943 XXX XXX 2 29371658 compliance 2 SAFE Act - LO Company Unable to test LO company status due to missing information. 6/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
NMLS license status not Rate/Term
approved
649208943 XXX XXX 2 29371659 compliance 2 Safe Act NMLS - Missing Secure and Fair Enforcement for Mortgage Licensing Act: Unable to determine Liability appears to be limited to originators/licensees. 6/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Evidence of Initial Loan compliance with NMLSR timing requirements due to missing evidence of initial loan Rate/Term
Application Date application date.
649208943 XXX XXX 2 29371660 compliance 2 RESPA - Initial GFE Not Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 6/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Provided Within 3 Loan Application Date. implementing regulation, Regulation X, for these type of violations. Rate/Term
Business Days of
Application
649208943 XXX XXX 2 29371661 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 6/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Account Statement Missing implementing regulation, Regulation X, for these type of violations. Rate/Term
649208943 XXX XXX 2 29371662 compliance 2 RESPA Servicing Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 6/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Disclosure: Servicing Loan Application Date. implementing regulation, Regulation X, for these type of violations. Rate/Term
Disclosure Statement Not
Provided Within 3
Business Days of
Application
649208943 XXX XXX 2 29371663 compliance 2 TIL-MDIA - Initial TIL Unable to determine compliance with timing requirements due to missing Initial TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited as a defense to 6/XX/2013 6/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
Not Provided within 3 Loan Application Date. foreclosure. Assignee liability. Rate/Term
Business Days of
Application
649208943 XXX XXX 2 29371664 compliance 2 2011 TIL-MDIA - Truth in Lending Act (MDIA 2011): The amount of taxes and insurance, including TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 6/XX/2013 6/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Introductory Escrow any mortgage insurance, on the Final TIL does not match the amount of taxes and Assignee liability. Rate/Term
Payment Inaccurate insurance, including any mortgage insurance, for the loan.
649208943 XXX XXX 2 29371665 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): Total payment amount (PITI) on the Final TIL TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 6/XX/2013 6/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - does not match the total payment amount for the loan. Assignee liability. Rate/Term
Introductory Total
Payment (PITI) Inaccurate
649207865 XXX XXX 1 29371679 credit 3 Missing Document: Missing 6/XX/2013 CA Refinance - Primary No C C C C 7/XX/2023
Final 1003 Cash-out -
Debt
Consolidation
649207865 XXX XXX 1 29371680 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 6/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Application Test an application date of 05/XX/2013 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. Debt
Consolidation
649207865 XXX XXX 1 29371681 compliance 2 SAFE Act - LO Company not Unable to test LO company NMLS license due to missing information. Liability appears to be limited to originators/licensees. 6/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
licensed at time of Cash-out -
application Debt
Consolidation
649207865 XXX XXX 1 29371682 compliance 2 SAFE Act - Individual LO Unable to test Individual Loan Originator license status due to missing 6/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
NMLS license status not information. Cash-out -
approved Debt
Consolidation
649207865 XXX XXX 1 29371683 compliance 2 SAFE Act - Individual LO Unable to test Loan Originator license due to missing information. Liability appears to be limited to originators/licensees. 6/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
not licensed at time of Cash-out -
application Debt
Consolidation
649207865 XXX XXX 1 29371684 compliance 2 SAFE Act - LO Company Unable to test LO company status due to missing information. 6/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
NMLS license status not Cash-out -
approved Debt
Consolidation
649207865 XXX XXX 1 29371685 compliance 2 Safe Act NMLS - Missing Secure and Fair Enforcement for Mortgage Licensing Act: Unable to determine Liability appears to be limited to originators/licensees. 6/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Evidence of Initial Loan compliance with NMLSR timing requirements due to missing evidence of initial loan Cash-out -
Application Date application date. Debt
Consolidation
649207865 XXX XXX 1 29371686 compliance 2 RESPA - Initial GFE Not Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 6/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Provided Within 3 Loan Application Date. implementing regulation, Regulation X, for these type of violations. Cash-out -
Business Days of Debt
Application Consolidation
649207865 XXX XXX 1 29371687 compliance 2 RESPA Servicing Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 6/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
Disclosure: Servicing Loan Application Date. implementing regulation, Regulation X, for these type of violations. Cash-out -
Disclosure Statement Not Debt
Provided Within 3 Consolidation
Business Days of
Application
649207865 XXX XXX 1 29371688 compliance 2 TIL-MDIA - Initial TIL Unable to determine compliance with timing requirements due to missing Initial TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited as a defense to 6/XX/2013 6/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
Not Provided within 3 Loan Application Date. foreclosure. Assignee liability. Cash-out -
Business Days of Debt
Application Consolidation
649207865 XXX XXX 1 29371689 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum Ever" date on the Final TIL does TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 6/XX/2013 6/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - not match the earliest date on which the maximum rate may apply. Assignee liability. Cash-out -
Maximum Ever Change Date Debt
Inaccurate Consolidation
649207865 XXX XXX 1 29371690 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "First Adjustment" date on the Final TIL TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 6/XX/2013 6/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - does not match the first adjustment date for the loan. Assignee liability. Cash-out -
First Adjustment Change Debt
Date Inaccurate Consolidation
649207865 XXX XXX 1 29371691 compliance 2 ARM Disclosure Timing Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2013 6/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
Test application due to missing information. Cash-out -
Debt
Consolidation
649207865 XXX XXX 1 29371692 compliance 2 CHARM Booklet Disclosure Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2013 6/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
Timing Loan Application Date. Cash-out -
Debt
Consolidation
649207150 XXX XXX 1 29371826 credit 3 Missing Document: Missing 6/XX/2007 CA Purchase Primary No C C C C 7/XX/2023
Final 1003
649207150 XXX XXX 1 29371827 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 6/XX/2007 CA Purchase Primary No B B B B 7/XX/2023
Application Test an application date of 05/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
649207150 XXX XXX 1 29371828 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 CA Purchase Primary No B B B B 7/XX/2023
Test borrower.
649207150 XXX XXX 1 29371829 compliance 2 CHARM Booklet Disclosure Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 CA Purchase Primary No B B B B 7/XX/2023
Timing Loan Application Date.
649207150 XXX XXX 1 29371830 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 6/XX/2007 CA Purchase Primary No B B B B 7/XX/2023
649208134 XXX XXX 2 29371954 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. No 5/XX/1999 CA Purchase Primary No B B B B 7/XX/2023
Security Instrument Notary Date of 05/XX/1999 used as disbursement date for
compliance testing.
649208134 XXX XXX 2 29371955 compliance 3 Missing Final HUD-1: No Missing Final HUD-1. No document containing fees provided. Any applicable Received only page 1 and a HUD addendum, need page 2 of HUD No 5/XX/1999 CA Purchase Primary No D D D D 7/XX/2023 2023/XX/XX: Full 2023/XX/XX: Unclear what
Document Used For Fee Federal, State or Local compliance testing is unreliable. to complete testing. breakdown of final HUD specific document the seller
Testing Material can be found in the is referring to, however SAMC
Title Insurance does not accept escrow
Document pages 45-48 instructions or other similar
documentation in lieu of a
complete, fully executed HUD-
1. Exception remains.
649208134 XXX XXX 2 29371956 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using No 5/XX/1999 CA Purchase Primary No B B B B 7/XX/2023
Application No Fees an application date of 04/XX/1999 which is 1 months prior to consummation. A
lookback was performed to determine this application date. Due to missing HUD-1
or Closing Disclosure, no fees were used in testing.
649207445 XXX XXX 1 29371958 credit 3 Missing Document: Missing UTD 6/XX/2008 CA UTD - UTD UTD No C C C C 7/XX/2023
Final 1003
649207445 XXX XXX 1 29371959 compliance 2 (Doc Error) Initial GFE UTD 6/XX/2008 CA UTD - UTD UTD No B B B B 7/XX/2023
not provided
649207445 XXX XXX 1 29371960 compliance 2 Unable to determine UTD 6/XX/2008 CA UTD - UTD UTD No B B B B 7/XX/2023
occupancy, compliance
results were generated
using a defaulted value
of Primary.
649207445 XXX XXX 1 29371961 credit 3 Final Title Policy is UTD 6/XX/2008 CA UTD - UTD UTD No C C C C 7/XX/2023
missing. No evidence of
title in file.
649207445 XXX XXX 1 29371962 credit 3 Initial Rate Lock rate UTD 6/XX/2008 CA UTD - UTD UTD No C C C C 7/XX/2023
date is not documented in
file.
649207445 XXX XXX 1 29371963 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. UTD 6/XX/2008 CA UTD - UTD UTD No B B B B 7/XX/2023
Security Instrument Notary Date of 06/XX/2008 used as disbursement date for
compliance testing.
649207445 XXX XXX 1 29371964 compliance 3 Missing Final HUD-1: No Missing Final HUD-1. No document containing fees provided. Any applicable UTD 6/XX/2008 CA UTD - UTD UTD No D D D D 7/XX/2023
Document Used For Fee Federal, State or Local compliance testing is unreliable.
Testing Material
649207445 XXX XXX 1 29371965 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using UTD 6/XX/2008 CA UTD - UTD UTD No B B B B 7/XX/2023
Application No Fees an application date of 05/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date. Due to missing HUD-1
or Closing Disclosure, no fees were used in testing.
649207445 XXX XXX 1 29371966 compliance 2 Property Type Not (Missing Data) Property Type. If property type is other than single family UTD 6/XX/2008 CA UTD - UTD UTD No B B B B 7/XX/2023
Provided residence, state and federal testing may be impacted.
649207445 XXX XXX 1 29371967 compliance 2 Notice of Right to Cancel Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. UTD 6/XX/2008 6/XX/2011 CA UTD - UTD UTD No B B B B 7/XX/2023
Missing
649207445 XXX XXX 1 29371968 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. UTD 6/XX/2008 6/XX/2011 CA UTD - UTD UTD No B B B B 7/XX/2023
Assignee liability.
649207445 XXX XXX 1 29371969 credit 3 Missing Valuation: Appraisal not provided. UTD 6/XX/2008 CA UTD - UTD UTD No C C C C 7/XX/2023
649207633 XXX XXX 2 29371997 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 2/XX/2014 CA Refinance - Investment No B B B B 7/XX/2023
Application Compliance an application date of 12/XX/2013. The source for this date is Initial Cash-out -
Determined Application disclosures. Other
Date
649207055 XXX XXX 1 29372023 credit 3 Missing Document: Missing 6/XX/2013 OR Refinance - Primary No C C C C 7/XX/2023
Final 1003 Rate/Term
649207055 XXX XXX 1 29372024 compliance 2 Possible Federal Loan Loan Originator Compensation: Anti-Steering - Unable to determine Safe Harbor Assignee Liability: Civil actions that may be brought against a creditor may be maintained against 6/XX/2013 OR Refinance - Primary No B B B B 7/XX/2023
Originator Compensation - due to Anti-Steering Disclosure not provided to borrower. any assignee only if the violation is apparent on the face of the disclosure or other documents Rate/Term
Anti-Steering Disclosure assigned, except where the assignment was involuntary. This civil liability may include $XXX in the
Not Provided: Unable to case of an individual transaction, or the lesser of $XXX or 1% of the creditor's net worth in the
determine Anti-Steering case of a class action (effective 1/XX/14, this amount increases to the lesser of $XXX or 1%), as
compliance/Safe Harbor well as actual damages, court costs, and attorneys' fees. For an anti-steering violation, the
creditor may also be liable in an amount equal to the sum of all finance charges and fees paid by the
consumer, unless the creditor demonstrates the failure to comply is not material. Notwithstanding
any other provision of law, when a creditor, assignee, or other holder or anyone acting on behalf of
the creditor, assignee, or holder, initiates a judicial or nonjudicial foreclosure of the residential
mortgage loan, or any other action to collect the debt in connection with such loan, a consumer may
assert a violation as a matter of defense by recoupment or set off without regard for the time limit
on a private action for damages.
Effective 1/XX/2014 in addition to the aforementioned, the individual Loan Originator could be liable
for statutory damages. The maximum liability is the greater of actual damages or 3 times the loan
originator's compensation or gain, plus the cost to the consumer of the action. The Dodd-Frank Act
extended the statute of limitations on TILA violations to 3 years from the date of the violation.
649207055 XXX XXX 1 29372025 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 6/XX/2013 OR Refinance - Primary No B B B B 7/XX/2023
Rate/Term
649207055 XXX XXX 1 29372026 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 6/XX/2013 OR Refinance - Primary No B B B B 7/XX/2023
Application Test an application date of 05/XX/2013 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date.
649207055 XXX XXX 1 29372027 compliance 2 SAFE Act - LO Company not Unable to test LO company NMLS license due to missing information. Liability appears to be limited to originators/licensees. 6/XX/2013 OR Refinance - Primary No B B B B 7/XX/2023
licensed at time of Rate/Term
application
649207055 XXX XXX 1 29372028 compliance 2 SAFE Act - Individual LO Unable to test Individual Loan Originator license status due to missing 6/XX/2013 OR Refinance - Primary No B B B B 7/XX/2023
NMLS license status not information. Rate/Term
approved
649207055 XXX XXX 1 29372029 compliance 2 SAFE Act - Individual LO Unable to test Loan Originator license due to missing information. Liability appears to be limited to originators/licensees. 6/XX/2013 OR Refinance - Primary No B B B B 7/XX/2023
not licensed at time of Rate/Term
application
649207055 XXX XXX 1 29372030 compliance 2 SAFE Act - LO Company Unable to test LO company status due to missing information. 6/XX/2013 OR Refinance - Primary No B B B B 7/XX/2023
NMLS license status not Rate/Term
approved
649207055 XXX XXX 1 29372031 compliance 2 Safe Act NMLS - Missing Secure and Fair Enforcement for Mortgage Licensing Act: Unable to determine Liability appears to be limited to originators/licensees. 6/XX/2013 OR Refinance - Primary No B B B B 7/XX/2023
Evidence of Initial Loan compliance with NMLSR timing requirements due to missing evidence of initial loan Rate/Term
Application Date application date.
649207055 XXX XXX 1 29372032 compliance 2 RESPA - Initial GFE Not Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 6/XX/2013 OR Refinance - Primary No B B B B 7/XX/2023
Provided Within 3 Loan Application Date. implementing regulation, Regulation X, for these type of violations. Rate/Term
Business Days of
Application
649207055 XXX XXX 1 29372033 compliance 2 RESPA Servicing Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 6/XX/2013 OR Refinance - Primary No B B B B 7/XX/2023
Disclosure: Servicing Loan Application Date. implementing regulation, Regulation X, for these type of violations. Rate/Term
Disclosure Statement Not
Provided Within 3
Business Days of
Application
649207055 XXX XXX 1 29372034 compliance 2 Oregon Prepayment Penalty Oregon Prepayment Penalty: Loan agreement or Note does not clearly state the 6/XX/2013 OR Refinance - Primary No B B B B 7/XX/2023
Max Prepay maximum prepayment penalty applicable to each year of the loan. Rate/Term
649207055 XXX XXX 1 29372035 compliance 2 TIL-MDIA - Initial TIL Unable to determine compliance with timing requirements due to missing Initial TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited as a defense to 6/XX/2013 6/XX/2014 OR Refinance - Primary No B B B B 7/XX/2023
Not Provided within 3 Loan Application Date. foreclosure. Assignee liability. Rate/Term
Business Days of
Application
649207055 XXX XXX 1 29372036 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum Ever" date on the Final TIL does TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 6/XX/2013 6/XX/2016 OR Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - not match the earliest date on which the maximum rate may apply. Assignee liability. Rate/Term
Maximum Ever Change Date
Inaccurate
649207055 XXX XXX 1 29372037 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "First Adjustment" date on the Final TIL TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 6/XX/2013 6/XX/2016 OR Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - does not match the first adjustment date for the loan. Assignee liability. Rate/Term
First Adjustment Change
Date Inaccurate
649207055 XXX XXX 1 29372038 compliance 2 ARM Disclosure Compliant TIL variable rate disclosure: ARM loan program disclosure does not match terms of TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2013 6/XX/2014 OR Refinance - Primary No B B B B 7/XX/2023
Test loan. Rate/Term
649207055 XXX XXX 1 29372039 compliance 2 ARM Disclosure Timing Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2013 6/XX/2014 OR Refinance - Primary No B B B B 7/XX/2023
Test application due to missing information. Rate/Term
649207055 XXX XXX 1 29372040 compliance 2 CHARM Booklet Disclosure Unable to determine if loan file contains CHARM Booklet due to missing TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2013 6/XX/2014 OR Refinance - Primary No B B B B 7/XX/2023
Status information. Rate/Term
649206772 XXX XXX 2 29372087 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum Ever" date on the Final TIL does TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 11/XX/2013 11/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Payment Summary Table - not match the earliest date on which the maximum rate may apply. Assignee liability. Rate/Term
Maximum Ever Change Date
Inaccurate
649206772 XXX XXX 2 29372088 compliance 2 ARM Disclosure Compliant TIL variable rate disclosure: ARM loan program disclosure does not match terms of TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2013 11/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
Test loan. Rate/Term
649206772 XXX XXX 2 29372089 compliance 2 ARM Disclosure Timing Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2013 11/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
Test application due to missing information. Rate/Term
649206772 XXX XXX 2 29372090 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2013 11/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023
Status CHARM Booklet, not provided to the borrower. Rate/Term
649206772 XXX XXX 2 29372091 compliance 2 TILA - Incorrect Right To Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing 11/XX/2013 11/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023
Cancel Form Used - H-8 Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses Rate/Term
Used on Same Lender form should have been used. the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that
Refinance (Circuit 2, 5, creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for
7, 8, 9, 10 or DC) refinances involving the same creditor.
649206772 XXX XXX 2 29372092 compliance 2 SAFE Act - Individual LO Secure and Fair Enforcement for Mortgage Licensing Act: Individual Loan 11/XX/2013 CA Refinance - Primary No B B B B 7/XX/2023
NMLS license status not Originator not in approved license status to conduct loan origination activities. Rate/Term
approved
649209233 XXX XXX 1 29372199 credit 3 Initial Rate Lock rate 11/XX/1996 CA Refinance - Primary No C C C C 7/XX/2023
date is not documented in Cash-out -
file. Other
649209233 XXX XXX 1 29372200 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/1996 11/XX/1997 CA Refinance - Primary No B B B B 7/XX/2023
Test borrower. Cash-out -
Other
649209233 XXX XXX 1 29372201 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/1996 11/XX/1997 CA Refinance - Primary No B B B B 7/XX/2023
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649207214 XXX XXX 2 29372222 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA Disaster area 5/XX/2016 CA Refinance - Primary No A A A A 7/XX/2023 5/XX/2023 Yes Non QM 2023/XX/XX: BPO provided
most recent valuation Disaster End Date: XX/XX/XXXX post-close. A post-disaster inspection verifying there was Rate/Term reflecting no damage.
inspection is dated prior Disaster Name: XXX no damage to the subject property is required.
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207214 XXX XXX 2 29372223 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 5/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three (3) business days prior to consummation. Rate/Term
Business Days Prior to (Type:Primary/05/XX/2016)
Consummation
649207214 XXX XXX 2 29372224 compliance 1 Check Loan Designation Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Loan designation failure is due to missing VVOE for both Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 5/XX/2016 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/XX: N/A; 2023/XX/XX: None of the
Match - ATR not match Due Diligence Loan Designation of ATR Fail. borrower and co-borrower. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Rate/Term Duplicative Exception documents received are
sufficient to clear this
2023/XX/XX: Agree with condition. Please provide
error, but don't agree VVOE for co-borrower.
with ATR impact based
on overall file risk & 2023/XX/XX: Trailing
quality. documents reviewed unable to
clear. Provide missing Third
Party Verification.
2023/XX/XX: Loan approved as
Portfolio Express which is
reduced income, however due
to loan designation of Non
QM, a third party
verification is required for
the CB.
2023/XX/XX: Loan designation
failure due to missing
employment verifications. B1
Employment VOE dated 5.XX.16
is not within 10 Business
days of the Note date and no
VOE was provided for B2
employment verification.
2023/XX/XX: VVOE not required
for salaried borrower on
Portfolio Express.
2023/XX/XX: No supporting
trailing documentation was
provided to clear this
exception. Exception remains.
649207214 XXX XXX 2 29372225 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify current Wages/W-2 employment Due to missing VVOE for both borrower and co-borrower. Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 5/XX/2016 CA Refinance - Primary No A A A A 7/XX/2023 5/XX/2023 Yes Non QM 2023/XX/XX: Updated
Provision Employment - W- status using reasonably reliable third-party records. (XXX XXX/Wages) damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Rate/Term employment letter to VOE.
2 all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure
to comply is not material). A private right of action may be brought before the end of the three-
year period beginning on the date of the occurrence of the violation. However, when a creditor,
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649207214 XXX XXX 2 29372226 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify current Wages/W-2 employment Due to missing VVOE for both borrower and co-borrower. Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 5/XX/2016 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/XX: LOE 2023/XX/XX: None of the
Provision Employment - W- status using reasonably reliable third-party records. (XXX XXX/Wages) damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Rate/Term confirming employment documents received are
2 all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure from employer for B1 sufficient to clear this
to comply is not material). A private right of action may be brought before the end of the three- dated 5/XX/2016. There condition. Please provide
year period beginning on the date of the occurrence of the violation. However, when a creditor, is no documentation in VVOE for co-borrower.
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial file confirming
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter employment from 2023/XX/XX: Trailing
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set- employer or third documents reviewed unable to
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages party source and no clear. Provide missing Third
for a valid claim brought in an original action, plus the costs to the consumer of the action. If date completed on Age Party Verification.
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set- of Documentation
off shall not exceed three years of finance charges and fees. An action to enforce a violation may Checklists for VVOE in 2023/XX/XX: Loan approved as
also be brought by the appropriate state AGs. file for B2. Agree Portfolio Express which is
with finding for B2. reduced income, however due
to loan designation of Non
2023/XX/XX: Duplicate QM, a third party
and/or waterfall verification is required for
exception the CB.
2023/XX/XX: B1 Employment VOE
dated 5.XX.16 is not within
10 Business days of the Note
date and no VOE was provided
for B2 employment
verification.
2023/XX/XX: VVOE not required
for salaried borrower on
Portfolio Express.
649207214 XXX XXX 2 29372228 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Consumer Handbook on Adjustable Rate Mortgages, CHARM TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2016 5/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower. Booklet document not provided Rate/Term
649207214 XXX XXX 2 29372229 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the File contains ARM program disclosure; however, it is not TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2016 5/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Test borrower. dated to determine it was provided within 3 business days of Rate/Term
application.
649207214 XXX XXX 2 29372230 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Credit Report fee was last disclosed as $XXX on LE but TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2016 5/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Tolerance Violation Report Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no disclosed as $XXX on Final Closing Disclosure. File does not Rate/Term
Without Sufficient Cure cure was provided to the borrower. (7520) contain a valid COC for this fee, nor evidence of cure in
Provided file.
649207214 XXX XXX 2 29372231 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Loan Disclosures: Page 1 of final CD shows monthly Estimated TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2016 5/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure Property Costs Costs over Year 1 of $XXX on Final Closing Disclosure provided on 05/XX/2016 are Taxes, Insurance & Assessments of $XXX translating to an Rate/Term
Year 1 Underdisclosed - underdisclosed. (Final/05/XX/2016) annual payment of $XXX. Page 4 of final CD reflects Amount
Pre October 2018 of Estimated Property Costs over Year 1 of 19,906.34.
649207214 XXX XXX 2 29372232 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2016 5/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Tolerance Violation Appraisal Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no or no cure was provided to the borrower. Rate/Term
Without Sufficient Cure cure was provided to the borrower. (7506)
Provided
649207214 XXX XXX 2 29372233 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of File is missing List of Homeownership Counseling RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 5/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
of Homeownership Homeownership Counseling Organizations to borrower. Organizations. implementing regulation, Regulation X, for these type of violations. Rate/Term
Counseling Organizations
Missing
649206888 XXX XXX 2 29372449 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Property inspection report was not included in the file. 4/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 5/XX/2023 Yes Non QM 2023/XX/XX: BPO provided
most recent valuation Disaster End Date: XX/XX/XXXX Rate/Term reflecting no damage.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649206888 XXX XXX 2 29372450 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 4/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM 2023/XX/XX: Document provided
of Homeownership Homeownership Counseling Organizations to borrower. implementing regulation, Regulation X, for these type of violations. Rate/Term cannot be used to clear this
Counseling Organizations condition. Please provide
Missing the list of at least 10
counseling agencies, along
with date list was obtained.
649206888 XXX XXX 2 29372451 compliance 1 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2019 4/XX/2020 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received;
Status CHARM Booklet, not provided to the borrower. Rate/Term however, see updated
condition as it was not
provided within 3 business
days of application.
649206888 XXX XXX 2 29372452 compliance 1 Check Loan Designation Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Failure is due to missing asset and income documentation Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 4/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: VOE received.
Match - ATR not match Due Diligence Loan Designation of ATR Fail. which is waterfalling to ATR/QM testing. Lender approved firm performing the loan level due diligence and to have the TPR firm confirm said designation. Rate/Term Loan approved under Portfolio
loan as a portfolio express product. Express which allowed stated
assets. Condition cleared.
649206888 XXX XXX 2 29372453 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify current Wages/W-2 employment Failure is due to missing asset and income documentation Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 4/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: VOE received.
Provision Employment - W- status using reasonably reliable third-party records. (XXX XXX/Wages) which is waterfalling to ATR/QM testing. Lender approved damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Rate/Term Loan approved under Portfolio
2 loan as a portfolio express product. all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Express which allowed stated
to comply is not material). A private right of action may be brought before the end of the three- assets. Condition cleared.
year period beginning on the date of the occurrence of the violation. However, when a creditor,
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649206888 XXX XXX 2 29372455 compliance 1 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy Verification appraisal was delivered to borrower was not There is generally no Assignee Liability. 4/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Appraisal
Appraisal Not Provided at of the appraisal at least three (3) business days prior to closing, and appraisal provided. Rate/Term delivery received.
or Before Closing (3-Day was not provided at or before closing. (Type:Primary/03/XX/2019)
Waiver In File)
649206888 XXX XXX 2 29372456 credit 1 No evidence of fraud Credit Report: Original // Borrower: XXX 4/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received
report in file Rate/Term
649206888 XXX XXX 2 29372457 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement 4/XX/2019 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
is missing. Rate/Term
649206888 XXX XXX 2 29372458 credit 1 Missing Document: Missing File is missing fully signed/dated final application. 4/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received
Final 1003 Rate/Term
649206888 XXX XXX 2 29372460 credit 1 Missing Document: Rider - Executed PUD Rider not provided. 4/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received
PUD not provided Rate/Term
649206888 XXX XXX 2 29372461 credit 1 Missing Document: Executed Security Instrument not provided. 4/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received
Security Instrument - Rate/Term
Subject Lien not provided
649206888 XXX XXX 2 29372462 credit 1 Missing Document: Rider - Executed ARM Rider not provided. 4/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received
ARM not provided Rate/Term
649206888 XXX XXX 2 29372463 compliance 1 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM Disclosure is missing from the file. TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2019 4/XX/2020 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received;
Test borrower. Rate/Term however, see updated
condition as it was not
provided within 3 business
days of application.
649206888 XXX XXX 2 29372464 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify assets using reasonably Failure is due to missing asset and income documentation Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 4/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: VOE received.
Provision Income and reliable third-party records. (XXX/Savings) which is waterfalling to ATR/QM testing. Lender approved damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Rate/Term Loan approved under Portfolio
Assets - Assets loan as a portfolio express product. all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Express which allowed stated
to comply is not material). A private right of action may be brought before the end of the three- assets. Condition cleared.
year period beginning on the date of the occurrence of the violation. However, when a creditor,
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649206888 XXX XXX 2 29372465 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify assets using reasonably Failure is due to missing asset and income documentation Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 4/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: VOE received.
Provision Income and reliable third-party records. (XXX/401(k)/403(b) Account) which is waterfalling to ATR/QM testing. Lender approved damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Rate/Term Loan approved under Portfolio
Assets - Assets loan as a portfolio express product. all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Express which allowed stated
to comply is not material). A private right of action may be brought before the end of the three- assets. Condition cleared.
year period beginning on the date of the occurrence of the violation. However, when a creditor,
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649206888 XXX XXX 2 29372466 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM disclosure provided 3/XX/2019, which was not within 3 TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2019 4/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Test borrower within three (3) days of application. days of application. Rate/Term
649206888 XXX XXX 2 29372467 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM disclosure provided 3/XX/2019, which was not within 3 TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2019 4/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Timing CHARM Booklet, not provided to the borrower within three (3) days of application. days of application. Rate/Term
649208520 XXX XXX 1 29372475 compliance 2 Missing Document: Missing Provide signed and dated initial 1003. 7/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Lender's Initial 1003 Rate/Term
649208520 XXX XXX 1 29372476 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 7/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three (3) business days prior to consummation. Rate/Term
Business Days Prior to (Type:Primary/05/XX/2014)
Consummation
649208520 XXX XXX 1 29372477 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of List of Homeownership Counseling Organizations disclosure is RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 7/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
of Homeownership Homeownership Counseling Organizations to borrower. missing in file. implementing regulation, Regulation X, for these type of violations. Rate/Term
Counseling Organizations
Missing
649208520 XXX XXX 1 29372478 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Post Disaster Inspection Report is missing in file. 7/XX/2014 CA Refinance - Primary No A A A A 7/XX/2023 5/XX/2023 Yes Non QM 2023/XX/XX: BPO provided
most recent valuation Disaster End Date: XX/XX/XXXX Rate/Term reflecting no damage.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649208520 XXX XXX 1 29372479 property 1 The loan is to be Valuation Type: Appraisal / Valuation Report Date: 05/XX/2014 Appraiser's Certification is missing in file. 7/XX/2014 CA Refinance - Primary No A A A A 7/XX/2023 5/XX/2023 Yes Non QM 2023/XX/XX: Client not
securitized and the Rate/Term securitizing loan.
appraisal certification
was not included in the
provided valuation.
Securitization valuations
are required to be
FIRREA/USPAP compliant.
649208520 XXX XXX 1 29372480 compliance 2 (Doc Error) GFE Error: GFE Date: 07/XX/2014 Changed Circumstance not provided for GFE dated 07/XX/2014 Changed of Circumstance is not present in file. 7/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Changed Circumstance not from GFE dated 06/XX/2014 Rate/Term
provided.
649207790 XXX XXX 2 29372510 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. Initial Escrow Account Statement is missing from the loan RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 12/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Account Statement Missing file. implementing regulation, Regulation X, for these type of violations. Rate/Term
649207790 XXX XXX 2 29372511 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. FACTA disclosure missing from loan file. There is no Assignee Liability. 12/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Rate/Term
649207790 XXX XXX 2 29372512 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify debt obligations using Credit report is missing from the loan file. Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 12/XX/2015 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Risk 2023/XX/XX: Credit 2023/XX/XX: Trailing docs
Provision Credit History reasonably reliable third-party records. damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Rate/Term report not found. provided but resulted in: A
all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure file containing content that
to comply is not material). A private right of action may be brought before the end of the three- 2023/XX/XX: Uploaded is not permitted in this
year period beginning on the date of the occurrence of the violation. However, when a creditor, Credit Report storage location has been
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial quarantined.
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set- 2023/XX/XX: Credit report not
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages provided in file. Condition
for a valid claim brought in an original action, plus the costs to the consumer of the action. If remains.
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may 2023/XX/XX: Credit report was
also be brought by the appropriate state AGs. provided. Loan is Portfolio
express. Condition cleared
but updated.
649207790 XXX XXX 2 29372513 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Fee Amount of $XXX was added on the 11/XX/15 Closing TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2015 12/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Tolerance Violation Recording Service Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Disclosure. File did not contain a valid Change of Rate/Term
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (75197) Circumstance or evidence of a tolerance cure.
Provided
649207790 XXX XXX 2 29372514 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Fee Amount of $XXX was added on the 11/XX/15 Closing TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2015 12/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Tolerance Violation Endorsement Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or Disclosure. File did not contain a valid Change of Rate/Term
Without Sufficient Cure no cure was provided to the borrower. (7564) Circumstance or evidence of a tolerance cure.
Provided
649207790 XXX XXX 2 29372515 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, No evidence in file the CHARM booklet was provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2015 12/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Status CHARM Booklet, not provided to the borrower. borrower. Rate/Term
649207790 XXX XXX 2 29372516 credit 1 Missing Document: Credit Credit Report is not Provided 12/XX/2015 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Risk 2023/XX/XX: N/A; 2023/XX/XX: Trailing docs
Report not provided Rate/Term Duplicative Exception provided but resulted in: A
file containing content that
2023/XX/XX: Uploaded is not permitted in this
Credit Report storage location has been
quarantined.
2023/XX/XX: Credit report not
provided in file. Condition
remains.
2023/XX/XX: Credit report was
provided. Loan is Portfolio
express.Condition cleared.
649207790 XXX XXX 2 29372517 credit 3 File does not contain Valuation Type: Appraisal / Valuation Report Date: 11/XX/2015 File does not contain documentation from lender/seller 12/XX/2015 CA Refinance - Primary No C C C C 7/XX/2023 ATR Risk
documentation from confirming the condo is warrantable. Rate/Term
lender/seller confirming
the condo is warrantable.
649207790 XXX XXX 2 29372518 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Post-disaster Inspection missing from file. 12/XX/2015 CA Refinance - Primary No A A A A 7/XX/2023 5/XX/2023 Yes ATR Risk 2023/XX/XX: BPO provided
most recent valuation Disaster End Date: XX/XX/XXXX Rate/Term reflecting no damage.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207790 XXX XXX 2 29372519 compliance 1 Check Loan Designation Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Designation fail due to missing employment, asset and credit Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 12/XX/2015 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Risk 2023/XX/XX: N/A; 2023/XX/XX: Trailing docs did
Match - ATR not match Due Diligence Loan Designation of ATR Fail. documentation to meet ATR. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Rate/Term Duplicative Exception not contain any docs to clear
this exception.
2023/XX/XX: Uploaded
Credit Report 2023/XX/XX: Credit report not
provided in file. Condition
remains.
2023/XX/XX: Credit report was
provided. Loan is Portfolio
express. Condition cleared
but updated.
649207790 XXX XXX 2 29372520 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify assets using reasonably ATR failure due to lack of asset documentation. Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 12/XX/2015 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Risk 2023/XX/XX: N/A; 2023/XX/XX: Trailing docs did
Provision Income and reliable third-party records. (XXX/Checking) damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Rate/Term Duplicative Exception not contain any docs to clear
Assets - Assets all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure this exception.
to comply is not material). A private right of action may be brought before the end of the three- 2023/XX/XX: Uploaded
year period beginning on the date of the occurrence of the violation. However, when a creditor, Credit Report 2023/XX/XX: Trailing docs did
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial not contain any docs to clear
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter this exception.
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages 2023/XX/XX: Credit report was
for a valid claim brought in an original action, plus the costs to the consumer of the action. If provided. Loan is Portfolio
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set- express. Condition cleared
off shall not exceed three years of finance charges and fees. An action to enforce a violation may but updated.
also be brought by the appropriate state AGs.
649207790 XXX XXX 2 29372521 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify assets using reasonably ATR failure due to lack of asset documenation Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 12/XX/2015 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Risk 2023/XX/XX: N/A; 2023/XX/XX: Trailing docs did
Provision Income and reliable third-party records. (XXX/Checking) damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Rate/Term Duplicative Exception not contain any docs to clear
Assets - Assets all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure this exception.
to comply is not material). A private right of action may be brought before the end of the three- 2023/XX/XX: Uploaded
year period beginning on the date of the occurrence of the violation. However, when a creditor, Credit Report 2023/XX/XX: Trailing docs did
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial not contain any docs to clear
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter this exception.
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages 2023/XX/XX: Credit report was
for a valid claim brought in an original action, plus the costs to the consumer of the action. If provided. Loan is Portfolio
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set- express. Condition cleared
off shall not exceed three years of finance charges and fees. An action to enforce a violation may but updated.
also be brought by the appropriate state AGs.
649207790 XXX XXX 2 29372522 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2015 12/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Disclosure Other Includes provided on 12/XX/2015 disclosed whether Homeowners insurance is included in Rate/Term
Insurance Costs escrow in incorrect section. Creditor disclosed insurance to consumer in "Other"
section where regulation requires disclosure under "Homeowner's Insurance"
section of Projected Payments table. Disclosure requirement met, non-material
exception for incorrect format/placement. (Final/12/XX/2015)
649207790 XXX XXX 2 29372523 credit 1 AUS/Guideline Findings: Missing credit report 12/XX/2015 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Risk 2023/XX/XX: Credit report was
All conditions were not Rate/Term provided. Loan is Portfolio
met express. Condition cleared
649207790 XXX XXX 2 29372524 credit 1 Asset documentation File is missing all asset documentation 12/XX/2015 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Risk 2023/XX/XX: Loan is a
requirements not met. Rate/Term portfolio express per
rebuttal. Condition cleared.
649207790 XXX XXX 2 29372525 credit 1 Income documentation File is missing the borrower's 2 year employment history 12/XX/2015 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Risk 2023/XX/XX: Loan is a
requirements not met. Rate/Term portfolio express per
rebuttal. Condition cleared.
649207790 XXX XXX 2 29372526 compliance 1 Income/Asset Guideline Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to File is missing credit report, all asset documentation and a 12/XX/2015 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Risk 2023/XX/XX: Credit report was
Deficiency - ATR Impact income and/or asset doc requirements which could result in a risk to the 2 year employment history Rate/Term provided. Loan is Portfolio
borrower's ability to repay. (Exception is eligible to be regraded with express. Condition cleared
compensating factors.) but updated.
649207790 XXX XXX 2 29372527 compliance 3 Check Loan Designation Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does The maximum DTI is 38% per Portfolio Express guides. Loan Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 12/XX/2015 CA Refinance - Primary No C C B B 7/XX/2023 ATR Risk 2023/XX/XX: Disagree; 2023/XX/XX: Failure remains
Match - ATR Risk not match Due Diligence Loan Designation of ATR Risk. approved at 40.433% firm performing the loan level due diligence and to have the TPR firm confirm said designation. Rate/Term Portfolio Express due to insufficient assets to
loans do not have cover the increase reserves.
their own specific max Per the Portfolio Express and
DTI requirements. RLU- Expanded DTI guides, 43% is
NA 502-2 LOAN allowed with a 720 fico and
PARAMETERS / 12 months reserves.
UNDERWRITING
GUIDELINES section
states: Debt ratios
apply according to the
program selected. Max
DTI allowed is 43%.
649207790 XXX XXX 2 29372528 compliance 3 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more The maximum DTI is 38% per Portfolio Express guides. Loan 12/XX/2015 CA Refinance - Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/XX: Disagree; 2023/XX/XX: Failure remains
Provision Investor guideline components, the loan is at ATR risk. approved at 40.433% Rate/Term Portfolio Express due to insufficient assets to
Guidelines loans do not have cover the increase reserves.
their own specific max Per the Portfolio Express and
DTI requirements. RLU- Expanded DTI guides, 43% is
NA 502-2 LOAN allowed with a 720 fico and
PARAMETERS / 12 months reserves.
UNDERWRITING
GUIDELINES section
states: Debt ratios
apply according to the
program selected. Max
DTI allowed is 43%.
649207790 XXX XXX 2 29372529 compliance 1 General ATR Provision Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the The maximum DTI is 38% per Portfolio Express guides. Loan 12/XX/2015 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Risk 2023/XX/XX: Disagree; 2023/XX/XX: 43% is allowed
Investor and Non QM DTIs Lenders Guidelines and 1026.43(c)(5) of 39.95812% moderately exceeds the approved at 40.433% Rate/Term Portfolio Express under expanded criteria.
match and both moderately guideline maximum of 38.00%. (DTI Exception is eligible to be regraded with loans do not have However updated exceptions
exceed Guidelines compensating factors.) their own specific max were generated due to
DTI requirements. RLU- insufficient assets stated on
NA 502-2 LOAN the application.
PARAMETERS /
UNDERWRITING
GUIDELINES section
states: Debt ratios
apply according to the
program selected. Max
DTI allowed is 43%.
649207790 XXX XXX 2 29372530 credit 1 Guideline Requirement: Calculated investor qualifying total debt ratio of 39.95812% exceeds Guideline The maximum DTI is 38% per Portfolio Express guides. Loan 12/XX/2015 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Risk 2023/XX/XX: Disagree; 2023/XX/XX: 43% DTI is
Investor qualifying total total debt ratio of 38.00000%. approved at 40.433% Rate/Term Portfolio Express allowed within expanded
debt ratio discrepancy. loans do not have guides.
their own specific max
DTI requirements. RLU-
NA 502-2 LOAN
PARAMETERS /
UNDERWRITING
GUIDELINES section
states: Debt ratios
apply according to the
program selected. Max
DTI allowed is 43%.
649207790 XXX XXX 2 29372531 credit 3 Guideline Requirement: Calculated PITIA months reserves of 5.34 is less than Guideline PITIA months Per Portfolio Express and expanded DTI guides, 43% DTI is 12/XX/2015 CA Refinance - Primary No C C C C 7/XX/2023 ATR Risk
PITIA reserves months reserves of 12.00. allowed with a 720 fico and 12 months reserves. Insufficient Rate/Term
discrepancy. assets were listed on the application to cover 12 months
reserves.
649207043 XXX XXX 1 29372682 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is Due to missing self-employed income documentation, the 1/XX/2021 CA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor
Appraisal Provided Prior prior to the date when valuation was performed. Unable to determine compliance subject loan designation is QM (APOR) Fail. Cash-out - QM
to Date Performed with appraisal timing requirements. (Type:Primary/12/XX/2020) Debt
Consolidation
649207043 XXX XXX 1 29372683 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2021 1/XX/2022 CA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor
Test borrower within three (3) days of application. Cash-out - QM
Debt
Consolidation
649207043 XXX XXX 1 29372684 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2021 1/XX/2022 CA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor
Status CHARM Booklet, not provided to the borrower. Cash-out - QM
Debt
Consolidation
649207043 XXX XXX 1 29372685 credit 2 Loans with an application Index: LIBOR - 1 Year (Daily); Note Date: 01/XX/2021 1/XX/2021 CA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor
date after 10/XX/2020 Cash-out - QM
using a LIBOR Index are Debt
not Agency Salable. Consolidation
649207043 XXX XXX 1 29372686 credit 3 Verification(s) of Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: Loan file is missing borrower's Verification of employment 1/XX/2021 CA Refinance - Primary No C C C C 7/XX/2023 Safe Harbor
employment is not within 08/XX/2013 dated within 10 business days of the Note. Cash-out - QM
10 business days of the Debt
Note. Consolidation
649208237 XXX XXX 2 29372687 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX 2/XX/2021 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: BPO provided
most recent valuation Disaster End Date: XX/XX/XXXX QM reflects no damage.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649208237 XXX XXX 2 29372688 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement E-sign Consent Agreement not provided. 2/XX/2021 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
is missing. QM
649208237 XXX XXX 2 29372689 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy Verification of appraisal was delivered to borrower was not There is generally no Assignee Liability. 2/XX/2021 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Appraisal Not Provided at of the appraisal at least three (3) business days prior to closing, and appraisal provided QM
or Before Closing (3-Day was not provided at or before closing. (Type:Primary/01/XX/2021)
Waiver In File)
649208237 XXX XXX 2 29372691 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Credit Repot Fee was last disclosed $XXX on LE but disclosed TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 2/XX/2021 2/XX/2022 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Tolerance Violation Report Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no as$XXX on Final CD. File does not contain COC for this file QM
Without Sufficient Cure cure was provided to the borrower. (7520) Cure provided at closing
Provided
649208237 XXX XXX 2 29372692 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Flood Flood Certification Fee was not disclosed on Loan Estimate TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 2/XX/2021 2/XX/2022 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Tolerance Violation Certification (Initial Fee). Fee Amount of $XXX exceeds tolerance of $XXX. but was disclosed as $XXX on the final CD. File does not a QM
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (7531) valid COC for this fee cure provided at closing.
Provided
649208237 XXX XXX 2 29372693 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM loan program disclosure not provided to the borrower TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2021 2/XX/2022 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Test borrower within three (3) days of application. within three (3) days of application. QM
649208237 XXX XXX 2 29372694 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Consumer Handbook on Adjustable Rate Mortgages, CHARM TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2021 2/XX/2022 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor 2023/XX/XX: Missing CHARM
Timing CHARM Booklet, not provided to the borrower within three (3) days of application. Booklet, not provided to the borrower within three (3) days QM Booklet provided within 3
of application. days of application.
649208237 XXX XXX 2 29372695 credit 2 Loans with an application Index: LIBOR - 1 Year (Daily); Note Date: 02/XX/2021 2/XX/2021 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
date after 10/XX/2020 QM
using a LIBOR Index are
not Agency Salable.
649207506 XXX XXX 1 29372729 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA disaster area. A 1/XX/2021 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: BPO provided
most recent valuation Disaster End Date: XX/XX/XXXX post disaster inspection verifying there was no damage to QM reflects no damage.
inspection is dated prior Disaster Name: XXX the subject property is required.
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207506 XXX XXX 1 29372731 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the The ARM Disclosure was dated 12/XX/2020, more than three TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2021 2/XX/2022 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Test borrower within three (3) days of application. days from Applicaiton date of 12/XX/2020. QM
649207506 XXX XXX 1 29372732 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, The CHARM Booklet was dated 12/XX/2020, more than three days TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2021 2/XX/2022 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor 2023/XX/XX: Missing CHARM
Timing CHARM Booklet, not provided to the borrower within three (3) days of application. from Applicaiton date of 12/XX/2020. QM Booklet provided within 3
days of application.
649207506 XXX XXX 1 29372733 credit 2 Loans with an application Index: LIBOR - 1 Year (Daily); Note Date: 01/XX/2021 Libor 1 Year Daily was reflected on the Note. Loans with an 1/XX/2021 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
date after 10/XX/2020 application date on or after 10/XX/2020 using a LIBOR Index QM
using a LIBOR Index are are not Agency Salable.
not Agency Salable.
649207506 XXX XXX 1 29372734 credit 3 REO Documents are Address: XXX, CA Other The documents provided within the loan file for the REO do 1/XX/2021 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
missing. not total the amount listed for expenses on the final signed QM
1003. Short $XXX.
649208879 XXX XXX 2 29372743 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX 8/XX/2020 CA Purchase Primary No A A A A 7/XX/2023 5/XX/2023 Yes Non QM 2023/XX/XX: BPO provided
most recent valuation Disaster End Date: XX/XX/XXXX reflecting no damage.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649208879 XXX XXX 2 29372744 property 1 Loan is to be Lender guides require a complete interior/exterior appraisal 8/XX/2020 CA Purchase Primary No A A A A 7/XX/2023 5/XX/2023 Yes Non QM 2023/XX/XX: Client not
securitized. The only which is missing from the file. A secondary appraisal may be securitizing loan.
valuation provided was a needed.
Drive by. It is
interpreted that this
Drive By was used in
lieu of URAR and that
this file is missing the
secondary valuation (GSE
COVID19)
649208879 XXX XXX 2 29372745 credit 3 Missing Document: Purchase Agreement missing in file. 8/XX/2020 CA Purchase Primary No D D D D 7/XX/2023 Non QM
Purchase Agreement /
Sales Contract not
provided
649208879 XXX XXX 2 29372746 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 8/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three (3) business days prior to consummation.
Business Days Prior to (Type:Primary/08/XX/2020)
Consummation
649208879 XXX XXX 2 29372747 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. Initial Escrow Account Disclosure Missing in file. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 8/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Account Statement Missing implementing regulation, Regulation X, for these type of violations.
649208879 XXX XXX 2 29372748 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure not provided to Borrower(s) at least TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 8/XX/2020 8/XX/2021 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Disclosure Timing without at least three (3) business days prior to closing. (Initial/08/XX/2020) three (3) business days prior to closing
Waiver
649208879 XXX XXX 2 29372749 compliance 2 TRID Revised Loan TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on 08/XX/2020 Revised Loan Estimate provided on 08/XX/2020 not received by TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 8/XX/2020 8/XX/2021 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Estimate Timing Before not received by borrower at least four (4) business days prior to closing. borrower at least four (4) business days prior to closing.
Closing (Interim/08/XX/2020)
649208879 XXX XXX 2 29372751 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Disclosure reflects Finance Charge of $XXX but calculated TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 8/XX/2020 8/XX/2021 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Disclosure Finance Charge provided on 08/XX/2020 disclosed an inaccurate Finance Charge on page 5 that does Finance Charge of $XXX. Variance = $XXX. Lender to provide Assignee liability.
not match the actual Finance Charge for the loan (fee amounts included in Finance corrected CD and copy of letter sent to borrower explaining
Charge calculation are based on Closing Disclosure dated 09/XX/2020). changes.
(Final/08/XX/2020)
649208879 XXX XXX 2 29372752 compliance 2 Missing Document: Missing File is missing a fully executed initial 1003. 8/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Non QM 2023/XX/XX: Missing
Lender's Initial 1003 Signed/dated Initial 1003.
649208879 XXX XXX 2 29372753 credit 3 Guideline Requirement: Calculated PITIA months reserves of 0.00 is less than Guideline PITIA months Borrower has insufficient assets to cover funds to close and 8/XX/2020 CA Purchase Primary No C C C C 7/XX/2023 Non QM
PITIA reserves months reserves of 20.00. reserves.
discrepancy.
649208879 XXX XXX 2 29372754 credit 3 Available for Closing is Documented qualifying Assets for Closing of $XXX is less than Cash From Borrower Borrower is short assets for closing and reserves. 8/XX/2020 CA Purchase Primary No C C C C 7/XX/2023 Non QM
insufficient to cover $XXX.
Cash From Borrower.
649207314 XXX XXX 2 29372800 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Post Disaster Inspection Report is missing from file. 3/XX/2015 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Temporary 2023/XX/XX: BPO provided
most recent valuation Disaster End Date: XX/XX/XXXX Cash-out - SHQM reflects no damage.
inspection is dated prior Disaster Name: XXX Other (GSE/Agency
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX Eligible)
disaster.
649207314 XXX XXX 2 29372801 compliance 2 ECOA Appraisal - Right to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Borrower was not provided with Right to Receive Appraisal There is generally no Assignee Liability. 3/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 Temporary
Receive Copy of Appraisal Receive a Copy" appraisal disclosure to consumer. Disclosure. Cash-out - SHQM
Disclosure Missing Other (GSE/Agency
Eligible)
649207314 XXX XXX 2 29372802 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement The Affiliated Business Arrangement Disclosure in file is RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 Temporary
Affiliated Business Disclosure to applicant within three (3) business days of application. dated 03/XX/2015 which is more than 3 business days after implementing regulation, Regulation X, for these type of violations. Cash-out - SHQM
Arrangement Disclosure the application date of 02/XX/2015. Other (GSE/Agency
Not Provided Within 3 Eligible)
Business Days of
Application
649207314 XXX XXX 2 29372803 compliance 2 RESPA Servicing RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure The RESPA Servicing Disclosure in file is dated 03/XX/2015 RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 Temporary
Disclosure: Servicing Statement to applicant within three (3) business days of application. which is more than 3 business days after the application implementing regulation, Regulation X, for these type of violations. Cash-out - SHQM
Disclosure Statement Not date of 02/XX/2015. Other (GSE/Agency
Provided Within 3 Eligible)
Business Days of
Application
649207314 XXX XXX 2 29372804 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Disclosure reflects Finance Charge of $XXX but calculated $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 3/XX/2015 3/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Temporary
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. Finance Charge of $XXX. Variance is $XXX. Lender to transactions. Unlimited as a defense to foreclosure. Assignee liability. Cash-out - SHQM
provide corrected TIL and copy of letter sent to borrower Other (GSE/Agency
explaining changes. Eligible)
649207314 XXX XXX 2 29372806 compliance 2 (Doc Error) GFE Error: The only Good Faith Estimate in file reflects the interest 3/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 Temporary
There is no evidence that rate as not locked. Cash-out - SHQM
the interest rate was Other (GSE/Agency
locked prior to closing Eligible)
649207879 XXX XXX 1 29372816 credit 3 Missing Document: AUS not Missing AUS used at origination. 9/XX/2015 WA Refinance - Primary No C C C C 7/XX/2023 Safe Harbor
provided Cash-out - QM
Other
649207879 XXX XXX 1 29372817 credit 3 Missing Document: 9/XX/2015 WA Refinance - Primary No C C C C 7/XX/2023 Safe Harbor
Occupancy Certificate not Cash-out - QM
provided Other
649207879 XXX XXX 1 29372818 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy Verification appraisal was delivered to borrower was not There is generally no Assignee Liability. 9/XX/2015 WA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor
Appraisal Not Provided at of the appraisal at least three (3) business days prior to closing, and appraisal provided. Cash-out - QM
or Before Closing (3-Day was not provided at or before closing. (Type:Primary/06/XX/2015) Other
Waiver In File)
649207879 XXX XXX 1 29372819 compliance 3 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Temporary Failure due to missing AUS used at origination. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 9/XX/2015 WA Refinance - Primary No C C B B 7/XX/2023 Safe Harbor
Match - QM SHQM (GSE/Agency Eligible) does not match Due Diligence Loan Designation of Safe firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - QM
Harbor QM. Other
649207879 XXX XXX 1 29372820 compliance 2 RESPA (2010) - Interest RESPA (2010): Interest Rate on GFE does not match Note. Interest rate on the final GFE reflects 4.25%, however the RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 9/XX/2015 WA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor
Rate on GFE Inaccurate note rate is 4.50%. implementing regulation, Regulation X, for these type of violations. Cash-out - QM
Other
649207879 XXX XXX 1 29372821 compliance 2 RESPA (2010) - Initial RESPA (2010): Initial payment on GFE does not match actual payment on loan. Payment on GFE reflects $XXX however the payment on the note RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 9/XX/2015 WA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor
Payment on GFE Inaccurate is $XXX. implementing regulation, Regulation X, for these type of violations. Cash-out - QM
Other
649207879 XXX XXX 1 29372822 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Finance charge is under disclosed by $XXX. It appears the $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 9/XX/2015 9/XX/2018 WA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. lender is not including the Title premium sales tax fee in transactions. Unlimited as a defense to foreclosure. Assignee liability. Cash-out - QM
the prepaid finance charges. Other
649207290 XXX XXX 1 29372823 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX 6/XX/2016 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Temporary 2023/XX/XX: BPO provided
most recent valuation Disaster End Date: XX/XX/XXXX Rate/Term SHQM reflects no damage.
inspection is dated prior Disaster Name: XXX (GSE/Agency
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX Eligible)
disaster.
649207290 XXX XXX 1 29372824 credit 3 Insufficient Coverage: Replacement Cost Estimator required. 6/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 Temporary
Hazard insurance coverage Rate/Term SHQM
amount is insufficient. (GSE/Agency
Eligible)
649207290 XXX XXX 1 29372826 credit 3 Employment was not Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: 6/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 Temporary
verified within 10 days 11/XX/2013 Rate/Term SHQM
of the note date. (GSE/Agency
Eligible)
649206926 XXX XXX 1 29372917 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each There is no evidence in file which shows that borrower 5/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 Temporary
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. received the valuation report prior 3 days of loan funding. Cash-out - SHQM
Business Days Prior to (Type:Primary/04/XX/2015) Other (GSE/Agency
Consummation Eligible)
649206926 XXX XXX 1 29372918 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Most Recent Valuation Inspection Date: XX/XX/XXXX 5/XX/2015 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Temporary 2023/XX/XX: BPO provided
most recent valuation Disaster End Date: XX/XX/XXXX Disaster End Date: XX/XX/XXXX Cash-out - SHQM reflects no damage.
inspection is dated prior Disaster Name: XXX Disaster Name: XXX Other (GSE/Agency
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX Disaster Declaration Date: XX/XX/XXXX Eligible)
disaster.
649208717 XXX XXX 1 29372985 compliance 2 Missing Document: Missing Initial signed & dated 1003 was not present in file. 10/XX/2015 CA Purchase Investment No B B B B 7/XX/2023 N/A 2023/XX/XX: Missing
Lender's Initial 1003 Signed/dated Initial 1003.
649208717 XXX XXX 1 29372986 credit 3 File does not contain Valuation Type: Appraisal / Valuation Report Date: 09/XX/2015 File does not contain documentation from lender/seller 10/XX/2015 CA Purchase Investment No C C C C 7/XX/2023 N/A
documentation from confirming the condo is warrantable.
lender/seller confirming
the condo is warrantable.
649208717 XXX XXX 1 29372987 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA disaster area. A 10/XX/2015 CA Purchase Investment No A A A A 7/XX/2023 5/XX/2023 Yes N/A 2023/XX/XX: BPO dated 5/XX/23
most recent valuation Disaster End Date: XX/XX/XXXX post disaster inspection verifying there was no damage to showing no damage to property
inspection is dated prior Disaster Name: XXX the subject property is required. has been received.
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649208717 XXX XXX 1 29372988 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 10/XX/2015 CA Purchase Investment No B B B B 7/XX/2023 N/A
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three (3) business days prior to consummation.
Business Days Prior to (Type:Primary/09/XX/2015)
Consummation
649208717 XXX XXX 1 29372989 credit 3 AUS/Guideline Findings: The AUS used at origination is missing. 10/XX/2015 CA Purchase Investment No C C C C 7/XX/2023 N/A
All conditions were not
met
649208717 XXX XXX 1 29372990 credit 3 Missing Document: 10/XX/2015 CA Purchase Investment No C C C C 7/XX/2023 N/A
Occupancy Certificate not
provided
649208365 XXX XXX 1 29372991 compliance 2 Missing Document: Missing File is missing signed/dated initial 1003 8/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023 Temporary
Lender's Initial 1003 Rate/Term SHQM
(GSE/Agency
Eligible)
649208365 XXX XXX 1 29372992 credit 3 Missing Document: Fraud Fraud report is required. 8/XX/2014 CA Refinance - Primary No C C C C 7/XX/2023 Temporary
Report not provided Rate/Term SHQM
(GSE/Agency
Eligible)
649208365 XXX XXX 1 29372993 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Evidence of borrower's receipt of the appraisal was not 8/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023 Temporary
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. provided. Rate/Term SHQM
Business Days Prior to (Type:Primary/06/XX/2014) (GSE/Agency
Consummation Eligible)
649208365 XXX XXX 1 29372994 compliance 2 RESPA (2010) - 0% RESPA (2010): 0% tolerance violation for 1203 fee without evidence of sufficient Valid change of circumstance or sufficient cure is required. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 8/XX/2014 CA Refinance - Primary No B B B B 7/XX/2023 Temporary
Tolerance (Line 1203) cure provided. implementing regulation, Regulation X, for these type of violations. Rate/Term SHQM
Without Cure (GSE/Agency
Eligible)
649208365 XXX XXX 1 29372995 credit 3 No evidence of fraud Credit Report: Original // Borrower: XXX, Credit Report: Original // Borrower: Fraud report is required. 8/XX/2014 CA Refinance - Primary No C C C C 7/XX/2023 Temporary
report in file XXX, Credit Report: Original // Borrower: XXX Rate/Term SHQM
(GSE/Agency
Eligible)
649208365 XXX XXX 1 29372996 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Latest disaster inspection report is required. 8/XX/2014 CA Refinance - Primary No A A A A 7/XX/2023 5/XX/2023 Yes Temporary 2023/XX/XX: BPO dated 5/XX/23
most recent valuation Disaster End Date: XX/XX/XXXX Rate/Term SHQM showing no damage to property
inspection is dated prior Disaster Name: XXX (GSE/Agency has been received
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX Eligible)
disaster.
649209053 XXX XXX 2 29373565 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement E-Sign Consent Agreement is not provided. 12/XX/2016 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
is missing. QM
649209053 XXX XXX 2 29373566 credit 1 Income Docs Missing: Borrower: XXX VVOE - Employment Only VVOE is missing for XXX employer XXX. 12/XX/2016 CA Purchase Primary No A A A A 7/XX/2023 8/XX/2023 Yes Safe Harbor 2023/XX/XX: VVOE was
QM provided.
649209053 XXX XXX 2 29373567 credit 3 REO Documents are Address: XXX, CA Insurance Verification Hazard insurance is missing for REO XXX, CA. 12/XX/2016 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor 2023/XX/XX: Trailing docs did
missing. QM not contain any docs to clear
this exception.
649209053 XXX XXX 2 29373568 credit 3 File does not contain Valuation Type: Appraisal / Valuation Report Date: 11/XX/2016 File does not contain documentation from lender/seller to 12/XX/2016 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
documentation from verify it is confirming condo is warrantable or not. QM
lender/seller confirming
the condo is warrantable.
649209053 XXX XXX 2 29373569 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2016 12/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Status CHARM Booklet, not provided to the borrower. QM
649209053 XXX XXX 2 29373570 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for File does not contain a valid COC for this fee, cure not TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2016 12/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Tolerance Violation Appraisal Re-Inspection Fee. Fee Amount of $XXX exceeds tolerance of $XXX. provided at closing. QM
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (75103)
Provided
649209053 XXX XXX 2 29373572 credit 3 Guideline Requirement: Calculated PITIA months reserves of 3.32 is less than Guideline PITIA months 12/XX/2016 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor 2023/XX/XX: Trailing docs did
PITIA reserves months reserves of 6.00. QM not contain any docs to clear
discrepancy. this exception.
649209053 XXX XXX 2 29373573 credit 1 Verification(s) of Borrower: XXX// Employment Type: Employment / Income Type: Wages / Start Date: 12/XX/2016 CA Purchase Primary No A A A A 7/XX/2023 8/XX/2023 Yes Safe Harbor 2023/XX/XX: VVOE was
employment is not within 01/XX/2016 QM provided.
10 business days of the
Note.
649209053 XXX XXX 2 29373574 credit 3 Guideline Requirement: Calculated loan to value percentage of 78.85305% exceeds Guideline loan to value LTV exceeds guidelines and file does not meet required 12/XX/2016 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
Loan to value percentage of 75.00000%. credit score for increased LTV to 80%. QM
discrepancy.
649209053 XXX XXX 2 29373575 credit 3 Guideline Requirement: Calculated investor qualifying total debt ratio of 43.08924% exceeds Guideline DTI exceeds guidelines and borrower credit score is not high 12/XX/2016 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
Investor qualifying total total debt ratio of 38.00000%. enough to qualify for the expanded DTI guidelines. QM
debt ratio discrepancy.
649209053 XXX XXX 2 29373576 credit 3 Verification(s) of Borrower: XXX// Employment Type: Employment / Income Type: Wages / Start Date: File is missing a VVOE within 10 days for this employment 12/XX/2016 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor 2023/XX/XX: Trailing docs did
employment is not within 09/XX/2014 QM not contain any docs to clear
10 business days of the this exception.
Note.
649208621 XXX XXX 1 29373612 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The property is located in FEMA Disaster area. Provide a 4/XX/2016 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received BPO
most recent valuation Disaster End Date: XX/XX/XXXX post-disaster inspection verifying there was no damage. The confirming no damage.
inspection is dated prior Disaster Name: XXX inspection must include exterior photos and the property
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX must be re-inspected on or after XX/XX/XXXX declared end
disaster. date.
649208621 XXX XXX 1 29373613 credit 3 Insufficient Coverage: HOI coverage is insufficient by $XXX. Provide updated 4/XX/2016 CA Purchase Primary No C C C C 7/XX/2023 Non QM
Hazard insurance coverage policy reflecting minimum coverage of $XXX OR provide copy
amount is insufficient. of insurer's replacement cost estimate supporting current
coverage amount.
649208621 XXX XXX 1 29373614 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure not provided to Borrower(s) at least TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2016 4/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Disclosure Timing without at least three (3) business days prior to closing. (Final/04/XX/2016) three (3) business days prior to closing.
Waiver
649208621 XXX XXX 1 29373615 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Title- Courier Fee was not disclosed on Loan Estimate. Title TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2016 4/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Tolerance Violation Courier / Express Mail / Messenger Fee. Fee Amount of $XXX exceeds tolerance of fee added on CD and disclosed in Sec B and paid to a
Without Sufficient Cure $XXX. Insufficient or no cure was provided to the borrower. (75187) different company than title fees disclosed in Sec C making
Provided them subject to 0% tolerance testing. File does not contain
a valid COC for this fee, nor evidence of cure. Provide a
post-close CD disclosing the tolerance cure to include $XXX
a copy of refund check, proof of delivery, and a copy of the
letter of explanation sent to the borrower disclosing the
changes made.
649208621 XXX XXX 1 29373616 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Title- Electronic Delivery was not disclosed on Loan TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2016 4/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Tolerance Violation Electronic Document Delivery Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Estimate. Title fee added on CD and disclosed in Sec B and
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (75188) paid to a different company than title fees disclosed in Sec
Provided C making them subject to 0% tolerance testing. File does not
contain a valid COC for this fee, nor evidence of cure.
Provide a post-close CD disclosing the tolerance cure to
include $XXX a copy of refund check, proof of delivery, and
a copy of the letter of explanation sent to the borrower
disclosing the changes made.
649208621 XXX XXX 1 29373617 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Title- Loan Tie-In was not disclosed on Loan Estimate. Title TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2016 4/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Tolerance Violation Loan Tie-In Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or fee added on CD and disclosed in Sec B and paid to a
Without Sufficient Cure no cure was provided to the borrower. (75190) different company than title fees disclosed in Sec C making
Provided them subject to 0% tolerance testing. File does not contain
a valid COC for this fee, nor evidence of cure. Provide a
post-close CD disclosing the tolerance cure to include $XXX
a copy of refund check, proof of delivery, and a copy of the
letter of explanation sent to the borrower disclosing the
changes made.
649208621 XXX XXX 1 29373618 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Zero Percent Fee Tolerance exceeded for Credit Report Fee. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2016 4/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Tolerance Violation Report Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no Fee Amount of $XXX exceeds tolerance of $XXX.No cure was
Without Sufficient Cure cure was provided to the borrower. (7520) provided to the borrower.
Provided
649208621 XXX XXX 1 29373619 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Title- Wire was not disclosed on Loan Estimate. Title fee TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2016 4/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Tolerance Violation Wire /Funding/ Disbursement Fee. Fee Amount of $XXX exceeds tolerance of $XXX. added on CD and disclosed in Sec B and paid to a different
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (75206) company than title fees disclosed in Sec C making them
Provided subject to 0% tolerance testing. File does not contain a
valid COC for this fee, nor evidence of cure. Provide a
post-close CD disclosing the tolerance cure to include $XXX
a copy of refund check, proof of delivery, and a copy of the
letter of explanation sent to the borrower disclosing the
changes made.
649208621 XXX XXX 1 29373620 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Title- Document Prep Fee was not disclosed on Loan Estimate. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2016 4/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Tolerance Violation Document Preparation Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Title fee added on CD and disclosed in Sec B and paid to a
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (7563) different company than title fees disclosed in Sec C making
Provided them subject to 0% tolerance testing. File does not contain
a valid COC for this fee, nor evidence of cure. Provide a
post-close CD disclosing the tolerance cure to include $XXX
a copy of refund check, proof of delivery, and a copy of the
letter of explanation sent to the borrower disclosing the
changes made.
649208621 XXX XXX 1 29373622 credit 3 Borrower has been on Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: File is missing a complete 2 year verified employment 4/XX/2016 CA Purchase Primary No C C C C 7/XX/2023 Non QM
current job less than 2 11/XX/2014 history for the co-borrower.
years, and prior
employment history was
not documented as
required.
649208621 XXX XXX 1 29373623 compliance 3 QM Employment History Qualified Mortgage (Dodd-Frank 2014): Employment history requirement not met. Co-borrower previous employment was not verified to confirm 4/XX/2016 CA Purchase Primary No C C C C 7/XX/2023 Non QM
(XXX XXX/12402404) employment dates as required by Appendix Q.
649208621 XXX XXX 1 29373624 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender Guidelines reflect Qualifying Rate as the start rate. 4/XX/2016 CA Purchase Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Cleared
Provision Investor does not match the ATR payment calculation methods under 1026.43(c)(5).
Qualification Method not
Matching ATR
649208621 XXX XXX 1 29373625 compliance 3 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Loan Designation determined to be Non QM due to missing Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 4/XX/2016 CA Purchase Primary No C C B B 7/XX/2023 Non QM
Match - QM QM does not match Due Diligence Loan Designation of Non QM. employment verification for co-borrower as well as signed firm performing the loan level due diligence and to have the TPR firm confirm said designation.
and dated business returns for the borrower.
649208621 XXX XXX 1 29373626 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Warehousing fee was not disclosed on Loan Estimate. Title TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2016 4/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Tolerance Violation Warehousing Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or fee added on CD and disclosed in Sec B and paid to a
Without Sufficient Cure no cure was provided to the borrower. (75209) different company than title fees disclosed in Sec C making
Provided them subject to 0% tolerance testing. File does not contain
a valid COC for this fee, nor evidence of cure. Provide a
post-close CD disclosing the tolerance cure to include $XXX,
a copy of refund check, proof of delivery, and a copy of the
letter of explanation sent to the borrower disclosing the
changes made.
649207610 XXX XXX 2 29373730 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 6/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three (3) business days prior to consummation. Cash-out -
Business Days Prior to (Type:Primary/05/XX/2017) (Type:Primary/05/XX/2017) Other
Consummation
649207610 XXX XXX 2 29373731 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender The Qualification Method used by the lender does not match 6/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: qual method
Provision Investor does not match the ATR payment calculation methods under 1026.43(c)(5). the ATR payment calculation methods under 1026.43(c)(5). Cash-out - updated
Qualification Method not Other
Matching ATR
649207610 XXX XXX 2 29373732 compliance 2 Self-Employed Tax Return Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or Self Employed Tax Returns - The business or personal tax 6/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Recency - ATR personal tax returns provided are not the most recent. Application Date returns provided are not the most recent. Application Date Cash-out -
05/XX/2017, Most Recent Tax Return End Date 12/XX/2015, Tax Return Due Date 05/XX/2017, Most Recent Tax Return End Date 12/XX/2015, Tax Other
04/XX/2017. (XXX XXX/Schedule C) Return Due Date 04/XX/2017. (XXX XXX/Schedule C)
649207610 XXX XXX 2 29373733 compliance 2 Self-Employed Tax Return Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or Self Employed Tax Returns - The business or personal tax 6/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Recency - ATR personal tax returns provided are not the most recent. Application Date returns provided are not the most recent. Application Date Cash-out -
05/XX/2017, Most Recent Tax Return End Date 12/XX/2015, Tax Return Due Date 05/XX/2017, Most Recent Tax Return End Date 12/XX/2015, Tax Other
03/XX/2017. (XXX XXX/S-Corp) Return Due Date 03/XX/2017. (XXX XXX/S-Corp)
649207610 XXX XXX 2 29373734 compliance 2 ARM Disclosure Timing Unable to determine if ARM disclosure was provided within three (3) days of Unable to determine if ARM disclosure was provided within TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2017 6/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Test application due to missing information. three (3) days of application due to missing information. Cash-out -
Other
649207610 XXX XXX 2 29373735 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Consumer Handbook on Adjustable Rate Mortgages, CHARM TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2017 6/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower. Booklet, not provided to the borrower. Cash-out -
Other
649207610 XXX XXX 2 29373736 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX 6/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received BPO
most recent valuation Disaster End Date: XX/XX/XXXX Cash-out - confirming no damage.
inspection is dated prior Disaster Name: XXX Other
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207610 XXX XXX 2 29373737 credit 3 Insufficient Coverage: 6/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Hazard insurance coverage Cash-out -
amount is insufficient. Other
649207610 XXX XXX 2 29373738 credit 3 REO Documents are Address: XXX, CA, Address: XXX, CA, Address: XXX, CA Insurance Verification, Tax 6/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
missing. Verification Cash-out -
Statement Other
Lease Agreement, Statement
649207928 XXX XXX 2 29373851 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The most recent valuation inspection is dated prior to the 9/XX/2017 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received BPO
most recent valuation Disaster End Date: XX/XX/XXXX most recent FEMA disaster. confirming no damage.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207928 XXX XXX 2 29373852 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Consumer Handbook on Adjustable-Rate Mortgages, CHARM TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2017 9/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower. Booklet, not provided to the borrower.
649207928 XXX XXX 2 29373853 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Evidence of borrowers receipt of the appraisal prior to 9/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. closing was not provided.
Business Days Prior to (Type:Primary/08/XX/2017)
Consummation
649207928 XXX XXX 2 29373854 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure Violation was cured on the PCCD dated 03/XX/2018, however TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2017 9/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Disclosure Will Not Have provided on 09/XX/2017 incorrectly disclosed whether the loan will have an escrow for a full remediation cure, a copy of the letter to the
Escrow - Reason account. (Final/09/XX/2017) borrower explaining the error is required, however is
missing from the file.
649207928 XXX XXX 2 29373856 credit 3 Missing Document: HELOC The Heloc agreement for the 2nd lien is missing from the 9/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 Non QM
Agreement not provided file.
649207928 XXX XXX 2 29373857 credit 3 Missing Document: Note - Second mortgage Note is mssing. 9/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 Non QM
Subordinate Lien not
provided
649207928 XXX XXX 2 29373858 credit 3 Income Docs Missing: Borrower: XXX Balance Sheet Per lender guides, a year to date Balance Sheet through the 9/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 Non QM
most recent quarter prior to the note date is required
however is missing.
649207928 XXX XXX 2 29373859 compliance 2 ARM Disclosure Timing Unable to determine if ARM disclosure was provided within three (3) days of Date of disclosure or evidence of when borrower received the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2017 9/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Test application due to missing information. disclosure is missing.
649206993 XXX XXX 2 29373860 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement E-sign Consent Agreement is missing in the file. 6/XX/2016 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
is missing. QM
649206993 XXX XXX 2 29373861 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Subject property was appraised on XX/XX/XXXX prior to the 6/XX/2016 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Received BPO
most recent valuation Disaster End Date: XX/XX/XXXX FEMA disaster (XXX) dated XX/XX/XXXX. File is missing a QM confirming no damage.
inspection is dated prior Disaster Name: XXX property inspection dated after the disaster, or the
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX lander's Rep and warranty attestation along with visible
disaster. confirmation that the subject property was not damaged.
649206993 XXX XXX 2 29373862 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the The file was missing a copy of the executed ARM Disclosure TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2016 6/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Test borrower within three (3) days of application. or proof of the borrower's receipt within 3 days of QM
originator application date.
649206993 XXX XXX 2 29373863 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, The file was missing a copy of the executed ARM Disclosure TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2016 6/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Status CHARM Booklet, not provided to the borrower. or proof of the borrower's receipt within 3 days of QM
originator application date.
649206993 XXX XXX 2 29373865 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Integrated Disclosure: Zero Percent Fee Tolerance exceeded TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 6/XX/2016 6/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Tolerance Violation Appraisal Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no for Appraisal Fee. Fee Amount of $XXX Insufficient or no QM
Without Sufficient Cure cure was provided to the borrower. (7506) cure was provided.
Provided
649206993 XXX XXX 2 29373866 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure not provided to Borrower(s) at least TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 6/XX/2016 6/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Disclosure Timing without at least three (3) business days prior to closing. (Initial/06/XX/2016) three (3) business days prior to closing. QM
Waiver
649206993 XXX XXX 2 29373867 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure Final Closing Disclosure provided on 06/XX/2016 disclosed a TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 6/XX/2016 6/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Disclosure Product provided on 06/XX/2016 disclosed a Product that does not match the actual product Product that does not match the actual product for the loan QM
Testing for the loan. Additional AIR/AP table failures could apply for loans with an
adjustable rate or adjustable payment with incorrect Product disclosure.
(Final/06/XX/2016)
649206993 XXX XXX 2 29373868 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final Closing Disclosure provided on 06/XX/2016 with an TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. Assignee liability. 6/XX/2016 6/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Disclosure Payment on 06/XX/2016 with an increasing payment did not disclose the frequency of increasing payment did not disclose the frequency of QM
Adjusts Every adjustments. (Final/06/XX/2016) adjustments
649206993 XXX XXX 2 29373869 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure The Contact Information section of the final CD did not TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 6/XX/2016 6/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Disclosure Contact provided on 06/XX/2016 did not disclose the required Lender Contact Information disclose the Lender's Contact. QM
Information - Lender (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/06/XX/2016)
649206993 XXX XXX 2 29373870 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing Adjustable Interest Rate Table: Final Closing Disclosure TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 6/XX/2016 6/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Disclosure AIR Table Disclosure provided on 06/XX/2016 disclosed a Subsequent Changes frequency that provided on 06/XX/2016 disclosed a Subsequent Changes QM
Subsequent Change does not match the actual subsequent change frequency for the loan. frequency that does not match the actual subsequent change
Frequency (Final/06/XX/2016) frequency for the loan.
649206993 XXX XXX 2 29373871 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not 6/XX/2016 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. provide a copy of each valuation to applicant three (3) QM
Business Days Prior to (Type:Primary/05/XX/2016) business days prior to consummation.
Consummation
649208626 XXX XXX 1 29373891 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX 6/XX/2015 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received BPO
most recent valuation Disaster End Date: XX/XX/XXXX Cash-out - confirming no damage.
inspection is dated prior Disaster Name: XXX Other
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649208626 XXX XXX 1 29373892 property 3 Appraiser's license or Valuation Type: Appraisal / Valuation Report Date: 05/XX/2015 As Per Appraiser's license Certificate Effective date is 6/XX/2015 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
certification was not 05/XX/2015. Cash-out -
active at the time of the Other
appraisal.
649208626 XXX XXX 1 29373893 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 6/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three (3) business days prior to consummation. Cash-out -
Business Days Prior to (Type:Primary/05/XX/2015) Other
Consummation
649208626 XXX XXX 1 29373894 compliance 3 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Average Monthly Income YTD not provided in file. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 6/XX/2015 CA Refinance - Primary No C C B B 7/XX/2023 Non QM
Match - QM QM does not match Due Diligence Loan Designation of Non QM. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out -
Other
649208626 XXX XXX 1 29373895 compliance 3 QM DTI Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and DTI meets the 42% when the bonus is calculated at two Although this issue is subject to a 3 year SOL for affirmative claims under TILA, AMC does not adjust 6/XX/2015 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
the images do not provide evidence loan is eligible for purchase, guarantee or years. Because there is no bonus income for the current year grading taking into account TILA SOL for exceptions under ATR, given the potential for enhanced Cash-out -
insurance by the appropriate agency. it needed to be calculated at two years plus year to date. damages when asserting an ability to repay defense in response to an action to collect a debt by Other
recoupment or set-off.
649207164 XXX XXX 2 29373961 credit 3 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Most Recent Valuation Inspection Date: XX/XX/XXXX 4/XX/2016 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor 2023/XX/XX: BPO inspector
most recent valuation Disaster End Date: XX/XX/XXXX Disaster End Date: XX/XX/XXXX QM unable to access property to
inspection is dated prior Disaster Name: XXX Disaster Name: XXX determine condition. Finding
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX Disaster Declaration Date: XX/XX/XXXX remains open.
disaster.
649207164 XXX XXX 2 29373962 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. Initial escrow account statement was not provided to the RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 4/XX/2016 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Account Statement Missing borrower missing in file implementing regulation, Regulation X, for these type of violations. QM
649207164 XXX XXX 2 29373964 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Post closing CD cured the violation, however for a full TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 4/XX/2016 4/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Disclosure Total Of provided on 04/XX/2016 disclosed an inaccurate Total of Payments on page 5 that remediation, a copy of the letter to the borrower explaining Assignee liability. QM
Payments does not match the actual total of payments for the loan (fee amounts included in the error would be required.
TOP calculation are based on Closing Disclosure dated 04/XX/2016). The disclosed
Total of Payments in the amount of $XXX is under disclosed by $XXX compared to
the calculated total of payments of $XXX which exceeds the $XXX per month
threshold. (Final/04/XX/2016)
649207305 XXX XXX 1 29373967 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA Disaster area 11/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Received BPO
most recent valuation Disaster End Date: XX/XX/XXXX post-close. There is no end declared date for the disaster QM confirming no damage.
inspection is dated prior Disaster Name: XXX as of yet. A post-disaster inspection verifying there was
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX no damage to the subject property is required once a
disaster. declared end date is identified.
649207305 XXX XXX 1 29373968 credit 3 File does not contain Valuation Type: Appraisal / Valuation Report Date: 10/XX/2019 condo warrantable document is missing 11/XX/2019 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
documentation from QM
lender/seller confirming
the condo is warrantable.
649207305 XXX XXX 1 29373969 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of List of Homeownership Counseling Organizations to borrower RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 11/XX/2019 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
of Homeownership Homeownership Counseling Organizations to borrower. is missing implementing regulation, Regulation X, for these type of violations. QM
Counseling Organizations
Missing
649207305 XXX XXX 1 29373971 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM Disclosure not provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2019 11/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Test borrower within three (3) days of application. application QM
649207305 XXX XXX 1 29373972 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet Disclosure Status is missing TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2019 11/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Status CHARM Booklet, not provided to the borrower. QM
649207305 XXX XXX 1 29373973 compliance 2 Missing Document: Missing Initial Loan application is missing from file. 11/XX/2019 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Lender's Initial 1003 QM
649207305 XXX XXX 1 29373974 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Evidence of appraisal delivery within 3 days of closing is 11/XX/2019 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. not in file. QM
Business Days Prior to (Type:Primary/10/XX/2019)
Consummation
649207305 XXX XXX 1 29373975 credit 3 Asset Verification Level Borrower: XXX, Borrower: XXX Asset Verification Level: Level 2-Stated/Not Copy of note, or heloc agreement of secondary financing is 11/XX/2019 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
is less than 4. Verified not in file. QM
Asset Verification Level: Level 2-Stated/Not Verified
649207683 XXX XXX 1 29374068 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Post Disaster Inspection Report is required. 4/XX/2015 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: Received BPO
most recent valuation Disaster End Date: XX/XX/XXXX QM confirming no damage.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207683 XXX XXX 1 29374069 compliance 2 Missing Document: Missing Initial 1003 is missing in the file. 4/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Lender's Initial 1003 QM
649207683 XXX XXX 1 29374070 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each 4/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. QM
Business Days Prior to (Type:Primary/03/XX/2015)
Consummation
649207683 XXX XXX 1 29374071 compliance 2 ECOA Appraisal - Right to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Creditor did not provide "Right to Receive a Copy" appraisal There is generally no Assignee Liability. 4/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Receive Copy of Appraisal Receive a Copy" appraisal disclosure to consumer. disclosure to consumer. QM
Disclosure Missing
649207683 XXX XXX 1 29374072 compliance 2 RESPA Disclosure - HUD RESPA Disclosure Rule: Creditor did not provide HUD Settlement Cost Booklet. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 4/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Settlement Cost Booklet implementing regulation, Regulation X, for these type of violations. QM
Missing
649207683 XXX XXX 1 29374073 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2015 4/XX/2016 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Test borrower within three (3) days of application. QM
649207683 XXX XXX 1 29374074 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet is missing in the file. TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2015 4/XX/2016 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Status CHARM Booklet, not provided to the borrower. QM
649207683 XXX XXX 1 29374075 compliance 2 RESPA (2010) - 0% RESPA (2010): 0% tolerance violation for 1203 fee without evidence of sufficient GFE states fee as $XXX and HUD states fee as $XXX Variance RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 4/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Tolerance (Line 1203) cure provided. is of $XXX & 0.00505%. implementing regulation, Regulation X, for these type of violations. QM
Without Cure
649207683 XXX XXX 1 29374076 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum Ever" date on the Final TIL does The "Maximum Ever" date on the Final TIL is 06/XX/2024. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 4/XX/2015 4/XX/2016 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Payment Summary Table - not match the earliest date on which the maximum rate may apply. Assignee liability. QM
Maximum Ever Change Date
Inaccurate
649207683 XXX XXX 1 29374077 credit 3 Verification(s) of Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: Work Number Employment is post note dated and Work Number 4/XX/2015 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor 2023/XX/XX: Trailing docs did
employment is not within 01/XX/2009 Income is more than 10 days of Note. QM not contain any docs to clear
10 business days of the this exception.
Note.
649207683 XXX XXX 1 29374078 credit 3 File does not contain Valuation Type: Appraisal / Valuation Report Date: 03/XX/2015 Condo Warranty Document is required. 4/XX/2015 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
documentation from QM
lender/seller confirming
the condo is warrantable.
649207683 XXX XXX 1 29374079 credit 3 Guideline Requirement: Calculated investor qualifying total debt ratio of 40.87350% exceeds Guideline The calculated dti exceeds max allowable dti of 38%. 4/XX/2015 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor 2023/XX/XX: Trailing docs did
Investor qualifying total total debt ratio of 38.00000%. QM not contain any docs to clear
debt ratio discrepancy. this exception.
649207683 XXX XXX 1 29374080 credit 3 Available for Closing is Documented qualifying Assets for Closing of $XXX is less than Cash From Borrower The $XXX gift was deposited into borrower's bank account in 4/XX/2015 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor 2023/XX/XX: Trailing docs did
insufficient to cover $XXX. 2014 and the EMD is unsourced. QM not contain any docs to clear
Cash From Borrower. this exception.
649208141 XXX XXX 2 29374107 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Subject property was appraised on 12/XX/2018 prior to the 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes ATR Risk 2023/XX/XX: PDI provided,
most recent valuation Disaster End Date: XX/XX/XXXX FEMA disaster ( XXX) dated XX/XX/XXXX through XX/XX/XXXX. Cash-out - exception cleared.
inspection is dated prior Disaster Name: XXX File is missing a property inspection dated after the Debt
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX disaster, or the lender's Rep and Warranty attestation along Consolidation
disaster. with visible confirmation that the subject property was not
damaged.
649208141 XXX XXX 2 29374108 credit 1 Borrower has less than 2 incomplete Credit report was provided no Fico scores in the 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Risk 2023/XX/XX: Received required
FICO scores document Cash-out - documentation. Condition
Debt cleared.
Consolidation
649208141 XXX XXX 2 29374109 credit 1 REO Documents are Address: XXX, CA, Address: XXX, CA, Address: XXX, CA, Address: XXX, CA, Address: Insurance and tax verification documents not in the file to 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Risk 2023/XX/XX: Received required
missing. XXX, CA, Address: XXX, CA Insurance Verification, Tax Verification verify amounts Cash-out - documentation. Condition
Insurance Verification, Tax Verification Debt cleared.
Tax Verification Consolidation
Insurance Verification, Tax Verification
Insurance Verification, Tax Verification
Insurance Verification, Tax Verification
649208141 XXX XXX 2 29374110 compliance 1 Partnership Income Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not Business license or recent years 1040 document missing 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes ATR Risk 2023/XX/XX: Balance sheet in
Documentation Test sufficient (Partnership). (XXX XXX/Partnership) Cash-out - file, exception cleared.
Debt
Consolidation
649208141 XXX XXX 2 29374111 compliance 1 QM Employment History - Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two Recent year 1040 document missing 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Risk 2023/XX/XX: Received required
Current Employment years current employment. (XXX/12401928) Cash-out - documentation. Condition
Documentation lacks Date Debt cleared.
Info Consolidation
649208141 XXX XXX 2 29374112 compliance 1 Rental Income Qualified Mortgage (Dodd-Frank 2014): Rental income documentation requirement not QM loans require a lease agreement, which is missing from 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Risk 2023/XX/XX: unable to 2023/XX/XX: Trailing docs did
Documentation - Schedule met for XXX. Lease Agreement and/or Tax Return not provided. (XXX/Schedule E) the loan file, causing the loan to waterfall through the QM Cash-out - locate lease for XXX not contain any docs to clear
E Method Test Testing. Debt property, Schedule E this exception.
Consolidation identifies property as
Multi-Family Residence 2023/XX/XX: Lease was located
in the file. Condition
2023/XX/XX: Agree with cleared.
error
2023/XX/XX: No supporting
trailing documentation was
provided to clear this
exception. Exception remains.
649208141 XXX XXX 2 29374113 compliance 1 Rental Income Qualified Mortgage (Dodd-Frank 2014): Rental income documentation requirement not QM loans require a lease agreement, which is missing from 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 10/XX/2023 Yes ATR Risk 2023/XX/XX: unable to 2023/XX/XX: Trailing docs did
Documentation - Schedule met for XXX. Lease Agreement and/or Tax Return not provided. (XXX/Schedule E) the loan file, causing the loan to waterfall through the QM Cash-out - locate lease for XXX not contain any docs to clear
E Method Test Testing. Debt property, Schedule E this exception.
Consolidation identifies property as
Multi-Family Residence 2023/XX/XX: No supporting
trailing documentation was
2023/XX/XX: Agree with provided to clear this
error exception. Exception remains.
2023/XX/XX: Client elects to
restate loan designation to
Non QM.
649208141 XXX XXX 2 29374114 compliance 1 Rental Income Qualified Mortgage (Dodd-Frank 2014): Rental income documentation requirement not QM loans require a lease agreement, which is missing from 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 10/XX/2023 Yes ATR Risk 2023/XX/XX: unable to 2023/XX/XX: Trailing docs did
Documentation - Schedule met for XXX. Lease Agreement and/or Tax Return not provided. (XXX/Schedule E) the loan file, causing the loan to waterfall through the QM Cash-out - locate lease for XXX not contain any docs to clear
E Method Test Testing. Debt property, Schedule E this exception.
Consolidation identifies property as
SFR 2023/XX/XX: No supporting
trailing documentation was
2023/XX/XX: Agree with provided to clear this
error exception. Exception remains.
2023/XX/XX: Client elects to
restate loan designation to
Non QM.
649208141 XXX XXX 2 29374115 compliance 1 Rental Income Qualified Mortgage (Dodd-Frank 2014): Rental income documentation requirement not QM loans require a lease agreement, which is missing from 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Risk 2023/XX/XX: Received required
Documentation - Schedule met for XXX. Lease Agreement and/or Tax Return not provided. (XXX/Schedule E) the loan file, causing the loan to waterfall through the QM Cash-out - documentation. Condition
E Method Test Testing. Debt cleared.
Consolidation
649208141 XXX XXX 2 29374116 compliance 1 S-Corp Income Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not A P&L statement is missing from the file, which is required 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Risk 2023/XX/XX: Received required
Documentation Test sufficient (S-Corp). (XXX XXX/S-Corp) for QM loans, causing the loan to waterfall through the QM Cash-out - documentation. Condition
Testing. Debt cleared.
Consolidation
649208141 XXX XXX 2 29374117 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. FACTA disclosure document not provided There is no Assignee Liability. 1/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Cash-out -
Debt
Consolidation
649208141 XXX XXX 2 29374118 compliance 2 Federal Loan Originator Truth in Lending Act (NMLSR Dodd- Frank 2014): Individual Loan Originator not Individual Loan Originator not NMLS licensed or registered "Assignee Liability: Civil actions that may be brought against a creditor may be maintained against 1/XX/2019 1/XX/2022 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Compensation - Individual NMLS licensed or registered at time of application. at time of application. any assignee only if the violation is apparent on the face of the disclosure or other documents Cash-out -
LO Not NMLS Licensed at assigned, except where the assignment was involuntary. This civil liability may include $XXX in the Debt
Time of Application case of an individual transaction, or the lesser of $XXX or 1% of the creditor's net worth in the Consolidation
case of a class action (effective 1/XX/14, this amount increases to the lesser of $XXX or 1%), as
well as actual damages, court costs, and attorneys' fees. For an anti-steering violation, the
creditor may also be liable in an amount equal to the sum of all finance charges and fees paid by the
consumer, unless the creditor demonstrates the failure to comply is not material. Notwithstanding
any other provision of law, when a creditor, assignee, or other holder or anyone acting on behalf of
the creditor, assignee, or holder, initiates a judicial or nonjudicial foreclosure of the residential
mortgage loan, or any other action to collect the debt in connection with such loan, a consumer may
assert a violation as a matter of defense by recoupment or set off without regard for the time limit
on a private action for damages.
Effective 1/XX/2014 in addition to the aforementioned, the individual Loan Originator could be liable
for statutory damages. The maximum liability is the greater of actual damages or 3 times the loan
originator's compensation or gain, plus the cost to the consumer of the action. The Dodd-Frank Act
extended the statute of limitations on TILA violations to 3 years from the date of the violation."
649208141 XXX XXX 2 29374119 compliance 1 General Ability To Repay Ability-to-Repay (Dodd-Frank 2014): Unable to verify current S-Corp status due to The P&L statement provided in the file is borrower prepared Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Risk 2023/XX/XX: Missing lease
Provision Employment - S- most recent Tax Return end date is older than 120 days before Closing Date, and and QM requires it to be audited or third party prepared, damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Cash-out - agreements for rental
Corp Test one of these docs is required yet missing: Audited/Third Party P&L, CPA Letter, causing the loan to waterfall through the QM Testing. all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Debt income, missing P&L and
or other Third Party Verification. (XXX XXX/S-Corp) to comply is not material). A private right of action may be brought before the end of the three- Consolidation balance sheets for S-Corp.,
year period beginning on the date of the occurrence of the violation. However, when a creditor, and calculated dti exceeds
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial max allowable dti per
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter guidelines, exceptions
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set- remains.
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If 2023/XX/XX: Received required
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set- documentation. Condition
off shall not exceed three years of finance charges and fees. An action to enforce a violation may cleared.
also be brought by the appropriate state AGs.
649208141 XXX XXX 2 29374121 compliance 1 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor The loan is missing income, asset and credit documents and Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 10/XX/2023 Yes ATR Risk 2023/XX/XX: N/A; 2023/XX/XX: Failure due to
Match - QM QM does not match Due Diligence Loan Designation of ATR Risk. the DTI exceeds the maximum allowed, causing the loan to firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - Duplicative Exception the exclusion of the 3 XXX
waterfall through the QM Testing. Debt accounts (paid by business)
Consolidation 2023/XX/XX: Duplicate which is not Safe Harbor
and/or waterfall compliant and missing the 3
exception leases as previously
exceptioned.
2023/XX/XX: Trailing docs did
not contain any docs to clear
this exception.
2023/XX/XX: EXCEPTION HISTORY
- Exception Detail was
updated on 09/XX/2023 PRIOR
Exception Detail: Qualified
Mortgage (Dodd-Frank 2014):
Originator Loan Designation
of Safe Harbor QM does not
match Due Diligence Loan
Designation of ATR Fail.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
2023/XX/XX: Client elects to
restate loan designation to
Non QM.
649208141 XXX XXX 2 29374122 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final Closing Disclosure provided on 01/XX/2019 with an TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. Assignee liability. 1/XX/2019 1/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Disclosure Payment on 01/XX/2019 with an increasing payment disclosed the frequency of adjustments increasing payment disclosed the frequency of adjustments Cash-out -
Adjusts Every that does not match the actual adjustment period for the loan. (Final/01/XX/2019) that does not match the actual adjustment period for the Debt
loan Consolidation
649208141 XXX XXX 2 29374123 compliance 2 TRID Loan Estimate Timing TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the Loan Estimate not delivered or placed in the mail to TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 1/XX/2019 1/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
mail to Borrower(s) within three (3) business days of application. Borrower(s) within three (3) business days of application Cash-out -
(Initial/11/XX/2018) Debt
Consolidation
649208141 XXX XXX 2 29374124 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Zero Percent Fee Tolerance exceeded for Loan Discount TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 1/XX/2019 1/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Tolerance Violation Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or Points. Fee Amount of $XXX exceeds tolerance of $XXX Cash-out -
Without Sufficient Cure no cure was provided to the borrower. (7200) Debt
Provided Consolidation
649208141 XXX XXX 2 29374125 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Zero Percent Fee Tolerance exceeded for Title - Recording TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 1/XX/2019 1/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Tolerance Violation Recording Service Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Service Fee. Fee Amount of $XXX exceeds tolerance of $XXX Cash-out -
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (75197) Debt
Provided Consolidation
649208141 XXX XXX 2 29374126 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Zero Percent Fee Tolerance exceeded for Title - Endorsement TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 1/XX/2019 1/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Tolerance Violation Endorsement Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or Fee. Fee Amount of $XXX exceeds tolerance of $XXX Cash-out -
Without Sufficient Cure no cure was provided to the borrower. (7564) Debt
Provided Consolidation
649208141 XXX XXX 2 29374127 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Consumer Handbook on Adjustable Rate Mortgages, CHARM TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2019 1/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk 2023/XX/XX: Missing CHARM
Status CHARM Booklet, not provided to the borrower. Booklet, not provided to the borrower Cash-out - Booklet provided within 3
Debt days of application.
Consolidation
649208141 XXX XXX 2 29374128 credit 1 Guideline Requirement: Representative FICO score of is less than Guideline representative FICO score of Credit report was not in the file to verify Credit score 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Risk 2023/XX/XX: Received required
Representative FICO score 700. Cash-out - documentation. Condition
discrepancy. Debt cleared.
Consolidation
649208141 XXX XXX 2 29374129 credit 1 Missing Document: Credit Missing Full Credit Report 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Risk 2023/XX/XX: Received required
Report not provided Cash-out - documentation. Condition
Debt cleared.
Consolidation
649208141 XXX XXX 2 29374130 credit 1 Asset documentation The qualifying income included asset utilization source of 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Risk 2023/XX/XX: Received required
requirements not met. income in the amount of $XXX; however, the file is missing Cash-out - documentation. Condition
all the of asset verification for the accounts used for Debt cleared.
qualifying. Consolidation
649208141 XXX XXX 2 29374131 credit 1 Guideline Requirement: Calculated investor qualifying total debt ratio of 60.93413% exceeds Guideline The qualifying income included asset utilization source of 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Risk 2023/XX/XX: Received required
Investor qualifying total total debt ratio of 43.00000%. income in the amount of $XXX; however, the file is missing Cash-out - documentation. Condition
debt ratio discrepancy. all the of asset verification for the accounts used for Debt cleared.
qualifying. Excluding the asset utilization source of Consolidation
income, the DTI exceeds the maximum allowed by guidelines.
649208141 XXX XXX 2 29374132 credit 1 Income documentation The qualifying income included asset utilization source of 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Risk 2023/XX/XX: Received required
requirements not met. income in the amount of $XXX; however, the file is missing Cash-out - documentation. Condition
all the of asset verification for the accounts used for Debt cleared.
qualifying. Excluding the asset utilization source of Consolidation
income, the DTI exceeds the maximum allowed by guidelines.
649208141 XXX XXX 2 29374133 credit 1 AUS/Guideline Findings: The qualifying income included asset utilization source of 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Risk 2023/XX/XX: Received required
All conditions were not income in the amount of $XXX; however, the file is missing Cash-out - documentation. Condition
met all the of asset verification for the accounts used for Debt cleared.
qualifying. Excluding the asset utilization source of Consolidation
income, the DTI exceeds the maximum allowed by guidelines.
649208141 XXX XXX 2 29374134 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender The guidelines require 10/1 ARMS to be qualified using the 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 10/XX/2023 Yes ATR Risk 2023/XX/XX: Received required
Provision Investor does not match the ATR payment calculation methods under 1026.43(c)(5). Note rate, causing the loan to waterfall through the QM Cash-out - documentation. Condition
Qualification Method not Testing. Debt cleared.
Matching ATR Consolidation
649208141 XXX XXX 2 29374135 compliance 1 General ATR Provision Ability to Repay (Dodd-Frank 2014): The DTIs calculated in accordance with the The qualifying income included asset utilization source of 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Risk 2023/XX/XX: Missing lease
Investor and Non QM DTIs Lenders Guidelines of 60.93413% and based on 1026.43(c)(5) of 66.86% income in the amount of $XXX; however, the file is missing Cash-out - agreements for rental
don't match and both significantly exceed the guideline maximum of 43.00%. (DTI Exception requires all the of asset verification for the accounts used for Debt income, missing P&L and
significantly exceed compelling compensating factors to consider regrading to EV2-B.) qualifying. Excluding the asset utilization source of Consolidation balance sheets for S-Corp.,
Guidelines income, the DTI exceeds the maximum allowed by guidelines, and calculated dti exceeds
causing the loan to waterfall through the QM Testing. max allowable dti per
guidelines, exceptions
remains.
2023/XX/XX: Received required
documentation. Condition
cleared.
649208141 XXX XXX 2 29374136 compliance 1 Income/Asset Guideline Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to The qualifying income included asset utilization source of 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Risk 2023/XX/XX: Missing lease
Deficiency - ATR Impact income and/or asset doc requirements which could result in a risk to the income in the amount of $XXX; however, the file is missing Cash-out - agreements for rental
borrower's ability to repay. (Exception is eligible to be regraded with all the of asset verification for the accounts used for Debt income, missing P&L and
compensating factors.) qualifying, causing the loan to waterfall through the QM Consolidation balance sheets for S-Corp.,
Testing. and calculated dti exceeds
max allowable dti per
guidelines, exceptions
remains.
2023/XX/XX: Received required
documentation. Condition
cleared.
649208141 XXX XXX 2 29374137 compliance 1 QM DTI Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and The qualifying income included asset utilization source of Although this issue is subject to a 3 year SOL for affirmative claims under TILA, AMC does not adjust 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Risk 2023/XX/XX: Received required
the images do not provide evidence loan is eligible for purchase, guarantee or income in the amount of $XXX; however, the file is missing grading taking into account TILA SOL for exceptions under ATR, given the potential for enhanced Cash-out - documentation. Condition
insurance by the appropriate agency. all the of asset verification for the accounts used for damages when asserting an ability to repay defense in response to an action to collect a debt by Debt cleared.
qualifying. Excluding the asset utilization source of recoupment or set-off. Consolidation
income, the DTI exceeds the maximum allowed by guidelines,
causing the loan to waterfall through the QM Testing.
649208141 XXX XXX 2 29374138 compliance 1 Appendix Q Liabilities - Qualified Mortgage (Dodd-Frank 2014): One or more liabilities have been excluded Documentation was provided to verify the business makes 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 10/XX/2023 Yes ATR Risk 2023/XX/XX: unable to 2023/XX/XX: Trailing docs did
Invalid Exclusion Basis from DTI calculation for a prohibited reason. payments for three installment loans; however, this doesn't Cash-out - support exclusion of not contain any docs to clear
meet QM requirements, causing the loan to waterfall through Debt debts on QM loan. this exception.
the QM testing. Consolidation
2023/XX/XX: Agree with 2023/XX/XX: No supporting
error trailing documentation was
provided to clear this
exception. Exception remains.
2023/XX/XX: Client elects to
restate loan designation to
Non QM.
649208141 XXX XXX 2 29374139 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more The loan is missing income, asset and credit documents and 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Risk 2023/XX/XX: Missing lease
Provision Investor guideline components, the loan is at ATR risk. the DTI exceeds the maximum allowed, causing the loan to Cash-out - agreements for rental
Guidelines waterfall through the QM Testing. Debt income, missing P&L and
Consolidation balance sheets for S-Corp.,
and calculated dti exceeds
max allowable dti per
guidelines, exceptions
remains.
2023/XX/XX: Received required
documentation. Condition
cleared.
649208141 XXX XXX 2 29374140 compliance 1 Other Income - Not to be Qualified Mortgage (Dodd-Frank 2014): Income used to qualify borrower(s) not 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 10/XX/2023 Yes ATR Risk 2023/XX/XX: All asset 2023/XX/XX: Trailing docs did
used for qualifying permitted for use under Appendix Q. (XXX XXX/Asset Depletion) Cash-out - documentation not contain any docs to clear
Debt requirements met to this exception.
Consolidation support required
reserve level of 9 2023/XX/XX: Loan was
months PITIA and zero submitted with a loan
funds to close designation of Safe Harbor
required. XXX QM. Asset Depletion income is
investment account and not permitted under Safe
XXX IRA support $XXX Harbor loan designation.
for adjusted liquidity Condition remains.
reserves taking 70% of
the investment account 2023/XX/XX: Reviewed trailing
and 60% of the IRA documentation. Documents
which equates to 142 necessary to clear the
months PITIA conditions were not provided.
Exception remains.
2023/XX/XX: Provided
UW Income Workbook, 2023/XX/XX: Client elects to
Asset Utilization restate loan designation to
Calculation, 1003, Non QM.
1008. Note: There are
$XXX est reserves
documented in file and
used for
qualifyication. Only
$XXX est was required
for reserves.
2023/XX/XX: Disagree;
Provided UW Income
Workbook, Asset
Utilization
Calculation, 1003,
1008. Note: There are
$XXX est reserves
documented in file and
used for
qualifyication. Only
$XXX est was required
for reserves.
649208141 XXX XXX 2 29374141 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the 1/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 10/XX/2023 Yes ATR Risk 2023/XX/XX: All asset 2023/XX/XX: Trailing docs did
Provision Non QM DTI 1026.43(c)(5) of 45.15% moderately exceeds the guideline maximum of 43.00%. (DTI Cash-out - documentation not contain any docs to clear
moderately exceeds Exception is eligible to be regraded with compensating factors.) Debt requirements met to this exception.
Guidelines Consolidation support required
reserve level of 9 2023/XX/XX: Received lender's
months PITIA and zero asset depletion worksheet,
funds to close however the income used is
required. XXX higher than due diligence
investment account and calculated. DTI of 44.47%
XXX IRA support $XXX still exceeds the maximum of
for adjusted liquidity 43%. Assets used for AD
reserves taking 70% of income are $XXX with a 15
the investment account year amortization equaling
and 60% of the IRA $XXX/mo income.
which equates to 142
months PITIA 2023/XX/XX: Reviewed trailing
documentation. Documents
2023/XX/XX: Provided necessary to clear the
UW Income Workbook, conditions were not provided.
Asset Utilization Exception remains.
Calculation, 1003,
1008. Note: There are 2023/XX/XX: Received required
$XXX est reserves documentation. Condition
documented in file and cleared.
used for
qualifyication. Only
$XXX est was required
for reserves.
2023/XX/XX: Disagree;
Provided UW Income
Workbook, Asset
Utilization
Calculation, 1003,
1008. Note: There are
$XXX est reserves
documented in file and
used for
qualifyication. Only
$XXX est was required
for reserves.
649208141 XXX XXX 2 29374142 compliance 3 Check Loan Designation Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Client elects to restate loan designation to Non QM. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 1/XX/2019 CA Refinance - Primary No C C B B 7/XX/2023 ATR Risk
Match - ATR Risk not match Due Diligence Loan Designation of ATR Risk. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out -
Debt
Consolidation
649208141 XXX XXX 2 29374143 compliance 3 General ATR Provision Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the 1/XX/2019 CA Refinance - Primary No C C C C 7/XX/2023 ATR Risk
Investor and Non QM DTIs Lenders Guidelines and 1026.43(c)(5) of 44.47497% moderately exceeds the Cash-out -
match and both moderately guideline maximum of 43.00%. (DTI Exception is eligible to be regraded with Debt
exceed Guidelines compensating factors.) Consolidation
649208141 XXX XXX 2 29374144 credit 3 Guideline Requirement: Calculated investor qualifying total debt ratio of 44.47497% exceeds Guideline DTI exceeds maximum due to qualification method. 1/XX/2019 CA Refinance - Primary No C C C C 7/XX/2023 ATR Risk
Investor qualifying total total debt ratio of 43.00000%. Cash-out -
debt ratio discrepancy. Debt
Consolidation
649206892 XXX XXX 2 29374175 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement E-sign Consent Agreement is missing in this loan file. 9/XX/2020 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
is missing. QM
649206892 XXX XXX 2 29374176 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX 9/XX/2020 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: PDI provided,
most recent valuation Disaster End Date: XX/XX/XXXX QM exception cleared.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649206892 XXX XXX 2 29374177 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy Borrower waived right to receive a copy of the appraisal at There is generally no Assignee Liability. 9/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Appraisal Not Provided at of the appraisal at least three (3) business days prior to closing, and appraisal least three (3) business days prior to closing, and QM
or Before Closing (3-Day was not provided at or before closing. (Type:Primary/09/XX/2020) appraisal was not provided at or before closing.
Waiver In File)
649206892 XXX XXX 2 29374178 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Creditor did not provide List of Homeownership Counseling RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 9/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
of Homeownership Homeownership Counseling Organizations to borrower. Organizations to borrower. implementing regulation, Regulation X, for these type of violations. QM
Counseling Organizations
Missing
649206892 XXX XXX 2 29374179 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure not provided to Borrower(s) at least TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2020 9/XX/2021 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Disclosure Timing without at least three (3) business days prior to closing. (Initial/09/XX/2020) three (3) business days prior to closing. QM
Waiver
649206892 XXX XXX 2 29374181 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2020 9/XX/2021 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Tolerance Violation Appraisal Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no Amount of $XXX exceeds tolerance of $XXX. Insufficient or no QM
Without Sufficient Cure cure was provided to the borrower. (7506) cure was provided to the borrower.
Provided
649206892 XXX XXX 2 29374182 property 3 Missing Document: Valuation Type: Appraisal / Valuation Report Date: 09/XX/2020 9/XX/2020 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
Appraisal was made QM
"subject to" and Form
1004D/442 was not
provided.
649206892 XXX XXX 2 29374183 credit 3 Guideline Financial Institution: XXX // Account Type: Savings / Account Number: XXX Two months required per guidelines. 9/XX/2020 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
Issue:Insufficient asset QM
documentation.
649209146 XXX XXX 1 29374202 credit 1 Missing Document: Flood 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Flood cert.
Certificate not provided Cash-out - provided, exception remains.
Debt
Consolidation
649209146 XXX XXX 1 29374203 credit 1 YTD Date is dated more Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: Paystub or WVOE or Work Number Income are missing to verify 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/XX: Per lender
than 90 days before the 01/XX/2016 YTD date. Cash-out - rebuttal, this income is a
application date. Debt retirement. This specific
Consolidation condition is cleared.
649209146 XXX XXX 1 29374204 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement 12/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
is missing. Cash-out -
Debt
Consolidation
649209146 XXX XXX 1 29374205 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Verification appraisal was delivered to borrower was not 12/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. provided. Cash-out -
Business Days Prior to (Type:Primary/11/XX/2018) Debt
Consummation Consolidation
649209146 XXX XXX 1 29374206 compliance 1 QM Employment History - Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two Loan file is missing third party verification of employment 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Documentation
Current Employment years current employment. (XXX/12401893) to verify start date and continuation. Cash-out - provided, exception cleared.
Documentation lacks Date Debt
Info Consolidation
649209146 XXX XXX 1 29374207 compliance 1 QM Employment History - Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two Verbal Verification of Employment and Paystubs are missing 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/XX: Per lender
Current Employment years current employment. (XXX/12401894) in the file. Cash-out - rebuttal, this income is a
Documentation lacks Date Debt retirement. This specific
Info Consolidation condition is cleared.
649209146 XXX XXX 1 29374208 compliance 1 S-Corp Income Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not Loan file is missing third party verification of employment 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Documentation
Documentation Test sufficient (S-Corp). (XXX XXX/S-Corp) to verify start date and continuation. Cash-out - provided, exception cleared.
Debt
Consolidation
649209146 XXX XXX 1 29374209 compliance 1 Sole Proprietorship Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not Missing most recent YTD P&L and balance sheet for Sch C 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/XX: 2018 P&L 2023/XX/XX: Trailing docs did
Income Documentation Test sufficient (Sole Proprietorship). (XXX XXX/Schedule C) income. Cash-out - located under Letter not contain any docs to clear
Debt of Explanation - this exception.
Consolidation client used a 2018
Schedule C Form to use 2023/XX/XX: Loan was
as P&L, balance sheet submitted as Safe harbor. Per
not required on safe harbor requirements, the
Schedule C entity. following is required: One
or more of the following
2023/XX/XX: 2018 Sched documents is missing: 1) Most
C form provided as recent 2 yrs Signed and Dated
P&L. Balance Sheet not Personal Tax returns (with
required for busienss Sched C); 2) Most recent YTD
type. Documentation quarterly P&L Statement (if
uploaded. 1040s are > 90 days old at
application); 3) Balance
2023/XX/XX: Disagree Sheet. Received the P&L,
with interpretation of however the year to date
ATR requirements. UB balance sheet is still
guidelines (RLU-NA required per Safe Harbor.
section 302-2.1.3)
state YTD Balance 2023/XX/XX: Loan was re
Sheets are not designated to non qm
required for Schedule
C businesses unless
the business carries
an inventory.
649209146 XXX XXX 1 29374210 compliance 1 General Ability To Repay Ability-to-Repay (Dodd-Frank 2014): Unable to verify current S-Corp status due to Third Party Verification is missing for XXX. Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/XX: 2016-2017 2023/XX/XX: Missing third
Provision Employment - S- most recent Tax Return end date is older than 120 days before Closing Date, and damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Cash-out - 1120S verifies party verification to verify
Corp Test one of these docs is required yet missing: Audited/Third Party P&L, CPA Letter, all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Debt business established existence of the business and
or other Third Party Verification. (XXX XXX/S-Corp) to comply is not material). A private right of action may be brought before the end of the three- Consolidation 03/XX/2010, 1120S start date.
year period beginning on the date of the occurrence of the violation. However, when a creditor, features CPA PTIN and
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial typed signature, copy 2023/XX/XX: Trailing docs did
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter of renewed business not contain any docs to clear
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set- license valid through this exception.
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages 06/XX/2019
for a valid claim brought in an original action, plus the costs to the consumer of the action. If 2023/XX/XX: Received required
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set- 2023/XX/XX: Agree with documentation. Condition
off shall not exceed three years of finance charges and fees. An action to enforce a violation may error cleared.
also be brought by the appropriate state AGs.
2023/XX/XX: No supporting
trailing documentation was
provided to clear this
exception. Exception remains.
649209146 XXX XXX 1 29374211 compliance 1 General Ability To Repay Ability-to-Repay (Dodd-Frank 2014): Unable to verify current Sole Proprietorship Loan file is missing third party verification of employment Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Documentation
Provision Employment - status using reasonably reliable third-party records. (XXX XXX/Schedule C) to verify start date and continuation. damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Cash-out - provided, exception cleared.
Schedule C Test all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Debt
to comply is not material). A private right of action may be brought before the end of the three- Consolidation
year period beginning on the date of the occurrence of the violation. However, when a creditor,
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649209146 XXX XXX 1 29374212 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify current Wages/W-2 employment Verbal Verification of Employment and Paystubs for XXX are Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/XX: This is 2023/XX/XX: Trailing docs did
Provision Employment - W- status using reasonably reliable third-party records. (XXX XXX/Wages) missing in the file. damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Cash-out - not required, the XXX not contain any docs to clear
2 all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Debt W2 wages is actually this exception.
to comply is not material). A private right of action may be brought before the end of the three- Consolidation the XXX Pension income
year period beginning on the date of the occurrence of the violation. However, when a creditor, for XXX. 2023/XX/XX: Per lender
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial rebuttal, this income is a
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter 2023/XX/XX: Borrower retirement. This specific
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set- was retired and condition is cleared.
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages receiving pension
for a valid claim brought in an original action, plus the costs to the consumer of the action. If income from his prior
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set- employer (XXX) via
off shall not exceed three years of finance charges and fees. An action to enforce a violation may XXX. Income
also be brought by the appropriate state AGs. documentation
uploaded.
649209146 XXX XXX 1 29374213 compliance 1 Income/Asset Guideline Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to Third party verification of borrower's employment dates and 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/XX: 2018 P&L 2023/XX/XX: Missing P&L and
Deficiency - ATR Impact income and/or asset doc requirements which could result in a risk to the status of business was not provided. Cash-out - located under Letter balance sheets for Sch C
borrower's ability to repay. (Exception is eligible to be regraded with Debt of Explanation - income, third party
compensating factors.) Consolidation client used a 2018 verification for S-Corp, and
Schedule C Form to use pay stubs and vvoe for wage
as P&L, balance sheet income.
not required on
Schedule C entity. 2023/XX/XX: Trailing docs did
2016-2017 1120S not contain any docs to clear
validated by CPA this exception.
w/PTIN + copy of
business license. WVOE 2023/XX/XX: Received
for wage income not duplicate documentation. The
required as this isnt file remains missing the year
wage income, its to day balance sheet as
pension income. required by Safe Harbor and
the supporting income
2023/XX/XX: Business documentation for the large
license documentation retirement income.
uploaded.
2023/XX/XX: Loan was re
designated to non qm
649209146 XXX XXX 1 29374215 compliance 1 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Loan designation failure due to ATR failure. This exception Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/XX: this will 2023/XX/XX: Trailing docs did
Match - QM QM does not match Due Diligence Loan Designation of ATR Fail. will be cleared once all ATR specific exceptions have been firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - be cleared once other not contain any docs to clear
cured/ cleared. Debt defects have been this exception.
Consolidation cleared. See above.
2023/XX/XX: Loan was re
2023/XX/XX: Duplicate designated to non qm
and/or waterfall
exception
649209146 XXX XXX 1 29374216 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure Sign and Date Captured as 12/XX/2018 from TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2018 12/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure Timing without at least three (3) business days prior to closing. (Initial/12/XX/2018) Page 5. Cash-out -
Waiver Debt
Consolidation
649209146 XXX XXX 1 29374217 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Loan Discount Points Fee was not disclosed on LE but TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2018 12/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Tolerance Violation Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or disclosed as $XXX on Final Closing Disclosure. File does not Cash-out -
Without Sufficient Cure no cure was provided to the borrower. (7200) contain a valid COC for this fee, nor evidence of cure in Debt
Provided file. Consolidation
649209146 XXX XXX 1 29374218 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more ATR failure due to insufficient income documentation. 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/XX: N/A; 2023/XX/XX: Missing P&L and
Provision Investor guideline components, the loan is at ATR risk. Cash-out - Duplicative Exception balance sheets for Sch C
Guidelines Debt income, third party
Consolidation 2023/XX/XX: Duplicate verification for S-Corp, and
and/or waterfall pay stubs and vvoe for wage
exception income.
2023/XX/XX: Trailing docs did
not contain any docs to clear
this exception.
2023/XX/XX: Loan was re
designated to non qm
649209146 XXX XXX 1 29374219 credit 1 Income documentation Third party verification of borrower's employment dates and 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/XX: N/A; 2023/XX/XX: Missing P&L and
requirements not met. status of business was not provided as well as Verification Cash-out - Duplicative Exception balance sheets for Sch C
of employment within 10 days. Debt income, third party
Consolidation 2023/XX/XX: Duplicate verification for S-Corp, and
and/or waterfall pay stubs and vvoe for wage
exception income.
2023/XX/XX: Trailing docs did
not contain any docs to clear
this exception.
649209146 XXX XXX 1 29374220 credit 1 Verification(s) of Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: Verbal Verification of Employment for XXX is missing in the 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/XX: Applicant 2023/XX/XX: Trailing docs did
employment is not within 01/XX/2016 file. Cash-out - receives Pension (not not contain any docs to clear
10 business days of the Debt employment), see this exception.
Note. Consolidation pension letter in file
(under Verification of 2023/XX/XX: Per lender
Other Income) rebuttal, this income is a
retirement. This specific
2023/XX/XX: Borrower condition is cleared.
was retired and
receiving pension
income from his prior
employer (XXX) via
XXX. Income
documentation
uploaded.
649209146 XXX XXX 1 29374221 credit 3 Income Docs Missing: Borrower: XXX, Borrower: XXX Third Party Verification Verbal Verification of Employment & Paystubs for XXX, Award 12/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM 2023/XX/XX: VVOE for 2023/XX/XX: EXCEPTION HISTORY
Paystubs, VVOE - Employment Only Letter and Third Party Verification for XXX with Year 2017 Cash-out - intel not required as - Exception Explanation was
Signed and Dated 1040- Schedule C are missing in the file. Debt this is pension updated on 06/XX/2023 PRIOR
Consolidation income, not wages. Exception Explanation: 1040 -
Business license for Schedule C (2017), K-1
Scorp in file. All (2016), Third Party
1040s/1120S's were Verification, W-2 (2017)
signed as part of the VVOE - Employment Only
closing package.
2023/XX/XX: Missing P&L and
2023/XX/XX: Agree with balance sheets for Sch C
error income, third party
verification for S-Corp, and
pay stubs and vvoe for wage
income.
2023/XX/XX: Trailing docs did
not contain any docs to clear
this exception.
2023/XX/XX: No supporting
trailing documentation was
provided to clear this
exception. Exception remains.
649209146 XXX XXX 1 29374222 compliance 1 Retirement Documentation Qualified Mortgage (Dodd-Frank 2014): Retirement income documentation Per lender rebuttal, the CB is receiving retirement from 12/XX/2018 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/XX: Loan was re
insufficient. (XXX XXX/Pension) Fidelity in the amount of $XXX in addition to a pension of Cash-out - designated to non qm
$XXX. File is missing the supporting documentation for the Debt
$XXX monthly income. Consolidation
649209146 XXX XXX 1 29374223 compliance 2 Check Restated Loan Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not Loan was re designated to non qm Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 12/XX/2018 CA Refinance - Primary No B B A A 7/XX/2023 Non QM
Designation Match - match. However, the updated Loan Designation of Non QM matches the Due Diligence firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out -
General Ability to Repay Loan Designation of Non QM. Debt
Consolidation
649206831 XXX XXX 2 29374277 compliance 2 ECOA Appraisal - Right to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to File is missing a signed/dated initial appraisal disclosure There is generally no Assignee Liability. 7/XX/2014 CA Refinance - Investment No B B B B 7/XX/2023 N/A
Receive Copy of Appraisal Receive a Copy" appraisal disclosure to applicant within three (3) business days dated within 3 business days of the application Rate/Term
Disclosure Not Provided of application or determination of first lien status.
Timely
649206831 XXX XXX 2 29374278 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX 7/XX/2014 CA Refinance - Investment No A A A A 7/XX/2023 5/XX/2023 Yes N/A 2023/XX/XX: Received BPO.
most recent valuation Disaster End Date: XX/XX/XXXX Rate/Term Condition cleared.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649206831 XXX XXX 2 29374279 compliance 2 Missing Document: Missing File is missing signed/dated initial application 7/XX/2014 CA Refinance - Investment No B B B B 7/XX/2023 N/A
Lender's Initial 1003 Rate/Term
649206831 XXX XXX 2 29374280 credit 3 Insufficient Coverage: Hazard coverage of $XXX is insufficient to cover the loan 7/XX/2014 CA Refinance - Investment No C C C C 7/XX/2023 N/A
Hazard insurance coverage amount of $XXX. Rate/Term
amount is insufficient.
649206831 XXX XXX 2 29374281 credit 3 File does not contain Valuation Type: Appraisal / Valuation Report Date: 07/XX/2014 7/XX/2014 CA Refinance - Investment No C C C C 7/XX/2023 N/A
documentation from Rate/Term
lender/seller confirming
the condo is warrantable.
649206831 XXX XXX 2 29374282 credit 3 Aged document: Asset Financial Institution: XXX // Account Type: Savings / Account Number: XXX File is missing an updated consecutive bank statement for 7/XX/2014 CA Refinance - Investment No C C C C 7/XX/2023 N/A
Account date is more than this account. Account is required to cover reserves. Rate/Term
90 days prior to Closing.
649206831 XXX XXX 2 29374283 credit 3 REO Documents are Address: XXX, CA, Address: XXX, CA Statement File is missing current mortgage statements for these 2 7/XX/2014 CA Refinance - Investment No C C C C 7/XX/2023 N/A
missing. Statement properties. Rate/Term
649207022 XXX XXX 2 29374300 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The property is located in FEMA Disaster area. Provide a 6/XX/2017 CA Purchase Primary No A A A A 7/XX/2023 5/XX/2023 Yes Safe Harbor 2023/XX/XX: Received BPO.
most recent valuation Disaster End Date: XX/XX/XXXX post-disaster inspection verifying there was no damage. The QM Condition cleared.
inspection is dated prior Disaster Name: XXX inspection must include exterior photos and the property
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX must be re-inspected on or after XX/XX/XXXX declared end
disaster. date.
649207022 XXX XXX 2 29374301 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM Disclosure is missing. TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2017 6/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Test borrower. QM
649207022 XXX XXX 2 29374302 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet Disclosure is missing. TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2017 6/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor 2023/XX/XX: Missing CHARM
Status CHARM Booklet, not provided to the borrower. QM Booklet provided within 3
days of application.
649207022 XXX XXX 2 29374303 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling List of Homeownership Counseling disclosure was not provided RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 6/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
of Homeownership Organizations not provided to applicant within three (3) business days of within three days of application. implementing regulation, Regulation X, for these type of violations. QM
Counseling Organizations application.
Not Provided Within 3
Business Days of
Application
649207022 XXX XXX 2 29374304 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each The updated appraisal was received on the day of closing and 6/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. no waiver for timing receipt in file. QM
Business Days Prior to (Type:Primary/06/XX/2017)
Consummation
649207022 XXX XXX 2 29374305 compliance 2 ECOA Appraisal Disclosure ECOA - File does not evidence the consumer was provided with the right to receive Verification of appraisal delivery to borrower was not 6/XX/2017 6/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
- ECOA Timing a copy of the Appraisal Disclosure within 3 days of the loan application date. provided. QM
649207022 XXX XXX 2 29374306 compliance 2 TRID Loan Estimate Timing TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the Initial application date 5/XX/2017, Loan estimate is TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 6/XX/2017 6/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
mail to Borrower(s) within three (3) business days of application. 5/XX/2017 which not placed within three days of application. QM
(Initial/05/XX/2017)
649207022 XXX XXX 2 29374308 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Zero Percent Fee Tolerance exceeded for Credit Report Fee. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 6/XX/2017 6/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Tolerance Violation Report Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no QM
Without Sufficient Cure cure was provided to the borrower. (7520)
Provided
649207022 XXX XXX 2 29374309 compliance 2 TRID Ten Percent TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total 10% tolerance was exceeded by $XXX due to increase of 6/XX/2017 6/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Tolerance Violation amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no recording fee. No valid COC provided, nor evidence of cure QM
Without Sufficient Cure cure was provided to the borrower. (0) in file. Provide a post-close CD disclosing the tolerance
Provided cure to include $XXX, a copy of refund check, proof of
delivery, and a copy of the letter of explanation sent to
the borrower disclosing the changes made.
649207003 XXX XXX 1 29374351 compliance 2 Missing Document: Missing Lender's Initial signed/dated 1003 is missing in the file. 9/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM 2023/XX/XX: Missing signed
Lender's Initial 1003 Cash-out - and dated initial
Other application.
649207003 XXX XXX 1 29374352 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Post Inspection Disaster Report is required. 9/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 5/XX/2023 Yes Non QM 2023/XX/XX: Received BPO.
most recent valuation Disaster End Date: XX/XX/XXXX Cash-out - Condition cleared.
inspection is dated prior Disaster Name: XXX Other
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207003 XXX XXX 1 29374354 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Final Closing Disclosure provided on 09/XX/2017 disclosed TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 9/XX/2017 9/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure Finance Charge provided on 09/XX/2017 disclosed an inaccurate Finance Charge on page 5 that does Finance Charge as $XXX However Calculated Finance Charge is Assignee liability. Cash-out -
not match the actual Finance Charge for the loan (fee amounts included in Finance $XXX Variance is of -$XXX. Unable to determine cause for Other
Charge calculation are based on Closing Disclosure dated 09/XX/2017). under disclosure due to missing the final itemization of
(Final/09/XX/2017) amount financed.
649207003 XXX XXX 1 29374355 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each 9/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. Cash-out -
Business Days Prior to (Type:Primary/08/XX/2017) Other
Consummation
649208650 XXX XXX 2 29374533 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA disaster area. A 12/XX/2016 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: BPO provided does
most recent valuation Disaster End Date: XX/XX/XXXX post disaster inspection verifying there was no damage to Cash-out - QM not reflect damage.
inspection is dated prior Disaster Name: XXX the subject property is required. Home
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX Improvement
disaster.
649208650 XXX XXX 2 29374534 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy Borrower waived right to receive a copy of the appraisal at There is generally no Assignee Liability. 12/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor
Appraisal Not Provided at of the appraisal at least three (3) business days prior to closing, and appraisal least three (3) business days prior to closing, and Cash-out - QM
or Before Closing (3-Day was not provided at or before closing. (Type:Primary/12/XX/2016) appraisal was not provided at or before closing. Home
Waiver In File) Improvement
649208650 XXX XXX 2 29374535 credit 3 Missing Document: Flood Missing Document: Flood Certificate not provided in loan 12/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 Safe Harbor
Certificate not provided file Cash-out - QM
Home
Improvement
649208650 XXX XXX 2 29374536 credit 3 Insufficient Coverage: HOI coverage is insufficient by $XXX. Provide updated 12/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 Safe Harbor
Hazard insurance coverage policy reflecting minimum coverage of $XXX OR provide copy Cash-out - QM
amount is insufficient. of insurer's replacement cost estimate supporting current Home
coverage amount. Improvement
649208650 XXX XXX 2 29374537 credit 3 Guideline Requirement: Calculated loan to value percentage of 82.35294% exceeds Guideline loan to value The calculated LTV/CLTV exceeds guideline max of 80/80. 12/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 Safe Harbor
Loan to value percentage of 80.00000%. Cash-out - QM
discrepancy. Home
Improvement
649208650 XXX XXX 2 29374538 credit 3 Guideline Requirement: Calculated combined loan to value percentage of 82.35294% exceeds Guideline The calculated LTV/CLTV exceeds guideline max of 80/80. 12/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 Safe Harbor
Combined loan to value combined loan to value percentage of 80.00000%. Cash-out - QM
discrepancy. Home
Improvement
649208650 XXX XXX 2 29374539 compliance 2 QM Employment History - Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two Missing Employment Dates to verify two years employment 12/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor
Current and/or Previous years employment history for current and/or prior employment. (XXX/12402117) history for current and/or prior employment. Cash-out - QM
Employment Documentation Home
lacks Date Info Improvement
649208650 XXX XXX 2 29374540 credit 3 Credit Exception: Provide corrected 1003 removing co-borrower's income not 12/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 Safe Harbor
being used to qualify. Cash-out - QM
Home
Improvement
649207300 XXX XXX 2 29374561 credit 1 Missing Document: Credit Credit report missing for both borrowers. 4/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Safe Harbor 2023/XX/XX: Credit report was
Report not provided Cash-out - QM provided.
Other
649207300 XXX XXX 2 29374562 credit 3 Missing Document: Fraud Fraud Report is missing for both borrowers. 4/XX/2019 CA Refinance - Primary No C C C C 7/XX/2023 Safe Harbor
Report not provided Cash-out - QM
Other
649207300 XXX XXX 2 29374563 credit 1 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement E-sign Consent Agreement is missing. 4/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Safe Harbor 2023/XX/XX: Not required.
is missing. Cash-out - QM
Other
649207300 XXX XXX 2 29374564 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX There is damage for property hence updated as per the 4/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: BPO provided does
most recent valuation Disaster End Date: XX/XX/XXXX appraisal report. Cash-out - QM not reflect damage.
inspection is dated prior Disaster Name: XXX Other
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207300 XXX XXX 2 29374565 credit 3 No evidence of fraud Credit Report: Original // Borrower: XXX Credit report missing for both borrowers. 4/XX/2019 CA Refinance - Primary No C C C C 7/XX/2023 Safe Harbor
report in file Cash-out - QM
Other
649207300 XXX XXX 2 29374566 credit 3 No evidence of fraud Credit Report: Original // Borrower: XXX Fraud Report is missing for both borrowers. 4/XX/2019 CA Refinance - Primary No C C C C 7/XX/2023 Safe Harbor
report in file Cash-out - QM
Other
649207300 XXX XXX 2 29374567 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy Verification appraisal was delivered to borrower was not There is generally no Assignee Liability. 4/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor
Appraisal Not Provided at of the appraisal at least three (3) business days prior to closing, and appraisal provided. Cash-out - QM
or Before Closing (3-Day was not provided at or before closing. (Type:Primary/03/XX/2019) Other
Waiver In File)
649207300 XXX XXX 2 29374568 compliance 1 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor File is missing credit report. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 4/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Safe Harbor 2023/XX/XX: Credit report was
Match - QM QM does not match Due Diligence Loan Designation of Non QM. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - QM provided.
Other
649207300 XXX XXX 2 29374569 compliance 1 QM Required Credit Report Qualified Mortgage (Dodd-Frank 2014): The loan file does not contain a Credit Credit report was not provided. 4/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Safe Harbor 2023/XX/XX: Credit report was
Not Provided to Evidence report to evidence the consumers outstanding liabilities. (XXX/12402134) Cash-out - QM provided.
Debts Other
649207300 XXX XXX 2 29374570 compliance 1 QM Required Credit Report Qualified Mortgage (Dodd-Frank 2014): The loan file does not contain a Credit Credit Report was not provided. Liabilities consider from 4/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Safe Harbor 2023/XX/XX: Credit report was
Not Provided to Evidence report to evidence the consumers outstanding liabilities. (XXX/12402135) the final 1003 document. Cash-out - QM provided.
Debts Other
649207300 XXX XXX 2 29374571 credit 3 Insufficient Coverage: HOI coverage is insufficient by $XXX. Coverage must be at 4/XX/2019 CA Refinance - Primary No C C C C 7/XX/2023 Safe Harbor
Hazard insurance coverage least the lessor of the Cost new from the appraisal or the Cash-out - QM
amount is insufficient. loan amount. Provide verification of policy with sufficient Other
coverage OR provide copy of insurer's replacement cost
estimate supporting current coverage amount.
649207300 XXX XXX 2 29374572 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender Qualification rate = Note Rate per guidelines. 4/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Safe Harbor 2023/XX/XX: Credit report was
Provision Investor does not match the ATR payment calculation methods under 1026.43(c)(5). Cash-out - QM provided.
Qualification Method not Other
Matching ATR
649207300 XXX XXX 2 29374573 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Zero Percent Fee Tolerance exceeded for Tax Service Fee TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2019 4/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 Safe Harbor
Tolerance Violation Service Fee (Life Of Loan). Fee Amount of $XXX exceeds tolerance of $XXX. (Life Of Loan). Fee Amount of $XXX exceeds tolerance of Cash-out - QM
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (7580) $XXX. Insufficient or no cure was provided to the borrower. Other
Provided
649206907 XXX XXX 1 29374574 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX 8/XX/2017 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: BPO provided does
most recent valuation Disaster End Date: XX/XX/XXXX not reflect damage.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649206907 XXX XXX 1 29374575 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each 8/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation.
Business Days Prior to (Type:Primary/08/XX/2017)
Consummation
649206907 XXX XXX 1 29374576 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 8/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Account Statement Missing implementing regulation, Regulation X, for these type of violations.
649206907 XXX XXX 1 29374577 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2017 8/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower.
649206907 XXX XXX 1 29374578 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement 8/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 Non QM
is missing.
649206907 XXX XXX 1 29374579 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Initial Closing Disclosure dated 8/XX/2017 received by TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 8/XX/2017 8/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Disclosure Timing without at least three (3) business days prior to closing. (Initial/08/XX/2017) Borrower on 8/XX/2017 past 8/XX/2017 (8/XX/2017 closing date
Waiver less 3). Closing Disclosure is not signed by Borrower.
649206907 XXX XXX 1 29374580 credit 3 Guideline Requirement: Calculated PITIA months reserves of 0.82 is less than Guideline PITIA months 0.82 months reserves is less than 6 months required 8/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 Non QM
PITIA reserves months reserves of 6.00.
discrepancy.
649206907 XXX XXX 1 29374581 compliance 2 ARM Disclosure Timing Unable to determine if ARM disclosure was provided within three (3) days of SRM Disclosure does not indicate a document date or date TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2017 8/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Test application due to missing information. received.
649207531 XXX XXX 1 29374602 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The property is located in a FEMA disaster area. Provide a 6/XX/2017 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor 2023/XX/XX: BPO provided
most recent valuation Disaster End Date: XX/XX/XXXX post-disaster inspection verifying there was no damage. The QM reflects no damage.
inspection is dated prior Disaster Name: XXX inspection must include exterior photos and the property
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX must be re-inspected on or after XX/XX/XXXX declared end
disaster. date.
649207531 XXX XXX 1 29374603 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Verification appraisal was delivered to borrower three days 6/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. prior to closing was not provided. QM
Business Days Prior to (Type:Primary/06/XX/2017)
Consummation
649207531 XXX XXX 1 29374605 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, The file was missing evidence the CHARM Booklet was provided TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2017 6/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor 2023/XX/XX: Missing CHARM
Status CHARM Booklet, not provided to the borrower. to borrower within 3 days of initial application. QM Booklet provided within 3
days of application.
649207531 XXX XXX 1 29374606 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Evidence of earlier borrower receipt was not found in file. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 6/XX/2017 6/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Disclosure Timing without at least three (3) business days prior to closing. (Initial/06/XX/2017) QM
Waiver
649207531 XXX XXX 1 29374607 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Loan Discount Points was last disclosed as $XXX on LE but TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 6/XX/2017 6/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor
Tolerance Violation Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or disclosed as $XXX on Final Closing Disclosure. File does not QM
Without Sufficient Cure no cure was provided to the borrower. (7200) contain a valid COC for this fee, nor evidence of cure in
Provided file. Provide a post-close CD disclosing the tolerance
cure to include $XXX, a copy of refund check, proof of
delivery, and a copy of the letter of explanation sent to
the borrower disclosing the changes made.
649207531 XXX XXX 1 29374610 credit 3 AUS/Guideline Findings: The borrower is a first time home buyer and the guidelines 6/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
All conditions were not require a 12 month rental payment history, which is missing QM
met from the loan file.
649207531 XXX XXX 1 29374611 credit 3 The Verification of Rent The borrower is a first time home buyer and the guidelines 6/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor
(VOR) / Verification of require a 12 month rental payment history, which is missing QM
Mortgage (VOM) is from the loan file.
required and was not
found in file.
649207271 XXX XXX 2 29374640 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each No proof of appraisal being sent to borrower 3 days prior to 7/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. closing.
Business Days Prior to (Type:Primary/06/XX/2017)
Consummation
649207271 XXX XXX 2 29374641 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) The Initial Closing Disclosure provided on 07/XX/2017 was TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 7/XX/2017 7/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Disclosure Timing without at least three (3) business days prior to closing. (Initial/07/XX/2017) not provided at least 3 days prior to closing date of
Waiver 07/XX/2017.
649207271 XXX XXX 2 29374643 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement Require E-Sign Consent Agreement. 7/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 Non QM
is missing.
649207271 XXX XXX 2 29374644 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA Disaster area 7/XX/2017 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: BPO provided does
most recent valuation Disaster End Date: XX/XX/XXXX post-close. There is no end declared date for the disaster not state condition of
inspection is dated prior Disaster Name: XXX as of yet. A post-disaster inspection verifying there was property. Exception remains.
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX no damage to the subject property is required.
disaster. 2023/XX/XX: Received BPO.
Condition cleared.
649207271 XXX XXX 2 29374645 compliance 1 Check Loan Designation Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Income documentation missing from the loan file, causing the Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 7/XX/2017 CA Purchase Primary No A A A A 7/XX/2023 10/XX/2023 Yes Non QM 2023/XX/XX: N/A; 2023/XX/XX: Trailing docs did
Match - ATR not match Due Diligence Loan Designation of ATR Fail. loan to waterfall through the QM Testing. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Duplicative Exception not contain any docs to clear
this exception.
2023/XX/XX: Disagree;
provided 2016 proof of 2023/XX/XX: File is missing
filing extension with third party verification
supporting docs, along dated within 30 days prior to
with CPA letter to closing date verifying dates
validate 2017 tax of operation and good
return amounts. Also standing status for all
provided Notepad log business entities.
showing requirements
for when IRS rejects 2023/XX/XX: Reviewed trailing
transcript request documentation. Documents
with requirements to necessary to clear the
waive transcripts and conditions were not provided.
UW Manager notes that Exception remains.
she reviewed extension
for 2016 and CPA 2023/XX/XX: Loan is NonQM.
letter for 2017 and
waived the
transcripts, which was
allowed by UB
guidelines, see RLU-NA
302-1.6.4 "IRS
REJECTION OF TAX
TRANSCRIPT REQUEST DUE
TO... OTHER CONCERNS"
649207271 XXX XXX 2 29374646 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify K-1 (Less than 25% The file is missing the tax transcripts, causing the loan to Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 7/XX/2017 CA Purchase Primary No A A A A 7/XX/2023 10/XX/2023 Yes Non QM 2023/XX/XX: Borrower 2023/XX/XX: Missing signed
Provision Income and Ownership) income using reasonably reliable third-party records. (XXX waterfall through the QM Testing. damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of provided evidence of and dated 2016 personal tax
Assets - K-1 Less 25% XXX/Schedule K-1 less than 25 Percent) all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure XXX, detail loe returns or 2016 Tax
to comply is not material). A private right of action may be brought before the end of the three- provided verifying Transcripts. Condition
year period beginning on the date of the occurrence of the violation. However, when a creditor, reason for not able to remains.
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial obtain transcripts due
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter to amendments. 2023/XX/XX: File is missing
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set- Evidence of 2016 third party verification
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages extension has been dated within 30 days prior to
for a valid claim brought in an original action, plus the costs to the consumer of the action. If provided and also closing date verifying dates
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set- evidence of payment of operation and good
off shall not exceed three years of finance charges and fees. An action to enforce a violation may paid to IRS for any standing status for all
also be brought by the appropriate state AGs. estaimated amount owed business entities
for 2016. Signed 4506t
is also provided in 2023/XX/XX: Reviewed trailing
the file. documentation. Documents
necessary to clear the
2023/XX/XX: Disagree; conditions were not provided.
provided 2016 proof of Exception remains.
filing extension with
supporting docs, along 2023/XX/XX: Guidelines have
with CPA letter to been met for K-1 income
validate 2017 tax documentation or are silent
return amounts. Also and do not defer to Fannie.
provided Notepad log No violation. Exception
showing requirements cleared.
for when IRS rejects
transcript request
with requirements to
waive transcripts and
UW Manager notes that
she reviewed extension
for 2016 and CPA
letter for 2017 and
waived the
transcripts, which was
allowed by UB
guidelines, see RLU-NA
302-1.6.4 "IRS
REJECTION OF TAX
TRANSCRIPT REQUEST DUE
TO... OTHER CONCERNS"
649207271 XXX XXX 2 29374648 compliance 2 Self-Employed Tax Return Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or 2016 tax return with all Schedules not provided. Only tax 7/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Non QM 2023/XX/XX: The EV2 exception
Recency - ATR personal tax returns provided are not the most recent. Application Date return extension was provided, causing the loan to waterfall is for informational
06/XX/2017, Most Recent Tax Return End Date 12/XX/2015, Tax Return Due Date through the QM Testing. purposes. The reason for the
04/XX/2017. (XXX XXX/Schedule K-1 less than 25 Percent) exception is due to the
recency of the tax returns
provided.
649207271 XXX XXX 2 29374649 compliance 2 Self-Employed Tax Return Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or 2016 tax return with all Schedules not provided. Only tax 7/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Non QM 2023/XX/XX: The EV2 exception
Recency - ATR personal tax returns provided are not the most recent. Application Date return extension was provided, causing the loan to waterfall is for informational
06/XX/2017, Most Recent Tax Return End Date 12/XX/2015, Tax Return Due Date through the QM Testing. purposes. The reason for the
04/XX/2017. (XXX XXX/Schedule K-1 less than 25 Percent) exception is due to the
recency of the tax returns
provided.
649207271 XXX XXX 2 29374650 compliance 2 Self-Employed Tax Return Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or 2016 tax return with all Schedules not provided. Only tax 7/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Non QM 2023/XX/XX: The EV2 exception
Recency - ATR personal tax returns provided are not the most recent. Application Date return extension was provided, causing the loan to waterfall is for informational
06/XX/2017, Most Recent Tax Return End Date 12/XX/2015, Tax Return Due Date through the QM Testing. purposes. The reason for the
04/XX/2017. (XXX XXX/Schedule K-1 less than 25 Percent) exception is due to the
recency of the tax returns
provided.
649207549 XXX XXX 2 29374921 credit 1 The Preliminary title 7/XX/2017 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes ATR Risk 2023/XX/XX: Exception
policy is within CA or NV cleared.
and does not reflect a
coverage amount (no final
title policy in file).
Unable to determine if
appropriate coverage is
provided.
649207549 XXX XXX 2 29374922 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement 7/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 ATR Risk
is missing.
649207549 XXX XXX 2 29374923 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX 7/XX/2017 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes ATR Risk 2023/XX/XX: BPO provided. No
most recent valuation Disaster End Date: XX/XX/XXXX damage noted. Cleared.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207549 XXX XXX 2 29374924 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Missing a valid Change of Circumstance. Final Closing TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 7/XX/2017 7/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 ATR Risk
Tolerance Violation Endorsement Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or Disclosure does not disclose a Lender cure credit.
Without Sufficient Cure no cure was provided to the borrower. (7564)
Provided
649207549 XXX XXX 2 29374925 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2017 7/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 ATR Risk
Status CHARM Booklet, not provided to the borrower.
649207549 XXX XXX 2 29374927 compliance 3 Check Loan Designation Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Failure due to age of document for asset documentation. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 7/XX/2017 CA Purchase Primary No C C B B 7/XX/2023 ATR Risk 2023/XX/XX: Assets 2023/XX/XX: Trailing Activity
Match - ATR Risk not match Due Diligence Loan Designation of ATR Risk. firm performing the loan level due diligence and to have the TPR firm confirm said designation. used in qualifying are printout dated 07/XX/20217
all updated and dated provided. Print out does not
May-June with Note reflect XXX, Borrower's Name,
date 7/XX/2017 meeting Account Number and/or Start
age of document and End Date. Most recent XXX
requirements Employee Stock Plan Account
provided for periods
2023/XX/XX: Agree with 01/XX/2017 - 03/XX/2017.
error. Exception remains.
2023/XX/XX: Updated statement
was not provided in the
trailing docs. condition
remains.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649207549 XXX XXX 2 29374928 credit 3 Aged document: Asset Financial Institution: XXX // Account Type: Stocks / Account Number: XXX, An updated consecutive (04/2017) statement for both accounts 7/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/XX: No new
Account date is more than Financial Institution: XXX // Account Type: 401(k)/403(b) Account / Account would be required to meet reserve requirements and lender documentation provided,
90 days prior to Closing. Number: XXX guides. exception remains.
2023/XX/XX: Only current
statement was provided for
Merrill Lynch. Condition
remains.
2023/XX/XX: Trailing Activity
printout dated 07/XX/20217
provided. Print out does not
reflect XXX, Borrower's Name,
Account Number and/or Start
and End Date. Most recent XXX
Employee Stock Plan Account
provided for periods
01/XX/2017 - 03/XX/2017.
Exception remains.
2023/XX/XX: Updated statement
was not provided in the
trailing docs. condition
remains.
649207549 XXX XXX 2 29374929 credit 3 Asset documentation 2 of the accounts required and used by lender exceeds the 90 7/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/XX: Assets 2023/XX/XX: Trailing Activity
requirements not met. day age of document per lender guides. used in qualifying are printout dated 07/XX/20217
all updated and dated provided. Print out does not
May-June with Note reflect XXX, Borrower's Name,
date 7/XX/2017 meeting Account Number and/or Start
age of document and End Date. Most recent XXX
requirements Employee Stock Plan Account
provided for periods
2023/XX/XX: Agree with 01/XX/2017 - 03/XX/2017.
error. Exception remains.
2023/XX/XX: Updated statement
was not provided in the
trailing docs. condition
remains.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649207549 XXX XXX 2 29374930 compliance 3 Income/Asset Guideline Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to Asset accounts used by lender and required to meet reserves 7/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/XX: Assets 2023/XX/XX: Trailing Activity
Deficiency - ATR Impact income and/or asset doc requirements which could result in a risk to the exceeds the 90 day age of documentation requirement per used in qualifying are printout dated 07/XX/20217
borrower's ability to repay. (Exception is eligible to be regraded with lender guides. all updated and dated provided. Print out does not
compensating factors.) May-June with Note reflect XXX, Borrower's Name,
date 7/XX/2017 meeting Account Number and/or Start
age of document and End Date. Most recent XXX
requirements Employee Stock Plan Account
provided for periods
2023/XX/XX: Agree with 01/XX/2017 - 03/XX/2017.
error. Exception remains.
2023/XX/XX: Updated statement
was not provided in the
trailing docs. condition
remains.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649207549 XXX XXX 2 29374931 credit 3 Large deposits were not The source of the large deposit into the Keypoint account in 7/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/XX: Unable to 2023/XX/XX: Trailing docs did
sourced and/or letter of the amount of 20,054.79 was not provided in the loan file. locate the source of not contain any docs to clear
explanation was not the $XXX deposit this exception.
provided.
2023/XX/XX: Agree with 2023/XX/XX: Provide Source of
error. Funds/Deposit into XXX
account ending XXX for $XXX
dated 06/XX/2017. Exception
remains.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649207549 XXX XXX 2 29374932 compliance 3 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Failure due to age of docs for assets. Required to cover 7/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/XX: Assets 2023/XX/XX: Trailing Activity
Provision Investor guideline components, the loan is at ATR risk. reserve requirements. used in qualifying are printout dated 07/XX/20217
Guidelines all updated and dated provided. Print out does not
May-June with Note reflect XXX, Borrower's Name,
date 7/XX/2017 meeting Account Number and/or Start
age of document and End Date. Most recent XXX
requirements Employee Stock Plan Account
provided for periods
2023/XX/XX: Agree with 01/XX/2017 - 03/XX/2017.
error. Exception remains.
2023/XX/XX: Updated statement
was not provided in the
trailing docs. condition
remains.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649207339 XXX XXX 1 29374964 credit 3 Missing Document: Flood 3/XX/2018 CA Purchase Primary No C C C C 7/XX/2023 Non QM
Certificate not provided
649207339 XXX XXX 1 29374965 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 3/XX/2018 3/XX/2019 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Disclosure Homeowners provided on 03/XX/2018 incorrectly disclosed whether Homeowners Insurance is
Insurance Included In included in escrow. (Final/03/XX/2018)
Escrow Test
649207339 XXX XXX 1 29374966 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure not provided to Borrower(s) at least TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 3/XX/2018 3/XX/2019 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Disclosure Timing without at least three (3) business days prior to closing. (Initial/03/XX/2018) three (3) business days prior to closing.
Waiver
649207339 XXX XXX 1 29374967 compliance 2 TRID Revised Loan TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on 03/XX/2018 Revised Loan Estimate provided on 03/XX/2018 not received by TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 3/XX/2018 3/XX/2019 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Estimate Timing Before not received by borrower at least four (4) business days prior to closing. borrower at least four (4) business days prior to closing.
Closing (Interim/03/XX/2018)
649207339 XXX XXX 1 29374968 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Account Statement Missing implementing regulation, Regulation X, for these type of violations.
649207339 XXX XXX 1 29374969 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy There is generally no Assignee Liability. 3/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided at of the appraisal at least three (3) business days prior to closing, and appraisal
or Before Closing (3-Day was not provided at or before closing. (Type:Primary/03/XX/2018)
Waiver In File)
649207339 XXX XXX 1 29374970 compliance 3 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Missing vvoe from previous employer to verify complete two Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 3/XX/2018 CA Purchase Primary No C C B B 7/XX/2023 Non QM
Match - QM QM does not match Due Diligence Loan Designation of Non QM. year employment history resulting in a loan designation of firm performing the loan level due diligence and to have the TPR firm confirm said designation.
Non-QM.
649207339 XXX XXX 1 29374972 compliance 2 QM Employment History - Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two Missing vvoe from previous employer to verify complete two 3/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Current and/or Previous years employment history for current and/or prior employment. (XXX XXX/12402147) year employment history.
Employment Documentation
lacks Date Info
649207339 XXX XXX 1 29374973 compliance 3 Appendix Q Liabilities - Qualified Mortgage (Dodd-Frank 2014): One or more liabilities have been excluded Borrowers employer pays the monthly car payment per the 3/XX/2018 CA Purchase Primary No C C C C 7/XX/2023 Non QM
Invalid Exclusion Basis from DTI calculation for a prohibited reason. statement on XXX.
649207339 XXX XXX 1 29374974 credit 3 No evidence of fraud Credit Report: Original // Borrower: XXX XXX Missing fraud report. 3/XX/2018 CA Purchase Primary No C C C C 7/XX/2023 Non QM
report in file
649207339 XXX XXX 1 29374975 credit 3 Missing Document: Fraud 3/XX/2018 CA Purchase Primary No C C C C 7/XX/2023 Non QM
Report not provided
649209111 XXX XXX 1 29375007 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The property is located in a FEMA disaster area. Provide a 10/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: BPO provided. No
most recent valuation Disaster End Date: XX/XX/XXXX post-disaster inspection verifying there was no damage. The Rate/Term damage noted. Cleared.
inspection is dated prior Disaster Name: XXX inspection must include exterior photos and the property
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX must be re-inspected on or after XX/XX/XXXX declared end
disaster. date.
649209111 XXX XXX 1 29375008 credit 3 File does not contain Valuation Type: Appraisal / Valuation Report Date: 09/XX/2017 File does not contain documentation from lender/seller 10/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
documentation from confirming the condo is warrantable hence please provide Rate/Term
lender/seller confirming document .
the condo is warrantable.
649209111 XXX XXX 1 29375009 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement E-sign Consent Agreement is missing in loan file . 10/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
is missing. Rate/Term
649209111 XXX XXX 1 29375010 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Mortgage Broker Fee is incased on final closing disclosure TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 10/XX/2017 10/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Tolerance Violation Mortgage Broker Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient by $XXX hence please provide valid changed circumstance Rate/Term
Without Sufficient Cure or no cure was provided to the borrower. (75138)
Provided
649209111 XXX XXX 1 29375011 credit 1 Verification(s) of Borrower: XXX XXX // Employment Type: Employment / Income Type: Wages / Start Verification(s) of employment is not within 10 business days 10/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: VVOE was
employment is not within Date: 05/XX/2002 of the Note. Rate/Term provided.
10 business days of the
Note.
649207810 XXX XXX 1 29375107 credit 3 FEMA Disaster Issue: The Disaster Name: XXX The subject property is located in a FEMA Disaster area 11/XX/2016 CA Refinance - Investment No C C C C 7/XX/2023 N/A 2023/XX/XX: BPO provided
subject property is Disaster Declaration Date: XX/XX/XXXX post-close. A post-disaster inspection verifying there was Rate/Term prior to disaster end date
located in a FEMA no damage to the subject property is required. does not reflect damage
disaster that does not
have a declared end date.
649207810 XXX XXX 1 29375108 credit 3 Insufficient Coverage: HOI coverage is insufficient by $XXX. Provide updated 11/XX/2016 CA Refinance - Investment No C C C C 7/XX/2023 N/A
Hazard insurance coverage policy reflecting minimum coverage of $XXX OR provide copy Rate/Term
amount is insufficient. of insurer's replacement cost estimate supporting current
coverage amount.
649207810 XXX XXX 1 29375109 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Verification appraisal was delivered to borrower was not 11/XX/2016 CA Refinance - Investment No B B B B 7/XX/2023 N/A
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. provided. Rate/Term
Business Days Prior to (Type:Primary/08/XX/2016)
Consummation
649207810 XXX XXX 1 29375111 credit 3 Guideline Requirement: Calculated loan to value percentage of 73.04527% exceeds Guideline loan to value Per lender guides, the maximum LTV is 70%. 11/XX/2016 CA Refinance - Investment No C C C C 7/XX/2023 N/A
Loan to value percentage of 70.00000%. Rate/Term
discrepancy.
649209022 XXX XXX 2 29375432 compliance 2 Missing Document: Missing Missing signed and dated Initial Loan Application. 9/XX/2015 CA Refinance - Investment No B B B B 7/XX/2023 N/A
Lender's Initial 1003 Cash-out -
Other
649209022 XXX XXX 2 29375433 credit 3 Missing Document: The Approval document was not provided. 9/XX/2015 CA Refinance - Investment No C C C C 7/XX/2023 N/A
Approval not provided Cash-out -
Other
649209022 XXX XXX 2 29375434 credit 3 Missing Document: Flood Missing Flood Certificate. 9/XX/2015 CA Refinance - Investment No C C C C 7/XX/2023 N/A
Certificate not provided Cash-out -
Other
649209022 XXX XXX 2 29375435 credit 3 Missing Document: Occupancy Certificate was not provided. 9/XX/2015 CA Refinance - Investment No C C C C 7/XX/2023 N/A
Occupancy Certificate not Cash-out -
provided Other
649209022 XXX XXX 2 29375436 credit 3 Verification(s) of Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: Missing borrower(s) Verification of employment within 10 9/XX/2015 CA Refinance - Investment No C C C C 7/XX/2023 N/A
employment is not within 06/XX/1992 days of the Note. Cash-out -
10 business days of the Other
Note.
649209022 XXX XXX 2 29375437 compliance 2 ECOA Appraisal - Right to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to "Right to Receive a Copy" appraisal disclosure was not There is generally no Assignee Liability. 9/XX/2015 CA Refinance - Investment No B B B B 7/XX/2023 N/A
Receive Copy of Appraisal Receive a Copy" appraisal disclosure to applicant within three (3) business days provided to borrower(s) within three (3) business days of Cash-out -
Disclosure Not Provided of application or determination of first lien status. application. Other
Timely
649209022 XXX XXX 2 29375438 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA disaster area. 9/XX/2015 CA Refinance - Investment No A A A A 7/XX/2023 6/XX/2023 Yes N/A 2023/XX/XX: Received BPO
most recent valuation Disaster End Date: XX/XX/XXXX A post disaster inspection verifying there was no damage to Cash-out - confirming no damage.
inspection is dated prior Disaster Name: XXX the subject property is required. Other
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649208826 XXX XXX 1 29375452 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. Initial escrow account statement was not provided to the RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 12/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Account Statement Missing borrower. implementing regulation, Regulation X, for these type of violations.
649208826 XXX XXX 1 29375453 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Creditor did not provide List of Homeownership Counseling RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 12/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Non QM
of Homeownership Homeownership Counseling Organizations to borrower. Organizations to borrower. implementing regulation, Regulation X, for these type of violations.
Counseling Organizations
Missing
649208826 XXX XXX 1 29375454 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan There is no evidence of cure in the file or valid change of TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2015 12/XX/2016 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Tolerance Violation Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or circumstance.
Without Sufficient Cure no cure was provided to the borrower. (7200)
Provided
649208826 XXX XXX 1 29375455 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2015 12/XX/2016 CA Purchase Primary No B B B B 7/XX/2023 Non QM 2023/XX/XX: Missing CHARM
Status CHARM Booklet, not provided to the borrower. Booklet provided within 3
days of application.
649208826 XXX XXX 1 29375456 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Most Recent Valuation Inspection Date: XX/XX/XXXX 12/XX/2015 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received BPO
most recent valuation Disaster End Date: XX/XX/XXXX Disaster End Date: XX/XX/XXXX confirming no damage.
inspection is dated prior Disaster Name: XXX Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX Disaster Declaration Date: XX/XX/XXXX
disaster.
649208826 XXX XXX 1 29375457 compliance 2 Missing Document: Missing The initial 1003 was not signed by the borrower or loan 12/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Non QM 2023/XX/XX: Missing
Lender's Initial 1003 originator. Signed/dated Initial 1003.
649208826 XXX XXX 1 29375458 compliance 3 Sole Proprietorship Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not The borrower's most recent balance sheet was required by the 12/XX/2015 CA Purchase Primary No C C C C 7/XX/2023 Non QM 2023/XX/XX: Balance 2023/XX/XX: Appendix Q
Income Documentation Test sufficient (Sole Proprietorship). (XXX XXX/Schedule C) guidelines and not provided. Loan is waterfalling to ATR/QM sheet not required. requires a Balance Sheet
income documentation requirement. Service related since the tax returns are
business with no greater than 90 days from the
inventory listed on application date. Exception
schedule C. remains.
649208826 XXX XXX 1 29375459 compliance 3 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor The borrower's most recent balance sheet was required by the Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 12/XX/2015 CA Purchase Primary No C C B B 7/XX/2023 Non QM 2023/XX/XX: Balance 2023/XX/XX: Appendix Q
Match - QM QM does not match Due Diligence Loan Designation of Non QM. guidelines and not provided. Loan is waterfalling to ATR/QM firm performing the loan level due diligence and to have the TPR firm confirm said designation. sheet not required. requires a Balance Sheet
income documentation requirement. Service related since the tax returns are
business with no greater than 90 days from the
inventory listed on application date causing the
schedule C. loan to waterfall to ATR/QM
requirements and a final Due
Diligence Loan Designation on
Non QM.. Exception remains.
2023/XX/XX: EXCEPTION HISTORY
- Exception Detail was
updated on 08/XX/2023 PRIOR
Exception Detail: Qualified
Mortgage (Dodd-Frank 2014):
Originator Loan Designation
of Safe Harbor QM does not
match Due Diligence Loan
Designation of ATR Risk.
649208826 XXX XXX 1 29375460 compliance 2 ARM Disclosure Compliant TIL variable rate disclosure: ARM loan program disclosure does not match terms of The ARM disclosure provided was neither signed or dated TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2015 12/XX/2016 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Test loan.
649208826 XXX XXX 1 29375461 compliance 2 ARM Disclosure Timing Unable to determine if ARM disclosure was provided within three (3) days of The ARM disclosure provided was neither signed or dated TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2015 12/XX/2016 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Test application due to missing information.
649208826 XXX XXX 1 29375462 compliance 2 TRID Ten Percent TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total 10% tolerance was exceeded by $XXX due to increase of Title- 12/XX/2015 12/XX/2016 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Tolerance Violation amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no endorsement, Title-recording service fee, fee, and Title
Without Sufficient Cure cure was provided to the borrower. (0) Sub-escrow, and Title- wire fee. There is no evidence of
Provided cure in file, or valid COC provided.
649208826 XXX XXX 1 29375464 credit 1 Income documentation File is missing the required year to date signed/dated 12/XX/2015 CA Purchase Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Balance 2023/XX/XX: Per Portfolio
requirements not met. balance sheet for Alex. sheet not required. Guidelines, Balance Sheet is
Service related only required if the business
business with no entity carries an inventory
inventory listed on or the business tax returns
schedule C. reflect Cost of Goods sold.
Schedule C business with no
inventory. Exception
cleared.
649208826 XXX XXX 1 29375465 compliance 1 Income/Asset Guideline Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to Failure due to missing income docs. 12/XX/2015 CA Purchase Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Balance 2023/XX/XX: Per Portfolio
Deficiency - ATR Impact income and/or asset doc requirements which could result in a risk to the sheet not required. Guidelines, Balance Sheet is
borrower's ability to repay. (Exception is eligible to be regraded with Service related only required if the business
compensating factors.) business with no entity carries an inventory
inventory listed on or the business tax returns
schedule C. reflect Cost of Goods sold.
Schedule C business with no
inventory. Exception
cleared.
649208826 XXX XXX 1 29375466 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Due to missing income documents 12/XX/2015 CA Purchase Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/XX: Balance 2023/XX/XX: Reviewed trailing
Provision Investor guideline components, the loan is at ATR risk. sheet not required. documents provided.
Guidelines Service related Documentation for income was
business with no not included. Condition
inventory listed on remains.
schedule C.
2023/XX/XX: Reviewed the
Trailing documentation and
the provided documents are
not sufficient to clear.
Exception remains.
2023/XX/XX: Per Portfolio
Guidelines, Balance Sheet is
only required if the business
entity carries an inventory
or the business tax returns
reflect Cost of Goods sold.
Schedule C business with no
inventory. Exception
cleared.
649206916 XXX XXX 1 29375674 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The property is located in FEMA Disaster area. Provide a 11/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received BPO
most recent valuation Disaster End Date: XX/XX/XXXX post-disaster inspection verifying there was no damage. The Cash-out - confirming no damage.
inspection is dated prior Disaster Name: XXX inspection must include exterior photos and the property Other
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX must be re-inspected on or after XX/XX/XXXX declared end
disaster. date.
649206916 XXX XXX 1 29375675 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of List of Homeownership Counseling Organizations containing 10 RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 11/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
of Homeownership Homeownership Counseling Organizations to borrower. agencies and the date the list was updated is missing from implementing regulation, Regulation X, for these type of violations. Cash-out -
Counseling Organizations the loan file. Other
Missing
649207442 XXX XXX 2 29375748 credit 3 E-sign Consent Agreement E-sign consent is missing in loan file 10/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 ATR Risk
is missing. Rate/Term
649207442 XXX XXX 2 29375749 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Provide a post-disaster inspection verifying there was no 10/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes ATR Risk 2023/XX/XX: PDI provided,
most recent valuation Disaster End Date: XX/XX/XXXX damage. The inspection must include exterior photos and the Rate/Term exception cleared.
inspection is dated prior Disaster Name: XXX property must be re-inspected on or after declared end date.
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207442 XXX XXX 2 29375750 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet is missing in loan file TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2017 10/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Status CHARM Booklet, not provided to the borrower. Rate/Term
649207442 XXX XXX 2 29375751 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Verification appraisal was delivered to borrower was not 10/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. provided. Rate/Term
Business Days Prior to (Type:Primary/09/XX/2017)
Consummation
649207442 XXX XXX 2 29375752 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Fee increased without a valid change of circumstance. Cure TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 10/XX/2017 10/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Tolerance Violation Settlement / Closing / Escrow Fee. Fee Amount of $XXX exceeds tolerance of $XXX. was not provided at closing. Rate/Term
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (7555)
Provided
649207442 XXX XXX 2 29375753 credit 3 Verification(s) of Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: The VVOE for the co-borrower was dated 10/XX/2016 and the 10/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/XX: WVOE for 2023/XX/XX: VVOE provided is
employment is not within 08/XX/2016 loan closed on 10/XX/2017. Rate/Term B2 dated 09/XX/2017, dated 10/XX/2016. Condition
10 business days of the note dated 10/XX/2017 remains.
Note.
2023/XX/XX: Agree with 2023/XX/XX: Per the
error guidelines, verbal
verification of current
employment is to be done
within 10 days of the Note
Date. Condition remains.
2023/XX/XX: No supporting
trailing documentation was
provided to clear this
exception. Exception remains.
649207442 XXX XXX 2 29375754 compliance 2 Missing Document: Missing Initial Loan Application is not in file. 10/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Lender's Initial 1003 Rate/Term
649207442 XXX XXX 2 29375755 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Evidence of receipt of initial CD 3 days prior to closing is TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 10/XX/2017 10/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Disclosure Timing without at least three (3) business days prior to closing. (Initial/10/XX/2017) not in file. Rate/Term
Waiver
649207442 XXX XXX 2 29375756 compliance 2 ARM Disclosure Compliant TIL variable rate disclosure: ARM loan program disclosure does not match terms of Evidence of disclosure receipt is not in file. TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2017 10/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Test loan. Rate/Term
649207442 XXX XXX 2 29375757 compliance 2 ARM Disclosure Timing Unable to determine if ARM disclosure was provided within three (3) days of Evidence of disclosure receipt is not in file. TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2017 10/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Test application due to missing information. Rate/Term
649207442 XXX XXX 2 29375758 credit 3 Income documentation The VVOE for the co-borrower was dated 10/XX/2016 and the 10/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/XX: N/A; 2023/XX/XX: VVOE provided is
requirements not met. loan closed on 10/XX/2017. Rate/Term Duplicative Exception dated 10/XX/2016. Condition
remains.
2023/XX/XX: Duplicate
and/or waterfall 2023/XX/XX: Per the
exception guidelines, verbal
verification of current
employment is to be done
within 10 days of the Note
Date. Condition remains.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649207442 XXX XXX 2 29375759 compliance 3 Check Loan Designation Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does The VVOE for the co-borrower was dated 10/XX/2016 and the Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 10/XX/2017 CA Refinance - Primary No C C B B 7/XX/2023 ATR Risk 2023/XX/XX: N/A; 2023/XX/XX: VVOE provided is
Match - ATR Risk not match Due Diligence Loan Designation of ATR Risk. loan closed on 10/XX/2017, causing the loan to waterfall firm performing the loan level due diligence and to have the TPR firm confirm said designation. Rate/Term Duplicative Exception dated 10/XX/2016. Condition
through the QM Testing. remains.
2023/XX/XX: Duplicate
and/or waterfall 2023/XX/XX: Per the
exception guidelines, verbal
verification of current
employment is to be done
within 10 days of the Note
Date. Condition remains.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649207442 XXX XXX 2 29375760 compliance 3 Income/Asset Guideline Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to The VVOE for the co-borrower was dated 10/XX/2016 and the 10/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/XX: N/A; 2023/XX/XX: VVOE provided is
Deficiency - ATR Impact income and/or asset doc requirements which could result in a risk to the loan closed on 10/XX/2017, causing the loan to waterfall Rate/Term Duplicative Exception dated 10/XX/2016. Condition
borrower's ability to repay. (Exception is eligible to be regraded with through the QM Testing. remains.
compensating factors.) 2023/XX/XX: Duplicate
and/or waterfall 2023/XX/XX: Per the
exception guidelines, verbal
verification of current
employment is to be done
within 10 days of the Note
Date. Condition remains.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649207442 XXX XXX 2 29375761 compliance 3 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more The VVOE for the co-borrower was dated 10/XX/2016 and the 10/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/XX: N/A; 2023/XX/XX: VVOE provided is
Provision Investor guideline components, the loan is at ATR risk. loan closed on 10/XX/2017, causing the loan to waterfall Rate/Term Duplicative Exception dated 10/XX/2016. Condition
Guidelines through the QM Testing. remains.
2023/XX/XX: Duplicate
and/or waterfall 2023/XX/XX: Per the
exception guidelines, verbal
verification of current
employment is to be done
within 10 days of the Note
Date. Condition remains.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649208211 XXX XXX 1 29375922 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the The Disclosure was dated 12/XX/2017, this is longer than TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2018 1/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Test borrower within three (3) days of application. three days from applicaiton date of 12/XX/2017. Cash-out -
Other
649208211 XXX XXX 1 29375923 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, The Disclosure was dated 12/XX/2017, this is longer than TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2018 1/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Timing CHARM Booklet, not provided to the borrower within three (3) days of application. three days from applicaiton date of 12/XX/2017. Cash-out -
Other
649208005 XXX XXX 1 29375949 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX 2/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: PDI provided,
most recent valuation Disaster End Date: XX/XX/XXXX Rate/Term exception cleared.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649208005 XXX XXX 1 29375951 credit 2 The Preliminary title 2/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
policy is within CA or NV Rate/Term
and does not reflect a
coverage amount (no final
title policy in file).
Unable to determine if
appropriate coverage is
provided.
649208005 XXX XXX 1 29375952 credit 3 Insufficient Coverage: Replacement cost estimator is required. 2/XX/2019 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Hazard insurance coverage Rate/Term
amount is insufficient.
649208005 XXX XXX 1 29375953 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 2/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three business days. Rate/Term
Business Days Prior to (Type:Primary/01/XX/2019)
Consummation
649208005 XXX XXX 1 29375954 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Consumer Handbook on Adjustable-Rate Mortgages, CHARM TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2019 2/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 Non QM 2023/XX/XX: Missing CHARM
Status CHARM Booklet, not provided to the borrower. Booklet, not provided to the borrower. Rate/Term Booklet provided within 3
days of application.
649208005 XXX XXX 1 29375955 compliance 2 Notice of Right to Cancel Truth in Lending Act: Notice of Right to Cancel was not provided. Notice of Right to Cancel was provided to borrower however, TILA ROR - 3yrs for rescindable transactions. 2/XX/2019 2/XX/2022 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Missing it is not signed by borrower. Rate/Term
649207992 XXX XXX 2 29375994 credit 3 File does not contain Valuation Type: Appraisal / Valuation Report Date: 06/XX/2015 File does not contain documentation from lender/seller 8/XX/2015 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
documentation from confirming the condo is warrantable. Rate/Term
lender/seller confirming
the condo is warrantable.
649207992 XXX XXX 2 29375995 compliance 2 Missing Document: Missing File is missing a fully executed initial application. 8/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 Non QM 2023/XX/XX: Missing Initial
Lender's Initial 1003 Rate/Term signed/dated 1003.
2023/XX/XX: Missing
Signed/dated Initial 1003.
649207992 XXX XXX 2 29375996 credit 3 Missing Document: 8/XX/2015 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Approval not provided Rate/Term
649207992 XXX XXX 2 29375997 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM loan program disclosure not provided to the borrower TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2015 8/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Test borrower within three (3) days of application. within three (3) days of application. Rate/Term
649207992 XXX XXX 2 29375998 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet Disclosure is required to mitigate this TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2015 8/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 Non QM 2023/XX/XX: Missing CHARM
Status CHARM Booklet, not provided to the borrower. exception. Rate/Term Booklet provided within 3
days of application.
649207992 XXX XXX 2 29375999 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each As per Appraisal acknowledgement document signed on closing 8/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. borrower did not select any option Rate/Term
Business Days Prior to (Type:Primary/06/XX/2015)
Consummation
649207992 XXX XXX 2 29376000 compliance 2 RESPA Servicing RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure RESPA disclosure signed at close 8/XX/2015. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 8/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure: Servicing Statement to applicant within three (3) business days of application. implementing regulation, Regulation X, for these type of violations. Rate/Term
Disclosure Statement Not
Provided Within 3
Business Days of
Application
649206764 XXX XXX 2 29376116 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "First Adjustment" date on the Final TIL TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 3/XX/2015 3/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Payment Summary Table - does not match the first adjustment date for the loan. Assignee liability. Rate/Term
First Adjustment Change
Date Inaccurate
649206764 XXX XXX 2 29376117 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "First Adjustment" amount of taxes and TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 3/XX/2015 3/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Payment Summary Table - insurance, including any mortgage insurance, on the Final TIL does not match the Assignee liability. Rate/Term
First Adjustment Taxes escrow payment that may apply during the first rate adjustment of the loan.
and Insurance Inaccurate
649206764 XXX XXX 2 29376118 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "First Adjustment" total payment amount Due to lender qualification method of 2% above the start TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 3/XX/2015 3/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Payment Summary Table - (PITI) on the Final TIL does not match the total payment amount that may apply rate fully amortized over 40 years not matching the Assignee liability. Rate/Term
First Adjustment Total during the first rate adjustment of the loan. qualification method required under ATR.
Payment (PITI) Inaccurate
649206764 XXX XXX 2 29376119 compliance 2 TILA NMLSR - Individual Truth in Lending Act (NMLSR Dodd- Frank 2014): Individual Loan Originator not Per NMLS website, loan originator not found. 3/XX/2015 3/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Originator License Status licensed to conduct loan origination activities. Rate/Term
Not Approved
649206764 XXX XXX 2 29376120 compliance 2 TILA NMLSR - Individual Truth in Lending Act (NMLSR Dodd- Frank 2014): Individual Loan Originator NMLSR Per NMLS website, loan originator not found. Assignee Liability: Civil actions that may be brought against a creditor may be maintained against 3/XX/2015 3/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Originator NMLS information on loan documents does not match NMLSR. any assignee only if the violation is apparent on the face of the disclosure or other documents Rate/Term
information on documents assigned, except where the assignment was voluntary. This civil liability may include $XXX in the
does not match NMLS case of an individual transaction, or the lesser of $XXX or 1% of the creditor's net worth in the
website case of a class action (effective 1/XX/14, this amount increases to the lesser of $XXX or 1%), as
well as actual damages, court costs, and attorneys' fees. For an anti-steering violation, the
creditor may also be liable in an amount equal to the sum of all finance charges and fees paid by the
consumer, unless the creditor demonstrates the failure to comply is not material. Notwithstanding
any other provision of law, when a creditor, assignee, or other holder or anyone acting on behalf of
the creditor, assignee, or holder, initiates a judicial or nonjudicial foreclosure of the residential
mortgage loan, or any other action to collect the debt in connection with such loan, a consumer may
assert a violation as a matter of defense by recoupment or set off without regard for the time limit
on a private action for damages.
Effective 1/XX/2014 in addition to the aforementioned, the individual Loan Originator could be liable
for statutory damages. The maximum liability is the greater of actual damages or 3 times the loan
originator's compensation or gain, plus the cost to the consumer of the action. The Dodd-Frank Act
extended the statute of limitations on TILA violations to 3 years from the date of the violation.
649206764 XXX XXX 2 29376121 compliance 2 General Ability To Repay Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender Lender qualification method of 2% above the start rate fully 3/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Provision Investor does not match the ATR payment calculation methods under 1026.43(c)(5). amortized over 40 years does not match the qualification Rate/Term
Qualification Method not method required under 1026.43(c)(5).
Matching ATR
649206764 XXX XXX 2 29376122 compliance 2 RESPA (2010) - 10% RESPA (2010): 10% tolerance violation without evidence of sufficient cure 10% tolerance violation with no cure provided. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Tolerance Without Cure provided. implementing regulation, Regulation X, for these type of violations. Rate/Term
649206764 XXX XXX 2 29376123 credit 3 FEMA Disaster Issue: The Disaster Name: XXX 3/XX/2015 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: BPO provided
subject property is Disaster Declaration Date: XX/XX/XXXX Rate/Term prior to disaster end date
located in a FEMA does not reflect damage.
disaster that does not
have a declared end date. 2023/XX/XX: BPO provided
prior to disaster end date
does not reflect damage.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
A Post Disaster Inspection is
required to verify no damage
to the Subject. Exception
remains.
649206764 XXX XXX 2 29376124 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Account Statement Missing implementing regulation, Regulation X, for these type of violations. Rate/Term
649206764 XXX XXX 2 29376125 compliance 2 RESPA (2010) - GFE RESPA (2010): GFE does not provide minimum ten (10) business day availability RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Settlement charges Good for estimate of charges and terms for all other settlement charges. implementing regulation, Regulation X, for these type of violations. Rate/Term
Thru Date Less than 10
Days
649206764 XXX XXX 2 29376126 compliance 2 ECOA Appraisal - Right to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Document was provided 12/XX/2014, which is more than 3 There is generally no Assignee Liability. 3/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Receive Copy of Appraisal Receive a Copy" appraisal disclosure to applicant within three (3) business days business days after application date of 11/XX/2014. Rate/Term
Disclosure Not Provided of application or determination of first lien status.
Timely
649206764 XXX XXX 2 29376127 compliance 2 RESPA Servicing RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure Document was provided 12/XX/2014, which is more than 3 RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Disclosure: Servicing Statement to applicant within three (3) business days of application. business days after application date of 11/XX/2014. implementing regulation, Regulation X, for these type of violations. Rate/Term
Disclosure Statement Not
Provided Within 3
Business Days of
Application
649206764 XXX XXX 2 29376128 compliance 2 TIL-MDIA - Initial TIL Truth in Lending Act (Early TIL Disclosure): Initial TIL was not sent within Document was provided 12/XX/2014, which is more than 3 TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited as a defense to 3/XX/2015 3/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Not Provided within 3 three (3) business days of the creditor application date. business days after application date of 11/XX/2014. foreclosure. Assignee liability. Rate/Term
Business Days of
Application
649206764 XXX XXX 2 29376129 credit 3 Verification(s) of Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: VOE was not provided within 10 business day of the note. 3/XX/2015 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: Concur. 2023/XX/XX: Trailing docs did
employment is not within 06/XX/1983 Rate/Term Date of VVOE was not contain any docs to clear
10 business days of the 3/XX/15 and note was this exception.
Note. dated 3/XX/15.
Borrower has been with 2023/XX/XX: Rebuttal comment
employer since XXX and indicates client agrees with
is a XXX. WVOE notes finding. Finding remains
continued employment open.
is "excellent."
2023/XX/XX: No supporting
2023/XX/XX: Agree with trailing documentation was
error based on timing, provided to clear this
but don't agree that a exception. Exception remains.
missing VOE
significantly changes
ATR impact based on
the overall risk &
quality of the
transaction.
649206764 XXX XXX 2 29376130 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" date on the TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 3/XX/2015 3/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Payment Summary Table - Final TIL does not match the date on which the first regular periodic payment Assignee liability. Rate/Term
Maximum In First 5 Years will be due and the earliest date on which that rate may apply.
Change Date Inaccurate
(ARM loan)
649206764 XXX XXX 2 29376131 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" interest rate TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 3/XX/2015 3/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Payment Summary Table - on the Final TIL does not match the maximum interest rate that may apply during Assignee liability. Rate/Term
Maximum In First 5 Years the first five (5) years of the loan.
Interest Rate Inaccurate
649206764 XXX XXX 2 29376132 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" total payment TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 3/XX/2015 3/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Payment Summary Table - amount (PITI) on the Final TIL does not match the maximum total payment on the Assignee liability. Rate/Term
Maximum In First 5 Years loan during the first five (5) years for the loan.
Total Payment (PITI)
Inaccurate
649206764 XXX XXX 2 29376133 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum Ever" date on the Final TIL does TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 3/XX/2015 3/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Payment Summary Table - not match the earliest date on which the maximum rate may apply. Assignee liability. Rate/Term
Maximum Ever Change Date
Inaccurate
649206764 XXX XXX 2 29376134 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" interest payment TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 3/XX/2015 3/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Payment Summary Table - on the Final TIL does not match the maximum interest payment that may apply Assignee liability. Rate/Term
Maximum In First 5 Years during the first five (5) years of the loan.
Interest Payment
Inaccurate
649206764 XXX XXX 2 29376135 compliance 2 2011 TIL-MDIA Rate- Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" principal TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 3/XX/2015 3/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Payment Summary Table - payment on the Final TIL does not match the maximum principal payment that may Assignee liability. Rate/Term
Maximum In First 5 Years apply during the first five (5) years of the loan.
Principal Payment
Inaccurate
649206764 XXX XXX 2 29376136 compliance 3 Check Loan Designation Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Waterfall exception due to missing third party verification Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 3/XX/2015 CA Refinance - Primary No C C B B 7/XX/2023 ATR Fail 2023/XX/XX: Concur. 2023/XX/XX: Trailing docs did
Match - ATR not match Due Diligence Loan Designation of ATR Fail. of borrower's LLC. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Rate/Term However, LOE in file not contain any docs to clear
states that these this exception.
entities have
ownership in multiple 2023/XX/XX: Rebuttal comment
properties. Income is indicates client agrees with
increasing and ATR is finding. Finding remains
met. open.
2023/XX/XX: Duplicate 2023/XX/XX: Reviewed trailing
and/or waterfall documentation. Documents
exception necessary to clear the
conditions were not provided.
Exception remains.
649206764 XXX XXX 2 29376137 compliance 3 General Ability To Repay Ability-to-Repay (Dodd-Frank 2014): Unable to verify current Partnership status File is missing third party verification of borrower's LLC. Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 3/XX/2015 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: Concur. 2023/XX/XX: Trailing docs did
Provision Employment - due to most recent Tax Return end date is older than 120 days before Closing damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Rate/Term However, LOE in file not contain any docs to clear
Partnership Test Date, and one of these docs is required yet missing: Audited/Third Party P&L, all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure states that these this exception.
CPA Letter, or other Third Party Verification. (XXX XXX/Partnership) to comply is not material). A private right of action may be brought before the end of the three- entities have
year period beginning on the date of the occurrence of the violation. However, when a creditor, ownership in multiple 2023/XX/XX: Rebuttal comment
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial properties. Income is indicates client agrees with
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter increasing and ATR is finding. Finding remains
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set- met. open.
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If 2023/XX/XX: Duplicate 2023/XX/XX: Reviewed trailing
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set- and/or waterfall documentation. Documents
off shall not exceed three years of finance charges and fees. An action to enforce a violation may exception necessary to clear the
also be brought by the appropriate state AGs. conditions were not provided.
Exception remains.
649206764 XXX XXX 2 29376139 compliance 2 RESPA (2010) - 0% RESPA (2010): 0% tolerance violation for 802 fee without evidence of sufficient Zero percent fee tolerance with no cure provided. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Tolerance (Line 802) cure provided. implementing regulation, Regulation X, for these type of violations. Rate/Term
Without Cure
649206764 XXX XXX 2 29376140 credit 3 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The property is in a FEMA disaster area. Provide a 3/XX/2015 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail
most recent valuation Disaster End Date: XX/XX/XXXX satisfactory post-disaster inspection verifying there was no Rate/Term
inspection is dated prior Disaster Name: XXX damage. The inspection must include exterior photos and the
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX property must be re-inspected on or after XX/XX/XXXX (XXX)
disaster. Declared Disaster End Date.
649208507 XXX XXX 1 29376141 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA disaster area. A 5/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes ATR Fail 2023/XX/XX: PDI provided,
most recent valuation Disaster End Date: XX/XX/XXXX post disaster inspection verifying there was no damage to Rate/Term exception cleared.
inspection is dated prior Disaster Name: XXX the subject property is required.
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649208507 XXX XXX 1 29376142 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement E-sign Consent Agreement is missing in file. 5/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail
is missing. Rate/Term
649208507 XXX XXX 1 29376143 credit 3 Insufficient Coverage: HOI coverage is insufficient by $XXX. Provide updated 5/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail
Hazard insurance coverage policy reflecting minimum coverage of $XXX OR Rate/Term
amount is insufficient. provide copy of insurer's replacement cost estimate
supporting current coverage amount.
649208507 XXX XXX 1 29376144 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, The file was missing evidence the CHARM Booklet was provided TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2017 5/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Status CHARM Booklet, not provided to the borrower. to borrower within 3 days of initial application. Rate/Term
649208507 XXX XXX 1 29376145 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM loan program disclosure not provided to the borrower TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2017 5/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Test borrower within three (3) days of application. within three (3) days of application. Rate/Term
649208507 XXX XXX 1 29376146 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Credit report Fee was last disclosed as $XXX on Loan TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2017 5/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Tolerance Violation Report Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no Estimate but disclosed as $XXX on Final Closing Disclosure. Rate/Term
Without Sufficient Cure cure was provided to the borrower. (7520) File does not contain a valid change of circumstance for
Provided this fee, no cure provided.
649208507 XXX XXX 1 29376147 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Title-Wire/Funding/Disbursement Fee was last disclosed as TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2017 5/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Tolerance Violation Wire /Funding/ Disbursement Fee. Fee Amount of $XXX exceeds tolerance of $XXX. $XXX on Loan Estimate but disclosed as $XXX on Final Closing Rate/Term
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (77190) Disclosure. File does not contain a valid change of
Provided circumstance for this fee, no cure provided.
649208507 XXX XXX 1 29376148 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Lender's Title Insurance Fee was last disclosed as $XXX on TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2017 5/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Tolerance Violation Lender's Title Insurance. Fee Amount of $XXX exceeds tolerance of $XXX. Loan Estimate but disclosed as $XXX on Final Closing Rate/Term
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (7739) Disclosure. File does not contain a valid change of
Provided circumstance for this fee, no cure provided.
649208507 XXX XXX 1 29376149 compliance 3 Check Loan Designation Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does The file is missing required income documents, causing the Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 5/XX/2017 CA Refinance - Primary No C C B B 7/XX/2023 ATR Fail 2023/XX/XX: N/A; 2023/XX/XX: Rebuttal comment
Match - ATR not match Due Diligence Loan Designation of ATR Fail. loan to waterfall through the QM Testing. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Rate/Term Duplicative Exception under related finding
indicates client agrees with
2023/XX/XX: Duplicate finding. Finding remains
and/or waterfall open.
exception
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649208507 XXX XXX 1 29376150 compliance 3 General Ability To Repay Ability-to-Repay (Dodd-Frank 2014): Unable to verify current Partnership status The file is missing third party verification and the 2017 Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 5/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: 2023/XX/XX: Rebuttal comment
Provision Employment - due to missing Tax Return/Transcript for the most recent year, and one of these year to date P&L statement, causing the loan to waterfall damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Rate/Term 2014/2015/2016 indicates client agrees with
Partnership Test docs is required yet missing: Audited/Third Party P&L, CPA Letter, or other through the QM Testing. all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure business tax returns finding. Finding remains
Third Party Verification. (XXX XXX/Partnership) to comply is not material). A private right of action may be brought before the end of the three- for Partnership in open.
year period beginning on the date of the occurrence of the violation. However, when a creditor, file under
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial Miscellaneous Bus Tax 2023/XX/XX: No supporting
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter Returns. 2016 P&L thru trailing documentation was
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set- 12/XX/2016 provided. provided to clear this
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages Age of Documentation exception. Exception remains.
for a valid claim brought in an original action, plus the costs to the consumer of the action. If Checklist in file
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set- shows date of P&L as
off shall not exceed three years of finance charges and fees. An action to enforce a violation may 12/2016. Agree with
also be brought by the appropriate state AGs. finding that no
updated YTD P&L for
2017 in file.
2023/XX/XX: Agree with
error, but don't agree
with ATR impact based
on overall file risk &
quality.
649208696 XXX XXX 1 29376257 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The property is located in a FEMA disaster area. Provide a 12/XX/2016 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes ATR Fail 2023/XX/XX: PDI provided,
most recent valuation Disaster End Date: XX/XX/XXXX post-disaster inspection verifying there was no damage. The Cash-out - exception cleared.
inspection is dated prior Disaster Name: XXX inspection must include exterior photos and the property Home
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX must be re-inspected on or after XX/XX/XXXX declared end Improvement
disaster. date.
649208696 XXX XXX 1 29376258 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Acknowledgement of Appraisal receipt by borrower 3 business 12/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. days prior Consummation required. Cash-out -
Business Days Prior to (Type:Primary/12/XX/2016) Home
Consummation Improvement
649208696 XXX XXX 1 29376259 compliance 3 Check Loan Designation Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does The loan was approved under the Green Loan program which Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 12/XX/2016 CA Refinance - Primary No C C B B 7/XX/2023 ATR Fail 2023/XX/XX: Green 2023/XX/XX: File is missing a
Match - ATR not match Due Diligence Loan Designation of ATR Fail. allows verification of income in the form of two years tax firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - Loan, Income Calc for year to date balance sheet
transcripts which were provided. However, this does not Home borrower Sch C for the borrowers business
meet ATR requirements and resulted in a calculated Due Improvement business based on which is required under the
Diligence Loan Designation of ATR Fail. transcripts for Green Loan program guides. In
2014/2015 and there is addition, the file is missing
a signed dated P%L additional supporting income
through 10/XX/2016 to documentation which may not
support historical be required per the guides,
income. Borrower is a however is testing to QM/ATR
XXX and does not carry standards.
inventory and a
Balance Sheet would 2023/XX/XX: Trailing docs did
not be required. Note not contain any docs to clear
VOE uploaded does this exception.
verify the borrower
information, being a 2023/XX/XX: Reviewed trailing
XXX that files income documentation. Documents
under their name on a necessary to clear the
Schedule C would be conditions were not provided.
difficult to verify an Exception remains.
active business. SS
income based on
transcripts under
Green Loan
requirements.
2023/XX/XX: Provided
2014/15 IRS tax
transcripts provided
by 3rd party, along
with 2016 YTD P&L.
Agree with error for
VOE. Note: loan was
qualified using Green
Loan guidelines using
RLU-NA section 503,
which is a low-doc
loan program and tax
transcripts can be
utilized to validate
income. Additionally,
UB guidelines (RLU-NA
section 302-2.1.3)
state YTD Balance
Sheets are not
required for Schedule
C businesses unless
the business carries
an inventory.
649208696 XXX XXX 1 29376260 compliance 3 General Ability To Repay Ability-to-Repay (Dodd-Frank 2014): Unable to verify current Sole Proprietorship File is missing a year to date signed/dated P&L/Balance Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 12/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/XX: Green 2023/XX/XX: Upload did not
Provision Employment - status using reasonably reliable third-party records. (XXX XXX/Schedule C) sheet and third party verification dated within 21 days damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of Cash-out - Loan, Income Calc for contain a year to date
Schedule C Test prior to note date verifying dates of operation, good all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure Home borrower Sch C signed/dated P&L/Balance
standing and active at closing. to comply is not material). A private right of action may be brought before the end of the three- Improvement business based on sheet and third party
year period beginning on the date of the occurrence of the violation. However, when a creditor, transcripts for verification dated within 21
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial 2014/2015 and there is days prior to note date
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter a signed dated P%L verifying dates of operation,
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set- through 10/XX/2016 to good standing and active at
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages support historical closing. Unable to clear.
for a valid claim brought in an original action, plus the costs to the consumer of the action. If income. Borrower is a
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set- XXX and does not carry 2023/XX/XX: Upload did not
off shall not exceed three years of finance charges and fees. An action to enforce a violation may inventory and a contain fully executed
also be brought by the appropriate state AGs. Balance Sheet would Balance Sheet third party
not be required. Note verification dated within 21
VOE uploaded does days prior to note date
verify the borrower verifying dates of operation,
information, being a good standing and active at
XXX that files income closing or a Social Security
under their name on a Awards letter, and asset
Schedule C would be documentation to verify
difficult to verify an receipt.
active business. SS
income based on 2023/XX/XX: File is missing a
transcripts under year to date balance sheet
Green Loan for the borrowers business
requirements. which is required under the
Green Loan program guides. In
2023/XX/XX: Provided addition, the file is missing
2014/15 IRS tax additional supporting income
transcripts provided documentation which may not
by 3rd party, along be required per the guides,
with 2016 YTD P&L. however is testing to QM/ATR
Agree with error for standards.
VOE. Note: loan was
qualified using Green 2023/XX/XX: Trailing docs did
Loan guidelines, which not contain any docs to clear
is a low-doc loan this exception.
program and tax
transcripts can be 2023/XX/XX: Unable to clear
utilized to validate due to missing third party
income. Additionally, verification as is required.
note: difference of Condition remains.
guideline/ATR
interpretation as UB 2023/XX/XX: Reviewed trailing
guidelines did not documentation. Documents
require YTD Balance necessary to clear the
Sheet for Schedule C conditions were not provided.
borrowers when a sole Exception remains.
prop business does not
carry inventory.
2023/XX/XX: Provided
2014/15 IRS tax
transcripts provided
by 3rd party, along
with 2016 YTD P&L.
Agree with error for
VOE. Note: loan was
qualified using Green
Loan guidelines using
RLU-NA section 503,
which is a low-doc
loan program and tax
transcripts can be
utilized to validate
income. Additionally,
UB guidelines (RLU-NA
section 302-2.1.3)
state YTD Balance
Sheets are not
required for Schedule
C businesses unless
the business carries
an inventory.
649208696 XXX XXX 1 29376262 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, The file was missing evidence the CHARM Booklet was provided TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2016 12/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 ATR Fail 2023/XX/XX: Missing CHARM
Status CHARM Booklet, not provided to the borrower. to borrower within 3 days of initial application. Cash-out - Booklet provided within 3
Home days of application.
Improvement
649208696 XXX XXX 1 29376263 compliance 1 Income/Asset Guideline Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to File is missing all supporting documentation for the 12/XX/2016 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Fail 2023/XX/XX: Green 2023/XX/XX: File is missing a
Deficiency - ATR Impact income and/or asset doc requirements which could result in a risk to the borrower's Sch C business. Signed/dated Year to date Cash-out - Loan, Income Calc for year to date balance sheet
borrower's ability to repay. (Exception is eligible to be regraded with P&L/Balance sheet and third party verification dated within Home borrower Sch C for the borrowers business
compensating factors.) 21 days of the note date verifying dates of operation, good Improvement business based on which is required under the
standing and active at closing. transcripts for Green Loan program guides. In
2014/2015 and there is addition, the file is missing
a signed dated P%L additional supporting income
through 10/XX/2016 to documentation which may not
support historical be required per the guides,
income. Borrower is a however is testing to QM/ATR
XXX and does not carry standards.
inventory and a
Balance Sheet would 2023/XX/XX: Trailing docs did
not be required. Note not contain any docs to clear
VOE uploaded does this exception.
verify the borrower
information, being a 2023/XX/XX: Per lender
XXX that files income rebuttal, loan is a green
under their name on a loan transaction. Condition
Schedule C would be cleared.
difficult to verify an
active business. SS
income based on
transcripts under
Green Loan
requirements.
2023/XX/XX: Provided
2014/15 IRS tax
transcripts provided
by 3rd party, along
with 2016 YTD P&L.
Agree with error for
VOE. Note: loan was
qualified using Green
Loan guidelines, which
is a low-doc loan
program and tax
transcripts can be
utilized to validate
income. Additionally,
note: difference of
guideline/ATR
interpretation as UB
did not require YTD
Balance Sheet for
Schedule C borrowers
when business does not
carry inventory.
2023/XX/XX: Provided
2014/15 IRS tax
transcripts provided
by 3rd party, along
with 2016 YTD P&L.
Agree with error for
VOE. Note: loan was
qualified using Green
Loan guidelines using
RLU-NA section 503,
which is a low-doc
loan program and tax
transcripts can be
utilized to validate
income. Additionally,
UB guidelines (RLU-NA
section 302-2.1.3)
state YTD Balance
Sheets are not
required for Schedule
C businesses unless
the business carries
an inventory.
649208696 XXX XXX 1 29376264 credit 1 Income documentation File is missing all supporting documentation for the 12/XX/2016 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Fail 2023/XX/XX: Green 2023/XX/XX: File is missing a
requirements not met. borrower's Sch C business. Signed/dated Year to date Cash-out - Loan, Income Calc for year to date balance sheet
P&L/Balance sheet and third party verification dated within Home borrower Sch C for the borrowers business
21 days of the note date verifying dates of operation, good Improvement business based on which is required under the
standing and active at closing. transcripts for Green Loan program guides. In
2014/2015 and there is addition, the file is missing
a signed dated P%L additional supporting income
through 10/XX/2016 to documentation which may not
support historical be required per the guides,
income. Borrower is a however is testing to QM/ATR
XXX and does not carry standards.
inventory and a
Balance Sheet would 2023/XX/XX: Trailing docs did
not be required. Note not contain any docs to clear
VOE uploaded does this exception.
verify the borrower
information, being a 2023/XX/XX: Per lender
XXX that files income rebuttal, loan is a green
under their name on a loan transaction. Condition
Schedule C would be cleared.
difficult to verify an
active business. SS
income based on
transcripts under
Green Loan
requirements.
2023/XX/XX: Provided
2014/15 IRS tax
transcripts provided
by 3rd party, along
with 2016 YTD P&L.
Agree with error for
VOE. Note: loan was
qualified using Green
Loan guidelines, which
is a low-doc loan
program and tax
transcripts can be
utilized to validate
income. Additionally,
note: difference of
guideline/ATR
interpretation as UB
did not require YTD
Balance Sheet for
Schedule C borrowers
when business does not
carry inventory.
2023/XX/XX: Provided
2014/15 IRS tax
transcripts provided
by 3rd party, along
with 2016 YTD P&L.
Agree with error for
VOE. Note: loan was
qualified using Green
Loan guidelines using
RLU-NA section 503,
which is a low-doc
loan program and tax
transcripts can be
utilized to validate
income. Additionally,
UB guidelines (RLU-NA
section 302-2.1.3)
state YTD Balance
Sheets are not
required for Schedule
C businesses unless
the business carries
an inventory.
649208696 XXX XXX 1 29376265 credit 1 Income Docs Missing: Borrower: XXX Account Statements, Award Letter / Continuance Letter File is missing the award letter for borrower's social 12/XX/2016 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Fail 2023/XX/XX: Trailing docs did
security and asset statements to support current receipt. Cash-out - not contain any docs to clear
Home this exception.
Improvement
2023/XX/XX: Not required per
guides.
649208696 XXX XXX 1 29376266 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Failure due to missing income documentation. 12/XX/2016 CA Refinance - Primary No A A A A 7/XX/2023 9/XX/2023 Yes ATR Fail 2023/XX/XX: Green 2023/XX/XX: Upload did not
Provision Investor guideline components, the loan is at ATR risk. Cash-out - Loan, Income Calc for contain a year to date
Guidelines Home borrower Sch C signed/dated P&L/Balance
Improvement business based on sheet and third party
transcripts for verification dated within 21
2014/2015 and there is days prior to note date
a signed dated P%L verifying dates of operation,
through 10/XX/2016 to good standing and active at
support historical closing or a Social Security
income. Borrower is a Awards letter, and asset
XXX and does not carry documentation to verify
inventory and a receipt. Sch C for borrower's
Balance Sheet would sole proprietor income also
not be required. Note missing.
VOE uploaded does
verify the borrower 2023/XX/XX: Upload did not
information, being a contain fully executed
XXX that files income Balance Sheet third party
under their name on a verification dated within 21
Schedule C would be days prior to note date
difficult to verify an verifying dates of operation,
active business. SS good standing and active at
income based on closing or a Social Security
transcripts under Awards letter, and asset
Green Loan documentation to verify
requirements. receipt.
2023/XX/XX: Provided 2023/XX/XX: File is missing a
2014/15 IRS tax year to date balance sheet
transcripts provided for the borrowers business
by 3rd party, along which is required under the
with 2016 YTD P&L. Green Loan program guides. In
Agree with error for addition, the file is missing
VOE. Note: loan was additional supporting income
qualified using Green documentation which may not
Loan guidelines, which be required per the guides,
is a low-doc loan however is testing to QM/ATR
program and tax standards.
transcripts can be
utilized to validate 2023/XX/XX: Trailing docs did
income. Additionally, not contain any docs to clear
note: difference of this exception.
guideline/ATR
interpretation as UB 2023/XX/XX: Received required
guidelines did not documentation. Condition
require YTD Balance cleared.
Sheet for Schedule C
borrowers when a sole
prop business does not
carry inventory.
2023/XX/XX: Provided
2014/15 IRS tax
transcripts provided
by 3rd party, along
with 2016 YTD P&L.
Agree with error for
VOE. Note: loan was
qualified using Green
Loan guidelines using
RLU-NA section 503,
which is a low-doc
loan program and tax
transcripts can be
utilized to validate
income. Additionally,
UB guidelines (RLU-NA
section 302-2.1.3)
state YTD Balance
Sheets are not
required for Schedule
C businesses unless
the business carries
an inventory.
649207748 XXX XXX 2 29376267 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Post close disaster end date XX/XX/XXXX. 4/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: PDI provided,
most recent valuation Disaster End Date: XX/XX/XXXX Rate/Term exception cleared.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207748 XXX XXX 2 29376268 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement E-sign Consent Agreement is missing in file 4/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
is missing. Rate/Term
649207748 XXX XXX 2 29376269 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Evidence of receipt of appraisal within 3 days of 4/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. consummation not provided. Rate/Term
Business Days Prior to (Type:Primary/04/XX/2017)
Consummation
649207748 XXX XXX 2 29376270 credit 3 Refi Purpose reflects Cash to Borrower: $XXX; Total Cash Out: $XXX; Refi Purpose: Rate/Term As per 1008 refi purpose is rate/term but as per final CD 4/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Rate/Term and cash out cash to borrower is $XXX. Rate/Term
greater than the lesser
of 2% of the loan amount
or $XXX.
649207748 XXX XXX 2 29376271 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2017 4/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Timing CHARM Booklet, not provided to the borrower within three (3) days of application. Rate/Term
649206797 XXX XXX 2 29376324 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement Copy of e-sign agreement document is not available in file. 7/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
is missing. Rate/Term
649206797 XXX XXX 2 29376325 property 3 Missing Document: Valuation Type: Appraisal / Valuation Report Date: 06/XX/2017 442 was not provided. 7/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Appraisal was made Rate/Term
"subject to" and Form
1004D/442 was not
provided.
649206797 XXX XXX 2 29376326 compliance 2 Self-Employed Tax Return Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or The business or personal tax returns provided are not the 7/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Recency - ATR personal tax returns provided are not the most recent. Application Date most recent. Application Date 05/XX/2017, Most Recent Tax Rate/Term
05/XX/2017, Most Recent Tax Return End Date 12/XX/2015, Tax Return Due Date Return End Date 12/XX/2015, Tax Return Due Date 04/XX/2017
04/XX/2017. (XXX XXX/Schedule C)
649206797 XXX XXX 2 29376327 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Zero percent fee tolerance exceeded. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 7/XX/2017 7/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Tolerance Violation Appraisal Re-Inspection Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Rate/Term
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (75103)
Provided
649206797 XXX XXX 2 29376328 credit 3 Refi Purpose reflects Cash to Borrower: ; Total Cash Out: $XXX; Refi Purpose: Rate/Term Borrower received total cash out of $XXX, which is greater 7/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Rate/Term and cash out than the lessor of $XXX or 2% of the loan amount. Rate/Term
greater than the lesser
of 2% of the loan amount
or $XXX.
649206797 XXX XXX 2 29376329 credit 3 Aged document: Asset Financial Institution: XXX // Account Type: 401(k)/403(b) Account / Account 7/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Account date is more than Number: XXX Rate/Term
90 days prior to Closing.
649208298 XXX XXX 2 29376350 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Evidence the Appraisal was provided to the Borrower three 11/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. days prior to closing is missing. Cash-out -
Business Days Prior to (Type:Primary/10/XX/2018) Other
Consummation
649208298 XXX XXX 2 29376352 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement E sign agreement was not in the file. 11/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
is missing. Cash-out -
Other
649207513 XXX XXX 1 29376357 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement 6/XX/2020 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
is missing. Cash-out -
Other
649207513 XXX XXX 1 29376358 compliance 2 General Ability To Repay Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender The Qualification Method used by the lender does not match 6/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Provision Investor does not match the ATR payment calculation methods under 1026.43(c)(5). the ATR payment calculation methods Cash-out -
Qualification Method not Other
Matching ATR
649207513 XXX XXX 1 29376359 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Homeownership Counseling is missing RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 6/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
of Homeownership Organizations not provided to applicant within three (3) business days of implementing regulation, Regulation X, for these type of violations. Cash-out -
Counseling Organizations application. Other
Not Provided Within 3
Business Days of
Application
649207513 XXX XXX 1 29376361 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2020 6/XX/2021 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Test borrower within three (3) days of application. Cash-out -
Other
649207513 XXX XXX 1 29376362 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet Disclosure is missing TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2020 6/XX/2021 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649207513 XXX XXX 1 29376363 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy Verification appraisal was delivered to borrower was not There is generally no Assignee Liability. 6/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided at of the appraisal at least three (3) business days prior to closing, and appraisal provided. Cash-out -
or Before Closing (3-Day was not provided at or before closing. (Type:Primary/04/XX/2020) Other
Waiver In File)
649207513 XXX XXX 1 29376364 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Credit report fee increased from $XXX to $XXX without a TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 6/XX/2020 6/XX/2021 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Tolerance Violation Report Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no valid change of circumstance. Cash-out -
Without Sufficient Cure cure was provided to the borrower. (7520) Other
Provided
649207462 XXX XXX 2 29376435 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Subject property was appraised on XX/XX/XXXX prior to the 11/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: PDI provided,
most recent valuation Disaster End Date: XX/XX/XXXX FEMA disaster (XXX) dated XX/XX/XXXX through XX/XX/XXXX. Rate/Term exception cleared.
inspection is dated prior Disaster Name: XXX File is missing a property inspection dated after the
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX disaster, or the lender's Rep and Warranty attestation along
disaster. with visible confirmation that the subject property was not
damaged.
649207462 XXX XXX 2 29376436 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each 11/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. Rate/Term
Business Days Prior to (Type:Primary/10/XX/2019)
Consummation
649207462 XXX XXX 2 29376437 compliance 2 General Ability To Repay Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender 11/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Provision Investor does not match the ATR payment calculation methods under 1026.43(c)(5). Rate/Term
Qualification Method not
Matching ATR
649207462 XXX XXX 2 29376438 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 11/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Account Statement Missing implementing regulation, Regulation X, for these type of violations. Rate/Term
649207462 XXX XXX 2 29376439 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2019 11/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Test borrower within three (3) days of application. Rate/Term
649207875 XXX XXX 1 29376491 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement E-sign Consent Agreement is missing. 9/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
is missing. Cash-out -
Home
Improvement
649207875 XXX XXX 1 29376492 credit 3 Insufficient Coverage: Hazard Insurance Coverage Amount is insufficient. 9/XX/2018 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Hazard insurance coverage Cash-out -
amount is insufficient. Home
Improvement
649207875 XXX XXX 1 29376493 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Consumer Handbook on Adjustable Rate Mortgages, CHARM TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2018 9/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower. Booklet is not reflecting in file. Cash-out -
Home
Improvement
649207875 XXX XXX 1 29376494 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy Creditor did not provide a copy of each valuation to There is generally no Assignee Liability. 9/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided at of the appraisal at least three (3) business days prior to closing, and appraisal applicant three (3) business days prior to consumption Cash-out -
or Before Closing (3-Day was not provided at or before closing. (Type:Primary/08/XX/2018) Home
Waiver In File) Improvement
649207875 XXX XXX 1 29376496 compliance 2 Self-Employed Tax Return Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or Most recent tax returns document is missing in file. 9/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Recency - ATR personal tax returns provided are not the most recent. Application Date Cash-out -
07/XX/2018, Most Recent Tax Return End Date 12/XX/2016, Tax Return Due Date Home
04/XX/2018. (XXX XXX/C-Corp 1120) Improvement
649207875 XXX XXX 1 29376497 compliance 2 Self-Employed Tax Return Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or Most recent tax returns document is missing in file. 9/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Recency - ATR personal tax returns provided are not the most recent. Application Date Cash-out -
07/XX/2018, Most Recent Tax Return End Date 12/XX/2016, Tax Return Due Date Home
03/XX/2018. (XXX XXX/S-Corp) Improvement
649207875 XXX XXX 1 29376498 compliance 2 Self-Employed Tax Return Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or Most recent tax returns document is missing in file. 9/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Recency - ATR personal tax returns provided are not the most recent. Application Date Cash-out -
07/XX/2018, Most Recent Tax Return End Date 12/XX/2016, Tax Return Due Date Home
03/XX/2018. (XXX XXX/Partnership) Improvement
649207978 XXX XXX 2 29376614 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX 5/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes ATR Risk 2023/XX/XX: BPO provided. No
most recent valuation Disaster End Date: XX/XX/XXXX Cash-out - damage noted. Cleared.
inspection is dated prior Disaster Name: XXX Other
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207978 XXX XXX 2 29376615 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement E-sign consent agreement is missing 5/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 ATR Risk
is missing. Cash-out -
Other
649207978 XXX XXX 2 29376616 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each 5/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. Cash-out -
Business Days Prior to (Type:Primary/03/XX/2017) Other
Consummation
649207978 XXX XXX 2 29376617 compliance 2 General Ability To Repay Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender 10/1 ARM qualified at Note rate per guidelines. 5/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Provision Investor does not match the ATR payment calculation methods under 1026.43(c)(5). Cash-out -
Qualification Method not Other
Matching ATR
649207978 XXX XXX 2 29376618 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 5/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
of Homeownership Homeownership Counseling Organizations to borrower. implementing regulation, Regulation X, for these type of violations. Cash-out -
Counseling Organizations Other
Missing
649207978 XXX XXX 2 29376620 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2017 5/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 ATR Risk
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649207978 XXX XXX 2 29376621 compliance 3 Check Loan Designation Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 5/XX/2017 CA Refinance - Primary No C C B B 7/XX/2023 ATR Risk 2023/XX/XX: Agree 2023/XX/XX: Per lenders final
Match - ATR Risk not match Due Diligence Loan Designation of ATR Risk. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - 1003, loan was approved with
Other 2023/XX/XX: Disagree. a 44.871% DTI. Condition
Final 1003/08 provided remains.
show that final
qualifying DTI was 2023/XX/XX: Received updated
36.121% dated 1008, however it appears the
4/XX/2017. DTI >44% is lender did not include the
from previous/earlier REO liabilities in the DTI.
reviews but was not Condition remains.
final approved DTI.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649207978 XXX XXX 2 29376622 credit 1 REO Documents are Address: XXX, TN Statement 5/XX/2017 CA Refinance - Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Risk 2023/XX/XX: property 2023/XX/XX: Credit report
missing. Cash-out - identified as an used for P&I payment.
Other apartment Condition cleared.
complex/commercial
property - used 1040
for expenses, loss
includedi n ratios
649207978 XXX XXX 2 29376623 credit 3 Guideline Requirement: Calculated investor qualifying total debt ratio of 44.69592% exceeds Guideline Loan was approved at 44.7% exceeding 44% maximum DTI. 5/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/XX: Max DTI 2023/XX/XX: Per lenders final
Investor qualifying total total debt ratio of 44.00000%. Cash-out - for program is 43%, 1003, loan was approved with
debt ratio discrepancy. Other Uwer calcuated DTI at a 44.871% DTI. Condition
40.870% remains.
2023/XX/XX: Disagree. 2023/XX/XX: Received updated
Final 1003/08 provided 1008, however it appears the
show that final lender did not include the
qualifying DTI was REO liabilities in the DTI.
36.121% dated Condition remains.
4/XX/2017. DTI >44% is
from previous/earlier 2023/XX/XX: Reviewed trailing
reviews but was not documentation. Documents
final approved DTI. necessary to clear the
conditions were not provided.
Exception remains.
649207978 XXX XXX 2 29376624 compliance 3 General ATR Provision Ability to Repay (Dodd-Frank 2014): The DTIs calculated in accordance with the 5/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/XX: Agree 2023/XX/XX: Per lenders final
Investor and Non QM DTIs Lenders Guidelines of 44.69592% and based on 1026.43(c)(5) of 48.85% moderately Cash-out - 1003, loan was approved with
don't match and both exceed the guideline maximum of 44.00%. (DTI Exception is eligible to be regraded Other 2023/XX/XX: Disagree. a 44.871% DTI. Condition
moderately exceed with compensating factors.) Final 1003/08 provided remains.
Guidelines show that final
qualifying DTI was 2023/XX/XX: Received updated
36.121% dated 1008, however it appears the
4/XX/2017. DTI >44% is lender did not include the
from previous/earlier REO liabilities in the DTI.
reviews but was not Condition remains.
final approved DTI.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649207978 XXX XXX 2 29376625 compliance 3 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Waterfall due to DTI. 5/XX/2017 CA Refinance - Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/XX: Agree 2023/XX/XX: Per lenders final
Provision Investor guideline components, the loan is at ATR risk. Cash-out - 1003, loan was approved with
Guidelines Other 2023/XX/XX: Disagree. a 44.871% DTI. Condition
Final 1003/08 provided remains.
show that final
qualifying DTI was 2023/XX/XX: Received updated
36.121% dated 1008, however it appears the
4/XX/2017. DTI >44% is lender did not include the
from previous/earlier REO liabilities in the DTI.
reviews but was not Condition remains.
final approved DTI.
2023/XX/XX: Reviewed trailing
documentation. Documents
necessary to clear the
conditions were not provided.
Exception remains.
649206864 XXX XXX 1 29376633 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Latest inspection is after latest FEMA Disaster declaration. 6/XX/2019 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: BPO provided. No
most recent valuation Disaster End Date: XX/XX/XXXX Cash-out - damage noted. Cleared.
inspection is dated prior Disaster Name: XXX Home
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX Improvement
disaster.
649206864 XXX XXX 1 29376634 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Evidence of Receipt of Initial Closing Disclosure 3 days TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 6/XX/2019 6/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure Timing without at least three (3) business days prior to closing. (Initial/06/XX/2019) prior to closing is not in file. Cash-out -
Waiver Home
Improvement
649206864 XXX XXX 1 29376635 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the The disclosure was signed at closing. Evidence the TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2019 6/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Test borrower within three (3) days of application. disclosure was provided to the Borrower within three days of Cash-out -
application is missing. Home
Improvement
649206864 XXX XXX 1 29376636 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Disclosure is not in file. TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2019 6/XX/2020 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower. Cash-out -
Home
Improvement
649206864 XXX XXX 1 29376637 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement E-Sign Consent Agreement is missing in file. 6/XX/2019 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
is missing. Cash-out -
Home
Improvement
649206864 XXX XXX 1 29376638 compliance 2 Missing Document: Missing Signed Initial 1003 is not in file. 6/XX/2019 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Lender's Initial 1003 Cash-out -
Home
Improvement
649208222 XXX XXX 1 29376656 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Verification appraisal was delivered to borrower was not 12/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. provided. Rate/Term
Business Days Prior to (Type:Primary/11/XX/2015)
Consummation
649208222 XXX XXX 1 29376657 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2015 12/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 Non QM 2023/XX/XX: Missing CHARM
Status CHARM Booklet, not provided to the borrower. Rate/Term Booklet provided within 3
days of application.
649208222 XXX XXX 1 29376658 compliance 2 Incorrect Right To Cancel Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Right to Cancel was issued on incorrect form. TILA ROR - TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing 12/XX/2015 12/XX/2018 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Form Used - H-9 Used on Model Form for a refinance by a creditor that is not considered the original Provide the following: Letter of Explanation, Proof of risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses Rate/Term
Non Same Lender Refinance creditor. The H-9 form was used, the H-8 form should have been used. Delivery, and Re-open Rescission using the correct model the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that
form. H-8 Form must be used as lender is not the same as creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for
originating lender. refinances involving the same creditor.
649208222 XXX XXX 1 29376659 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX 12/XX/2015 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: BPO provided. No
most recent valuation Disaster End Date: XX/XX/XXXX Rate/Term damage noted. Cleared.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649209140 XXX XXX 1 29376696 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Subject property was appraised on XX/XX/XXXX prior to the 9/XX/2016 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: BPO provided. No
most recent valuation Disaster End Date: XX/XX/XXXX FEMA disaster (XXX) dated XX/XX/XXXX through XX/XX/XXXX. damage noted. Cleared.
inspection is dated prior Disaster Name: XXX File is missing a property inspection dated after the
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX disaster, or the lender's Rep and Warranty attestation along
disaster. with visible confirmation that the subject property was not
damaged.
649209140 XXX XXX 1 29376697 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement was not provided to the borrower. The final CD reflects some HOI will be escrowed, but an RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 9/XX/2016 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Account Statement Missing initial escrow account statement is missing. implementing regulation, Regulation X, for these type of violations.
649209140 XXX XXX 1 29376698 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower. TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2016 9/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower.
649207294 XXX XXX 1 29376774 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA disaster area. 12/XX/2015 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: BPO provided. No
most recent valuation Disaster End Date: XX/XX/XXXX Lender to provide Post Disaster Property Inspection Report. Rate/Term damage noted. Cleared.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207294 XXX XXX 1 29376775 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Evidence that borrower received copy of appraisal within 3 12/XX/2015 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. business days of closing not provided. Rate/Term
Business Days Prior to (Type:Primary/10/XX/2015)
Consummation
649207294 XXX XXX 1 29376776 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the Evince ARM Disclosure was provided to the borrower within TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2015 12/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Test borrower within three (3) days of application. three 3 days of application not provide. Lender to provide. Rate/Term
649207294 XXX XXX 1 29376777 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Lender to provide evidence CHARM Booklet was provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2015 12/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower. borrower within three 3 days of application. Rate/Term
649207479 XXX XXX 2 29376837 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX The property is located in FEMA Disaster area. Provide a 6/XX/2016 CA Purchase Investment No A A A A 7/XX/2023 6/XX/2023 Yes N/A 2023/XX/XX: BPO provided. No
most recent valuation Disaster End Date: XX/XX/XXXX post-disaster inspection verifying there was no damage. The damage noted. Cleared.
inspection is dated prior Disaster Name: XXX inspection must include exterior photos and the property
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX must be re-inspected on or after XX/XX/XXXX declared end
disaster. date.
649207479 XXX XXX 2 29376838 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Verification appraisal was delivered to borrower was not 6/XX/2016 CA Purchase Investment No B B B B 7/XX/2023 N/A
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. provided.
Business Days Prior to (Type:Primary/04/XX/2016)
Consummation
649207479 XXX XXX 2 29376839 credit 3 Guideline Requirement: Calculated loan to value percentage of 75.00000% exceeds Guideline loan to value loan to value percentage of 75.00000% exceeds Guideline loan 6/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
Loan to value percentage of 65.00000%. to value percentage of 65.00000%.
discrepancy.
649207479 XXX XXX 2 29376840 credit 3 Guideline Requirement: Calculated investor qualifying total debt ratio of 57.77389% exceeds Guideline Qualifying total debt ratio of 57.77389% exceeds Guideline 6/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 N/A
Investor qualifying total total debt ratio of 45.00000%. total debt ratio of 45.00000%
debt ratio discrepancy.
649207609 XXX XXX 1 29376922 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX 5/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: BPO provided. No
most recent valuation Disaster End Date: XX/XX/XXXX damage noted. Cleared.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207609 XXX XXX 1 29376923 credit 3 Insufficient Coverage: Coverage Amount is insufficient. A replacement cost 5/XX/2019 CA Purchase Primary No C C C C 7/XX/2023 Non QM
Hazard insurance coverage estimator was not provided. There is a shortfall in the
amount is insufficient. amount of $XXX.
649207609 XXX XXX 1 29376924 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement E-sign Consent Agreement is missing in file. 5/XX/2019 CA Purchase Primary No C C C C 7/XX/2023 Non QM
is missing.
649207609 XXX XXX 1 29376925 credit 3 Missing Document: Missing Final 1003 is missing from file. 5/XX/2019 CA Purchase Primary No C C C C 7/XX/2023 Non QM
Final 1003
649207609 XXX XXX 1 29376926 credit 1 Missing Document: Credit Credit report is missing from file. 5/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received credit
Report not provided report. Condition cleared.
649207609 XXX XXX 1 29376927 credit 3 Missing Document: Flood Flood Certificate is missing from file. 5/XX/2019 CA Purchase Primary No C C C C 7/XX/2023 Non QM
Certificate not provided
649207609 XXX XXX 1 29376928 credit 3 Missing Document: Occupancy certificate is missing from file. 5/XX/2019 CA Purchase Primary No C C C C 7/XX/2023 Non QM
Occupancy Certificate not
provided
649207609 XXX XXX 1 29376929 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy Borrower waived right to receive a copy of the appraisal at There is generally no Assignee Liability. 5/XX/2019 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided at of the appraisal at least three (3) business days prior to closing, and appraisal least three business days prior to closing.
or Before Closing (3-Day was not provided at or before closing. (Type:Primary/04/XX/2019)
Waiver In File)
649207609 XXX XXX 1 29376930 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy Borrower waived right to receive a copy of the appraisal at There is generally no Assignee Liability. 5/XX/2019 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided at of the appraisal at least three (3) business days prior to closing, and appraisal least three business days prior to closing,
or Before Closing (3-Day was not provided at or before closing. (Type:Secondary/04/XX/2019)
Waiver In File)
649207609 XXX XXX 1 29376931 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 5/XX/2019 CA Purchase Primary No B B B B 7/XX/2023 Non QM
649207609 XXX XXX 1 29376932 compliance 1 Check Loan Designation Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does A credit report is missing which resulted in a Due Diligence Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 5/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received credit
Match - ATR not match Due Diligence Loan Designation of ATR Fail. Loan Designation of ATR Fail. firm performing the loan level due diligence and to have the TPR firm confirm said designation. report. Condition cleared.
649207609 XXX XXX 1 29376933 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Unable to verify debt obligations using A credit report is missing. Assignee Liability: Violations can result in regular TILA damages (actual damages, statutory 5/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: Received credit
Provision Credit History reasonably reliable third-party records. damages of up to $XXX costs, and attorney's fees) and enhanced damages (an amount equal to the sum of report. Condition cleared.
all finance charges and fees paid by the consumer, unless the creditor demonstrates that the failure
to comply is not material). A private right of action may be brought before the end of the three-
year period beginning on the date of the occurrence of the violation. However, when a creditor,
assignee, or other holder or anyone acting on their behalf initiates a judicial or non-judicial
foreclosure, or any other action to collect the debt, a consumer may assert a violation as a matter
of defense by recoupment or set-off without regard to a time limit. The amount of recoupment or set-
off shall equal the amount to which the consumer would be entitled as regular and/or enhanced damages
for a valid claim brought in an original action, plus the costs to the consumer of the action. If
judgment is rendered after the expiration of the three-year period, the amount of recoupment or set-
off shall not exceed three years of finance charges and fees. An action to enforce a violation may
also be brought by the appropriate state AGs.
649207609 XXX XXX 1 29376935 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Creditor did not provide List of Homeownership Counseling RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 5/XX/2019 CA Purchase Primary No B B B B 7/XX/2023 Non QM
of Homeownership Homeownership Counseling Organizations to borrower. Organizations to borrower. implementing regulation, Regulation X, for these type of violations.
Counseling Organizations
Missing
649207609 XXX XXX 1 29376936 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure not provided to Borrower(s) at least TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2019 5/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Disclosure Timing without at least three (3) business days prior to closing. (Initial/04/XX/2019) three (3) business days prior to closing.
Waiver
649207609 XXX XXX 1 29376937 compliance 2 TRID Interim Closing TILA-RESPA Integrated Disclosure - Corrected Closing Disclosure provided on or Corrected Closing Disclosure was not received by borrower at TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2019 5/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Disclosure Timing after 05/XX/2019 contains a change in loan product and was not received by least three business days prior to consummation
Irregular Transactions borrower at least three (3) business days prior to consummation
Test
649207609 XXX XXX 1 29376939 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM loan program disclosure not provided to the borrower. TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2019 5/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Test borrower.
649207609 XXX XXX 1 29376940 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Consumer Handbook on Adjustable Rate Mortgages, CHARM TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2019 5/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower. Booklet is missing in file.
649207829 XXX XXX 2 29377120 credit 1 FEMA Disaster Issue: The Most Recent Valuation Inspection Date: XX/XX/XXXX Latest inspection is prior to latest FEMA disaster 4/XX/2016 CA Refinance - Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/XX: BPO provided does
most recent valuation Disaster End Date: XX/XX/XXXX declaration. Rate/Term not reflect damage.
inspection is dated prior Disaster Name: XXX
to the most recent FEMA Disaster Declaration Date: XX/XX/XXXX
disaster.
649207829 XXX XXX 2 29377121 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Evidence of appraisal delivery 3 days prior to closing is 4/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. not in file. Rate/Term
Business Days Prior to (Type:Primary/03/XX/2016)
Consummation
649207829 XXX XXX 2 29377122 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Evidence of appraisal delivery 3 days prior to closing is 4/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. not in file. Rate/Term
Business Days Prior to (Type:Primary/03/XX/2016)
Consummation
649207829 XXX XXX 2 29377123 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Disclosure is not in file. TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2016 4/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Status CHARM Booklet, not provided to the borrower. Rate/Term
649207829 XXX XXX 2 29377124 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing Adjustable Interest Rate Table: Final Closing Disclosure TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2016 4/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure AIR Table Disclosure provided on 04/XX/2016 disclosed a Subsequent Changes frequency that provided on 04/XX/2016 disclosed a Subsequent Changes Rate/Term
Subsequent Change does not match the actual subsequent change frequency for the loan. frequency that does not match the actual subsequent change
Frequency (Final/04/XX/2016) frequency for the loan.
649207829 XXX XXX 2 29377125 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Evidence of receipt of Initial Closing Disclosure 3 days TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2016 4/XX/2017 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Disclosure Timing without at least three (3) business days prior to closing. (Final/04/XX/2016) prior to closing is not in file. Rate/Term
Waiver
649207829 XXX XXX 2 29377126 compliance 2 Missing Document: Missing Signed Initial 1003 is not in file. 4/XX/2016 CA Refinance - Primary No B B B B 7/XX/2023 Non QM
Lender's Initial 1003 Rate/Term
649207829 XXX XXX 2 29377127 credit 3 Aged document: Asset Financial Institution: XXX // Account Type: Stocks / Account Number: XXX, All bank statements exceed the 90 day age of document limit. 4/XX/2016 CA Refinance - Primary No C C C C 7/XX/2023 Non QM
Account date is more than Financial Institution: XXX // Account Type: Mutual Funds / Account Number: XXX, Please provide an updated consecutive bank statement for all Rate/Term
90 days prior to Closing. Financial Institution: XXX // Account Type: Individual Retirement Account (IRA) / accounts.
Account Number: XXX, Financial Institution: XXX // Account Type: Individual
Retirement Account (IRA) / Account Number: XXX, Financial Institution: XXX //
Account Type: Mutual Funds / Account Number: XXX, Financial Institution: XXX //
Account Type: Mutual Funds / Account Number: xxxx, Financial Institution: XXX //
Account Type: Mutual Funds / Account Number: XXX, Financial Institution: XXX //
Account Type: Mutual Funds / Account Number: XXX, Financial Institution: XXX //
Account Type: Mutual Funds / Account Number: XXX
649207202 XXX XXX 1 30672402 compliance 1 TRID Revised Loan TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on 11/XX/2022 Proof of earlier receipt was not provided. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 11/XX/2022 11/XX/2023 WA Refinance - Primary No A A A A 7/XX/2023 Yes Exempt from 2023/XX/17: LE issued 2023/XX/19: LE was received
Estimate Timing Before not received by borrower at least four (4) business days prior to closing. Cash-out - ATR on 11/XX was reviewed timely by borrower.
Closing (Interim/11/XX/2022) Other on 11/XX. LE uploaded
649207202 XXX XXX 1 30672403 credit 2 The Hazard Insurance Hazard Insurance Policy Effective Date 12/XX/2022; Disbursement Date: 11/XX/2022; 11/XX/2022 WA Refinance - Primary No B B B B Exempt from 2023/XX/XX: HOI 2023/XX/XX: Term dates were
Policy effective date is Note Date: 11/XX/2022; Transaction Date: 11/XX/2022 Cash-out - ATR showing coverage prior not located within the policy
after the funds Other to disbursement date provided. Exception remains
disbursed. open.
2023/XX/XX: Please
review new doc 2023/XX/XX: Trailing document
uploaded showing received does not have a
policy period 12/2021 policy effective date or
to 12/2022 loan closed policy expiration date.
11/2022 Exception remains.
2023/XX/XX: Policy 2023/XX/XX: Client
attached. acknowledges exception and
elects to regrade.
2023/XX/XX: policy
shows effective
between 12/2021-
12/2022
649208749 XXX XXX 2 31520391 compliance 2 New York Late Charge New York Late Charge: Note late charge percent of 5.00000% exceeds the state Note late charge percent of 5.00000% exceeds the state 2/XX/2020 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Percent Testing maximum of 2%. maximum of 2% Rate/Term SHQM
(GSE/Agency
Eligible)
649208749 XXX XXX 2 31520392 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Zero percent tolerance fee exceeded for Transfer Tax Fee. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 2/XX/2020 2/XX/2021 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Tolerance Violation Transfer Tax. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no Fee was last disclosed as $XXX on LE but disclosed as $XXX Rate/Term SHQM
Without Sufficient Cure cure was provided to the borrower. (8304) on Final Closing Disclosure. The file does not contain a (GSE/Agency
Provided valid COC for this fee, nor a cure. Eligible)
649207624 XXX XXX 1 31495681 compliance 2 Self-Employed Tax Return General QM: Self Employed Tax Returns - The business or personal tax returns 4868 Tax return Extension for is available in the file- 8/XX/2022 CO Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Recency - QM provided are not the most recent. Application Date 07/XX/2022, Most Recent Tax please override QM (APOR)
Return End Date 12/XX/2020, Tax Return Due Date 04/XX/2022. (XXX XXX/Schedule C)
649207624 XXX XXX 1 31495682 compliance 2 Self-Employed Tax Return General QM: Self Employed Tax Returns - The business or personal tax returns 4868 Tax return Extension for is available in the file 8/XX/2022 CO Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Recency - QM provided are not the most recent. Application Date 07/XX/2022, Most Recent Tax QM (APOR)
Return End Date 12/XX/2020, Tax Return Due Date 04/XX/2022. (XXX XXX/Schedule C)
649207561 XXX XXX 2 31454214 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure The disclosed Amount Financed in the amount of $XXX is over TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 12/XX/2022 12/XX/2023 TX Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Disclosure Amount provided on 12/XX/2022 disclosed an Amount Financed disclosed an inaccurate disclosed by $XXX compared to the calculated Amount Financed Assignee liability. QM (APOR)
Financed Test Amount Financed. The disclosed Amount Financed in the amount of $XXX is over of $XXX and the disclosed Finance Charge is not accurate
disclosed by $XXX compared to the calculated Amount Financed of $XXX and the within applicable tolerances for Amount Financed to be
disclosed Finance Charge is not accurate within applicable tolerances for Amount considered accurate (fee amounts included in Amount Financed
Financed to be considered accurate (fee amounts included in Amount Financed and and Finance Charge calculations are based on Closing
Finance Charge calculations are based on Closing Disclosure dated 12/XX/2022). Disclosure dated 12/XX/2022). (Final/12/XX/2022)
(Final/12/XX/2022)
649207561 XXX XXX 2 31454215 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure The disclosed Finance Charge in the amount of $XXX is under TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 12/XX/2022 12/XX/2023 TX Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Disclosure Finance Charge provided on 12/XX/2022 disclosed an inaccurate Finance Charge on page 5 that does disclosed by $XXX compared to the calculated Finance Charge Assignee liability. QM (APOR)
not match the actual Finance Charge for the loan. The disclosed Finance Charge of $XXX which exceeds the $XXX threshold (fee amounts
in the amount of $XXX is under disclosed by $XXX compared to the calculated included in Finance Charge calculation are based on Closing
Finance Charge of $XXX which exceeds the $XXX threshold (fee amounts included in Disclosure dated 12/XX/2022). (Final/12/XX/2022)
Finance Charge calculation are based on Closing Disclosure dated 12/XX/2022).
(Final/12/XX/2022)
649207561 XXX XXX 2 31454217 compliance 2 TRID Ten Percent TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Recording fee was increased on 08/XX/2022 Loan Estimate and 12/XX/2022 12/XX/2023 TX Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no again on 12/XX/2022 CD with no valid change evident. QM (APOR)
Without Sufficient Cure cure was provided to the borrower. (0)
Provided
649207561 XXX XXX 2 31454219 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Valid cure document or Change of circumstance not provided. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2022 12/XX/2023 TX Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or QM (APOR)
Without Sufficient Cure no cure was provided to the borrower. (7200)
Provided
649207561 XXX XXX 2 31454220 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Valid cure document or Change of circumstance not provided. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2022 12/XX/2023 TX Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Certificate Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or QM (APOR)
Without Sufficient Cure no cure was provided to the borrower. (77159)
Provided
649207561 XXX XXX 2 31467969 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each 12/XX/2022 TX Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. QM (APOR)
Business Days Prior to (Type:Primary/12/XX/2022)
Consummation
649206830 XXX XXX 2 31458628 credit 3 Missing Document: Fraud 10/XX/2019 MA Purchase Primary Yes C C C C 8/XX/2024 Temporary
Report not provided SHQM
(GSE/Agency
Eligible)
649206830 XXX XXX 2 31458888 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy There is generally no Assignee Liability. 10/XX/2019 MA Purchase Primary Yes B B B B 8/XX/2024 Temporary
Appraisal Not Provided at of the appraisal at least three (3) business days prior to closing, and appraisal SHQM
or Before Closing (3-Day was not provided at or before closing. (Type:Primary/04/XX/2019) (GSE/Agency
Waiver In File) Eligible)
649206830 XXX XXX 2 31458891 compliance 2 TRID Ten Percent TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Ten Percent Fee Tolerance of $XXX exceeds tolerance allowed 10/XX/2019 10/XX/2020 MA Purchase Primary Yes B B B B 8/XX/2024 Temporary
Tolerance Violation amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no of $XXX plus 10%. No valid change of circumstance nor cure SHQM
Without Sufficient Cure cure was provided to the borrower. (0) was provided to the borrower. (GSE/Agency
Provided Eligible)
649207019 XXX XXX 1 31521349 credit 3 Missing verification of Borrower: XXX // Employment Type: Employment / Income Type: Sole Proprietor / File is missing third party verification of self employment 12/XX/2021 NY Refinance - Primary No C C C C 8/XX/2024 Safe Harbor
the existance of self- Start Date: 01/XX/2016, Borrower: XXX // Employment Type: Employment / Income for Uber. Rate/Term QM (APOR)
employed business within Type: Sole Proprietor / Start Date: 01/XX/2016 Application Date: 10/XX/2021;
20 days of the Note Date Application Date: 10/XX/2021;
(COVID-19).
649207390 XXX XXX 1 31464980 compliance 2 TRID Lender Credit TILA-RESPA Integrated Disclosure:Zero Percent Fee Tolerance exceeded for Lender Fee disclosed was last disclosed as -$XXX on LE but TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 1/XX/2022 1/XX/2023 NJ Refinance - Primary Yes B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Credits. Final Lender Credit of $XXX exceeds tolerance of -$XXX. Insufficient or disclosed as $XXX on Final Closing Disclosure. File does Rate/Term QM (APOR)
Without Sufficient Cure no cure was provided to the borrower. (9300) not contain a valid COC for this fee, cure provided at
Provided closing.
649207390 XXX XXX 1 31464981 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Fee was not disclosed on Loan Estimate. File does not TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 1/XX/2022 1/XX/2023 NJ Refinance - Primary Yes B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or contain a valid COC for this fee, nor evidence of cure .. Rate/Term QM (APOR)
Without Sufficient Cure no cure was provided to the borrower. (7200)
Provided
649207390 XXX XXX 1 31464982 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Fee was not disclosed on Loan Estimate. File does not TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 1/XX/2022 1/XX/2023 NJ Refinance - Primary Yes B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Appraisal Re-Inspection Fee. Fee Amount of $XXX exceeds tolerance of $XXX. contain a valid COC for this fee, nor evidence of cure .. Rate/Term QM (APOR)
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (75103)
Provided
649207390 XXX XXX 1 31464983 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Fee was not disclosed on Loan Estimate. File does not TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 1/XX/2022 1/XX/2023 NJ Refinance - Primary Yes B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Subordination Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient contain a valid COC for this fee, nor evidence of cure .. Rate/Term QM (APOR)
Without Sufficient Cure or no cure was provided to the borrower. (7559)
Provided
649207390 XXX XXX 1 31464997 credit 3 Missing Document: Hazard Hazard Insurance Policy document not provided. 1/XX/2022 NJ Refinance - Primary Yes C C C C 8/XX/2024 Safe Harbor
Insurance Policy not Rate/Term QM (APOR)
provided
649206976 XXX XXX 1 31465576 credit 3 Missing Document: Fraud Fraud report is missing in the file. 9/XX/2021 CA Purchase Primary No C C C C 8/XX/2024 Temporary
Report not provided SHQM
(GSE/Agency
Eligible)
649206976 XXX XXX 1 31465654 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Dated Appraisal delivery receipt is not provided. 9/XX/2021 CA Purchase Primary No B B B B 8/XX/2024 Temporary
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. SHQM
Business Days Prior to (Type:Primary/09/XX/2021) (GSE/Agency
Consummation Eligible)
649206976 XXX XXX 1 31465655 compliance 2 TRID Final Closing TRID Final Closing Disclosure 09/XX/2021 on a first lien purchase transaction did No seller paid fees under closing disclosure. 9/XX/2021 9/XX/2022 CA Purchase Primary No B B B B 8/XX/2024 Temporary
Disclosure No Seller Paid not disclose any Seller paid fees/charges on page 2. (Points and Fees testing SHQM
Fees Primary Residence limited to Borrower paid fees.) (Final/09/XX/2021) (GSE/Agency
First Lien Eligible)
649206976 XXX XXX 1 31465657 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Zero Percent Fee Tolerance exceeded for Loan Discount TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2021 9/XX/2022 CA Purchase Primary No B B B B 8/XX/2024 Temporary
Tolerance Violation Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or Points. Fee Amount of $XXX exceeds tolerance of $XXX. No SHQM
Without Sufficient Cure no cure was provided to the borrower. (7200) cure was provided to the borrower. (GSE/Agency
Provided Eligible)
649206976 XXX XXX 1 31465658 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Zero Percent Fee Tolerance exceeded for Appraisal Management TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2021 9/XX/2022 CA Purchase Primary No B B B B 8/XX/2024 Temporary
Tolerance Violation Appraisal Management Company (Appraisal Review). Fee Amount of $XXX exceeds Company (Appraisal Review). Fee Amount of $XXX exceeds SHQM
Without Sufficient Cure tolerance of $XXX. Insufficient or no cure was provided to the borrower. (7358) tolerance of $XXX. No cure was provided to the borrower. (GSE/Agency
Provided Eligible)
649206976 XXX XXX 1 31465659 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Zero Percent Fee Tolerance exceeded for Transfer Tax. Fee TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2021 9/XX/2022 CA Purchase Primary No B B B B 8/XX/2024 Temporary
Tolerance Violation Transfer Tax. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no Amount of $XXX exceeds tolerance of $XXX. No cure was SHQM
Without Sufficient Cure cure was provided to the borrower. (8304) provided to the borrower. (GSE/Agency
Provided Eligible)
649206976 XXX XXX 1 XXX compliance 1 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Temporary Waterfall due to Analysis of Rental income requirement not Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 9/XX/2021 CA Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Temporary 2024/XX/XX: 9/5- 2024/XX/XX: EXCEPTION HISTORY
Match - QM SHQM (GSE/Agency Eligible) does not match Due Diligence Loan Designation of Fails met. Borrower is renting departure residence and market firm performing the loan level due diligence and to have the TPR firm confirm said designation. SHQM Appeal: Loan was - Exception Detail was
Temporary (GSE) QM Testing. analysis of the property value was not provided to determine (GSE/Agency approved DU, Fannie updated on 09/XX/2024 PRIOR
if LTV based on current balance was less than 75%. Eligible) guidelines at Exception Detail: Qualified
origination did not Mortgage (Dodd-Frank 2014):
require market Originator Loan Designation
analysis of departing of Temporary SHQM (GSE/Agency
residence and deposit Eligible) does not match Due
check. Note date Diligence Loan Designation of
9/XX/2021. XXX ATR Risk.
2024/XX/XX: While application
date is prior to March 1,
2021 (with settlement after
8/XX/21), the loan falls into
the permissible Temp QM
timeline (GSE Patch) and also
meets the Revised General QM
Rule for SHQM (APOR) to be
eligible for GSE purchase.
Loan Designation has been set
to Temp SHQM (GSE/Agency
Eligible).
649206976 XXX XXX 1 31517043 compliance 1 Rental Income Vacating Qualified Mortgage (Dodd-Frank 2014): Analysis of Rental income requirement not Investment income is being used from the Borrower's 9/XX/2021 CA Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Temporary 2024/XX/XX: 9/5-Refer 2024/XX/XX: Exception
Primary met. Borrower's current address matches the REO property address. (XXX/25% departing residence without documentation supporting at SHQM to appeal in Exception cleared.
Vacancy Method) least 75% equity and a copy of the security deposit check. (GSE/Agency ID #XXX
Eligible)
649206976 XXX XXX 1 31517044 compliance 1 Income/Asset Guideline Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to Investment income is being used from the Borrower's 9/XX/2021 CA Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Temporary 2024/XX/XX: 9/5-Refer 2024/XX/XX: Exception
Deficiency - ATR Impact income and/or asset doc requirements which could result in a risk to the departing residence without documentation supporting at SHQM to appeal in Exception cleared.
borrower's ability to repay. (Exception is eligible to be regraded with least 75% equity and a copy of the security deposit check. (GSE/Agency ID #XXX
compensating factors.) Eligible)
649206976 XXX XXX 1 31517045 compliance 1 QM DTI Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and Investment income is being used from the Borrower's Although this issue is subject to a 3 year SOL for affirmative claims under TILA, AMC does not adjust 9/XX/2021 CA Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Temporary 2024/XX/XX: 9/5-Refer 2024/XX/XX: While application
the images do not provide evidence loan is eligible for purchase, guarantee or departing residence without documentation supporting at grading taking into account TILA SOL for exceptions under ATR, given the potential for enhanced SHQM to appeal in Exception date is prior to March 1,
insurance by the appropriate agency. least 75% equity and a copy of the security deposit check. damages when asserting an ability to repay defense in response to an action to collect a debt by (GSE/Agency ID #XXX 2021 (with settlement after
recoupment or set-off. Eligible) 8/XX/21), the loan falls into
the permissible Temp QM
timeline (GSE Patch) and also
meets the Revised General QM
Rule for SHQM (APOR) to be
eligible for GSE
purchase.Loan Designation has
been
set to Temp SHQM
(GSE/Agency Eligible).
649206976 XXX XXX 1 31517051 credit 1 Income documentation Investment income is being used from the Borrower's 9/XX/2021 CA Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Temporary 2024/XX/XX: Exception
requirements not met. departing residence without documentation supporting at SHQM cleared.
least 75% equity and a copy of the security deposit check. (GSE/Agency
Eligible)
649206976 XXX XXX 1 31517078 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Investment income is being used from the Borrower's 9/XX/2021 CA Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Temporary 2024/XX/XX: 9/5-Refer 2024/XX/XX: Exception
Provision Investor guideline components, the loan is at ATR risk. departing residence without documentation supporting at SHQM to appeal in Exception cleared.
Guidelines least 75% equity and a copy of the security deposit check. (GSE/Agency ID #XXX
Eligible)
649206976 XXX XXX 1 31611870 compliance 1 Not Eligible to be GSE Qualified Mortgage: Loan is not eligible for Temp QM status under GSE 9/XX/2021 CA Purchase Primary No A A A A 9/XX/2024 9/XX/2024 Yes Temporary 2024/XX/XX: While application
Temporary QM requirements (application date is on or after 7/XX/21 or loan was SHQM date is prior to March 1,
purchased/securitized after 8/XX/21). (GSE/Agency 2021 (with settlement after
Eligible) 8/XX/21), the loan falls into
the permissible Temp QM
timeline (GSE Patch) and also
meets the Revised General QM
Rule for SHQM (APOR) to be
eligible for GSE purchase.
649208536 XXX XXX 1 31473375 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of List of Homeownership Counseling Organizations was not RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 1/XX/2022 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor
of Homeownership Homeownership Counseling Organizations to borrower. provided to borrower. implementing regulation, Regulation X, for these type of violations. QM (APOR)
Counseling Organizations
Missing
649208536 XXX XXX 1 31473376 compliance 2 TRID Ten Percent TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Ten Percent Fee Tolerance exceeded. Total amount of $XXX 1/XX/2022 1/XX/2023 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no exceeds tolerance of $XXX plus 10% or $XXX. Vartance due to QM (APOR)
Without Sufficient Cure cure was provided to the borrower. (0) increase in Recording Fee. No valid changed circumstance was
Provided provided. No cure was provided to the Borrower.
649208536 XXX XXX 1 31473434 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Survey Zero Percent Fee Tolerance exceeded for Survey Fee. Fee TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 1/XX/2022 1/XX/2023 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no cure was Amount of $XXX exceeds tolerance of $XXX. No valid changed QM (APOR)
Without Sufficient Cure provided to the borrower. (75174) circumstance was provided. No cure was provided to the
Provided Borrower.
649207221 XXX XXX 2 31469799 credit 3 REO Documents are Address: XXX, WA HOA Verification, Insurance Verification, Statement, Tax 10/XX/2021 WA Refinance - Primary No C C C C 8/XX/2024 Safe Harbor
missing. Verification Cash-out - QM (APOR)
Other
649207221 XXX XXX 2 31469866 credit 3 1003/Declarations: D. 1. Borrower: XXX 10/XX/2021 WA Refinance - Primary No C C C C 8/XX/2024 Safe Harbor
Have you or will you be Cash-out - QM (APOR)
applying for a mortgage Other
loan on another property
(not the property
securing this loan) on or
before closing this
transaction that is not
disclosed on this loan
application? was entered
Yes. Unable to determine
qualification without
this information.
649207221 XXX XXX 2 31469873 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each 10/XX/2021 WA Refinance - Primary No B B B B 8/XX/2024 Safe Harbor
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. Cash-out - QM (APOR)
Business Days Prior to (Type:Primary/10/XX/2021) Other
Consummation
649207221 XXX XXX 2 31469885 credit 3 Tax Return end date is Borrower: XXX // Employment Type: Employment / Income Type: Sole Proprietor / 10/XX/2021 WA Refinance - Primary No C C C C 8/XX/2024 Safe Harbor
more than 90 days prior Start Date: 01/XX/2019 Note Date: 10/XX/2021; Cash-out - QM (APOR)
to note date. P&L was Calendar End Date: 12/XX/2020; Other
not found in file. (GSE
COVID-19)
649207221 XXX XXX 2 31515155 compliance 1 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Loan designation mismatch due to COVID overlay Guidelines Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 10/XX/2021 WA Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: 9/XX/24 - 2024/XX/XX: Exception
Match - QM QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Risk. regarding missing 2021 YTD P&L. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - QM (APOR) Appeal: see page 335 D cleared.
Other 0201 of the file in
Clarity the P&L
Statement for
2021{ellipsis}XXx
649207221 XXX XXX 2 31515156 compliance 1 Income/Asset Guideline General QM: There are guideline deficiencies related to income and/or asset doc File is missing 2021 YTD P&L required by the COVID overlays 10/XX/2021 WA Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: 9/XX/24 - 2024/XX/XX: Exception
Deficiency - QM Impact requirements which could result in a risk to the borrower's ability to repay. Guidelines. Cash-out - QM (APOR) Appeal: see page 335 D cleared.
(Exception is eligible to be regraded with compensating factors.) Other 0201 of the file in
Clarity the P&L
Statement for
2021{ellipsis}XXx
649207221 XXX XXX 2 31515158 credit 1 Income documentation File is missing 2021 YTD P&L required by the COVID overlays 10/XX/2021 WA Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Exception
requirements not met. Guidelines. Cash-out - QM (APOR) cleared.
Other
649207221 XXX XXX 2 31515160 compliance 1 General QM Provision General QM: Based on the loan failing one or more guideline components, the loan File is missing 2021 YTD P&L required by the COVID overlays 10/XX/2021 WA Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: 9/XX/24 - 2024/XX/XX: Exception
Investor Guidelines is at QM risk. Guidelines. Cash-out - QM (APOR) Appeal: see page 335 D cleared.
Violation Other 0201 of the file in
Clarity the P&L
Statement for
2021{ellipsis}XXX
649207140 XXX XXX 1 31465693 credit 1 Income Docs Missing: Borrower: XXX, Borrower: XXX VA Verification of Benefits VA benefit income was used to qualify for borrower 1 and 9/XX/2021 CA Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Temporary 2024/XX/XX: Exception
Award Letter / Continuance Letter file is missing VA Letter or Distribution form. SHQM cleared. Income documentation
(GSE/Agency has been provided.
Eligible)
649207140 XXX XXX 1 31465730 credit 3 Missing Document: Fraud 9/XX/2021 CA Purchase Primary No C C C C 8/XX/2024 Temporary
Report not provided SHQM
(GSE/Agency
Eligible)
649207140 XXX XXX 1 XXX compliance 1 Retirement Documentation Qualified Mortgage (Dodd-Frank 2014): Retirement income documentation VA benefit income was used to qualify for borrower 1 and 9/XX/2021 CA Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Temporary 2024/XX/XX: Appeal: 2024/XX/XX: While application
insufficient. (XXX XXX/Pension) file is missing VA Letter or Distribution form. SHQM Attached please find date is prior to March 1,
(GSE/Agency the borrower XXX 2021 (with settlement after
Eligible) Letter confirming 8/XX/21), the loan falls into
monthly income of $XXX the permissible Temp QM
per month. timeline (GSE Patch) and also
meets the Revised General QM
2024/XX/XX: VA letter Rule for SHQM (APOR) to be
eligible for GSE purchase.
649207140 XXX XXX 1 31465996 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 9/XX/2021 CA Purchase Primary No B B B B 8/XX/2024 Temporary
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three (3) business days prior to consummation. SHQM
Business Days Prior to (Type:Primary/09/XX/2021) (GSE/Agency
Consummation Eligible)
649207140 XXX XXX 1 31465997 compliance 1 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Temporary VA benefit income was used to qualify for borrower 1 and Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 9/XX/2021 CA Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Temporary 2024/XX/XX: XXX has 2024/XX/XX: Loan is Temp SHQM
Match - QM SHQM (GSE/Agency Eligible) does not match Due Diligence Loan Designation of ATR file is missing VA Letter or Distribution form, causing a firm performing the loan level due diligence and to have the TPR firm confirm said designation. SHQM uploaded the VA income (GSE/Agency Eligible.
Risk. Loan Designation discrepancy. (GSE/Agency information under
Eligible) exception ID XXX above
649207140 XXX XXX 1 31465998 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 9/XX/2021 CA Purchase Primary No B B B B 8/XX/2024 Temporary
of Homeownership Homeownership Counseling Organizations to borrower. implementing regulation, Regulation X, for these type of violations. SHQM
Counseling Organizations (GSE/Agency
Missing Eligible)
649207140 XXX XXX 1 31466001 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Loan Discount Point $XXX disclosed on the final Closing TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2021 9/XX/2022 CA Purchase Primary No B B B B 8/XX/2024 Temporary
Tolerance Violation Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or Disclosure was not disclosed on the Loan Estimate. No valid SHQM
Without Sufficient Cure no cure was provided to the borrower. (7200) COC in file and no cure provided at closing. (GSE/Agency
Provided Eligible)
649207140 XXX XXX 1 31466007 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax was disclosed Loan Estimate as $XXX and TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2021 9/XX/2022 CA Purchase Primary No B B B B 8/XX/2024 Temporary
Tolerance Violation Transfer Tax. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no increased to $XXX on the final Closing Disclosure. No valid SHQM
Without Sufficient Cure cure was provided to the borrower. (8304) COC in file and no cure provided at closing. (GSE/Agency
Provided Eligible)
649207140 XXX XXX 1 31466021 compliance 2 TRID Final Closing TRID Final Closing Disclosure 09/XX/2021 on a first lien purchase transaction did Final buyer's Closing Disclosure does not disclose any 9/XX/2021 9/XX/2022 CA Purchase Primary No B B B B 8/XX/2024 Temporary
Disclosure No Seller Paid not disclose any Seller paid fees/charges on page 2. (Points and Fees testing seller paid fees. SHQM
Fees Primary Residence limited to Borrower paid fees.) (Final/09/XX/2021) (GSE/Agency
First Lien Eligible)
649207140 XXX XXX 1 31466040 credit 3 AUS Findings: Property Appraisal property type of Single Family Detached does not match AUS property DU reflect property as a PUD and property type according to 9/XX/2021 CA Purchase Primary No C C C C 8/XX/2024 Temporary
type discrepancy. type of PUD. appraisal is a single family residence. SHQM
(GSE/Agency
Eligible)
649207140 XXX XXX 1 31515930 credit 1 Income documentation VA benefit income was used to qualify for borrower 1 and 9/XX/2021 CA Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Temporary 2024/XX/XX: Exception
requirements not met. file is missing VA Letter or Distribution form. SHQM cleared. Income documentation
(GSE/Agency has been provided.
Eligible)
649207140 XXX XXX 1 31515948 compliance 1 Income/Asset Guideline Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to VA benefit income was used to qualify for borrower 1 and 9/XX/2021 CA Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Temporary 2024/XX/XX: XXX has 2024/XX/XX: Exception
Deficiency - ATR Impact income and/or asset doc requirements which could result in a risk to the file is missing VA Letter or Distribution form. SHQM uploaded the VA income cleared. Income documentation
borrower's ability to repay. (Exception is eligible to be regraded with (GSE/Agency information under has been provided.
compensating factors.) Eligible) exception ID XXX above
649207140 XXX XXX 1 31516041 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more VA benefit income was used to qualify for borrower 1 and 9/XX/2021 CA Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Temporary 2024/XX/XX: XXX has 2024/XX/XX: Exception
Provision Investor guideline components, the loan is at ATR risk. file is missing VA Letter or Distribution form. SHQM uploaded the VA income cleared. Income documentation
Guidelines (GSE/Agency information under has been provided.
Eligible) exception ID XXX above
649207759 XXX XXX 2 31466665 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 6/XX/2022 NY Refinance - Investment No B B B B 8/XX/2024 N/A
Cash-out -
Other
649206807 XXX XXX 2 31464351 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to 5/XX/2021 PA Purchase Primary No B B B B 8/XX/2024 Temporary
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. applicant three (3) business days prior to consummation. SHQM
Business Days Prior to (Type:Primary/05/XX/2021) (GSE/Agency
Consummation Eligible)
649206807 XXX XXX 2 31464355 compliance 2 TRID Final Closing TRID Final Closing Disclosure 05/XX/2021 on a first lien purchase transaction did Final Closing Disclosure 05/XX/2021 on a first lien purchase 5/XX/2021 5/XX/2022 PA Purchase Primary No B B B B 8/XX/2024 Temporary
Disclosure No Seller Paid not disclose any Seller paid fees/charges on page 2. (Points and Fees testing transaction did not disclose any Seller paid fees/charges on SHQM
Fees Primary Residence limited to Borrower paid fees.) (Final/05/XX/2021) page 2 (GSE/Agency
First Lien Eligible)
649206807 XXX XXX 2 31516089 compliance 2 (Missing Data) Last Rate Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario 5/XX/2021 PA Purchase Primary No B B B B 8/XX/2024 Temporary
Set Date between Creditor Application Date and Transaction Date used to determine rate SHQM
used for testing. (GSE/Agency
Eligible)
649206995 XXX XXX 1 31497685 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Pest Pest Inspection Fee was last disclosed as $XXX on Loan TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2021 12/XX/2022 DE Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Inspection Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or Estimate but disclosed as $XXX on Final Closing Disclosure. QM (APOR)
Without Sufficient Cure no cure was provided to the borrower. (7713) File does not contain a valid change of circumstance for
Provided this fee, no cure provided.
649209197 XXX XXX 1 31469971 credit 3 Missing Document: Hazard 9/XX/2021 AZ Refinance - Second Home No C C C C 8/XX/2024 Safe Harbor
Insurance Policy not Cash-out - QM (APOR)
provided Other
649209197 XXX XXX 1 31470033 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 9/XX/2021 AZ Refinance - Second Home No B B B B 8/XX/2024 Safe Harbor
Cash-out - QM (APOR)
Other
649209197 XXX XXX 1 31473288 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Zero Percent Fee Tolerance exceeded for Loan Discount TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2021 9/XX/2022 AZ Refinance - Second Home No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or Points. Fee Amount of $XXX exceeds tolerance of $XXX. No Cash-out - QM (APOR)
Without Sufficient Cure no cure was provided to the borrower. (7200) valid changed circumstance was provided. No cure was Other
Provided provided to the Borrower.
649209197 XXX XXX 1 31474003 credit 3 Missing Valuation: Valuation Type: Appraisal / Valuation Report Date: <empty> Appraisal is missing 9/XX/2021 AZ Refinance - Second Home No C C C C 8/XX/2024 Safe Harbor
Cash-out - QM (APOR)
Other
649209197 XXX XXX 1 31474008 credit 3 AUS/Guideline Findings: The AUS required an Appraisal which is missing. 9/XX/2021 AZ Refinance - Second Home No C C C C 8/XX/2024 Safe Harbor
All conditions were not Cash-out - QM (APOR)
met Other
649209197 XXX XXX 1 31474025 credit 3 Missing Document: The AUS required an Appraisal which is missing. 9/XX/2021 AZ Refinance - Second Home No D D D D 8/XX/2024 Safe Harbor
Appraisal not provided Cash-out - QM (APOR)
Other
649208783 XXX XXX 2 31468812 compliance 1 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Loan designation discrepancy due to Points and Fees on Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 5/XX/2022 NC Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Non QM 2024/XX/XX: Wish to 2024/XX/XX: Designation has
Match - QM QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. subject loan is in excess of the allowable maximum. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - re-state lender been restated.
Other designation to NonQM.
649208783 XXX XXX 2 31468813 compliance 1 QM Points and Fees 2021 Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of 3.04726% Points and Fees on subject loan of 3.04726% is in excess of 5/XX/2022 NC Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Non QM 2024/XX/XX: Appeal: 2024/XX/XX: The compliance
is in excess of the allowable maximum of 3.00000% of the Federal Total Loan the allowable maximum of 3.00000% of the Federal Total Loan Cash-out - Per LAS bona fide report in file includes an
Amount. Points and Fees total $XXX on a Federal Total Loan Amount of $XXX vs. an Amount. Points and Fees total $XXX on a Federal Total Loan Other testing, which tested undiscounted rate of 5.625%
allowable total of $XXX (an overage of $XXX or .04726%). Amount of $XXX vs. an allowable total of $XXX using the lenders but is missing the
Compliance Ease undiscounted rate price.
Undiscounted Rate, Please provide the
provides for a .125% undiscounted rate price,
rate reduction. which is the amount of points
Please advise that the borrower would have
threshold used or why paid for the undiscounted
bona fide exclusion rate of 5.625%.
was not applied to QM
testing. 2024/XX/XX: Designation has
been restated.
649208783 XXX XXX 2 31468814 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Zero Percent Fee Tolerance exceeded for Loan Discount TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2022 5/XX/2023 NC Refinance - Primary No B B B B 8/XX/2024 Non QM
Tolerance Violation Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or Points. Fee Amount of $XXX exceeds tolerance of $XXX. No Cash-out -
Without Sufficient Cure no cure was provided to the borrower. (7200) valid changed circumstance was provided. No cure was Other
Provided provided to the Borrower.
649208783 XXX XXX 2 31663354 compliance 2 Check Restated Loan Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not Designation has been restated. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 5/XX/2022 NC Refinance - Primary No B B A A 9/XX/2024 Non QM
Designation Match - match. However, the updated Loan Designation of Non QM matches the Due Diligence firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out -
General Ability to Repay Loan Designation of Non QM. Other
649208210 XXX XXX 1 31468512 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Appraisal report dated 10/XX/2021 missing evidence of 11/XX/2021 NJ Purchase Primary Yes B B B B 8/XX/2024 Safe Harbor
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. receipt. QM (APOR)
Business Days Prior to (Type:Primary/10/XX/2021)
Consummation
649208210 XXX XXX 1 31468513 compliance 2 (Missing Data) Last Rate Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario 11/XX/2021 NJ Purchase Primary Yes B B B B 8/XX/2024 Safe Harbor
Set Date between Creditor Application Date and Transaction Date used to determine rate QM (APOR)
used for testing.
649208210 XXX XXX 1 31468563 credit 3 Missing Document: Fraud 11/XX/2021 NJ Purchase Primary Yes C C C C 8/XX/2024 Safe Harbor
Report not provided QM (APOR)
649207463 XXX XXX 2 31467176 compliance 1 QM Points and Fees 2021 Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of 3.90558% Points and Fees on subject loan of 3.90558 is in excess of 10/XX/2021 IL Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Non QM 2024/XX/XX: Please see 2024/XX/XX: The bona fide
is in excess of the allowable maximum of 3.00000% of the Federal Total Loan the allowable maximum of 3.00000% of the Federal Total Loan Rate/Term undiscounted rate on discount point exclusion
Amount. Points and Fees total $XXX on a Federal Total Loan Amount of $XXX vs. an Amount. Points and Fees total $XXX on a Federal Total Loan Mavent report in file looks like this:
allowable total of $XXX (an overage of $XXX or .90558%). Amount of $XXX vs an allowable total of $XXX, an overage of (D0113- page 4 of 25). Undiscounted Starting Rate -
$XXX or .90558%. Compliance Report in file reflect a Pass Rate reduction of > 3.625%
for Points and Fees. .125%. Please advise Note Rate - 3.125%
threshold used or why Loan Discounts (page 2 of CD)
excluded points were - 2.75%
not applied to QM Undiscounted Starting Rate
testing. Price - 0.125%
3.625 - 3.125 = 0.5
2.75 - 0.125 = 2.625
0.5 / 2.625 = 0.19 does not
meet deal setting of 0.25 to
be considered bona fide and
therefore excludable.
2024/XX/XX: Designation has
been restated.
649207463 XXX XXX 2 31467177 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Disclosures: Non Escrowed Property Costs Non- Escrowed Property Cost over Year 1 on Final Closing TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 10/XX/2021 10/XX/2022 IL Refinance - Primary No B B B B 8/XX/2024 Non QM
Disclosure Non Escrow over Year 1 of on Final Closing Disclosure provided on 10/XX/2021 are Disclosure provided on 10/XX/2021 are under disclosed. Rate/Term
Costs Year 1 underdisclosed. (Final/10/XX/2021)
Underdisclosed - October
2018
649207463 XXX XXX 2 31467179 compliance 1 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Originator Loan Designation of Safe Harbor QM (APOR) updated Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 10/XX/2021 IL Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Non QM 2024/XX/XX: Wish to 2024/XX/XX: Designation has
Match - QM QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. from guidelines. Loan DEIGNATION discrepancy due to Points firm performing the loan level due diligence and to have the TPR firm confirm said designation. Rate/Term re-state lender been restated.
and Fees over by .09558% designation to NonQM.
649207463 XXX XXX 2 31663343 compliance 2 Check Restated Loan Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did not Designation has been restated. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 10/XX/2021 IL Refinance - Primary No B B A A 9/XX/2024 Non QM
Designation Match - match. However, the updated Loan Designation of Non QM matches the Due Diligence firm performing the loan level due diligence and to have the TPR firm confirm said designation. Rate/Term
General Ability to Repay Loan Designation of Non QM.
649207968 XXX XXX 1 31492428 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re- Inspection Fee was last disclosed as $XXX on TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2021 12/XX/2022 FL Refinance - Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Appraisal Re-Inspection Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Loan Estimate but disclosed as $XXX on Final Closing Cash-out - QM (APOR)
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (75103) Disclosure. File does not contain a valid Change of Other
Provided circumstance for this fee, nor evidence of cure in file.
649207968 XXX XXX 1 31492429 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Review Fee was last disclosed as $XXX on Loan TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2021 12/XX/2022 FL Refinance - Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Appraisal Review Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Estimate but disclosed as $XXX on Final Closing Disclosure. Cash-out - QM (APOR)
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (75104) File does not contain a valid Change of circumstance for Other
Provided this fee, nor evidence of cure in file.
649207280 XXX XXX 1 31498808 compliance 2 (Missing Data) Last Rate Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario Rate lock date not provided. 10/XX/2021 WI Refinance - Primary No B B B B 8/XX/2024 Safe Harbor
Set Date between Creditor Application Date and Transaction Date used to determine rate Cash-out - QM (APOR)
used for testing. Other
649207280 XXX XXX 1 31498834 compliance 2 TRID Lender Credit TILA-RESPA Integrated Disclosure:Zero Percent Fee Tolerance exceeded for Lender Fee disclosed was last disclosed as $XXX on LE but TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 10/XX/2021 10/XX/2022 WI Refinance - Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Credits. Final Lender Credit of $XXX exceeds tolerance of -$XXX. Insufficient or disclosed as $XXX on Final Closing Disclosure. File does Cash-out - QM (APOR)
Without Sufficient Cure no cure was provided to the borrower. (9300) not contain a valid COC for this fee, cure provided at Other
Provided closing.
649207280 XXX XXX 1 31498836 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan The Loan Discount Point Fee was not disclosed on initial TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 10/XX/2021 10/XX/2022 WI Refinance - Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or Loan Estimate, but it appeared on the closing disclosure as Cash-out - QM (APOR)
Without Sufficient Cure no cure was provided to the borrower. (7200) $XXX. File does not contain a valid COC for this fee, nor Other
Provided evidence of cure.
649208731 XXX XXX 1 31452969 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 11/XX/2021 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor
QM (APOR)
649208731 XXX XXX 1 31452987 compliance 2 TRID Lender Credit TILA-RESPA Integrated Disclosure:Zero Percent Fee Tolerance exceeded for Lender Lender Credit disclosed as $XXX on LE dated 09/XX/2021, but TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 11/XX/2021 11/XX/2022 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Credits. Final Lender Credit of -$XXX exceeds tolerance of -$XXX. Insufficient disclosed as $XXX on Final Closing Disclosure. Insufficient QM (APOR)
Without Sufficient Cure or no cure was provided to the borrower. (9300) or no cure was provided to the borrower.
Provided
649208731 XXX XXX 1 31452988 compliance 2 TRID Ten Percent TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total $XXX violation due to increase in Recording Fees. 11/XX/2021 11/XX/2022 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no Insufficient or no cure was provided to the borrower. QM (APOR)
Without Sufficient Cure cure was provided to the borrower. (0)
Provided
649208731 XXX XXX 1 31452989 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax Fee disclosed as $XXX on LE dated 09/XX/2021, TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 11/XX/2021 11/XX/2022 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Transfer Tax. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no but disclosed as $XXX on Final Closing Disclosure. QM (APOR)
Without Sufficient Cure cure was provided to the borrower. (8304) Insufficient or no cure was provided to the borrower.
Provided
649208731 XXX XXX 1 31454458 compliance 2 TRID Closing Disclosure TILA-RESPA Integrated Disclosure: Closing Disclosure estimated to be provided on Closing Disclosure estimated to be provided on 09/XX/2021 TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 11/XX/2021 11/XX/2022 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Issue Date Not Provided 09/XX/2021 did not disclose the actual Date Issued. Unable to conclusively did not disclose the actual Date Issued. Unable to Assignee liability. QM (APOR)
determine Final Closing disclosure to use to test for compliance with applicable conclusively determine Final Closing disclosure to use to
TRID timing requirements, TRID fee tolerance testing or accuracy of disclosures test for compliance with applicable TRID timing
at or before consummation due to missing Issue Date. Tested using an estimated requirements, TRID fee tolerance testing or accuracy of
Date Issued based on best information available. (Interim/09/XX/2021) disclosures at or before consummation due to missing Issue
Date. Tested using an estimated Date Issued based on best
information available
649208731 XXX XXX 1 31454459 compliance 2 TRID Closing Disclosure TILA-RESPA Integrated Disclosure: Closing Disclosure estimated to be provided on Closing Disclosure estimated to be provided on 09/XX/2021 TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 11/XX/2021 11/XX/2022 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Issue Date Not Provided 09/XX/2021 did not disclose the actual Date Issued. Unable to conclusively did not disclose the actual Date Issued. Unable to Assignee liability. QM (APOR)
determine Final Closing disclosure to use to test for compliance with applicable conclusively determine Final Closing disclosure to use to
TRID timing requirements, TRID fee tolerance testing or accuracy of disclosures test for compliance with applicable TRID timing
at or before consummation due to missing Issue Date. Tested using an estimated requirements, TRID fee tolerance testing or accuracy of
Date Issued based on best information available. (Interim/09/XX/2021) disclosures at or before consummation due to missing Issue
Date. Tested using an estimated Date Issued based on best
information available
649208731 XXX XXX 1 31454460 compliance 2 TRID Closing Disclosure TILA-RESPA Integrated Disclosure: Closing Disclosure estimated to be provided on Closing Disclosure estimated to be provided on 09/XX/2021 TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 11/XX/2021 11/XX/2022 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Issue Date Not Provided 09/XX/2021 did not disclose the actual Date Issued. Unable to conclusively did not disclose the actual Date Issued. Unable to Assignee liability. QM (APOR)
determine Final Closing disclosure to use to test for compliance with applicable conclusively determine Final Closing disclosure to use to
TRID timing requirements, TRID fee tolerance testing or accuracy of disclosures test for compliance with applicable TRID timing
at or before consummation due to missing Issue Date. Tested using an estimated requirements, TRID fee tolerance testing or accuracy of
Date Issued based on best information available. (Interim/09/XX/2021) disclosures at or before consummation due to missing Issue
Date. Tested using an estimated Date Issued based on best
information available
649208731 XXX XXX 1 31454461 compliance 2 TRID Closing Disclosure TILA-RESPA Integrated Disclosure: Closing Disclosure estimated to be provided on Closing Disclosure estimated to be provided on 09/XX/2021 TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 11/XX/2021 11/XX/2022 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Issue Date Not Provided 09/XX/2021 did not disclose the actual Date Issued. Unable to conclusively did not disclose the actual Date Issued. Unable to Assignee liability. QM (APOR)
determine Final Closing disclosure to use to test for compliance with applicable conclusively determine Final Closing disclosure to use to
TRID timing requirements, TRID fee tolerance testing or accuracy of disclosures test for compliance with applicable TRID timing
at or before consummation due to missing Issue Date. Tested using an estimated requirements, TRID fee tolerance testing or accuracy of
Date Issued based on best information available. (Initial/09/XX/2021) disclosures at or before consummation due to missing Issue
Date. Tested using an estimated Date Issued based on best
information available
649208915 XXX XXX 2 31492069 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 10/XX/2021 WI Purchase Primary No B B B B 8/XX/2024 Safe Harbor
QM (APOR)
649208832 XXX XXX 2 31492201 compliance 2 (Missing Data) Last Rate Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario Rate Set Date is missing. 5/XX/2022 IL Purchase Primary No B B B B 8/XX/2024 HUD Safe
Set Date between Creditor Application Date and Transaction Date used to determine rate Harbor QM
used for testing.
649208832 XXX XXX 2 31492202 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re- Inspection Fee increased from $XXX to $XXX, an TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2022 5/XX/2023 IL Purchase Primary No B B B B 8/XX/2024 HUD Safe
Tolerance Violation Appraisal Re-Inspection Fee. Fee Amount of $XXX exceeds tolerance of $XXX. increase of $XXX, without a Changed Circumstance form in Harbor QM
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (75103) file. A cure of $XXX was provided.
Provided
649208832 XXX XXX 2 31492212 credit 2 Loan has been identified Mortgage Type: FHA Mortgage Type is FHA documentation in file 5/XX/2022 IL Purchase Primary No B B B B 8/XX/2024 HUD Safe
as FHA/VA/USDA Harbor QM
649207450 XXX XXX 2 31492519 credit 3 Missing Document: AUS not File is missing final AUS; final 1008 showing AUS approved 1/XX/2022 IL Refinance - Primary No C C C C 8/XX/2024 Safe Harbor
provided was used for review. Cash-out - QM (APOR)
Other
649207450 XXX XXX 2 31492521 credit 3 AUS/Guideline Findings: AUS is missing in file. 1/XX/2022 IL Refinance - Primary No C C C C 8/XX/2024 Safe Harbor
All conditions were not Cash-out - QM (APOR)
met Other
649207450 XXX XXX 2 31492535 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Zero percent tolerance Loan Discount Points Fee disclosed as TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 1/XX/2022 1/XX/2023 IL Refinance - Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or $XXX on Loan Estimate dated 10/XX/2021 but disclosed as $XXX Cash-out - QM (APOR)
Without Sufficient Cure no cure was provided to the borrower. (7200) on Final Closing Disclosure. A valid COC nor cure were not Other
Provided provided.
649208162 XXX XXX 2 31493081 credit 3 FHA MIP Error (Non- Date Issued: 03/XX/2022 Calculated FHA upfront premium of $XXX does not match 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor
Borrower Paid): the mortgage insurance premium collected on the Closing Disclosure of . QM (43-Q)
649208162 XXX XXX 2 31493083 credit 3 Real Estate Certification Disclosure: FHA - Real Estate Certification (Government Documents) 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor
is missing. QM (43-Q)
649208162 XXX XXX 2 31493085 credit 3 Lead Based Paint Disclosure: FHA - Lead Based Paint Attachment - Attached to Purchase Contract Lead Based Paint attachment not provided 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor
Attachment - Attached to (Government Documents) QM (43-Q)
Purchase Contract is
missing.
649208162 XXX XXX 2 31493088 credit 3 CAIVRS Authorization is Disclosure: CAIVRS Authorization (Government Documents) CAIVRS Authorization not provided 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor
missing. QM (43-Q)
649208162 XXX XXX 2 31493091 credit 2 Loan has been identified Mortgage Type: FHA 3/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor
as FHA/VA/USDA QM (43-Q)
649208162 XXX XXX 2 31493094 property 3 Missing Document: Valuation Type: Appraisal / Valuation Report Date: 02/XX/2022 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor
Appraisal was made QM (43-Q)
"subject to" and Form
1004D/442 was not
provided.
649208162 XXX XXX 2 31493099 compliance 2 Loan was originated as 3/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor
FHA insured and QM (43-Q)
compliance was evaluated
using the originally
intended loan type though
the loan is no longer FHA
insured
649208162 XXX XXX 2 31493133 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Acopy of each valuation to applicant three (3) business days 3/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. prior to consummation QM (43-Q)
Business Days Prior to (Type:Secondary/02/XX/2022)
Consummation
649208162 XXX XXX 2 31493134 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each A copy of each valuation to applicant three (3) business 3/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. days prior to consummation QM (43-Q)
Business Days Prior to (Client:5228/01/XX/2022)
Consummation
649208162 XXX XXX 2 31493135 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. ACTA Credit Score Disclosure not provided There is no Assignee Liability. 3/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor
QM (43-Q)
649208162 XXX XXX 2 31493136 compliance 2 RESPA Disclosure - List RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of List of Homeownership Counseling Organizations to borrower RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor
of Homeownership Homeownership Counseling Organizations to borrower. not provided implementing regulation, Regulation X, for these type of violations. QM (43-Q)
Counseling Organizations
Missing
649208162 XXX XXX 2 31493137 compliance 2 Ohio Consumer Sales Ohio Consumer Sales Practices Act: Acknowledgement of Receipt of Home Mortgage Acknowledgement of Receipt of Home Mortgage Loan Information The Consumer Sales Practices Act (CSPA) generally does not provide for assignee liability. The Act 3/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Practices Act Loan Information Document not retained by lender. Document not provided provides that no claim or defense may be asserted under the Act by the Attorney General or any QM (43-Q)
(Acknowledgement of consumer against a purchaser or assignee of a mortgage loan for value for any action under the
Receipt of Home Mortgage statute unless: (a) the violation was committed by the purchaser or assignee; or (b) the assignee or
Loan Information Document purchaser is affiliated by common control with the seller of the loan at the time the loan was
Not Retained by Lender) purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant injunctions, and levy monetary
fines. Additionally, the CSPA provides borrowers with a private right of action. Therefore, it is
possible that any action commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law as part of the
private right of action, a court could reform the loan terms which could impact purchasers.
Therefore, if the seller cannot be compelled to repurchase the loan, the assignee could face
exposure.
649208162 XXX XXX 2 31493138 compliance 2 Ohio Consumer Sales Ohio Consumer Sales Practices Act: Borrower not provided Right Not To Close Right Not To Close Disclosure not provided "The Consumer Sales Practices Act (CSPA) generally does not provide for assignee liability. The Act 3/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Practices Act (Right Not Disclosure. provides that no claim or defense may be asserted under the Act by the Attorney General or any QM (43-Q)
To Close Disclosure Not consumer against a purchaser or assignee of a mortgage loan for value for any action under the
Provided) statute unless: (a) the violation was committed by the purchaser or assignee; or (b) the assignee or
purchaser is affiliated by common control with the seller of the loan at the time the loan was
purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant injunctions, and levy monetary
fines. Additionally, the CSPA provides borrowers with a private right of action. Therefore, it is
possible that any action commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law as part of the
private right of action, a court could reform the loan terms which could impact purchasers.
Therefore, if the seller cannot be compelled to repurchase the loan, the assignee could face
exposure."
649208162 XXX XXX 2 31493140 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Survey Zero Percent Fee Tolerance exceeded for Survey Fee. Fee TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 3/XX/2022 3/XX/2023 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no cure was Amount of $XXX exceeds tolerance of $XXX. Insufficient or no QM (43-Q)
Without Sufficient Cure provided to the borrower. (75174) cure was provided to the borrower.
Provided
649208162 XXX XXX 2 31493141 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Zero Percent Fee Tolerance exceeded for Credit Report Fee. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 3/XX/2022 3/XX/2023 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Report Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient QM (43-Q)
Without Sufficient Cure cure was provided to the borrower. (7520) or no cure was provided to the borrower
Provided
649208162 XXX XXX 2 31493142 compliance 3 HUD QM AU Finding Fail HUD Qualified Mortgage (Dodd-Frank 2014): Subject loan is not eligible to be Subject loan is not eligible to be insured or guaranteed by 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor
insured or guaranteed by FHA. FHA. QM (43-Q)
649208162 XXX XXX 2 31493143 compliance 3 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of HUD Safe Originator Loan Designation of HUD Safe Harbor QM does not Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 3/XX/2022 OH Purchase Primary No C C B B 8/XX/2024 Safe Harbor
Match - QM Harbor QM does not match Due Diligence Loan Designation of Safe Harbor QM (43-Q). match Due Diligence Loan Designation of Safe Harbor QM firm performing the loan level due diligence and to have the TPR firm confirm said designation. QM (43-Q)
649208162 XXX XXX 2 31493146 credit 3 Guideline Requirement: Calculated high loan to value percentage of 98.18778% exceeds Guideline high loan 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor
Combined High loan to to value percentage of 95.00000% QM (43-Q)
value discrepancy.
649208162 XXX XXX 2 31493147 credit 3 Guideline Requirement: Calculated loan to value percentage of 98.18778% exceeds Guideline loan to value 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor
Loan to value percentage of 95.00000%. QM (43-Q)
discrepancy.
649208162 XXX XXX 2 31493148 credit 3 Guideline Requirement: Calculated combined loan to value percentage of 98.18778% exceeds Guideline 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor
Combined loan to value combined loan to value percentage of 95.00000%. QM (43-Q)
discrepancy.
649208162 XXX XXX 2 31493149 credit 3 Guideline Requirement: Calculated PITIA months reserves of 3.29 is less than Guideline PITIA months 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor
PITIA reserves months reserves of 6.00. QM (43-Q)
discrepancy.
649208162 XXX XXX 2 31493150 credit 3 Recent sale within 90 Valuation Type: Appraisal / Valuation Report Date: 02/XX/2022 Last Sale Date: 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor
days is not eligible per 11/XX/2021; Case Number Assignment Date: 01/XX/2022 QM (43-Q)
FHA guidelines.
649208162 XXX XXX 2 31493151 credit 3 Recent sale within 90 Valuation Type: Appraisal / Valuation Report Date: 02/XX/2022 Last Sale Date: 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor
days is not eligible per 11/XX/2021; Case Number Assignment Date: 01/XX/2022 QM (43-Q)
FHA guidelines.
649209038 XXX XXX 1 31492126 credit 3 Missing Document: Provide document to verify Non-US Citizenship. 10/XX/2021 MI Refinance - Primary No C C C C 8/XX/2024 Safe Harbor
Verification of Non-US Rate/Term QM (APOR)
Citizen Status not
provided
649209038 XXX XXX 1 31492172 compliance 1 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Temporary Loan Designation discrepancy due to loan disbursed after Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 10/XX/2021 MI Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Appeal: 2024/XX/XX: Exception
Match - QM SHQM (GSE/Agency Eligible) does not match Due Diligence Loan Designation of Fails 7/XX/2021 firm performing the loan level due diligence and to have the TPR firm confirm said designation. Rate/Term QM (APOR) Please check tape cleared.
Temporary (GSE) QM Testing. data. XXX shows
designation as QM Safe
Harbor
2024/XX/XX: Appeal:
Per XXX Transaction
Management, please see
supplemental QM data
file posted to deal
room
649209038 XXX XXX 1 31492173 compliance 1 Not Eligible to be GSE Qualified Mortgage: Loan is not eligible for Temp QM status under GSE Loan is not eligible for Temp QM status under GSE 10/XX/2021 MI Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Exception
Temporary QM requirements (application date is on or after 7/XX/21 or loan was requirements (application date is on or after 7/XX/21 or Rate/Term QM (APOR) cleared.
purchased/securitized after 8/XX/21). loan was purchased/securitized after 8/XX/21
649209038 XXX XXX 1 31492174 compliance 2 Michigan CMPA Home Loan Michigan Consumer Mortgage Protection Act: Home Loan Toolkit not provided to The file was missing a copy of the Your Home Loan Toolkit 10/XX/2021 MI Refinance - Primary No B B B B 8/XX/2024 Safe Harbor
Toolkit Status borrower. disclosure or proof of the borrower's receipt within 3 days Rate/Term QM (APOR)
of originator application date.
649209038 XXX XXX 1 31492176 compliance 2 TRID Lender Credit TILA-RESPA Integrated Disclosure:Zero Percent Fee Tolerance exceeded for Lender Lender credit was last disclosed as -$XXX on Loan estimate TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 10/XX/2021 10/XX/2022 MI Refinance - Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Credits. Final Lender Credit of $XXX exceeds tolerance of -$XXX. Insufficient or but disclosed as $XXX on Final Closing Disclosure. File does Rate/Term QM (APOR)
Without Sufficient Cure no cure was provided to the borrower. (9300) not contain a valid Changed of Circumstance for this fee,
Provided nor evidence of cure in file. Provide a post-close Closing
disclosure disclosing the tolerance cure to include -$XXX, a
copy of refund check, proof of delivery, and a copy of the
letter of explanation sent to the borrower disclosing the
changes made.
649209038 XXX XXX 1 31492177 compliance 2 TRID Ten Percent TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Ten Percent Fee Tolerance exceeded. Total amount of $XXX 10/XX/2021 10/XX/2022 MI Refinance - Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no exceeds tolerance of $XXX plus 10% or $XXX Rate/Term QM (APOR)
Without Sufficient Cure cure was provided to the borrower. (0)
Provided
649209038 XXX XXX 1 31492178 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan The loan discount point was not previously disclosed to the TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 10/XX/2021 10/XX/2022 MI Refinance - Primary No B B B B 8/XX/2024 Safe Harbor
Tolerance Violation Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or borrower on the loan estimate but it appeared on the closing Rate/Term QM (APOR)
Without Sufficient Cure no cure was provided to the borrower. (7200) disclosure as $XXX with no cure provided.
Provided
649209038 XXX XXX 1 31515845 credit 3 Missing Document: Hazard The hazard insurance policy is missing 10/XX/2021 MI Refinance - Primary No C C C C 8/XX/2024 Safe Harbor
Insurance Policy not Rate/Term QM (APOR)
provided
649207213 XXX XXX 2 31492954 compliance 1 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Waterfall due income asset documents are not provided in Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 9/XX/2020 CO Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: 9.XX.24 2024/XX/XX: Exception
Match - QM QM does not match Due Diligence Loan Designation of Non QM. file firm performing the loan level due diligence and to have the TPR firm confirm said designation. QM Appeal attached final cleared. Documentation
uw approval,XXX, provided that Borrower's were
income + assets in removed from Rue Residential.
AMC pages 406-416 of
1265 D-0165 XXX
partnership TR 2019 -
1065, pages 417-437 of
1265 D-0179 XXX
partnership TR 2018 -
1065 kindly
review,recind, advise,
thank you XXX. please
see uploads
649207213 XXX XXX 2 31492956 compliance 1 Partnership Income Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not Third Party Verification on Partnership is missing from the 9/XX/2020 CO Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: 9.XX.24 2024/XX/XX: Exception
Documentation Test sufficient (Partnership). (XXX/Partnership) loan file. QM Appeal attached final cleared. Documentation
uw approval, XXX, provided that Borrower's were
income + assets in removed from Rue Residential.
AMC pages 406-416 of
1265 D-0165 XXX
partnership TR 2019 -
1065, pages 417-437 of
1265 D-0179 XXX
partnership TR 2018 -
1065 kindly
review,recind,advise,
thank you XXX.
649207213 XXX XXX 2 31492957 compliance 1 Partnership Income Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not Third Party Verification on Partnership is missing from the 9/XX/2020 CO Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: 9.XX.24 2024/XX/XX: Exception
Documentation Test sufficient (Partnership). (XXX/Partnership) loan file. QM Appeal attached final cleared. Documentation
uw approval,XXX, provided that Borrower's were
income + assets in removed from Rue Residential.
AMC pages 406-416 of
1265 D-0165 XXX
partnership TR 2019 -
1065, pages 417-437 of
1265 D-0179 XXX
partnership TR 2018 -
1065 kindly
review,recind, advise,
thank you XXX. p;easwe
see uploads
649209115 XXX XXX 1 31492190 compliance 2 ECOA Appraisal - Copy of ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Proof of appraisal delivery dated 12/XX/2019 is missing. 12/XX/2019 MA Refinance - Primary Yes B B B B 8/XX/2024 Safe Harbor
Appraisal Not Provided 3 valuation to applicant three (3) business days prior to consummation. Rate/Term QM
Business Days Prior to (Type:Primary/12/XX/2019)
Consummation
649209115 XXX XXX 1 31492194 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Initial Closing Disclosure issued on 12/XX/2019 is not TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 12/XX/2019 12/XX/2020 MA Refinance - Primary Yes B B B B 8/XX/2024 Safe Harbor
Disclosure Timing without at least three (3) business days prior to closing. (Initial/12/XX/2019) signed by the borrower Rate/Term QM
Waiver
649206982 XXX XXX 1 31465276 compliance 2 TRID Lender Credit TILA-RESPA Integrated Disclosure:Zero Percent Fee Tolerance exceeded for Lender Lender Credit Fee was last disclosed as -$XXX on LE but TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 2/XX/2020 2/XX/2021 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Tolerance Violation Credits. Final Lender Credit of -$XXX exceeds tolerance of -$XXX. Insufficient disclosed as -$XXX on Final Closing Disclosure. File does Limited Cash- SHQM
Without Sufficient Cure or no cure was provided to the borrower. (9300) not contain a valid Change of Circumstance for this fee, out GSE (GSE/Agency
Provided nor a cure. Eligible)
649206982 XXX XXX 1 31465277 compliance 2 TRID Ten Percent TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total 10% tolerance was exceeded by $XXX . No valid Change of 2/XX/2020 2/XX/2021 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Tolerance Violation amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no Circumstance provided, nor evidence of cure in file. Limited Cash- SHQM
Without Sufficient Cure cure was provided to the borrower. (0) out GSE (GSE/Agency
Provided Eligible)
649206982 XXX XXX 1 31465278 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Reinspection Fee was not disclosed on Loan Estimate. File TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 2/XX/2020 2/XX/2021 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Tolerance Violation Reinspection Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or does not contain a valid Change of Circumstance for this Limited Cash- SHQM
Without Sufficient Cure no cure was provided to the borrower. (7552) fee, nor evidence of cure. out GSE (GSE/Agency
Provided Eligible)
649206982 XXX XXX 1 31465279 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Administration Fee was not disclosed on Loan Estimate. File TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 2/XX/2020 2/XX/2021 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Tolerance Violation Administration Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient does not contain a valid Change of Circumstance for this Limited Cash- SHQM
Without Sufficient Cure or no cure was provided to the borrower. (7755) fee, nor evidence of cure. out GSE (GSE/Agency
Provided Eligible)
649206982 XXX XXX 1 31465357 credit 3 Missing Document: Fraud 2/XX/2020 NY Refinance - Primary No C C C C 8/XX/2024 Temporary
Report not provided Limited Cash- SHQM
out GSE (GSE/Agency
Eligible)
649206982 XXX XXX 1 31515506 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is 2/XX/2020 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Appraisal Provided Prior prior to the date when valuation was performed. Unable to determine compliance Limited Cash- SHQM
to Date Performed with appraisal timing requirements. (Type:Primary/01/XX/2020) out GSE (GSE/Agency
Eligible)
649207862 XXX XXX 2 31467294 credit 3 Available for Closing is Documented qualifying Assets for Closing of $XXX is less than Cash From Borrower No asset verification provided. Per final Closing 11/XX/2020 CA Refinance - Primary No C C C C 8/XX/2024 Temporary
insufficient to cover $XXX. Disclosure, funds from borrower are $XXX. Additionally, Rate/Term SHQM
Cash From Borrower. source of fees paid prior to closing ($XXX) are not (GSE/Agency
verified. Eligible)
649207862 XXX XXX 2 31514926 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy Neither evidence of appraisal delivery nor compliant There is generally no Assignee Liability. 11/XX/2020 CA Refinance - Primary No B B B B 8/XX/2024 Temporary
Appraisal Not Provided at of the appraisal at least three (3) business days prior to closing, and appraisal acknowledgment of receipt signed at closing is provided. Rate/Term SHQM
or Before Closing (3-Day was not provided at or before closing. (Type:Primary/11/XX/2020) (GSE/Agency
Waiver In File) Eligible)
649207264 XXX XXX 2 31469734 credit 3 Insufficient Coverage: HOI coverage is insufficient by $XXX. Provide verification 1/XX/2021 NY Refinance - Primary No C C C C 8/XX/2024 Temporary
Hazard insurance coverage of policy with sufficient coverage OR provide copy of Cash-out - SHQM
amount is insufficient. insurer's replacement cost estimate supporting current Other (GSE/Agency
coverage amount. Eligible)
649207264 XXX XXX 2 31469794 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Final Closing Disclosure reflects Amount Finance of $XXX but TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 1/XX/2021 1/XX/2024 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Disclosure Amount provided on 01/XX/2021 disclosed an Amount Financed disclosed an inaccurate calculated Amount Finance of $XXX. Variance = $XXX. Lender Assignee liability. Cash-out - SHQM
Financed Test Amount Financed. The disclosed Amount Financed in the amount of $XXX is over to provide corrected CD and copy of letter sent to borrower Other (GSE/Agency
disclosed by $XXX compared to the calculated Amount Financed of $XXX and the explaining changes. Eligible)
disclosed Finance Charge is not accurate within applicable tolerances for Amount
Financed to be considered accurate (fee amounts included in Amount Financed and
Finance Charge calculations are based on Closing Disclosure dated 01/XX/2021).
(Final/XX/20/2021)
649207264 XXX XXX 2 31469795 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Final Closing Disclosure reflects Finance Charge of $XXX but TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 1/XX/2021 1/XX/2024 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Disclosure Finance Charge provided on 01/XX/2021 disclosed an inaccurate Finance Charge on page 5 that does calculated Finance Charge of $XXX.Variance = -$XXX. Lender Assignee liability. Cash-out - SHQM
not match the actual Finance Charge for the loan. The disclosed Finance Charge to provide corrected CD and copy of letter sent to borrower Other (GSE/Agency
in the amount of $XXX is under disclosed by $XXX compared to the calculated explaining changes. Eligible)
Finance Charge of $XXX which exceeds the $XXX threshold (fee amounts included in
Finance Charge calculation are based on Closing Disclosure dated 01/XX/2021).
(Final/XX/20/2021)
649207264 XXX XXX 2 31469796 compliance 2 TRID Ten Percent TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Total amount of $XXX exceeds tolerance of $XXX plus 10% or 1/XX/2021 1/XX/2022 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Tolerance Violation amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no $XXX. Insufficient or no cure was provided to the borrower. Cash-out - SHQM
Without Sufficient Cure cure was provided to the borrower. (0) (0) Other (GSE/Agency
Provided Eligible)
649207264 XXX XXX 2 31469797 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee was last disclosed as $.00 on LE but disclosed TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 1/XX/2021 1/XX/2022 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Tolerance Violation Appraisal Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no as $XXX on Final Closing Disclosure. File does not contain a Cash-out - SHQM
Without Sufficient Cure cure was provided to the borrower. (7506) valid COC for this fee, cure provided at closing. Other (GSE/Agency
Provided Eligible)
649208171 XXX XXX 2 31506887 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Fee amount disclosed in Final CD issued 1/XX/2020 with no TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 1/XX/2020 1/XX/2021 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Tolerance Violation Originator Compensation. Fee Amount of $XXX exceeds tolerance of $XXX. valid Change of Circumstance evident. Cash-out - SHQM
Without Sufficient Cure Insufficient or no cure was provided to the borrower. (7326) Other (GSE/Agency
Provided Eligible)
649208171 XXX XXX 2 31506904 compliance 2 TRID Ten Percent TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Recording fee amount increased in Final CD issued 1/XX/2020 1/XX/2020 1/XX/2021 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Tolerance Violation amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no with no valid Change of Circumstance evident. Cash-out - SHQM
Without Sufficient Cure cure was provided to the borrower. (0) Other (GSE/Agency
Provided Eligible)
649208171 XXX XXX 2 31506942 compliance 2 TRID Interim Closing TILA-RESPA Integrated Disclosure - Corrected Closing Disclosure provided on or Final CD issued 1/XX/2020 provided to and received by TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 1/XX/2020 1/XX/2021 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Disclosure Timing Test after 01/XX/2020 contains a change in APR and was not received by borrower at Borrower on 1/XX/2020 closing date. Revised CD issued Cash-out - SHQM
least three (3) business days prior to consummation 1/XX/2020 is incomplete. Closing Date is not disclosed. Other (GSE/Agency
Sections of pages 1, 3, 4 and 5 are blank/incomplete. Eligible)
649208563 XXX XXX 2 31491841 compliance 2 TRID Initial Loan TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) Loan Estimate not delivered to Borrower within three TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 2/XX/2020 2/XX/2021 CO Purchase Primary No B B B B 8/XX/2024 Temporary
Estimate Timing within three (3) business days of application. Initial Loan Estimate dated business days of application. SHQM
Electronically Provided 01/XX/2020 was electronically provided without or prior to borrower's consent to (GSE/Agency
receive electronic disclosures. Failure to comply with the provisions of the E- Eligible)
Sign Act and failure to provide good faith estimate of fees timely may result in
additional fee tolerance violations. (Initial/01/XX/2020)
649208070 XXX XXX 2 31492537 credit 3 Missing Document: Fraud Fraud Report is missing in file. 11/XX/2019 NY Refinance - Primary No C C C C 8/XX/2024 Non QM
Report not provided Cash-out -
Other
649208070 XXX XXX 2 31492573 compliance 3 QM Points and Fees Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of XX.XX% Points and Fees on subject loan of 4.31292% is in excess of 11/XX/2019 NY Refinance - Primary No C C C C 8/XX/2024 Yes Non QM 2024/XX/XX: Appeal: 2024/XX/XX: With the
is in excess of the allowable maximum of 3.00000% of the Federal Total Loan the allowable maximum of 3.00000% of the Federal Total Loan Cash-out - See D0256 Mavent undiscounted rate of X.XX%,
Amount. Points and Fees total $XXX on a Federal Total Loan Amount of $XXX vs. an Amount. Points and Fees total $XXX on a Federal Total Loan Other Report reflecting the points and fees are
allowable total of $XXX (an overage of $XXX or XX.XX%). Amount of $XXX vs. an allowable total of $XXX (an overage of lenders undiscounted exceeded by $XXX.
$XXX or 1.31292%). interest rate of
X.XX%. Up to 2 Bona
Fide discount points
are excludable as each
point reduced the rate
by 0.2083% which
exceeds the threshold
to be considered bona
fide. $XXX (or 2%) of
the discount point fee
is excludable.
649208070 XXX XXX 2 31499183 compliance 3 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Temporary Loan designation mismatch due to loan failing QM Points and Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 11/XX/2019 NY Refinance - Primary No C C B B 8/XX/2024 Non QM
Match - QM SHQM (GSE/Agency Eligible) does not match Due Diligence Loan Designation of Non Fees testing. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out -
QM. Other
649207296 XXX XXX 2 31492286 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Initial Closing Disclosure not provided to Borrower at least TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2019 4/XX/2020 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Disclosure Timing without at least three (3) business days prior to closing. (Final/04/XX/2019) three business days prior to closing.. Cash-out - SHQM
Waiver Other (GSE/Agency
Eligible)
649207296 XXX XXX 2 31492305 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2019 4/XX/2020 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Tolerance Violation Appraisal Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no Amount of $XXX exceeds tolerance of $XXX. No valid changed Cash-out - SHQM
Without Sufficient Cure cure was provided to the borrower. (7506) circumstance was provided. Other (GSE/Agency
Provided Insufficient cure provided for all closing costs above the Eligible)
legal limit.
649207296 XXX XXX 2 31503164 compliance 2 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Zero Percent Fee Tolerance exceeded for Attorney's Fee TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 4/XX/2019 4/XX/2020 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Tolerance Violation Attorney's Fee (Closing Agent and Other). Fee Amount of $XXX exceeds tolerance (Closing Agent and Other). Fee Amount of $XXX exceeds Cash-out - SHQM
Without Sufficient Cure of $XXX. Insufficient or no cure was provided to the borrower. (7742) tolerance of $XXX. No valid changed circumstance was Other (GSE/Agency
Provided provided. Insufficient cure provided for all closing costs Eligible)
above the legal limit.
649208367 XXX XXX 2 31492639 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure not provided to Borrower(s) at least TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 2/XX/2020 2/XX/2021 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Disclosure Timing without at least three (3) business days prior to closing. (Initial/02/XX/2020) three (3) business days prior to closing. Rate/Term SHQM
Waiver (GSE/Agency
Eligible)
649208367 XXX XXX 2 31492640 compliance 2 TRID Ten Percent TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Ten Percent Fee Tolerance exceeded. Total amount of $XXX 2/XX/2020 2/XX/2021 NY Refinance - Primary No B B B B 8/XX/2024 Temporary
Tolerance Violation amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or Rate/Term SHQM
Without Sufficient Cure cure was provided to the borrower. (0) no cure was provided to the borrower. (0) (GSE/Agency
Provided Eligible)
649208257 XXX XXX 1 31493423 credit 3 Available for Closing is Documented qualifying Assets for Closing of $XXX is less than Cash From Borrower 1/XX/2020 MA Refinance - Primary Yes C C C C 8/XX/2024 Temporary
insufficient to cover $XXX. Rate/Term SHQM
Cash From Borrower. (GSE/Agency
Eligible)
649208257 XXX XXX 1 31493433 compliance 2 TRID Ten Percent TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Ten Percent Fee Tolerance exceeded. Total amount of $XXX 1/XX/2020 1/XX/2021 MA Refinance - Primary Yes B B B B 8/XX/2024 Temporary
Tolerance Violation amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or Rate/Term SHQM
Without Sufficient Cure cure was provided to the borrower. (0) no cure was provided to the borrower (GSE/Agency
Provided Eligible)
649208257 XXX XXX 1 31507892 compliance 2 Massachusetts Home Loan - Unable to test due to missing tangible net benefit information. Tangible Net Benefit Worksheet is not signed by borrower. The regulations do not clarify the enforcement provisions of Mass. Gen. L. c. 183. Accordingly, the 1/XX/2020 1/XX/2023 MA Refinance - Primary Yes B B B B 8/XX/2024 Temporary
Borrower's Interest consequences of a compliance failure remain unclear. In particular, it is probable that a violation Rate/Term SHQM
Tangible Net Benefit of the "borrower's interest" standard can be raised as a defense to, or otherwise impede, (GSE/Agency
Worksheet Not in File foreclosure. Also, it is possible that a violation of the "borrower's interest" standard would Eligible)
constitute a violation of the Massachusetts unfair and deceptive acts and practices statute.
649207959 XXX XXX 2 31468785 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure Due to a portion of the property tax escrows being disclosed TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Material violations for inaccurate 12/XX/2019 12/XX/2020 CO Purchase Primary No B B B B 8/XX/2024 Temporary
Disclosure Will Have provided on 12/XX/2019 disclosed an Initial Escrow Payment that includes both as seller-paid, the total escrow amount on p.2, Section G of disclosures carry assignee liability. SHQM
Escrow - Initial Escrow borrower and non-borrower paid amounts. (Final/12/XX/2019) the final Closing Disclosure is $XXX. The initial escrow Non-material if amounts disclosed includes both borrower and non-borrower paid escrow amounts. (GSE/Agency
Payment By All Parties payment disclosed on p.4 reflects all borrower-paid escrows Eligible)
($XXX).
649207961 XXX XXX 2 31468764 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement 3/XX/2020 FL Purchase Primary No C C C C 8/XX/2024 Temporary
is missing. SHQM
(GSE/Agency
Eligible)
649208378 XXX XXX 1 31468343 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is Appraisal proof of delivery is not provided within 3 9/XX/2020 NJ Purchase Primary Yes B B B B 8/XX/2024 Temporary
Appraisal Provided Prior prior to the date when valuation was performed. Unable to determine compliance business days prior to closing SHQM
to Date Performed with appraisal timing requirements. (Type:Primary/08/XX/2020) (GSE/Agency
Eligible)
649209110 XXX XXX 2 31494358 compliance 2 (Missing Data) Last Rate Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario 6/XX/2021 GA Purchase Primary No B B B B 8/XX/2024 Temporary
Set Date between Creditor Application Date and Transaction Date used to determine rate SHQM
used for testing. (GSE/Agency
Eligible)
649208027 XXX XXX 2 31492084 credit 3 E-sign Consent Agreement Disclosure: E-Sign Consent Agreement 9/XX/2019 TX Purchase Primary No C C C C 8/XX/2024 Temporary
is missing. SHQM
(GSE/Agency
Eligible)
649208027 XXX XXX 2 31492160 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy No evidence in file of when the borrower received a copy of There is generally no Assignee Liability. 9/XX/2019 TX Purchase Primary No B B B B 8/XX/2024 Temporary
Appraisal Not Provided at of the appraisal at least three (3) business days prior to closing, and appraisal the dated 08/XX/2019. SHQM
or Before Closing (3-Day was not provided at or before closing. (Type:Primary/08/XX/2019) (GSE/Agency
Waiver In File) Eligible)
649208027 XXX XXX 2 31492163 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: APR of XX.XX% on Final Loan Calculations: APR of 3.82000% on Final Closing TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 9/XX/2019 9/XX/2020 TX Purchase Primary No B B B B 8/XX/2024 Temporary
Disclosure APR Closing Disclosure provided on 09/XX/2019 is under-disclosed from the calculated Disclosure provided on 09/XX/2019 is under-disclosed from Assignee liability. SHQM
APR of XX.XX% outside of 0.125% tolerance. (Final/09/XX/2019) the calculated APR of 4.04231% outside of 0.125% tolerance. (GSE/Agency
Eligible)
649208027 XXX XXX 2 31492164 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Final Closing Disclosure provided on 09/XX/2019 disclosed an TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 9/XX/2019 9/XX/2020 TX Purchase Primary No B B B B 8/XX/2024 Temporary
Disclosure Finance Charge provided on 09/XX/2019 disclosed an inaccurate Finance Charge on page 5 that does inaccurate Finance Charge on page 5 that does not match the Assignee liability. SHQM
not match the actual Finance Charge for the loan. The disclosed Finance Charge actual Finance Charge for the loan. The disclosed Finance (GSE/Agency
in the amount of $XXX is under disclosed by $XXX compared to the calculated Charge in the amount of $XXX is under disclosed by $XXX Eligible)
Finance Charge of $XXX which exceeds the $XXX threshold (fee amounts included in compared to the calculated Finance Charge of $XXX which
Finance Charge calculation are based on Closing Disclosure dated 09/XX/2019). exceeds the $XXX threshold (fee amounts included in Finance
(Final/09/XX/2019) Charge calculation are based on Closing Disclosure dated
09/XX/2019).
649208027 XXX XXX 2 31492165 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided The interest rate on the Note does not match the interest TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 9/XX/2019 9/XX/2020 TX Purchase Primary No B B B B 8/XX/2024 Temporary
Disclosure Principal and on 09/XX/2019 disclosed a Principal and Interest Payment that does not match the rate on Final CD which increases the P&I and DTI. Assignee liability. SHQM
Interest actual payment for the loan. (Final/09/XX/2019) (GSE/Agency
Eligible)
649208027 XXX XXX 2 31492166 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure P&I ($XXX) from Note document not matched with Final TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 9/XX/2019 9/XX/2020 TX Purchase Primary No B B B B 8/XX/2024 Temporary
Disclosure Projected P&I provided on 09/XX/2019 disclosed a periodic principal and interest payment for CD($XXX) Assignee liability. SHQM
Min Payment Fixed Rate payment stream 2 that does not match the actual payment for the loan. The interest rate on the Note does not match the interest (GSE/Agency
Subsequent Payments (ProjSeq:2/2545236) rate on Final CD which increases the P&I and DTI. Eligible)
649208027 XXX XXX 2 31492167 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure P&I ($XXX) from Note document not matched with Final TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 9/XX/2019 9/XX/2020 TX Purchase Primary No B B B B 8/XX/2024 Temporary
Disclosure Projected P&I provided on 09/XX/2019 disclosed a periodic principal and interest payment for CD($XXX) Assignee liability. SHQM
Payment Min Payment Fixed payment stream 1 that does not match the actual payment for the loan. (GSE/Agency
Rate Initial Payment (ProjSeq:1/2545235) Eligible)
649208027 XXX XXX 2 31492168 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Loan Calculations: Final Closing Disclosure provided on TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 9/XX/2019 9/XX/2020 TX Purchase Primary No B B B B 8/XX/2024 Temporary
Disclosure Total Of provided on 09/XX/2019 disclosed an inaccurate Total of Payments on page 5 that 09/XX/2019 disclosed an inaccurate Total of Payments on page Assignee liability. SHQM
Payments does not match the actual total of payments for the loan (fee amounts included in 5 that does not match the actual total of payments for the (GSE/Agency
TOP calculation are based on Closing Disclosure dated 09/XX/2019). The disclosed loan (fee amounts included in TOP calculation are based on Eligible)
Total of Payments in the amount of $XXX is under disclosed by $XXX compared to Closing Disclosure dated 09/XX/2019). The disclosed Total of
the calculated total of payments of $XXX which exceeds the $XXX threshold. Payments in the amount of $XXX is under disclosed by $XXX
(Final/09/XX/2019) compared to the calculated total of payments of $XXX which
exceeds the $XXX threshold.
649208027 XXX XXX 2 31492169 compliance 2 TRID Initial Closing TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure not provided to Borrower(s) at least TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2019 9/XX/2020 TX Purchase Primary No B B B B 8/XX/2024 Temporary
Disclosure Timing without at least three (3) business days prior to closing. (Initial/09/XX/2019) three (3) business days prior to closing. SHQM
Waiver (GSE/Agency
Eligible)
649207750 XXX XXX 1 31520436 compliance 2 (Missing Data) Last Rate Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario 5/XX/2018 GA Refinance - Primary No B B B B 8/XX/2024 Temporary
Set Date between Creditor Application Date and Transaction Date used to determine rate Rate/Term SHQM
used for testing. (GSE/Agency
Eligible)
649207750 XXX XXX 1 31520451 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure Final Closing Disclosure did not disclose Estimated Property TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2018 5/XX/2019 GA Refinance - Primary No B B B B 8/XX/2024 Temporary
Disclosure Will Not Have provided on 05/XX/2018 did not disclose Estimated Property Costs over Year 1 for Costs over Year 1 for loan with no escrow account Rate/Term SHQM
Escrow - Property Costs loan with no escrow account established. (Final/05/XX/2018) established. (GSE/Agency
Year 1 Eligible)
649207750 XXX XXX 1 31520452 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure Final Closing Disclosure incorrectly disclosed whether the TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2018 5/XX/2019 GA Refinance - Primary No B B B B 8/XX/2024 Temporary
Disclosure Will Not Have provided on 05/XX/2018 incorrectly disclosed whether the loan will have an escrow loan will have an escrow account. Rate/Term SHQM
Escrow - Reason account. (Final/05/XX/2018) (GSE/Agency
Eligible)
649207750 XXX XXX 1 31522092 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing Missing the Final Closing Disclosure for the subject loan TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2018 5/XX/2019 GA Refinance - Primary No B B B B 8/XX/2024 Temporary
Disclosure AIR Table Disclosure provided on 05/XX/2018 disclosed a First Change frequency that does note. Rate/Term SHQM
First Change Frequency not match the actual first change frequency for the loan. (Final/05/XX/2018) (GSE/Agency
Eligible)
649207750 XXX XXX 1 31522093 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing Missing the Final Closing Disclosure for the subject loan TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2018 5/XX/2019 GA Refinance - Primary No B B B B 8/XX/2024 Temporary
Disclosure AIR Table Disclosure provided on 05/XX/2018 disclosed a Minimum Interest Rate that does not note. Rate/Term SHQM
Minimum Interest Rate match the actual minimum interest rate for the loan. (Final/05/XX/2018) (GSE/Agency
Eligible)
649207750 XXX XXX 1 31522095 compliance 1 TRID Final Closing TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure Missing the Final Closing Disclosure for the subject loan TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2018 5/XX/2019 GA Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Temporary 2024/XX/XX: Exception
Disclosure Product provided on 05/XX/2018 disclosed a Product that does not match the actual product note. Rate/Term SHQM cleared.
Testing for the loan. Additional AIR/AP table failures could apply for loans with an (GSE/Agency
adjustable rate or adjustable payment with incorrect Product disclosure. Eligible)
(Final/05/XX/2018)
649207750 XXX XXX 1 31522097 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Missing the Final Closing Disclosure for the subject loan TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 5/XX/2018 5/XX/2019 GA Refinance - Primary No B B B B 8/XX/2024 Temporary
Disclosure Projected provided on 05/XX/2018 disclosed a periodic principal and interest payment for note. Assignee liability. Rate/Term SHQM
Principal And Interest payment stream 1 that does not match the actual payment for the loan. (GSE/Agency
Payment Min Payment ARM (ProjSeq:1/2550792) Eligible)
649207750 XXX XXX 1 31523511 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 5/XX/2018 5/XX/2019 GA Refinance - Primary No B B B B 8/XX/2024 Temporary
Disclosure Principal and on 05/XX/2018 disclosed a Principal and Interest Payment that does not match the Assignee liability. Rate/Term SHQM
Interest Test actual payment for the loan. (Final/05/XX/2018) (GSE/Agency
Eligible)
649207750 XXX XXX 1 31523518 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Adjustable Payment Table: Final Closing Final CD disclosed incorrect amount of $XXX. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2018 5/XX/2019 GA Refinance - Primary No B B B B 8/XX/2024 Temporary
Disclosure AP Table First Disclosure provided on 05/XX/2018 disclosed a First Change minimum, maximum, and Rate/Term SHQM
Change Amount Advanced payment period that does not match the actual terms for the loan. (GSE/Agency
Construction-Permanent (Final/05/XX/2018) Eligible)
649207750 XXX XXX 1 31523519 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final CD disclosed payment adjusts once in year 2. TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2018 5/XX/2019 GA Refinance - Primary No B B B B 8/XX/2024 Temporary
Disclosure Payment on 05/XX/2018 with an increasing payment disclosed the due date of the first Rate/Term SHQM
Adjusts Every Starting In adjustment that does not match the actual due date for the loan. (GSE/Agency
(Final/05/XX/2018) Eligible)
649207750 XXX XXX 1 31523520 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final CD disclosed payment adjusts once in year 2. TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2018 5/XX/2019 GA Refinance - Primary No B B B B 8/XX/2024 Temporary
Disclosure Payment on 05/XX/2018 with an increasing payment did not disclose the frequency of Rate/Term SHQM
Adjusts Every Test adjustments. (Final/05/XX/2018) (GSE/Agency
Eligible)
649207750 XXX XXX 1 31535334 credit 1 Credit Exception: Note date provided on tape is 2/XX/19. File contains a 5/XX/2018 GA Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Temporary 2024/XX/XX: Please 2024/XX/XX: Exception
signed CD from that date but no legal documents. Lender Rate/Term SHQM confirm documentation cleared.
correspondence in file and further research by client (GSE/Agency needed to remedy
indicates that a modification was done on that date. Eligible) exception. PA
Remainder of review completed using origination documents.
649207750 XXX XXX 1 31623494 compliance 2 TRID Interim Closing TILA-RESPA Integrated Disclosure - Corrected Closing Disclosure provided on or TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 5/XX/2018 5/XX/2019 GA Refinance - Primary No B B B B 9/XX/2024 Temporary
Disclosure Timing Test after 05/XX/2018 contains a change in loan product and was not received by Rate/Term SHQM
borrower at least three (3) business days prior to consummation. (GSE/Agency
Eligible)
649208872 XXX XXX 1 31492968 credit 1 Missing Document: Asset Assets - Closing Statement not provided. 10/XX/2023 TX Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Exception
not provided Cash-out - QM (APOR) cleared.
Other
649208872 XXX XXX 1 31493092 credit 1 Guideline Financial Institution: XXX // Account Type: Individual Retirement Account (IRA) / 2 month's continuous bank statement is required as per AUS. 10/XX/2023 TX Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Exception
Issue:Insufficient asset Account Number: XXX Cash-out - QM (APOR) cleared.
documentation. Other
649208872 XXX XXX 1 31493158 compliance 1 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Originator Loan Designation of Safe Harbor QM (APOR) does Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 10/XX/2023 TX Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Please see 2024/XX/XX: Exception
Match - QM QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Risk. not match Due Diligence Loan Designation of QM (APOR) Fail. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Cash-out - QM (APOR) exception response cleared.
Other notes regarding rental
under exception ID XXX
below
649208872 XXX XXX 1 XXX compliance 1 General QM Provision General QM: The DTI calculated in accordance with the Lenders Guidelines and A Net Monthly Rental Income of -$XXX was not included in DTI 10/XX/2023 TX Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Appeal: 2024/XX/XX: Exception
Investor and QM DTIs 1026.43(e) of 49.92724% moderately exceeds the guideline maximum of 48.00%. (DTI calculation by the lender. Cash-out - QM (APOR) The subject loan was cleared.
match and both moderately Exception is eligible to be regraded with compensating factors.) Other approved with $XXX in
exceed Guidelines additional debt which
includes $XXX in
student loans, $XXX
XXX card and $XXX
rental loss on
additional property.
There was additional
debt that was paid at
close per the final CD
that is excluded from
debts. Please advise
if additional
documentation or
explanation is
required regarding the
DTI exception. Thank
you,
649208872 XXX XXX 1 31493163 compliance 1 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Loan Disclosures: Amount of Estimated Property Costs over TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 10/XX/2023 10/XX/2024 TX Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: 9/XX/24 2024/XX/XX: SitusAMC received
Disclosure Property Costs Costs over Year 1 of $XXX on Final Closing Disclosure provided on 10/XX/2023 are Year 1 of $XXX on Final Closing Disclosure provided on Cash-out - QM (APOR) Appeal: Please see rebuttal is sufficient to
Year 1 Underdisclosed - underdisclosed (Final/10/XX/2023) 10/XX/2023 are underdisclosed Other the Homeowner's clear.
October 2018 Insurance Policy (DOC
ID 0553, page 2967 of
the Clarity loan file)
which lists the annual
premium as $XXX ($XXX
monthly) rather than
the $XXX as listed on
the LAS report. The
difference is a $XXX
fee. It is acceptable
to only include the
premium amount listed
on the insurance
policy. Without the
$XXX included on the
LAS report calculation
the amount of
estimated property
costs over year would
match at $XXX. XXX
649208872 XXX XXX 1 31493164 compliance 1 TRID Zero Percent TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan The file is missing a valid Change of Circumstance for the TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 10/XX/2023 10/XX/2024 TX Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: 9/XX/24 2024/XX/XX: SitusAMC received
Tolerance Violation Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or increase in Discount Points. Insufficient or no cure was Cash-out - QM (APOR) Appeal: Please see LOE and COC snip for changes
Without Sufficient Cure no cure was provided to the borrower. (7200) provided to the borrower. Other the included MX made on 09/29 however, the
Provided screenshots fee was again increased on
documenting the revised CD dated 10/XX/24
changed circumstance from $XXX to $XXX. Please
for Discount Points provide information as to
fee increasing from what changed circumstance
$XXX (LE issued occurred (as defined under
8/XX/23) to $XXX (CD 1026.19(e)(4)(A)-(F) that
issued 10/XX/23) as a resulted in an increase in
result of a decrease closing costs.
in cash to the
borrower from $XXX to 2024/XX/XX: SitusAMC received
$XXX. XXX valid COC dated 10/XX/2023.
2024/XX/XX: 9/XX/24
Appeal: Please see
the included MX
screenshots
documenting the
changed circumstance
for Discount Points
fee increasing from
$XXX (CD issued
10/XX/23) to $XXX (CD
issued 10/XX/23) as a
result of a rate lock
extension on 10/XX/23.
XXX
649208872 XXX XXX 1 31493165 credit 1 AUS Findings: Investor Calculated investor qualifying total debt ratio of 49.92724% exceeds AUS total A Net Monthly Rental Income of -$XXX was not included in DTI 10/XX/2023 TX Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Exception
qualifying total debt debt ratio of 48.00000%. calculation by the lender. Cash-out - QM (APOR) cleared.
ratio discrepancy. Other
649208872 XXX XXX 1 31493166 compliance 1 General QM Provision General QM: Based on the loan failing one or more guideline components, the loan 10/XX/2023 TX Refinance - Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Please see 2024/XX/XX: Exception
Investor Guidelines is at QM risk. Cash-out - QM (APOR) exception response cleared.
Violation Other notes regarding rental
under exception ID XXX
above
649207206 XXX XXX 2 31492745 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Final Closing Disclosure provided on 08/XX/2023 disclosed an TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 8/XX/2023 8/XX/2024 FL Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Disclosure Amount provided on 08/XX/2023 disclosed an Amount Financed disclosed an inaccurate Amount Financed disclosed an inaccurate Amount Financed. The Assignee liability. QM (APOR)
Financed Test Amount Financed. The disclosed Amount Financed in the amount of $XXX is over disclosed Amount Financed in the amount of $XXX is over
disclosed by $XXX compared to the calculated Amount Financed of $XXX and the disclosed by $XXX compared to the calculated Amount Financed
disclosed Finance Charge is not accurate within applicable tolerances for Amount of $XXX and the disclosed Finance Charge is not accurate
Financed to be considered accurate (fee amounts included in Amount Financed and within applicable tolerances for Amount Financed to be
Finance Charge calculations are based on Closing Disclosure dated 08/XX/2023). considered accurate (fee amounts included in Amount Financed
(Final/08/XX/2023) and Finance Charge calculations are based on Closing
Disclosure dated 08/XX/2023).
649207206 XXX XXX 2 31492746 compliance 2 TRID Final Closing TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Final Closing Disclosure provided on 08/XX/2023 disclosed an TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 8/XX/2023 8/XX/2024 FL Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Disclosure Finance Charge provided on 08/XX/2023 disclosed an inaccurate Finance Charge on page 5 that does inaccurate Finance Charge on page 5 that does not match the Assignee liability. QM (APOR)
not match the actual Finance Charge for the loan. The disclosed Finance Charge actual Finance Charge for the loan. The disclosed Finance
in the amount of $XXX is under disclosed by $XXX compared to the calculated Charge in the amount of $XXX is under disclosed by $XXX
Finance Charge of $XXX which exceeds the $XXX threshold (fee amounts included in compared to the calculated Finance Charge of $XXX which
Finance Charge calculation are based on Closing Disclosure dated 08/XX/2023). exceeds the $XXX threshold (fee amounts included in Finance
(Final/08/XX/2023) Charge calculation are based on Closing Disclosure dated
08/XX/2023).
649207206 XXX XXX 2 31492751 credit 3 Missing Document: Verification of Identification is missing 8/XX/2023 FL Purchase Primary No C C C C 8/XX/2024 Safe Harbor
Verification of QM (APOR)
Identification not
provided
649208919 XXX XXX 2 31493765 compliance 1 ECOA Appraisal Disclosure ECOA - File does not evidence the consumer was provided with the right to receive File does not evidence the consumer was provided with the 9/XX/2023 9/XX/2024 NY Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: SitusAMC received
- ECOA Timing a copy of the Appraisal Disclosure within 3 days of the loan application date. right to receive a copy of the Appraisal Disclosure within 3 QM (APOR) proof of application date.
days of the loan application date.
649208919 XXX XXX 2 31493811 compliance 1 TRID Final Closing TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing Disclosure provided on 09/XX/2023 incorrectly TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2023 9/XX/2024 NY Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Please see 2024/XX/XX: Escrowed amount
Disclosure Homeowners provided on 09/XX/2023 incorrectly disclosed whether Homeowners Insurance is disclosed whether Homeowners Insurance is included in QM (APOR) IEADS. Property is a is correct.
Insurance Included In included in escrow. (Final/09/XX/2023) escrow. co-op and only Walls-
Escrow Test In coverage of XXX per
month is escrowed.
Final CD indicates YES
in projected payments.
649208919 XXX XXX 2 31493812 compliance 1 TRID Final Closing TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing Disclosure provided on 09/XX/2023 incorrectly TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2023 9/XX/2024 NY Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Please see 2024/XX/XX: Property taxes
Disclosure Property Taxes provided on 09/XX/2023 incorrectly disclosed whether property taxes are included disclosed whether property taxes are included in escrow. QM (APOR) IEADS uploaded on are included in HOA Dues as a
Included In Escrow in escrow. (Final/09/XX/2023) exception XXX1. CO-OP.
Property is a co-op
and only Walls-In
coverage of XXX per
month is escrowed.
Final CD indicates YES
in projected payments.
649208919 XXX XXX 2 31493813 compliance 1 TRID Interim Closing TILA-RESPA Integrated Disclosure - Corrected Closing Disclosure provided on or Corrected Closing Disclosure provided on or after 09/XX/2023 TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2023 9/XX/2024 NY Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Please 2024/XX/XX: Upon further
Disclosure Timing Test after 09/XX/2023 contains a change in APR and was not received by borrower at contains a change in APR and was not received by borrower at QM (APOR) identify CD in review removed unsigned blank
least three (3) business days prior to consummation least three business days prior to consummation. question. CD v5 and CD document(s) 0429 estimated
v6 both issued on 9/XX to be provided on 09/XX/2024,
have APR of X.XX from testing.
which does not exceed
v4 APR provided on
8/XX (7.071) by
greater than .125%.
649208919 XXX XXX 2 31493814 compliance 1 TRID Loan Estimate Timing TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the Initial application date is 4/XX/2023 and initial loan TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee liability. 9/XX/2023 9/XX/2024 NY Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor 2024/XX/XX: Please see 2024/XX/XX: The application
mail to Borrower(s) within three (3) business days of application. estimate is 6/XX/2023 QM (APOR) attached system screen in file indicates a signature
(Initial/06/XX/2023) shot showing LE date of 4/8, matching loan ID
Required Date of numbers and all six pieces of
6/XX/23. This is the application information.
date the system Please provide initial LE, or
captures the six provide documentation as to
pieces of information why the 4/8 application is
for a TRID application not valid.
and triggers the LE
requirement. 2024/XX/XX: SitusAMC received
proof of application date.
2024/XX/XX: Appeal:
Please see D0236,
D0134-D0136 and D0138
conditional approval
letters with no
purchase property
address identified.
D0277 is the first
conditional approval
letter following the
purchase property
address being
submitted to XXX.
D0239 is the original
URLA taken on 4/XX/23
and does not contain
the property address.
This date will not
change throughout the
shopping and loan
process. The date the
purchase property is
identified to XXX is
captured as the LE
required date
previously provided
triggering the LE to
be provided.
649207534 XXX XXX 1 31492683 credit 3 FHA - Informed Consumer Disclosure: FHA - Informed Consumer Choice Disclosure (Government Documents) FHA - Informed Consumer Choice Disclosure not provided to 10/XX/2023 NJ Purchase Primary Yes C C C C 8/XX/2024 HUD Safe
Choice Disclosure was not borrower within 3 business days of the loan application. Harbor QM
provided to borrower
within 3 business days of
the loan application.
649207534 XXX XXX 1 31492688 credit 1 Available for Closing is Documented qualifying Assets for Closing of $XXX is less than Cash From Borrower Documented qualifying Assets for Closing of $XXX is less 10/XX/2023 NJ Purchase Primary Yes A A A A 8/XX/2024 9/XX/2024 Yes HUD Safe 2024/XX/XX: Assets have bene
insufficient to cover $XXX. than Cash From Borrower $XXX. Harbor QM updated. Exception is clear.
Cash From Borrower.
649207534 XXX XXX 1 31492693 credit 2 Loan has been identified Mortgage Type: FHA Loan has been identified as FHA/VA/USDA. 10/XX/2023 NJ Purchase Primary Yes B B B B 8/XX/2024 HUD Safe
as FHA/VA/USDA Harbor QM
649207534 XXX XXX 1 31492710 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 10/XX/2023 NJ Purchase Primary Yes B B B B 8/XX/2024 HUD Safe
Harbor QM
649207534 XXX XXX 1 31492716 compliance 1 HUD QM AU Finding Fail HUD Qualified Mortgage (Dodd-Frank 2014): Subject loan is not eligible to be Subject loan is not eligible to be insured or guaranteed by 10/XX/2023 NJ Purchase Primary Yes A A A A 8/XX/2024 9/XX/2024 Yes HUD Safe 2024/XX/XX: Assets have bene
insured or guaranteed by FHA. FHA. Harbor QM updated. Exception is clear.
649207534 XXX XXX 1 31492717 compliance 1 Check Loan Designation Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of HUD Safe Loan Designation discrepancy due to insufficient asset Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR 10/XX/2023 NJ Purchase Primary Yes A A A A 8/XX/2024 9/XX/2024 Yes HUD Safe 2024/XX/XX: Assets have bene
Match - QM Harbor QM does not match Due Diligence Loan Designation of ATR Risk. required to verify the asset. firm performing the loan level due diligence and to have the TPR firm confirm said designation. Harbor QM updated. Exception is clear.
649207534 XXX XXX 1 31492725 credit 1 AUS Findings: Available Calculated Available for Reserves of $XXX is less than AUS Available for Reserves 10/XX/2023 NJ Purchase Primary Yes A A A A 8/XX/2024 9/XX/2024 Yes HUD Safe 2024/XX/XX: Assets have bene
for Reserves discrepancy. of $XXX. Harbor QM updated. Exception is clear.
649207534 XXX XXX 1 31492728 credit 1 Income documentation Assets requirement not met due to insufficient reserves 10/XX/2023 NJ Purchase Primary Yes A A A A 8/XX/2024 9/XX/2024 Yes HUD Safe 2024/XX/XX: Assets have bene
requirements not met. Harbor QM updated. Exception is clear.
649207534 XXX XXX 1 31509524 compliance 1 Income/Asset Guideline Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to waterfall exceptions firing due to the insufficient asset 10/XX/2023 NJ Purchase Primary Yes A A A A 8/XX/2024 9/XX/2024 Yes HUD Safe 2024/XX/XX: Appeal: 2024/XX/XX: Assets have bene
Deficiency - ATR Impact income and/or asset doc requirements which could result in a risk to the required for reserves Harbor QM Attached please find updated. Exception is clear.
borrower's ability to repay. (Exception is eligible to be regraded with the subject loan asset
compensating factors.) documentation
including bank
statements and
retirement
account/withdrawal of
funds information.
Please advise if
additional asset
documentation is
required.
2024/XX/XX: Assets
649207534 XXX XXX 1 31509526 compliance 1 QM DTI Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and waterfall exceptions firing due to the insufficient asset Although this issue is subject to a 3 year SOL for affirmative claims under TILA, AMC does not adjust 10/XX/2023 NJ Purchase Primary Yes A A A A 8/XX/2024 9/XX/2024 Yes HUD Safe 2024/XX/XX: Appeal: 2024/XX/XX: Assets have bene
the images do not provide evidence loan is eligible for purchase, guarantee or required for reserves grading taking into account TILA SOL for exceptions under ATR, given the potential for enhanced Harbor QM It appears the DTI updated. Exception is clear.
insurance by the appropriate agency. damages when asserting an ability to repay defense in response to an action to collect a debt by issue may be tied to
recoupment or set-off. missing income.
Attached please find
borrower's income
support documents,
please advise if
additional information
is required. Thank
you
2024/XX/XX: Income
docs
649207534 XXX XXX 1 31510242 compliance 1 General Ability To Repay Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more waterfall exceptions firing due to the insufficient asset 10/XX/2023 NJ Purchase Primary Yes A A A A 8/XX/2024 9/XX/2024 Yes HUD Safe 2024/XX/XX: Assets have bene
Provision Investor guideline components, the loan is at ATR risk. required for reserves Harbor QM updated. Exception is clear.
Guidelines
649208983 XXX XXX 2 31492958 compliance 2 ECOA Appraisal - ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy Borrower waived right to receive a copy of the appraisal at There is generally no Assignee Liability. 10/XX/2023 WI Purchase Primary No B B B B 8/XX/2024 Safe Harbor
Appraisal Not Provided at of the appraisal at least three (3) business days prior to closing, and appraisal least three (3) business days prior to closing, and QM (APOR)
or Before Closing (3-Day was not provided at or before closing. (Type:Primary/09/XX/2023) appraisal was not provided at or before closing.
Waiver In File) (Type:Primary/09/XX/2023)
649208983 XXX XXX 2 31492961 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. FACTA Disclosure not provided. There is no Assignee Liability. 10/XX/2023 WI Purchase Primary No B B B B 8/XX/2024 Safe Harbor
QM (APOR)
649210096 XXX XXX XXX 2 3184562 credit 3 Missing Document: Missing 4/XX/2002 MO Refinance - Primary No C C C C 5/XX/2017
Final 1003 Cash-out -
Debt
Consolidation
649210096 XXX XXX XXX 2 3184578 credit 2 Security Instrument is Homestead Exemption Waiver 4/XX/2002 MO Refinance - Primary No B B B B 5/XX/2017
not on a FNMA/FHLMC form Cash-out -
and does not contain the Debt
following clauses: Consolidation
649210096 XXX XXX XXX 2 3184625 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 4/XX/2002 MO Refinance - Primary No B B B B 5/XX/2017
Affiliated Business Disclosure to applicant within three (3) business days of application. implementing regulation, Regulation X, for these type of violations. Cash-out -
Arrangement Disclosure Debt
Not Provided Within 3 Consolidation
Business Days of
Application
649210097 XXX XXX XXX 1 3185731 compliance 2 (Doc Error) Initial GFE 9/XX/2002 OH Refinance - Primary No B B B B 5/XX/2017
not provided Rate/Term
649210097 XXX XXX XXX 1 3185752 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 9/XX/2002 OH Refinance - Primary No B B B B 5/XX/2017
Application Test an application date of 8/XX/2002 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date. The final date used
for testing was 3/XX/2002.
649210097 XXX XXX XXX 1 3204636 compliance 2 Missing Document: Missing 9/XX/2002 OH Refinance - Primary No B B B B 5/XX/2017
Lender's Initial 1003 Rate/Term
649210097 XXX XXX XXX 1 3204637 compliance 2 Final TIL APR Under/Over Truth In Lending Act: Final TIL APR of XX.XX0% is underdisclosed from calculated TILA APR - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions. 9/XX/2002 9/XX/2005 OH Refinance - Primary No B B B B 5/XX/2017
Disclosed By Greater Than APR of XX.XX4% outside of 0.125% tolerance. Unlimited as a defense to foreclosure. Assignee liability. Rate/Term
0.125%
649210097 XXX XXX XXX 1 3204638 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine the fee under disclosure due to missing $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 9/XX/2002 9/XX/2005 OH Refinance - Primary No B B B B 5/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. the itemization of amount financed. transactions. Unlimited as a defense to foreclosure. Assignee liability. Rate/Term
649210107 XXX XXX 1 3777339 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 9/XX/2005 NV Refinance - Primary No B B B B 8/XX/2017
Cash-out -
Other
649210107 XXX XXX 1 3848830 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2005 9/XX/2006 NV Refinance - Primary No B B B B 8/XX/2017
borrower within three (3) days of application. Cash-out -
Other
649210107 XXX XXX 1 3848831 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2005 9/XX/2006 NV Refinance - Primary No B B B B 8/XX/2017
Timing CHARM Booklet, not provided to the borrower within three (3) days of application. Cash-out -
Other
649210110 XXX XXX XXX 2 3897139 compliance 3 Missing Final HUD-1: Missing Final HUD-1: Title Company Closing Statement used for any applicable Yes 5/XX/2007 IL Refinance - Primary No D D D D 8/XX/2017 Yes 2017/XX/07: Per
Title Co. Closing Federal, State or Local compliance testing. Cash-out - exception comments,
Statement Used For Fee Debt looks like there were
Testing Consolidation other HUDs in the file
that can be used for
testing. this
shouldn't be an issue
649210110 XXX XXX XXX 2 3902587 credit 3 Missing Document: Missing Yes 5/XX/2007 IL Refinance - Primary No C C C C 8/XX/2017
Final 1003 Cash-out -
Debt
Consolidation
649210110 XXX XXX XXX 2 3902769 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using Yes 5/XX/2007 IL Refinance - Primary No B B B B 8/XX/2017
Application Test an application date of 05/XX/2007 which is 0 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Debt
for testing was 05/XX/2007. Consolidation
649210110 XXX XXX XXX 2 3902770 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 5/XX/2007 5/XX/2008 IL Refinance - Primary No B B B B 8/XX/2017
Loan Application Date. Cash-out -
Debt
Consolidation
649210110 XXX XXX XXX 2 3902771 compliance 2 CHARM Booklet Disclosure Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 5/XX/2007 5/XX/2008 IL Refinance - Primary No B B B B 8/XX/2017
Timing Loan Application Date. Cash-out -
Debt
Consolidation
649210110 XXX XXX XXX 2 3903120 compliance 2 Missing Document: Missing Yes 5/XX/2007 IL Refinance - Primary No B B B B 8/XX/2017
Lender's Initial 1003 Cash-out -
Debt
Consolidation
649210111 XXX XXX XXX 1 3941787 compliance 2 (Doc Error) Initial GFE 11/XX/2006 CA Refinance - Primary No B B B B 8/XX/2017
not provided Cash-out -
Debt
Consolidation
649210111 XXX XXX XXX 1 3941834 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 11/XX/2006 CA Refinance - Primary No B B B B 8/XX/2017
Application Test an application date of 10/XX/2006 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Debt
for testing was 05/XX/2006. Consolidation
649210111 XXX XXX XXX 1 3941835 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2006 11/XX/2007 CA Refinance - Primary No B B B B 8/XX/2017
Status CHARM Booklet, not provided to the borrower. Cash-out -
Debt
Consolidation
649210111 XXX XXX XXX 1 3953260 credit 3 Missing Document: Missing 11/XX/2006 CA Refinance - Primary No C C C C 8/XX/2017
Final 1003 Cash-out -
Debt
Consolidation
649210111 XXX XXX XXX 1 3953261 compliance 2 Missing Document: Missing 11/XX/2006 CA Refinance - Primary No B B B B 8/XX/2017
Lender's Initial 1003 Cash-out -
Debt
Consolidation
649209989 XXX XXX 1 3938434 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 6/XX/2004 OH Refinance - Primary No B B B B 8/XX/2017
Application Test an application date of 05/XX/2004 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Debt
for testing was 05/XX/2004. Consolidation
649209989 XXX XXX 1 3938435 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2004 6/XX/2005 OH Refinance - Primary No B B B B 8/XX/2017
Loan Application Date. Cash-out -
Debt
Consolidation
649209989 XXX XXX 1 3938436 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2004 6/XX/2005 OH Refinance - Primary No B B B B 8/XX/2017
Status CHARM Booklet, not provided to the borrower. Cash-out -
Debt
Consolidation
649209989 XXX XXX 1 3938437 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine underdisclosure due to missing $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 6/XX/2004 6/XX/2007 OH Refinance - Primary No B B B B 8/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. Itemization of prepaid finance charges. transactions. Unlimited as a defense to foreclosure. Assignee liability. Cash-out -
Debt
Consolidation
649209989 XXX XXX 1 3946564 credit 3 Missing Document: Missing 6/XX/2004 OH Refinance - Primary No C C C C 8/XX/2017
Final 1003 Cash-out -
Debt
Consolidation
649209989 XXX XXX 1 3946566 compliance 2 Missing Document: Missing 6/XX/2004 OH Refinance - Primary No B B B B 8/XX/2017
Lender's Initial 1003 Cash-out -
Debt
Consolidation
649209977 XXX XXX 1 3927917 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2007 2/XX/2008 NJ Refinance - Primary Yes B B B B 8/XX/2017
borrower within three (3) days of application. Cash-out -
Debt
Consolidation
649209988 XXX XXX 2 3934266 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 4/XX/2007 IN Purchase Investment Yes B B B B 8/XX/2017
649209988 XXX XXX 2 3934267 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 4/XX/2007 IN Purchase Investment Yes B B B B 8/XX/2017
Application Test an application date of 03/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2006.
649209988 XXX XXX 2 3946087 compliance 2 Missing Document: Missing 4/XX/2007 IN Purchase Investment Yes B B B B 8/XX/2017
Lender's Initial 1003
649209986 XXX XXX 1 3930477 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2006 1/XX/2007 GA Refinance - Primary No B B B B 8/XX/2017
Status CHARM Booklet, not provided to the borrower. Cash-out -
Debt
Consolidation
649210099 XXX XXX 1 3977538 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 5/XX/2005 CA Purchase Primary No B B B B 8/XX/2017
649210099 XXX XXX 1 3984884 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2005 5/XX/2006 CA Purchase Primary No B B B B 8/XX/2017
borrower within three (3) days of application.
649210099 XXX XXX 1 3984885 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2005 5/XX/2006 CA Purchase Primary No B B B B 8/XX/2017
Timing CHARM Booklet, not provided to the borrower within three (3) days of application.
649209562 XXX XXX 2 4354004 credit 3 Missing Document: Missing 11/XX/2004 CA Purchase Primary No C C C C 9/XX/2017
Final 1003
649209562 XXX XXX 2 4357168 credit 3 FEMA Disaster Issue: FEMA Disaster Date: XX/XX/XXXX 11/XX/2004 CA Purchase Primary No C C C C 9/XX/2017
Property is located in a
FEMA Disaster area and
has not been inspected.
649209562 XXX XXX 2 4357286 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 11/XX/2004 CA Purchase Primary No B B B B 9/XX/2017
Application Test an application date of 11/XX/2004 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2004.
649209562 XXX XXX 2 4357287 compliance 2 California Primary Note late charge exceeds maximum per state. Erroneous exception- California statute allows for a late 11/XX/2004 CA Purchase Primary No B B B B 9/XX/2017
Residence Late Charge charge of up to 6%; Note indicates penalty of 5% after 15
Percent Testing days.
649209562 XXX XXX 2 4357289 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2004 11/XX/2005 CA Purchase Primary No B B B B 9/XX/2017
Loan Application Date.
649209562 XXX XXX 2 4358761 credit 3 AUS/Guideline Findings: File does not contain one month's asset statements for all 11/XX/2004 CA Purchase Primary No C C C C 9/XX/2017
All conditions were not funds used to qualify, most recent paystub with 30 days YTD
met history, and verbal VOE dated within 10 days of closing as
required by AUS findings.
649209562 XXX XXX 2 4358768 credit 3 Income Docs Missing: Borrower: XXX Paystubs (2004), VVOE - Employment Only (2004) File does not contain most recent paystub with 30 days YTD 11/XX/2004 CA Purchase Primary No C C C C 9/XX/2017
history and verbal VOE dated within 10 days of closing per
AUS findings.
649209562 XXX XXX 2 4359284 compliance 2 CHARM Booklet Disclosure Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2004 11/XX/2005 CA Purchase Primary No B B B B 9/XX/2017
Timing Loan Application Date.
649209562 XXX XXX 2 4359285 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Variance is due to lender disclosing Escrow Fee as $XXX vs. $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 11/XX/2004 11/XX/2005 CA Purchase Primary No B B B B 9/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. $XXX on final HUD-1, transactions. Unlimited as a defense to foreclosure. Assignee liability.
649210112 XXX XXX XXX 1 4554273 credit 3 Missing Document: Missing No 10/XX/1998 TX Purchase Primary No C C C C 10/XX/2017
Final 1003
649210112 XXX XXX XXX 1 4554436 compliance 2 Due to lack of appraised No 10/XX/1998 TX Purchase Primary No B B B B 10/XX/2017
value, compliance tests
requiring an LTV were run
off an assumed value of a
contract sales price or
original loan amount,
whichever applies.
649210112 XXX XXX XXX 1 4554437 compliance 2 (Doc Error) Initial GFE No 10/XX/1998 TX Purchase Primary No B B B B 10/XX/2017
not provided
649210112 XXX XXX XXX 1 4554445 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. No 10/XX/1998 TX Purchase Primary No B B B B 10/XX/2017
Security Instrument Notary Date of 10/XX/1998 used as disbursement date for
compliance testing.
649210112 XXX XXX XXX 1 4554446 compliance 3 Missing Final HUD-1: No Missing Final HUD-1. No document containing fees provided. Any applicable No 10/XX/1998 TX Purchase Primary No D D D D 10/XX/2017
Document Used For Fee Federal, State or Local compliance testing is unreliable.
Testing
649210112 XXX XXX XXX 1 4554447 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using No 10/XX/1998 TX Purchase Primary No B B B B 10/XX/2017
Application No Fees an application date of 09/XX/1998 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/1998. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
649210100 XXX XXX 2 4543465 credit 3 Missing Document: Missing 9/XX/2005 OH Purchase Primary No C C C C 10/XX/2017
Final 1003
649210100 XXX XXX 2 4543547 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 9/XX/2005 OH Purchase Primary No B B B B 10/XX/2017
649210100 XXX XXX 2 4543548 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 9/XX/2005 OH Purchase Primary No B B B B 10/XX/2017
Application Test an application date of 08/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2005.
649210100 XXX XXX 2 4543549 compliance 2 RESPA Disclosure - Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 9/XX/2005 OH Purchase Primary No B B B B 10/XX/2017
Affiliated Business Loan Application Date. implementing regulation, Regulation X, for these type of violations.
Arrangement Disclosure
Not Provided Within 3
Business Days of
Application
649210102 XXX XXX 2 4545287 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 11/XX/2006 MA Refinance - Investment Yes B B B B 10/XX/2017
Cash-out -
Debt
Consolidation
649210282 XXX XXX 1 6334190 credit 3 Missing Document: Missing 3/XX/2007 FL Refinance - Primary No C C C C 5/XX/2018
Final 1003 Cash-out -
Debt
Consolidation
649210282 XXX XXX 1 6335009 compliance 2 (Doc Error) Initial GFE 3/XX/2007 FL Refinance - Primary No B B B B 5/XX/2018
not provided Cash-out -
Debt
Consolidation
649210282 XXX XXX 1 6335084 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 3/XX/2007 FL Refinance - Primary No B B B B 5/XX/2018
Application Test an application date of 02/XX/2007 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Debt
for testing was 02/XX/2007. Consolidation
649210282 XXX XXX 1 6335085 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2007 FL Refinance - Primary No B B B B 5/XX/2018
Missing Signature on Arrangement Disclosure. implementing regulation, Regulation X, for these type of violations. Cash-out -
Affiliated Business Debt
Arrangement Disclosure Consolidation
649210282 XXX XXX 1 6335086 compliance 2 RESPA Disclosure - Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2007 FL Refinance - Primary No B B B B 5/XX/2018
Affiliated Business Loan Application Date. implementing regulation, Regulation X, for these type of violations. Cash-out -
Arrangement Disclosure Debt
Not Provided Within 3 Consolidation
Business Days of
Application
649210282 XXX XXX 1 6335087 compliance 2 ARM Disclosure Prior to TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 FL Refinance - Primary No B B B B 5/XX/2018
Closing Timing borrower at least three (3) days prior to consummation for a loan that did not Cash-out -
start as an ARM. Debt
Consolidation
649210282 XXX XXX 1 6335088 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 FL Refinance - Primary No B B B B 5/XX/2018
Prior to Closing Timing CHARM Booklet, not provided to the borrower at least three (3) days prior to Cash-out -
consummation for a loan that did not start as an ARM. Debt
Consolidation
649210285 XXX XXX 1 6365034 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 9/XX/2005 PA Refinance - Primary No B B B B 5/XX/2018
Application Test an application date of 08/XX/2005 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Debt
for testing was 03/XX/2005. Consolidation
649210285 XXX XXX 1 6365037 compliance 2 (Doc Error) Initial GFE 9/XX/2005 PA Refinance - Primary No B B B B 5/XX/2018
not provided Cash-out -
Debt
Consolidation
649210283 XXX XXX 2 6328563 compliance 2 (Doc Error) Initial GFE 9/XX/2006 GA Refinance - Investment No B B B B 5/XX/2018
not provided Cash-out -
Debt
Consolidation
649210121 XXX XXX 2 6822784 credit 3 Missing Document: Missing Yes 8/XX/1997 WA Refinance - Primary No C C C C 6/XX/2018
Final 1003 UTD
649210121 XXX XXX 2 6823129 compliance 2 Due to lack of appraised Yes 8/XX/1997 WA Refinance - Primary No B B B B 6/XX/2018
value, compliance tests UTD
requiring an LTV were run
off an assumed value of a
contract sales price or
original loan amount,
whichever applies.
649210121 XXX XXX 2 6823141 compliance 2 (Doc Error) Initial GFE Yes 8/XX/1997 WA Refinance - Primary No B B B B 6/XX/2018
not provided UTD
649210121 XXX XXX 2 6823149 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. Yes 8/XX/1997 WA Refinance - Primary No B B B B 6/XX/2018
Security Instrument Notary Date of 08/XX/1997 used as disbursement date for UTD
compliance testing.
649210121 XXX XXX 2 6823150 compliance 3 Missing Final HUD-1: No Missing Final HUD-1. No document containing fees provided. Any applicable Yes 8/XX/1997 WA Refinance - Primary No D D D D 6/XX/2018
Document Used For Fee Federal, State or Local compliance testing is unreliable. UTD
Testing
649210121 XXX XXX 2 6823151 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using Yes 8/XX/1997 WA Refinance - Primary No B B B B 6/XX/2018
Application No Fees an application date of 07/XX/1997 which is 1 months prior to consummation. A UTD
lookback was performed to determine this application date. The final date used
for testing was 02/XX/1997. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
649210121 XXX XXX 2 6823153 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 8/XX/1997 8/XX/1998 WA Refinance - Primary No B B B B 6/XX/2018
borrower. UTD
649210121 XXX XXX 2 6823154 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 8/XX/1997 8/XX/1998 WA Refinance - Primary No B B B B 6/XX/2018
Status CHARM Booklet, not provided to the borrower. UTD
649210121 XXX XXX 2 6823155 compliance 2 Notice of Right to Cancel Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. Yes 8/XX/1997 8/XX/2000 WA Refinance - Primary No B B B B 6/XX/2018
Missing UTD
649210121 XXX XXX 2 6823156 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Yes 8/XX/1997 8/XX/2000 WA Refinance - Primary No B B B B 6/XX/2018
Assignee liability. UTD
649210126 XXX XXX 1 6944221 credit 3 Missing Document: Missing Yes 7/XX/2006 CA Refinance - Primary No C C C C 6/XX/2018
Final 1003 Cash-out -
Debt
Consolidation
649210126 XXX XXX 1 6949463 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using Yes 7/XX/2006 CA Refinance - Primary No B B B B 6/XX/2018
Application Test an application date of 06/XX/2006 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Debt
for testing was 01/XX/2006. Consolidation
649210126 XXX XXX 1 6949464 compliance 2 RESPA Disclosure - Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or Yes 7/XX/2006 CA Refinance - Primary No B B B B 6/XX/2018
Affiliated Business Loan Application Date. implementing regulation, Regulation X, for these type of violations. Cash-out -
Arrangement Disclosure Debt
Not Provided Within 3 Consolidation
Business Days of
Application
649210126 XXX XXX 1 6949465 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 7/XX/2006 7/XX/2007 CA Refinance - Primary No B B B B 6/XX/2018
Loan Application Date. Cash-out -
Debt
Consolidation
649210126 XXX XXX 1 6949466 compliance 2 CHARM Booklet Disclosure Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 7/XX/2006 7/XX/2007 CA Refinance - Primary No B B B B 6/XX/2018
Timing Loan Application Date. Cash-out -
Debt
Consolidation
649210126 XXX XXX 1 6949467 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization did not disclose a tax service fee of $XXX $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable Yes 7/XX/2006 7/XX/2009 CA Refinance - Primary No B B B B 6/XX/2018
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. as a prepaid finance charge. transactions. Unlimited as a defense to foreclosure. Assignee liability. Cash-out -
Debt
Consolidation
649210126 XXX XXX 1 7016597 compliance 3 Missing Final HUD-1: Missing Final HUD-1: Title Company Closing Statement used for any applicable Yes 7/XX/2006 CA Refinance - Primary No D D D D 6/XX/2018
Title Co. Closing Federal, State or Local compliance testing. Cash-out -
Statement Used For Fee Debt
Testing Consolidation
649210122 XXX XXX 2 6846539 compliance 2 (Doc Error) Initial GFE 8/XX/2007 NY Refinance - Primary No B B B B 6/XX/2018
not provided Cash-out -
Other
649210122 XXX XXX 2 6846645 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 8/XX/2007 NY Refinance - Primary No B B B B 6/XX/2018
Cash-out -
Other
649210122 XXX XXX 2 6846652 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 8/XX/2007 8/XX/2010 NY Refinance - Primary No B B B B 6/XX/2018
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. Itemization of Amount Financed. transactions. Unlimited as a defense to foreclosure. Assignee liability. Cash-out -
Other
649210122 XXX XXX 2 6846653 compliance 2 TILA - Incorrect Right To Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing 8/XX/2007 8/XX/2010 NY Refinance - Primary No B B B B 6/XX/2018
Cancel Form Used - H-8 Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses Cash-out -
Used on Same Lender form should have been used. the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that Other
Refinance (Circuit 2, 5, creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for
7, 8, 9, 10 or DC) refinances involving the same creditor.
649210122 XXX XXX 2 6873571 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 8/XX/2007 NY Refinance - Primary No B B B B 6/XX/2018
Affiliated Business Disclosure to applicant within three (3) business days of application. implementing regulation, Regulation X, for these type of violations. Cash-out -
Arrangement Disclosure Other
Not Provided Within 3
Business Days of
Application
649210122 XXX XXX 2 6873572 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2007 8/XX/2008 NY Refinance - Primary No B B B B 6/XX/2018
borrower within three (3) days of application. Cash-out -
Other
649210122 XXX XXX 2 6873573 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2007 8/XX/2008 NY Refinance - Primary No B B B B 6/XX/2018
Timing CHARM Booklet, not provided to the borrower within three (3) days of application. Cash-out -
Other
649210127 XXX XXX 2 6974236 compliance 2 Federal FACTA Disclosure FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 12/XX/2006 CA Refinance - Primary No B B B B 6/XX/2018
Timing Test within a reasonably practicable time after using credit score. Cash-out -
Other
649210127 XXX XXX 2 7048679 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 12/XX/2006 CA Refinance - Primary No B B B B 6/XX/2018
Application Test an application date of 11/XX/2006 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Other
for testing was 11/XX/2006.
649210127 XXX XXX 2 7048681 compliance 2 RESPA Disclosure - Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 12/XX/2006 CA Refinance - Primary No B B B B 6/XX/2018
Affiliated Business Loan Application Date. implementing regulation, Regulation X, for these type of violations. Cash-out -
Arrangement Disclosure Other
Not Provided Within 3
Business Days of
Application
649210124 XXX XXX 2 6859598 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 3/XX/2006 CA Refinance - Primary No B B B B 6/XX/2018
Application Test an application date of 02/XX/2006 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Debt
for testing was 09/XX/2005. Consolidation
649210131 XXX XXX 1 8981963 compliance 2 ARM Disclosure Status Unable to determine if loan file contains ARM Disclosure due to missing TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2004 10/XX/2005 NY Refinance - Primary No B B B B 11/XX/2018
information. Cash-out -
Other
649210131 XXX XXX 1 8981969 compliance 2 TILA Rescission - Truth in Lending Act: Subject loan transaction disbursed on 11/XX/2004, prior to TILA ROR - 3yrs for rescindable transactions. 10/XX/2004 10/XX/2007 NY Refinance - Primary No B B B B 11/XX/2018
Disbursement Date Less three (3) business days from transaction date of 11/XX/2004. Cash-out -
than 3 Business Days From Other
Transaction Date
649210131 XXX XXX 1 8981970 compliance 2 TILA Notice of Right to Truth in Lending Act: Actual Date(s) on Notice of Right to Cancel occurs prior TILA ROR - 3yrs for rescindable transactions. 10/XX/2004 10/XX/2007 NY Refinance - Primary No B B B B 11/XX/2018
Cancel Expiration Date to expected date(s). Cash-out -
Prior or equal to Other
Disbursement Date
649210131 XXX XXX 1 8983374 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2004 10/XX/2005 NY Refinance - Primary No B B B B 11/XX/2018
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649210135 XXX XXX XXX 1 9294186 compliance 2 Right of Rescission Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. 1/XX/2007 1/XX/2010 FL Refinance - Primary No B B B B 11/XX/2018
Timing - Receipt Date timing requirements. Cash-out -
Missing Debt
Consolidation
649210135 XXX XXX XXX 1 9294187 compliance 2 Final TIL Not Provided to Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 1/XX/2007 1/XX/2010 FL Refinance - Primary No B B B B 11/XX/2018
Borrower At or Before Assignee liability. Cash-out -
Consummation Debt
Consolidation
649210135 XXX XXX XXX 1 9317867 compliance 2 (Doc Error) TIL Error: TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 1/XX/2007 1/XX/2010 FL Refinance - Primary No B B B B 11/XX/2018
Borrower signature not Assignee liability. Cash-out -
dated. Debt
Consolidation
649210135 XXX XXX XXX 1 9318216 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 1/XX/2007 FL Refinance - Primary No B B B B 11/XX/2018
Application Test an application date of 12/XX/2006 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Debt
for testing was 07/XX/2006. Consolidation
649210138 XXX XXX XXX 2 10021154 credit 3 Missing Document: Missing 2/XX/2006 NJ Refinance - Primary Yes C C C C 1/XX/2019
Final 1003 Cash-out -
Debt
Consolidation
649210138 XXX XXX XXX 2 10021155 compliance 2 (Doc Error) Initial GFE 2/XX/2006 NJ Refinance - Primary Yes B B B B 1/XX/2019
not provided Cash-out -
Debt
Consolidation
649210138 XXX XXX XXX 2 10021156 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 2/XX/2006 NJ Refinance - Primary Yes B B B B 1/XX/2019
Cash-out -
Debt
Consolidation
649210138 XXX XXX XXX 2 10021157 compliance 2 Notice of Right to Cancel Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 2/XX/2006 2/XX/2009 NJ Refinance - Primary Yes B B B B 1/XX/2019
Missing Cash-out -
Debt
Consolidation
649210138 XXX XXX XXX 2 10021158 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 2/XX/2006 2/XX/2009 NJ Refinance - Primary Yes B B B B 1/XX/2019
Assignee liability. Cash-out -
Debt
Consolidation
649210138 XXX XXX XXX 2 10021159 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 2/XX/2006 NJ Refinance - Primary Yes B B B B 1/XX/2019
Application Test an application date of 01/XX/2006 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Debt
for testing was 01/XX/2006. Consolidation
649210138 XXX XXX XXX 2 10021160 compliance 2 Payoff Statement Missing Missing Payoff Statement: Unable to determine if a prepayment penalty was 2/XX/2006 NJ Refinance - Primary Yes B B B B 1/XX/2019
included in the pay-off which may impact high cost findings. Cash-out -
Debt
Consolidation
649210134 XXX XXX XXX 2 10031745 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 12/XX/2006 CA Refinance - Primary No B B B B 1/XX/2019
Application Test an application date of 11/XX/2006 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2006.
649210134 XXX XXX XXX 2 10031746 compliance 2 RESPA Disclosure - Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 12/XX/2006 CA Refinance - Primary No B B B B 1/XX/2019
Affiliated Business Loan Application Date. implementing regulation, Regulation X, for these type of violations. Rate/Term
Arrangement Disclosure
Not Provided Within 3
Business Days of
Application
649210134 XXX XXX XXX 2 10031747 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2006 12/XX/2007 CA Refinance - Primary No B B B B 1/XX/2019
Loan Application Date. Rate/Term
649210134 XXX XXX XXX 2 10031748 compliance 2 CHARM Booklet Disclosure Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2006 12/XX/2007 CA Refinance - Primary No B B B B 1/XX/2019
Timing Loan Application Date. Rate/Term
649210171 XXX XXX XXX 2 11117012 credit 3 Missing Document: 5/XX/2007 MA Refinance - Primary Yes C C C C
Mortgage Insurance Rate/Term
Certificate (MIC) not
provided
649210171 XXX XXX XXX 2 11117013 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 5/XX/2007 MA Refinance - Primary Yes B B B B
Affiliated Business Disclosure to applicant within three (3) business days of application. implementing regulation, Regulation X, for these type of violations. Rate/Term
Arrangement Disclosure
Not Provided Within 3
Business Days of
Application
649210174 XXX XXX XXX 1 11118062 credit 3 Missing Document: Missing 8/XX/2007 NY Purchase Primary No C C C C
Final 1003
649210174 XXX XXX XXX 1 11118063 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 8/XX/2007 NY Purchase Primary No B B B B
Application Test an application date of 07/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 07/XX/2007.
649210175 XXX XXX XXX 2 11119926 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 8/XX/2007 NY Refinance - Primary No B B B B
Affiliated Business Disclosure to applicant within three (3) business days of application. implementing regulation, Regulation X, for these type of violations. Cash-out -
Arrangement Disclosure Other
Not Provided Within 3
Business Days of
Application
649210175 XXX XXX XXX 2 11119927 compliance 2 TILA Rescission - Truth in Lending Act: Subject loan transaction disbursed on 08/XX/2007, prior to TILA ROR - 3yrs for rescindable transactions. 8/XX/2007 8/XX/2010 NY Refinance - Primary No B B B B
Disbursement Date Less three (3) business days from transaction date of 08/XX/2007. Cash-out -
than 3 Business Days From Other
Transaction Date
649210175 XXX XXX XXX 2 11119928 compliance 2 TILA - Incorrect Right To Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing 8/XX/2007 8/XX/2010 NY Refinance - Primary No B B B B
Cancel Form Used - H-8 Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses Cash-out -
Used on Same Lender form should have been used. the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that Other
Refinance (Circuit 2, 5, creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for
7, 8, 9, 10 or DC) refinances involving the same creditor.
649210175 XXX XXX XXX 2 11119929 compliance 2 TILA Notice of Right to Truth in Lending Act: Actual Date(s) on Notice of Right to Cancel occurs prior TILA ROR - 3yrs for rescindable transactions. 8/XX/2007 8/XX/2010 NY Refinance - Primary No B B B B
Cancel Expiration Date to expected date(s). Cash-out -
Prior or equal to Other
Disbursement Date
649210159 XXX XXX XXX 1 11126966 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 5/XX/2005 CA Refinance - Primary No B B B B
Application Test an application date of 04/XX/2005 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Other
for testing was 04/XX/2005.
649210159 XXX XXX XXX 1 11126967 compliance 2 RESPA Disclosure - Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 5/XX/2005 CA Refinance - Primary No B B B B
Affiliated Business Loan Application Date. implementing regulation, Regulation X, for these type of violations. Cash-out -
Arrangement Disclosure Other
Not Provided Within 3
Business Days of
Application
649210159 XXX XXX XXX 1 11126968 credit 3 Missing Document: Missing 5/XX/2005 CA Refinance - Primary No C C C C
Final 1003 Cash-out -
Other
649210160 XXX XXX XXX 2 11127483 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 7/XX/2005 CA Refinance - Primary No B B B B
Affiliated Business Disclosure to applicant within three (3) business days of application. implementing regulation, Regulation X, for these type of violations. Cash-out -
Arrangement Disclosure Debt
Not Provided Within 3 Consolidation
Business Days of
Application
649210160 XXX XXX XXX 2 11127484 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2005 7/XX/2006 CA Refinance - Primary No B B B B
borrower within three (3) days of application. Cash-out -
Debt
Consolidation
649210160 XXX XXX XXX 2 11127485 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2005 7/XX/2006 CA Refinance - Primary No B B B B
Status CHARM Booklet, not provided to the borrower. Cash-out -
Debt
Consolidation
649210160 XXX XXX XXX 2 11127486 compliance 2 TILA Rescission - Truth in Lending Act: Subject loan transaction disbursed on 07/XX/2005, prior to TILA ROR - 3yrs for rescindable transactions. 7/XX/2005 7/XX/2008 CA Refinance - Primary No B B B B
Disbursement Date Less three (3) business days from transaction date of 07/XX/2005. Cash-out -
than 3 Business Days From Debt
Transaction Date Consolidation
649210150 XXX XXX XXX 2 11130784 credit 3 Missing Document: 3/XX/2003 TX Purchase Primary No C C C C
Mortgage Insurance
Certificate (MIC) not
provided
649210150 XXX XXX XXX 2 11130785 credit 3 Missing Document: Missing 3/XX/2003 TX Purchase Primary No C C C C
Final 1003
649210150 XXX XXX XXX 2 11130786 compliance 2 (Doc Error) Initial GFE 3/XX/2003 TX Purchase Primary No B B B B
not provided
649210150 XXX XXX XXX 2 11130787 credit 3 Missing Document: Credit 3/XX/2003 TX Purchase Primary No D D D D
Report not provided
649210153 XXX XXX XXX 2 11131448 compliance 2 Michigan Consumer Michigan Consumer Mortgage Protection Act: List of HUD-approved credit 9/XX/2003 MI Refinance - Primary No B B B B
Mortgage Protection Act counseling agencies not provided to borrower. Cash-out -
(Counseling Agencies Debt
List) Consolidation
649210153 XXX XXX XXX 2 11131449 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2003 9/XX/2004 MI Refinance - Primary No B B B B
borrower within three (3) days of application. Cash-out -
Debt
Consolidation
649210153 XXX XXX XXX 2 11131450 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2003 9/XX/2004 MI Refinance - Primary No B B B B
Timing CHARM Booklet, not provided to the borrower within three (3) days of application. Cash-out -
Debt
Consolidation
649210153 XXX XXX XXX 2 11131451 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from It appears a lower Index was used at origination than the $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 9/XX/2003 9/XX/2006 MI Refinance - Primary No B B B B
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. 1.22% Index available within the look-back period. transactions. Unlimited as a defense to foreclosure. Assignee liability. Cash-out -
Debt
Consolidation
649210155 XXX XXX XXX 1 11133263 credit 3 Missing Document: 10/XX/2004 MI Refinance - Primary No C C C C
Mortgage Insurance Rate/Term
Certificate (MIC) not
provided
649210155 XXX XXX XXX 1 11133264 compliance 2 Michigan Consumer Michigan Consumer Mortgage Protection Act: List of HUD-approved credit 10/XX/2004 MI Refinance - Primary No B B B B
Mortgage Protection Act counseling agencies not provided to borrower. Rate/Term
(Counseling Agencies
List)
649210155 XXX XXX XXX 1 11133265 credit 3 Missing Document: Missing 10/XX/2004 MI Refinance - Primary No C C C C
Final 1003 Rate/Term
649210155 XXX XXX XXX 1 11133266 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 10/XX/2004 MI Refinance - Primary No B B B B
Application Test an application date of 10/XX/2004 which is 0 months prior to consummation. A Rate/Term
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2004.
649210155 XXX XXX XXX 1 11133267 compliance 2 RESPA Disclosure - Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 10/XX/2004 MI Refinance - Primary No B B B B
Affiliated Business Loan Application Date. implementing regulation, Regulation X, for these type of violations. Rate/Term
Arrangement Disclosure
Not Provided Within 3
Business Days of
Application
649210155 XXX XXX XXX 1 11133268 compliance 2 Michigan Consumer Unable to determine compliance with timing requirements due to missing Initial Assignee liability is unclear. Purchasers and assignees would not appear to be liable for violations 10/XX/2004 MI Refinance - Primary No B B B B
Mortgage Protection Act Loan Application Date. of the Act, except to the extent involved I violations arising from servicing or collecting. Rate/Term
(Borrower Bill of Rights
Disclosure Not Provided
Timely)
649210155 XXX XXX XXX 1 11133269 compliance 2 Michigan Consumer Caution Unable to determine compliance with timing requirements due to missing Initial Assignee liability is unclear. Purchasers and assignees would not appear to be liable for violations 10/XX/2004 MI Refinance - Primary No B B B B
and Home Ownership Loan Application Date. of the Act, except to the extent involved I violations arising from servicing or collecting. Rate/Term
Counseling Notice Not
Provided Timely
649210158 XXX XXX XXX 2 11133809 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 4/XX/2005 CA Refinance - Primary No B B B B
Application Test an application date of 03/XX/2005 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Debt
for testing was 03/XX/2005. Consolidation
649210158 XXX XXX XXX 2 11133810 credit 3 Missing Document: Missing 4/XX/2005 CA Refinance - Primary No C C C C
Final 1003 Cash-out -
Debt
Consolidation
649210161 XXX XXX XXX 1 11135044 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 10/XX/2005 NY Refinance - Primary No B B B B
Application Test an application date of 09/XX/2005 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Other
for testing was 04/XX/2005.
649210161 XXX XXX XXX 1 11135045 credit 3 Missing Document: Credit 10/XX/2005 NY Refinance - Primary No D D D D
Report not provided Cash-out -
Other
649210162 XXX XXX XXX 2 11137856 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 10/XX/2005 CA Refinance - Primary No B B B B
Application Test an application date of 09/XX/2005 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2005.
649210162 XXX XXX XXX 2 11137857 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 10/XX/2005 CA Refinance - Primary No B B B B
Missing Signature on Arrangement Disclosure. implementing regulation, Regulation X, for these type of violations. Rate/Term
Affiliated Business
Arrangement Disclosure
649210162 XXX XXX XXX 2 11137858 compliance 2 RESPA Disclosure - Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 10/XX/2005 CA Refinance - Primary No B B B B
Affiliated Business Loan Application Date. implementing regulation, Regulation X, for these type of violations. Rate/Term
Arrangement Disclosure
Not Provided Within 3
Business Days of
Application
649210162 XXX XXX XXX 2 11137859 credit 3 Missing Document: Missing 10/XX/2005 CA Refinance - Primary No C C C C
Final 1003 Rate/Term
649210162 XXX XXX XXX 2 11137860 compliance 2 Incorrect Right To Cancel Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing 10/XX/2005 10/XX/2008 CA Refinance - Primary No B B B B
Form Used - H-9 Used on Model Form for a refinance by a creditor that is not considered the original risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses Rate/Term
Non Same Lender Refinance creditor. The H-9 form was used, the H-8 form should have been used. the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that
creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for
refinances involving the same creditor.
649210164 XXX XXX XXX 1 11139407 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 8/XX/2006 NY Refinance - Primary No B B B B
Application Test an application date of 07/XX/2006 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Debt
for testing was 02/XX/2006. Consolidation
649210164 XXX XXX XXX 1 11139408 credit 3 Missing Document: Missing 8/XX/2006 NY Refinance - Primary No C C C C
Final 1003 Cash-out -
Debt
Consolidation
649210163 XXX XXX XXX 2 11141050 credit 3 Missing Document: 4/XX/2006 CA Refinance - Primary No C C C C
Mortgage Insurance Cash-out -
Certificate (MIC) not Other
provided
649210166 XXX XXX XXX 2 11144220 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 10/XX/2006 CA Purchase Second Home No B B B B
Affiliated Business Disclosure to applicant within three (3) business days of application. implementing regulation, Regulation X, for these type of violations.
Arrangement Disclosure
Not Provided Within 3
Business Days of
Application
649210166 XXX XXX XXX 2 11144221 compliance 2 Disparity in Occupancy The mortgage loan file contains documenting evidence the consumer intends to Discrepancy in Occupancy does not have high cost 10/XX/2006 CA Purchase Second Home No B B B B 2019/XX/XX: Discrepancy in
occupy the subject property as their primary residence. (Compliance testing implications. Testing loan as primary residence does not Occupancy does not have high
performed based on the Occupancy Type of Second Home) result in high cost findings. cost implications. Testing
loan as primary residence
does not result in high cost
findings.
649210157 XXX XXX XXX 2 11166742 compliance 2 (Doc Error) Initial GFE 3/XX/2005 FL Purchase Primary No B B B B
not provided
649210157 XXX XXX XXX 2 11166747 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 3/XX/2005 FL Purchase Primary No B B B B
Application Test an application date of 02/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 09/XX/2004.
649210157 XXX XXX XXX 2 11166751 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Itemization of amount financed does not reflect a $XXX $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 3/XX/2005 3/XX/2006 FL Purchase Primary No B B B B
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. closing delay fee, a $XXX scanning and storage fee, and a transactions. Unlimited as a defense to foreclosure. Assignee liability.
$XXX title courier fee as prepaid finance charges.
649210157 XXX XXX XXX 2 11166760 credit 2 Valuation Error: APN Valuation Type: Appraisal / Valuation Report Date: 01/XX/2005 3/XX/2005 FL Purchase Primary No B B B B
Number not provided.
649210169 XXX XXX XXX 2 11168842 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 3/XX/2007 CA Refinance - Primary No B B B B
Application Test an application date of 02/XX/2007 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Debt
for testing was 02/XX/2007. Consolidation
649210169 XXX XXX XXX 2 11168843 compliance 2 RESPA Disclosure - Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2007 CA Refinance - Primary No B B B B
Affiliated Business Loan Application Date. implementing regulation, Regulation X, for these type of violations. Cash-out -
Arrangement Disclosure Debt
Not Provided Within 3 Consolidation
Business Days of
Application
649210169 XXX XXX XXX 2 11168844 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 CA Refinance - Primary No B B B B
Loan Application Date. Cash-out -
Debt
Consolidation
649210169 XXX XXX XXX 2 11168845 compliance 2 CHARM Booklet Disclosure Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 CA Refinance - Primary No B B B B
Timing Loan Application Date. Cash-out -
Debt
Consolidation
649210149 XXX XXX XXX 2 11173742 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. Yes 7/XX/2001 PA Refinance - Primary No B B B B
Security Instrument Notary Date of 07/XX/2001 used as disbursement date for Cash-out -
compliance testing. Other
649210149 XXX XXX XXX 2 11173743 compliance 3 Missing Final HUD-1: No Missing Final HUD-1. No document containing fees provided. Any applicable Yes 7/XX/2001 PA Refinance - Primary No D D D D
Document Used For Fee Federal, State or Local compliance testing is unreliable. Cash-out -
Testing Other
649210149 XXX XXX XXX 2 11173744 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using Yes 7/XX/2001 PA Refinance - Primary No B B B B
Application No Fees an application date of 06/XX/2001 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Other
for testing was 01/XX/2001. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
649210149 XXX XXX XXX 2 11173745 compliance 2 Notice of Right to Cancel Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. Yes 7/XX/2001 7/XX/2004 PA Refinance - Primary No B B B B
Missing Cash-out -
Other
649210149 XXX XXX XXX 2 11173746 compliance 2 Final TIL Not Provided to Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Yes 7/XX/2001 7/XX/2004 PA Refinance - Primary No B B B B
Borrower At or Before Assignee liability. Cash-out -
Consummation Other
649210149 XXX XXX XXX 2 11173747 compliance 2 (Doc Error) Initial GFE Yes 7/XX/2001 PA Refinance - Primary No B B B B
not provided Cash-out -
Other
649210149 XXX XXX XXX 2 11173748 credit 3 Missing Document: Yes 7/XX/2001 PA Refinance - Primary No D D D D
Appraisal not provided Cash-out -
Other
649210149 XXX XXX XXX 2 11173749 compliance 2 Due to lack of appraised Yes 7/XX/2001 PA Refinance - Primary No B B B B
value, compliance tests Cash-out -
requiring an LTV were run Other
off an assumed value of a
contract sales price or
original loan amount,
whichever applies.
649210151 XXX XXX XXX 2 11175510 compliance 3 Missing Final HUD-1: Missing Final HUD-1: Estimated HUD-1 used for any applicable Federal, State or Yes 9/XX/2003 CA Refinance - Primary No D D D D
Estimated HUD-1 Used For Local compliance testing. Rate/Term
Fee Testing
649210154 XXX XXX XXX 1 11175595 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2003 11/XX/2004 NH Refinance - Primary No B B B B
Status CHARM Booklet, not provided to the borrower. Rate/Term
649210154 XXX XXX XXX 1 11175596 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine the reason for the under disclosure. No $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 11/XX/2003 11/XX/2006 NH Refinance - Primary No B B B B
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. itemization of the amount financed located. transactions. Unlimited as a defense to foreclosure. Assignee liability. Rate/Term
649210168 XXX XXX XXX 1 11176746 credit 3 Missing Document: Missing Yes 1/XX/2007 CA Refinance - Primary No C C C C
Final 1003 Cash-out -
Other
649210168 XXX XXX XXX 1 11176747 compliance 3 Missing Final HUD-1: Missing Final HUD-1: Title Company Closing Statement used for any applicable Yes 1/XX/2007 CA Refinance - Primary No D D D D
Title Co. Closing Federal, State or Local compliance testing. Cash-out -
Statement Used For Fee Other
Testing
649210168 XXX XXX XXX 1 11176748 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using Yes 1/XX/2007 CA Refinance - Primary No B B B B
Application Test an application date of 12/XX/2006 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Other
for testing was 12/XX/2006.
649210168 XXX XXX XXX 1 11176749 compliance 2 RESPA Disclosure - Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or Yes 1/XX/2007 CA Refinance - Primary No B B B B
Affiliated Business Loan Application Date. implementing regulation, Regulation X, for these type of violations. Cash-out -
Arrangement Disclosure Other
Not Provided Within 3
Business Days of
Application
649210168 XXX XXX XXX 1 11176750 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 1/XX/2007 1/XX/2008 CA Refinance - Primary No B B B B
Loan Application Date. Cash-out -
Other
649210168 XXX XXX XXX 1 11176751 compliance 2 CHARM Booklet Disclosure Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 1/XX/2007 1/XX/2008 CA Refinance - Primary No B B B B
Timing Loan Application Date. Cash-out -
Other
649210148 XXX XXX XXX 2 11185349 credit 3 Missing Document: Missing No 7/XX/1984 KY UTD - UTD UTD No C C C C
Final 1003
649210148 XXX XXX XXX 2 11185350 credit 3 Missing Document: Credit No 7/XX/1984 KY UTD - UTD UTD No D D D D
Report not provided
649210148 XXX XXX XXX 2 11185351 compliance 2 Due to lack of appraised No 7/XX/1984 KY UTD - UTD UTD No B B B B
value, compliance tests
requiring an LTV were run
off an assumed value of a
contract sales price or
original loan amount,
whichever applies.
649210148 XXX XXX XXX 2 11185352 credit 3 Missing Document: No 7/XX/1984 KY UTD - UTD UTD No D D D D
Appraisal not provided
649210148 XXX XXX XXX 2 11185353 compliance 2 (Doc Error) Initial GFE No 7/XX/1984 KY UTD - UTD UTD No B B B B
not provided
649210148 XXX XXX XXX 2 11185354 compliance 2 Unable to determine No 7/XX/1984 KY UTD - UTD UTD No B B B B
occupancy, compliance
results were generated
using a defaulted value
of Primary.
649210148 XXX XXX XXX 2 11185355 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. No 7/XX/1984 KY UTD - UTD UTD No B B B B
Security Instrument Notary Date of 07/XX/1984 used as disbursement date for
compliance testing.
649210148 XXX XXX XXX 2 11185357 compliance 3 Missing Final HUD-1: No Missing Final HUD-1. No document containing fees provided. Any applicable No 7/XX/1984 KY UTD - UTD UTD No D D D D
Document Used For Fee Federal, State or Local compliance testing is unreliable.
Testing
649210148 XXX XXX XXX 2 11185358 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using No 7/XX/1984 KY UTD - UTD UTD No B B B B
Application No Fees an application date of 06/XX/1984 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/1984. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
649210148 XXX XXX XXX 2 11185359 compliance 2 Property Type Not (Missing Data) Property Type. If property type is other than single family No 7/XX/1984 KY UTD - UTD UTD No B B B B
Provided residence, state and federal testing may be impacted.
649210148 XXX XXX XXX 2 11185360 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA No 7/XX/1984 7/XX/1985 KY UTD - UTD UTD No B B B B
borrower.
649210148 XXX XXX XXX 2 11185361 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA No 7/XX/1984 7/XX/1985 KY UTD - UTD UTD No B B B B
Status CHARM Booklet, not provided to the borrower.
649210148 XXX XXX XXX 2 11185362 compliance 2 Notice of Right to Cancel Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. No 7/XX/1984 7/XX/1987 KY UTD - UTD UTD No B B B B
Missing
649210148 XXX XXX XXX 2 11185363 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. No 7/XX/1984 7/XX/1987 KY UTD - UTD UTD No B B B B
Assignee liability.
649210117 XXX XXX XXX 2 11187179 compliance 2 (Doc Error) Initial GFE 8/XX/2003 MI Refinance - Primary No B B B B 3/XX/2019
not provided Cash-out -
Other
649210117 XXX XXX XXX 2 11187180 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 8/XX/2003 MI Refinance - Primary No B B B B 3/XX/2019
Application Test an application date of 07/XX/2003 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Other
for testing was 02/XX/2003.
649210117 XXX XXX XXX 2 11187181 compliance 2 Michigan Consumer Michigan Consumer Mortgage Protection Act: Borrower Bill of Rights disclosure Assignee liability is unclear. Purchasers and assignees would not appear to be liable for violations 8/XX/2003 MI Refinance - Primary No B B B B 3/XX/2019
Mortgage Protection Act not provided to borrower. of the Act, except to the extent involved I violations arising from servicing or collecting. Cash-out -
(Borrower Bill of Rights Other
Disclosure Not Provided)
649210117 XXX XXX XXX 2 11187182 compliance 2 Michigan Consumer Caution Michigan Consumer Mortgage Protection Act: Consumer Caution and Home Ownership Assignee liability is unclear. Purchasers and assignees would not appear to be liable for violations 8/XX/2003 MI Refinance - Primary No B B B B 3/XX/2019
and Home Ownership Counseling Notice not provided to borrower. of the Act, except to the extent involved I violations arising from servicing or collecting. Cash-out -
Counseling Notice Not Other
Provided
649210117 XXX XXX XXX 2 11187183 compliance 2 Michigan Consumer Michigan Consumer Mortgage Protection Act: List of HUD-approved credit 8/XX/2003 MI Refinance - Primary No B B B B 3/XX/2019
Mortgage Protection Act counseling agencies not provided to borrower. Cash-out -
(Counseling Agencies Other
List)
649210117 XXX XXX XXX 2 11187184 compliance 2 Notice of Right to Cancel Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 8/XX/2003 8/XX/2006 MI Refinance - Primary No B B B B 3/XX/2019
Missing Cash-out -
Other
649210117 XXX XXX XXX 2 11187185 credit 3 Missing Document: Credit 8/XX/2003 MI Refinance - Primary No D D D D 3/XX/2019
Report not provided Cash-out -
Other
649210279 XXX XXX 1 12981440 compliance 3 Missing Final HUD-1: No Missing Final HUD-1. No document containing fees provided. Any applicable Yes 12/XX/2005 CA Refinance - Primary No D D D D 7/XX/2019 Yes 2019/XX/XX: Not Found
Document Used For Fee Federal, State or Local compliance testing is unreliable. Cash-out -
Testing Other
649210279 XXX XXX 1 12981441 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 12/XX/2005 12/XX/2006 CA Refinance - Primary No B B B B 7/XX/2019
Test borrower within three (3) days of application. Cash-out -
Other
649210188 XXX XXX XXX 1 14195160 compliance 2 (Doc Error) Initial GFE 9/XX/2006 OH Refinance - Primary No B B B B 8/XX/2019
not provided Cash-out -
Other
649210188 XXX XXX XXX 1 14195161 credit 3 Final Title Policy is File does not contain either Preliminary or Final Title. 9/XX/2006 OH Refinance - Primary No C C C C 8/XX/2019
missing. No evidence of Cash-out -
title in file. Other
649210188 XXX XXX XXX 1 14195162 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 9/XX/2006 OH Refinance - Primary No B B B B 8/XX/2019
Application Test an application date of 08/XX/2006 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Other
for testing was 03/XX/2006.
649210188 XXX XXX XXX 1 14195163 compliance 2 Notice of Right to Cancel Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 9/XX/2006 9/XX/2009 OH Refinance - Primary No B B B B 8/XX/2019
Missing Cash-out -
Other
649210188 XXX XXX XXX 1 14195164 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 9/XX/2006 9/XX/2009 OH Refinance - Primary No B B B B 8/XX/2019
Assignee liability. Cash-out -
Other
649210179 XXX XXX XXX 2 14221036 compliance 2 (Doc Error) Initial GFE 6/XX/2005 FL Purchase Investment No B B B B 8/XX/2019
not provided
649210182 XXX XXX XXX 1 14221817 credit 3 Missing Document: 11/XX/2005 NC Purchase Investment No D D D D 8/XX/2019
Security Instrument -
Subject Lien not provided
649210183 XXX XXX XXX 2 14222344 compliance 2 (Doc Error) Initial GFE 5/XX/2004 CA Refinance - Investment No B B B B 8/XX/2019
not provided Rate/Term
649210184 XXX XXX XXX 1 14222372 compliance 1 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 10/XX/2006 NC Purchase Investment No A A A A 8/XX/2019 9/XX/2019 Yes 2019/XX/XX: Final HUD-1
Security Instrument Notary Date of 10/XX/2006 used as disbursement date for provided for review.
compliance testing. Exception cleared.
649210184 XXX XXX XXX 1 14222373 compliance 1 Missing Final HUD-1: No Missing Final HUD-1. No document containing fees provided. Any applicable 10/XX/2006 NC Purchase Investment No A A A A 8/XX/2019 9/XX/2019 Yes 2019/XX/XX: The issue 2019/XX/XX: Final HUD-1
Document Used For Fee Federal, State or Local compliance testing is unreliable. cited has either been provided for review.
Testing resolved or was Exception cleared.
determined to not be
an exception as noted.
The missing compliance
document (HUD1 signed
by borrower and
certified by
settlement agent)
required to test have
been located and
uploaded as #XXX_HUD1.
649210186 XXX XXX XXX 1 14223170 credit 3 Missing Document: Missing 12/XX/2006 FL Purchase Investment No C C C C 8/XX/2019
Final 1003
649210186 XXX XXX XXX 1 14223171 compliance 2 (Doc Error) Initial GFE 12/XX/2006 FL Purchase Investment No B B B B 8/XX/2019
not provided
649210186 XXX XXX XXX 1 14223172 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 12/XX/2006 FL Purchase Investment No B B B B 8/XX/2019
Application Test an application date of 11/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
649210187 XXX XXX XXX 1 14223179 credit 3 Missing Document: Missing 12/XX/2006 FL Purchase UTD No C C C C 8/XX/2019
Final 1003
649210187 XXX XXX XXX 1 14223180 compliance 2 Due to lack of appraised 12/XX/2006 FL Purchase UTD No B B B B 8/XX/2019
value, compliance tests
requiring an LTV were run
off an assumed value of a
contract sales price or
original loan amount,
whichever applies.
649210187 XXX XXX XXX 1 14223181 compliance 2 (Doc Error) Initial GFE 12/XX/2006 FL Purchase UTD No B B B B 8/XX/2019
not provided
649210187 XXX XXX XXX 1 14223182 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 12/XX/2006 FL Purchase UTD No B B B B 8/XX/2019
Application Test an application date of 11/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
649210187 XXX XXX XXX 1 14223183 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 12/XX/2006 12/XX/2007 FL Purchase UTD No B B B B 8/XX/2019
Assignee liability.
649210187 XXX XXX XXX 1 14223184 compliance 2 Unable to determine 12/XX/2006 FL Purchase UTD No B B B B 8/XX/2019
occupancy, compliance
results were generated
using a defaulted value
of Primary.
649210192 XXX XXX 1 15363421 credit 3 Missing Document: Missing No 7/XX/1995 CO Purchase Primary No C C C C 11/XX/2019
Final 1003
649210192 XXX XXX 1 15363423 credit 3 Missing Document: Flood No 7/XX/1995 CO Purchase Primary No C C C C 11/XX/2019
Certificate not provided
649210192 XXX XXX 1 15363424 compliance 2 (Doc Error) Initial GFE No 7/XX/1995 CO Purchase Primary No B B B B 11/XX/2019
not provided
649210192 XXX XXX 1 15363429 compliance 2 Due to lack of appraised No 7/XX/1995 CO Purchase Primary No B B B B 11/XX/2019
value, compliance tests
requiring an LTV were run
off an assumed value of a
contract sales price or
original loan amount,
whichever applies.
649210192 XXX XXX 1 15363430 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. No 7/XX/1995 CO Purchase Primary No B B B B 11/XX/2019
Security Instrument Notary Date of 07/XX/1995 used as disbursement date for
compliance testing.
649210192 XXX XXX 1 15363431 compliance 3 Missing Final HUD-1: No Missing Final HUD-1. No document containing fees provided. Any applicable No 7/XX/1995 CO Purchase Primary No D D D D 11/XX/2019
Document Used For Fee Federal, State or Local compliance testing is unreliable.
Testing
649210192 XXX XXX 1 15363432 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using No 7/XX/1995 CO Purchase Primary No B B B B 11/XX/2019
Application No Fees an application date of 06/XX/1995 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/1995. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
649210192 XXX XXX 1 15363433 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA No 7/XX/1995 7/XX/1996 CO Purchase Primary No B B B B 11/XX/2019
Test borrower.
649210192 XXX XXX 1 15363434 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA No 7/XX/1995 7/XX/1996 CO Purchase Primary No B B B B 11/XX/2019
Status CHARM Booklet, not provided to the borrower.
649210192 XXX XXX 1 15363435 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. No 7/XX/1995 7/XX/1996 CO Purchase Primary No B B B B 11/XX/2019
Assignee liability.
649210200 XXX XXX 1 16476785 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 2/XX/2007 SC Refinance - Primary No B B B B 2/XX/2020
Application Test an application date of 01/XX/2007 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date.
649210200 XXX XXX 1 16476786 compliance 2 South Carolina Home Loan South Carolina Home Loan: Borrower not provided with a document specifying the Exceptions occurring more than 6 years ago may be outside the states statute of limitations. Due to 2/XX/2007 2/XX/2013 SC Refinance - Primary No B B B B 2/XX/2020
(Complaint Agency agency designated to receive complaints or inquiries about the origination and the potential remedies available to a court, this exception carries elevated risk to an assignee Rate/Term
Disclosure Not Provided) making of the loan. during the initial 6 years after occurrence of the violation. After the expiration of this 6 year
period, the exception retains risk for claims raised as a defense to foreclosure, but not at the same
level as during the initial 6 years for affirmative claims.
649210200 XXX XXX 1 16477099 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 2/XX/2007 2/XX/2010 SC Refinance - Primary No B B B B 2/XX/2020
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. itemization of amount financed. transactions. Unlimited as a defense to foreclosure. Assignee liability. Rate/Term
649210280 XXX XXX 1 18222590 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2006 9/XX/2007 NY Purchase Primary No B B B B 9/XX/2020
Test borrower.
649210280 XXX XXX 1 18222591 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2006 9/XX/2007 NY Purchase Primary No B B B B 9/XX/2020
Status CHARM Booklet, not provided to the borrower.
649210281 XXX XXX 2 18222902 compliance 2 Right of Rescission Unable to conclusively determine date of consummation. Note date used as 4/XX/2005 CT Refinance - Primary No B B B B 9/XX/2020
Timing - Note Date used transaction date for purposes of determining compliance with rescission timing Cash-out -
as Transaction Date requirements Debt
Consolidation
649210288 XXX XXX 1 18269629 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 3/XX/2007 MO Refinance - Primary No B B B B 9/XX/2020
Application Test an application date of 02/XX/2007 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. Debt
Consolidation
649210288 XXX XXX 1 18269631 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 MO Refinance - Primary No B B B B 9/XX/2020
Status CHARM Booklet, not provided to the borrower. Cash-out -
Debt
Consolidation
649210289 XXX XXX 2 18270822 credit 3 Missing Document: Missing 9/XX/2004 NY Purchase Primary No C C C C 9/XX/2020
Final 1003
649210289 XXX XXX 2 18271304 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 9/XX/2004 NY Purchase Primary No B B B B 9/XX/2020
Application Test an application date of 08/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
649210204 XXX XXX XXX 1 18362792 compliance 2 (Doc Error) Initial GFE 12/XX/2000 FL Purchase Primary No B B B B
not provided
649210204 XXX XXX XXX 1 18362793 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 12/XX/2000 FL Purchase Primary No B B B B
Application Test an application date of 11/XX/2000 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
649210204 XXX XXX XXX 1 18362794 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2000 12/XX/2001 FL Purchase Primary No B B B B
Test borrower.
649210204 XXX XXX XXX 1 18362795 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2000 12/XX/2001 FL Purchase Primary No B B B B
Status CHARM Booklet, not provided to the borrower.
649210204 XXX XXX XXX 1 18362796 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 12/XX/2000 12/XX/2001 FL Purchase Primary No B B B B
Assignee liability.
649210204 XXX XXX XXX 1 18362797 credit 3 Missing Document: Credit 12/XX/2000 FL Purchase Primary No D D D D
Report not provided
649210205 XXX XXX XXX 2 18364284 compliance 2 (Doc Error) Initial GFE 9/XX/2001 WA Refinance - Primary No B B B B
not provided Cash-out -
Debt
Consolidation
649210205 XXX XXX XXX 2 18364285 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 9/XX/2001 WA Refinance - Primary No B B B B
Application Test an application date of 08/XX/2001 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. Debt
Consolidation
649210205 XXX XXX XXX 2 18364286 compliance 2 Notice of Right to Cancel Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 9/XX/2001 9/XX/2004 WA Refinance - Primary No B B B B
Missing Cash-out -
Debt
Consolidation
649210205 XXX XXX XXX 2 18364287 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 9/XX/2001 9/XX/2004 WA Refinance - Primary No B B B B
Assignee liability. Cash-out -
Debt
Consolidation
649210205 XXX XXX XXX 2 18364288 credit 3 Missing Document: Credit 9/XX/2001 WA Refinance - Primary No D D D D
Report not provided Cash-out -
Debt
Consolidation
649210207 XXX XXX XXX 1 18365053 credit 3 Missing Document: Missing 12/XX/2001 TX Refinance - Primary No C C C C
Final 1003 Rate/Term
649210207 XXX XXX XXX 1 18365054 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Itemization did not disclose the assignment recording fee of $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 12/XX/2001 12/XX/2004 TX Refinance - Primary No B B B B
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. $XXX settlement fee of $XXX and courier fee of $XXX as transactions. Unlimited as a defense to foreclosure. Assignee liability. Rate/Term
prepaid finance charges
649210208 XXX XXX XXX 1 18367359 credit 3 Missing Document: Missing Yes 8/XX/2002 FL Refinance - Primary No C C C C
Final 1003 UTD
649210208 XXX XXX XXX 1 18367360 credit 3 Missing Document: Yes 8/XX/2002 FL Refinance - Primary No D D D D
Appraisal not provided UTD
649210208 XXX XXX XXX 1 18367361 compliance 2 (Doc Error) Initial GFE Yes 8/XX/2002 FL Refinance - Primary No B B B B
not provided UTD
649210208 XXX XXX XXX 1 18367362 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. Yes 8/XX/2002 FL Refinance - Primary No B B B B
Security Instrument Notary Date of 08/XX/2002 used as disbursement date for UTD
compliance testing.
649210208 XXX XXX XXX 1 18367363 compliance 3 Missing Final HUD-1: No Missing Final HUD-1. No document containing fees provided. Any applicable Yes 8/XX/2002 FL Refinance - Primary No D D D D
Document Used For Fee Federal, State or Local compliance testing is unreliable. UTD
Testing
649210208 XXX XXX XXX 1 18367364 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using Yes 8/XX/2002 FL Refinance - Primary No B B B B
Application No Fees an application date of 07/XX/2002 which is 1 months prior to consummation. A UTD
lookback was performed to determine this application date. Due to missing HUD-1
or Closing Disclosure, no fees were used in testing.
649210208 XXX XXX XXX 1 18367366 compliance 2 Notice of Right to Cancel Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. Yes 8/XX/2002 8/XX/2005 FL Refinance - Primary No B B B B
Missing UTD
649210208 XXX XXX XXX 1 18367368 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Yes 8/XX/2002 8/XX/2005 FL Refinance - Primary No B B B B
Assignee liability. UTD
649210208 XXX XXX XXX 1 18367371 compliance 2 Due to lack of appraised Yes 8/XX/2002 FL Refinance - Primary No B B B B
value, compliance tests UTD
requiring an LTV were run
off an assumed value of a
contract sales price or
original loan amount,
whichever applies.
649210208 XXX XXX XXX 1 18367373 credit 3 Missing Document: Credit Yes 8/XX/2002 FL Refinance - Primary No D D D D
Report not provided UTD
649210209 XXX XXX XXX 2 18368927 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from The under disclosure is payment stream related due to $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 1/XX/2003 1/XX/2004 FL Purchase Primary No B B B B
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. lender's TIL reflecting MI being in force for 126 months, transactions. Unlimited as a defense to foreclosure. Assignee liability.
however based on loan amount and appraised value the MI
would be in force for 138 months.
649210210 XXX XXX XXX 1 18369140 credit 3 Valuation Error: Subject Valuation Type: Appraisal / Valuation Report Date: 01/XX/2003 2/XX/2003 OH Refinance - Primary No C C C C
year built not provided. Cash-out -
Debt
Consolidation
649210210 XXX XXX XXX 1 18369141 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 2/XX/2003 OH Refinance - Primary No B B B B
Application Test an application date of 01/XX/2003 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. Debt
Consolidation
649210210 XXX XXX XXX 1 18369142 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine amount of under disclosure due to $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 2/XX/2003 2/XX/2006 OH Refinance - Primary No B B B B
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. missing Itemization. transactions. Unlimited as a defense to foreclosure. Assignee liability. Cash-out -
Debt
Consolidation
649210211 XXX XXX XXX 2 18369679 compliance 3 Missing Final HUD-1: Missing Final HUD-1: HUD-1 Not Signed or Stamped used for any applicable No 3/XX/2003 FL Purchase Primary No D D D D
HUD-1 Not Signed or Federal, State or Local compliance testing.
Stamped Used For Fee
Testing
649210211 XXX XXX XXX 2 18369680 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using No 3/XX/2003 FL Purchase Primary No B B B B
Application Test an application date of 02/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
649210211 XXX XXX XXX 2 18369681 credit 3 Missing Document: Missing No 3/XX/2003 FL Purchase Primary No C C C C
Final 1003
649210211 XXX XXX XXX 2 18369682 credit 3 Missing Document: No 3/XX/2003 FL Purchase Primary No C C C C
Mortgage Insurance
Certificate (MIC) not
provided
649210212 XXX XXX XXX 1 18370241 compliance 3 Missing Final HUD-1: Missing Final HUD-1: Estimated HUD-1 used for any applicable Federal, State or Yes 5/XX/2003 CA Refinance - Primary No D D D D
Estimated HUD-1 Used For Local compliance testing. Cash-out -
Fee Testing Debt
Consolidation
649210212 XXX XXX XXX 1 18370242 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using Yes 5/XX/2003 CA Refinance - Primary No B B B B
Application Test an application date of 04/XX/2003 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. Debt
Consolidation
649210213 XXX XXX XXX 1 18370622 credit 3 Missing Document: Missing No 5/XX/2003 FL Purchase Investment No C C C C
Final 1003
649210213 XXX XXX XXX 1 18370623 credit 3 Missing Document: No 5/XX/2003 FL Purchase Investment No C C C C
Mortgage Insurance
Certificate (MIC) not
provided
649210213 XXX XXX XXX 1 18370624 compliance 3 Missing Final HUD-1: Missing Final HUD-1: HUD-1 Not Signed or Stamped used for any applicable No 5/XX/2003 FL Purchase Investment No D D D D
HUD-1 Not Signed or Federal, State or Local compliance testing.
Stamped Used For Fee
Testing
649210213 XXX XXX XXX 1 18370625 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using No 5/XX/2003 FL Purchase Investment No B B B B
Application Test an application date of 05/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
649210216 XXX XXX XXX 2 18372855 credit 3 Missing Document: Missing UTD 12/XX/2003 FL UTD - UTD Primary No C C C C
Final 1003
649210216 XXX XXX XXX 2 18372856 compliance 2 Due to lack of appraised UTD 12/XX/2003 FL UTD - UTD Primary No B B B B
value, compliance tests
requiring an LTV were run
off an assumed value of a
contract sales price or
original loan amount,
whichever applies.
649210216 XXX XXX XXX 2 18372857 compliance 2 (Doc Error) Initial GFE UTD 12/XX/2003 FL UTD - UTD Primary No B B B B
not provided
649210216 XXX XXX XXX 2 18372858 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. UTD 12/XX/2003 FL UTD - UTD Primary No B B B B
Security Instrument Notary Date of 12/XX/2003 used as disbursement date for
compliance testing.
649210216 XXX XXX XXX 2 18372859 compliance 3 Missing Final HUD-1: No Missing Final HUD-1. No document containing fees provided. Any applicable UTD 12/XX/2003 FL UTD - UTD Primary No D D D D
Document Used For Fee Federal, State or Local compliance testing is unreliable.
Testing
649210216 XXX XXX XXX 2 18372860 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using UTD 12/XX/2003 FL UTD - UTD Primary No B B B B
Application No Fees an application date of 11/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. Due to missing HUD-1
or Closing Disclosure, no fees were used in testing.
649210216 XXX XXX XXX 2 18372861 compliance 2 Property Type Not (Missing Data) Property Type. If property type is other than single family UTD 12/XX/2003 FL UTD - UTD Primary No B B B B
Provided residence, state and federal testing may be impacted.
649210216 XXX XXX XXX 2 18372862 compliance 2 Notice of Right to Cancel Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. UTD 12/XX/2003 12/XX/2006 FL UTD - UTD Primary No B B B B
Missing
649210216 XXX XXX XXX 2 18372863 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. UTD 12/XX/2003 12/XX/2006 FL UTD - UTD Primary No B B B B
Assignee liability.
649210216 XXX XXX XXX 2 18372864 credit 3 Missing Document: UTD 12/XX/2003 FL UTD - UTD Primary No D D D D
Appraisal not provided
649210215 XXX XXX XXX 1 18372980 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 1/XX/2004 GA Purchase Primary No B B B B
Application Test an application date of 12/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
649210215 XXX XXX XXX 1 18372981 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 1/XX/2004 GA Purchase Primary No B B B B
Affiliated Business Business Arrangement Disclosure to applicant within three (3) business days of implementing regulation, Regulation X, for these type of violations.
Arrangement Disclosure application due to missing information.
Not Provided Within 3
Business Days of
Application
649210217 XXX XXX XXX 2 18373425 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 2/XX/2004 CA Refinance - Primary No B B B B
Application Test an application date of 01/XX/2004 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. Debt
Consolidation
649210217 XXX XXX XXX 2 18373426 compliance 2 Right of Rescission Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. 2/XX/2004 2/XX/2007 CA Refinance - Primary No B B B B
Timing - Receipt Date timing requirements. Cash-out -
Missing Debt
Consolidation
649210218 XXX XXX XXX 2 18373958 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 4/XX/2004 LA Refinance - Primary No B B B B
Application Test an application date of 03/XX/2004 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date.
649210218 XXX XXX XXX 2 18373959 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine reason for under disclosure as the file $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 4/XX/2004 4/XX/2007 LA Refinance - Primary No B B B B
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. is missing the Itemization of Amount Financed. transactions. Unlimited as a defense to foreclosure. Assignee liability. Rate/Term
649210218 XXX XXX XXX 2 18373960 compliance 2 Notice of Right to Cancel Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 4/XX/2004 4/XX/2007 LA Refinance - Primary No B B B B
Missing Rate/Term
649210269 XXX XXX XXX 2 18374488 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 7/XX/2004 NY Purchase Primary No B B B B
Application Test an application date of 06/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
649210269 XXX XXX XXX 2 18374489 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 7/XX/2004 7/XX/2005 NY Purchase Primary No B B B B
Assignee liability.
649210219 XXX XXX XXX 1 18374792 credit 2 Security Instrument is Homestead Exemption Waiver 9/XX/2004 FL Purchase Primary No B B B B
not on a FNMA/FHLMC form
and does not contain the
following clauses:
649210219 XXX XXX XXX 1 18374793 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2004 9/XX/2005 FL Purchase Primary No B B B B
Status CHARM Booklet, not provided to the borrower.
649210219 XXX XXX XXX 1 18374794 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Rate Lock indicates the Index used was 1.463%. The closest $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 9/XX/2004 9/XX/2005 FL Purchase Primary No B B B B 2020/XX/29: Updated from:
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. Index available in our look-back period is 1.595%. transactions. Unlimited as a defense to foreclosure. Assignee liability. Truth In Lending Act: Final
TIL Finance Charge of $XXX is
underdisclosed from
calculated Finance Charge of
$XXX in the amount of $XXX.
649210219 XXX XXX XXX 1 18374795 compliance 2 Final TIL Not Provided to Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 9/XX/2004 9/XX/2005 FL Purchase Primary No B B B B
Borrower At or Before Assignee liability.
Consummation
649210220 XXX XXX XXX 2 18375270 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 12/XX/2004 NJ Purchase Primary Yes B B B B
Application Test an application date of 12/XX/2004 which is 0 months prior to consummation. A
lookback was performed to determine this application date.
649210220 XXX XXX XXX 2 18375271 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 12/XX/2004 NJ Purchase Primary Yes B B B B
Affiliated Business Business Arrangement Disclosure to applicant within three (3) business days of implementing regulation, Regulation X, for these type of violations.
Arrangement Disclosure application due to missing information.
Not Provided Within 3
Business Days of
Application
649210222 XXX XXX XXX 1 18375419 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2005 2/XX/2006 IL Refinance - Primary No B B B B
Status CHARM Booklet, not provided to the borrower. Rate/Term
649210222 XXX XXX XXX 1 18375420 compliance 2 Notice of Right to Cancel Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 2/XX/2005 2/XX/2008 IL Refinance - Primary No B B B B
Missing Rate/Term
649210222 XXX XXX XXX 1 18375421 credit 3 Missing Document: Missing 2/XX/2005 IL Refinance - Primary No C C C C
Final 1003 Rate/Term
649210222 XXX XXX XXX 1 18375422 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 2/XX/2005 IL Refinance - Primary No B B B B
Application Test an application date of 01/XX/2005 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date.
649210222 XXX XXX XXX 1 18375423 compliance 2 ARM Disclosure Timing Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2005 2/XX/2006 IL Refinance - Primary No B B B B
Test application due to missing information. Rate/Term
649210222 XXX XXX XXX 1 18375424 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine reason for underdisclosure due to $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 2/XX/2005 2/XX/2008 IL Refinance - Primary No B B B B
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. missing Itemization of Amount Financed. transactions. Unlimited as a defense to foreclosure. Assignee liability. Rate/Term
649210223 XXX XXX XXX 2 18375533 credit 3 Missing Document: Missing 2/XX/2005 NY Refinance - Primary No C C C C
Final 1003 Cash-out -
Other
649210223 XXX XXX XXX 2 18375534 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 2/XX/2005 NY Refinance - Primary No B B B B
Application Test an application date of 01/XX/2005 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. Other
649210223 XXX XXX XXX 2 18375535 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 2/XX/2005 NY Refinance - Primary No B B B B
Affiliated Business Business Arrangement Disclosure to applicant within three (3) business days of implementing regulation, Regulation X, for these type of violations. Cash-out -
Arrangement Disclosure application due to missing information. Other
Not Provided Within 3
Business Days of
Application
649210223 XXX XXX XXX 2 18375536 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 2/XX/2005 2/XX/2008 NY Refinance - Primary No B B B B
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. itemization of amount financed transactions. Unlimited as a defense to foreclosure. Assignee liability. Cash-out -
Other
649210224 XXX XXX XXX 2 18375691 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2005 CA Purchase Primary No B B B B
Affiliated Business Disclosure to applicant within three (3) business days of application. implementing regulation, Regulation X, for these type of violations.
Arrangement Disclosure
Not Provided Within 3
Business Days of
Application
649210224 XXX XXX XXX 2 18375692 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2005 3/XX/2006 CA Purchase Primary No B B B B
Test borrower within three (3) days of application.
649210224 XXX XXX XXX 2 18375693 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2005 3/XX/2006 CA Purchase Primary No B B B B
Status CHARM Booklet, not provided to the borrower.
649210224 XXX XXX XXX 2 18375694 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 3/XX/2005 3/XX/2006 CA Purchase Primary No B B B B
are estimates. Assignee liability.
649210224 XXX XXX XXX 2 18375695 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 3/XX/2005 3/XX/2006 CA Purchase Primary No B B B B
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. Itemization of Amount Financed. transactions. Unlimited as a defense to foreclosure. Assignee liability.
649210225 XXX XXX XXX 2 18376030 credit 3 Missing Document: Missing 5/XX/2004 LA Construction- Primary No C C C C
Final 1003 Permanent
649210225 XXX XXX XXX 2 18376031 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 5/XX/2004 LA Construction- Primary No B B B B
Security Instrument Notary Date of 05/XX/2004 used as disbursement date for Permanent
compliance testing.
649210225 XXX XXX XXX 2 18376032 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 5/XX/2004 LA Construction- Primary No B B B B
Application Test an application date of 04/XX/2004 which is 1 months prior to consummation. A Permanent
lookback was performed to determine this application date.
649210225 XXX XXX XXX 2 18376033 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2004 5/XX/2005 LA Construction- Primary No B B B B
Test borrower. Permanent
649210225 XXX XXX XXX 2 18376034 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2004 5/XX/2005 LA Construction- Primary No B B B B
Status CHARM Booklet, not provided to the borrower. Permanent
649210225 XXX XXX XXX 2 18376035 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 5/XX/2004 5/XX/2005 LA Construction- Primary No B B B B
Assignee liability. Permanent
649210225 XXX XXX XXX 2 18376036 compliance 2 (Doc Error) Initial GFE 5/XX/2004 LA Construction- Primary No B B B B
not provided Permanent
649210225 XXX XXX XXX 2 18376037 credit 3 Missing Document: Credit 5/XX/2004 LA Construction- Primary No D D D D
Report not provided Permanent
649210226 XXX XXX XXX 1 18376071 credit 3 Missing Document: Missing 5/XX/2005 SD Refinance - Primary No C C C C
Final 1003 Cash-out -
Other
649210226 XXX XXX XXX 1 18376072 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 5/XX/2005 SD Refinance - Primary No B B B B
Application Test an application date of 04/XX/2005 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. Other
649210226 XXX XXX XXX 1 18376073 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 5/XX/2005 SD Refinance - Primary No B B B B
Missing Signature on Arrangement Disclosure. implementing regulation, Regulation X, for these type of violations. Cash-out -
Affiliated Business Other
Arrangement Disclosure
649210226 XXX XXX XXX 1 18376074 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 5/XX/2005 SD Refinance - Primary No B B B B
Affiliated Business Business Arrangement Disclosure to applicant within three (3) business days of implementing regulation, Regulation X, for these type of violations. Cash-out -
Arrangement Disclosure application due to missing information. Other
Not Provided Within 3
Business Days of
Application
649210227 XXX XXX XXX 2 18376941 credit 3 Missing Document: Missing Yes 10/XX/2005 CA Refinance - Primary No C C C C
Final 1003 Rate/Term
649210227 XXX XXX XXX 2 18376942 compliance 3 Missing Final HUD-1: Missing Final HUD-1: Title Company Closing Statement used for any applicable Yes 10/XX/2005 CA Refinance - Primary No D D D D
Title Co. Closing Federal, State or Local compliance testing. Rate/Term
Statement Used For Fee
Testing
649210227 XXX XXX XXX 2 18376943 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using Yes 10/XX/2005 CA Refinance - Primary No B B B B
Application Test an application date of 09/XX/2005 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date.
649210227 XXX XXX XXX 2 18376944 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or Yes 10/XX/2005 CA Refinance - Primary No B B B B
Affiliated Business Business Arrangement Disclosure to applicant within three (3) business days of implementing regulation, Regulation X, for these type of violations. Rate/Term
Arrangement Disclosure application due to missing information.
Not Provided Within 3
Business Days of
Application
649210227 XXX XXX XXX 2 18376945 compliance 2 ARM Disclosure Timing Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 10/XX/2005 10/XX/2006 CA Refinance - Primary No B B B B
Test application due to missing information. Rate/Term
649210227 XXX XXX XXX 2 18376946 compliance 2 CHARM Booklet Disclosure Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 10/XX/2005 10/XX/2006 CA Refinance - Primary No B B B B
Timing Loan Application Date. Rate/Term
649210228 XXX XXX XXX 2 18377070 credit 3 Missing Document: Missing 11/XX/2005 FL Refinance - Primary No C C C C
Final 1003 Rate/Term
649210228 XXX XXX XXX 2 18377071 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 11/XX/2005 FL Refinance - Primary No B B B B
Application Test an application date of 10/XX/2005 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date.
649210228 XXX XXX XXX 2 18377072 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 11/XX/2005 FL Refinance - Primary No B B B B
Affiliated Business Business Arrangement Disclosure to applicant within three (3) business days of implementing regulation, Regulation X, for these type of violations. Rate/Term
Arrangement Disclosure application due to missing information.
Not Provided Within 3
Business Days of
Application
649210228 XXX XXX XXX 2 18377073 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine cause of under disclosure due to missing $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 11/XX/2005 11/XX/2008 FL Refinance - Primary No B B B B
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. itemization of amount financed. transactions. Unlimited as a defense to foreclosure. Assignee liability. Rate/Term
649210228 XXX XXX XXX 2 18377074 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 11/XX/2005 11/XX/2008 FL Refinance - Primary No B B B B
are estimates. Assignee liability. Rate/Term
649210229 XXX XXX XXX 2 18377151 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 11/XX/2005 FL Purchase Second Home No B B B B
Application Test an application date of 10/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
649210229 XXX XXX XXX 2 18377152 compliance 2 Final TIL Not Provided to Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 11/XX/2005 11/XX/2006 FL Purchase Second Home No B B B B
Borrower At or Before Assignee liability.
Consummation
649210234 XXX XXX XXX 1 18378110 compliance 2 (Doc Error) TIL Error: TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Yes 4/XX/2006 4/XX/2009 CA Refinance - Primary No B B B B
Borrower signature not Assignee liability. Cash-out -
dated. Debt
Consolidation
649210234 XXX XXX XXX 1 18378111 compliance 3 Missing Final HUD-1: Missing Final HUD-1: HUD-1 Not Signed or Stamped used for any applicable Yes 4/XX/2006 CA Refinance - Primary No D D D D
HUD-1 Not Signed or Federal, State or Local compliance testing. Cash-out -
Stamped Used For Fee Debt
Testing Consolidation
649210234 XXX XXX XXX 1 18378112 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using Yes 4/XX/2006 CA Refinance - Primary No B B B B
Application Test an application date of 03/XX/2006 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. Debt
Consolidation
649210234 XXX XXX XXX 1 18378113 compliance 2 ARM Disclosure Prior to TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 4/XX/2006 4/XX/2007 CA Refinance - Primary No B B B B
Closing Timing borrower at least three (3) days prior to consummation for a loan that did not Cash-out -
start as an ARM. Debt
Consolidation
649210234 XXX XXX XXX 1 18378114 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 4/XX/2006 4/XX/2007 CA Refinance - Primary No B B B B
Status CHARM Booklet, not provided to the borrower. Cash-out -
Debt
Consolidation
649210234 XXX XXX XXX 1 18378115 compliance 2 Right of Rescission Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. Yes 4/XX/2006 4/XX/2009 CA Refinance - Primary No B B B B
Timing - Receipt Date timing requirements. Cash-out -
Missing Debt
Consolidation
649210234 XXX XXX XXX 1 18378116 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Yes 4/XX/2006 4/XX/2009 CA Refinance - Primary No B B B B
are estimates. Assignee liability. Cash-out -
Debt
Consolidation
649210235 XXX XXX XXX 2 18379080 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 8/XX/2006 FL Refinance - Primary No B B B B
Cash-out -
Debt
Consolidation
649210235 XXX XXX XXX 2 18379081 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 8/XX/2006 FL Refinance - Primary No B B B B
Affiliated Business Disclosure to applicant within three (3) business days of application. implementing regulation, Regulation X, for these type of violations. Cash-out -
Arrangement Disclosure Debt
Not Provided Within 3 Consolidation
Business Days of
Application
649210235 XXX XXX XXX 2 18379082 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2006 8/XX/2007 FL Refinance - Primary No B B B B
Test borrower within three (3) days of application. Cash-out -
Debt
Consolidation
649210235 XXX XXX XXX 2 18379083 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2006 8/XX/2007 FL Refinance - Primary No B B B B
Status CHARM Booklet, not provided to the borrower. Cash-out -
Debt
Consolidation
649210233 XXX XXX XXX 1 18379105 credit 3 Missing Document: Missing 8/XX/2006 FL Refinance - Primary No C C C C
Final 1003 Cash-out -
Other
649210233 XXX XXX XXX 1 18379106 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 8/XX/2006 FL Refinance - Primary No B B B B
Application Test an application date of 07/XX/2006 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. Other
649210236 XXX XXX XXX 1 18379115 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 8/XX/2006 CA Refinance - Primary No B B B B
Application Test an application date of 07/XX/2006 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date.
649210236 XXX XXX XXX 1 18379116 compliance 2 ARM Disclosure Timing Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2006 8/XX/2007 CA Refinance - Primary No B B B B
Test application due to missing information. Rate/Term
649210236 XXX XXX XXX 1 18379117 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2006 8/XX/2007 CA Refinance - Primary No B B B B
Status CHARM Booklet, not provided to the borrower. Rate/Term
649210236 XXX XXX XXX 1 18379118 compliance 2 TILA - Incorrect Right To Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing 8/XX/2006 8/XX/2009 CA Refinance - Primary No B B B B
Cancel Form Used - H-8 Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses Rate/Term
Used on Same Lender form should have been used. the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that
Refinance (Circuit 2, 5, creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for
7, 8, 9, 10 or DC) refinances involving the same creditor.
649210236 XXX XXX XXX 1 18379119 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 8/XX/2006 CA Refinance - Primary No B B B B
Affiliated Business Business Arrangement Disclosure to applicant within three (3) business days of implementing regulation, Regulation X, for these type of violations. Rate/Term
Arrangement Disclosure application due to missing information.
Not Provided Within 3
Business Days of
Application
649210241 XXX XXX XXX 2 18379844 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 12/XX/2006 CA Refinance - Primary No B B B B
Application Test an application date of 11/XX/2006 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. Debt
Consolidation
649210242 XXX XXX XXX 1 18380219 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 1/XX/2007 NV Refinance - Investment No B B B B
Application Test an application date of 01/XX/2007 which is 0 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. Other
649210239 XXX XXX XXX 1 18380391 credit 3 Missing Document: Missing 2/XX/2007 CA Refinance - Primary No C C C C
Final 1003 Rate/Term
649210239 XXX XXX XXX 1 18380392 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 2/XX/2007 CA Refinance - Primary No B B B B
Application Test an application date of 01/XX/2007 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date.
649210238 XXX XXX XXX 1 18380433 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 2/XX/2007 FL Refinance - Primary No B B B B
Application Test an application date of 01/XX/2007 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. Other
649210238 XXX XXX XXX 1 18380434 credit 3 Missing Document: Valuation Type: Stated / Valuation Report Date: <empty> 2/XX/2007 FL Refinance - Primary No D D D D
Appraisal not provided Cash-out -
Other
649210240 XXX XXX XXX 1 18380989 credit 3 Missing Document: Credit 4/XX/2007 FL Purchase Primary No D D D D
Report not provided
649210240 XXX XXX XXX 1 18380990 credit 3 Missing Document: Valuation Type: Stated / Valuation Report Date: 04/XX/2007 4/XX/2007 FL Purchase Primary No D D D D
Appraisal not provided
649210240 XXX XXX XXX 1 18380991 compliance 2 (Doc Error) Initial GFE 4/XX/2007 FL Purchase Primary No B B B B
not provided
649210240 XXX XXX XXX 1 18380992 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 4/XX/2007 FL Purchase Primary No B B B B
649210244 XXX XXX XXX 2 18381195 compliance 2 Federal FACTA Disclosure FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 4/XX/2007 CA Refinance - Investment No B B B B
Timing Test within a reasonably practicable time after using credit score. Cash-out -
Other
649210272 XXX XXX XXX 2 18381613 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 5/XX/2007 FL Refinance - Primary No B B B B
Rate/Term
649210245 XXX XXX XXX 1 18381812 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 5/XX/2007 FL Refinance - Primary No B B B B
Cash-out -
Debt
Consolidation
649210245 XXX XXX XXX 1 18381813 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 5/XX/2007 FL Refinance - Primary No B B B B
Application Test an application date of 04/XX/2007 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. Debt
Consolidation
649210245 XXX XXX XXX 1 18381814 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 5/XX/2007 FL Refinance - Primary No B B B B
Affiliated Business Business Arrangement Disclosure to applicant within three (3) business days of implementing regulation, Regulation X, for these type of violations. Cash-out -
Arrangement Disclosure application due to missing information. Debt
Not Provided Within 3 Consolidation
Business Days of
Application
649210245 XXX XXX XXX 1 18381815 compliance 2 ARM Disclosure Timing Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2007 5/XX/2008 FL Refinance - Primary No B B B B
Test application due to missing information. Cash-out -
Debt
Consolidation
649210245 XXX XXX XXX 1 18381816 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2007 5/XX/2008 FL Refinance - Primary No B B B B
Status CHARM Booklet, not provided to the borrower. Cash-out -
Debt
Consolidation
649210273 XXX XXX XXX 2 18382097 credit 3 Missing Document: Missing 5/XX/2007 AZ Purchase Primary No C C C C
Final 1003
649210273 XXX XXX XXX 2 18382098 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 5/XX/2007 AZ Purchase Primary No B B B B
649210273 XXX XXX XXX 2 18382099 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 5/XX/2007 AZ Purchase Primary No B B B B
Application Test an application date of 05/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
649210273 XXX XXX XXX 2 18382100 compliance 2 ARM Disclosure Timing Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2007 6/XX/2008 AZ Purchase Primary No B B B B
Test application due to missing information.
649210273 XXX XXX XXX 2 18382101 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2007 6/XX/2008 AZ Purchase Primary No B B B B
Status CHARM Booklet, not provided to the borrower.
649210273 XXX XXX XXX 2 18382102 credit 3 Missing Document: Credit 5/XX/2007 AZ Purchase Primary No D D D D
Report not provided
649210274 XXX XXX XXX 1 18382783 credit 3 Missing Document: Missing 6/XX/2007 FL Refinance - Primary No C C C C
Final 1003 Rate/Term
649210274 XXX XXX XXX 1 18382784 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 FL Refinance - Primary No B B B B
Test borrower. Rate/Term
649210274 XXX XXX XXX 1 18382785 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 FL Refinance - Primary No B B B B
Status CHARM Booklet, not provided to the borrower. Rate/Term
649210274 XXX XXX XXX 1 18382786 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 6/XX/2007 FL Refinance - Primary No B B B B
Application Test an application date of 05/XX/2007 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date.
649210275 XXX XXX XXX 2 18383198 credit 3 Missing Document: Credit 7/XX/2007 FL Purchase Primary No D D D D
Report not provided
649210247 XXX XXX XXX 2 18384413 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 12/XX/2007 TX Purchase Primary No B B B B
649210246 XXX XXX XXX 1 18384425 credit 3 Missing Document: Missing 12/XX/2007 FL Purchase Primary No C C C C
Final 1003
649210246 XXX XXX XXX 1 18384426 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 12/XX/2007 FL Purchase Primary No B B B B
Application Test an application date of 11/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
649210246 XXX XXX XXX 1 18384427 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. 12/XX/2007 12/XX/2008 FL Purchase Primary No B B B B
are estimates. Assignee liability.
649210249 XXX XXX XXX 1 18385222 credit 3 Missing Document: Missing 3/XX/2008 NY Refinance - Primary No C C C C
Final 1003 Cash-out -
Other
649210249 XXX XXX XXX 1 18385223 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 3/XX/2008 NY Refinance - Primary No B B B B
Application Test an application date of 02/XX/2008 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. Other
649210249 XXX XXX XXX 1 18385224 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 3/XX/2008 3/XX/2011 NY Refinance - Primary No B B B B
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. itemization of amount financed. transactions. Unlimited as a defense to foreclosure. Assignee liability. Cash-out -
Other
649210252 XXX XXX XXX 2 18385979 compliance 2 Washington Residential Washington HB 2770: Mortgage loan file does not contain a disclosure summary of The Act does not appear to provide for assignee liability. 1/XX/2009 WA Refinance - Primary No B B B B
Mortgage Loan (Disclosure all material terms provided to borrower. Rate/Term
of Material Terms Not
Provided)
649210254 XXX XXX XXX 2 18387547 compliance 2 SAFE Act - NMLS Info Not Secure and Fair Enforcement for Mortgage Licensing Act: NMLSR information not Liability appears to be limited to originators/licensees. 8/XX/2011 NY Refinance - Primary No B B B B
in File present on loan application. Rate/Term
649210254 XXX XXX XXX 2 18387548 compliance 2 TILA - Incorrect Right To Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing 8/XX/2011 8/XX/2014 NY Refinance - Primary No B B B B
Cancel Form Used - H-8 Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses Rate/Term
Used on Same Lender form should have been used. the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that
Refinance (Circuit 2, 5, creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for
7, 8, 9, 10 or DC) refinances involving the same creditor.
649210256 XXX XXX XXX 1 18387576 credit 3 Missing Document: Valuation Type: Stated / Valuation Report Date: <empty> 9/XX/2011 IL Refinance - Primary No D D D D
Appraisal not provided Rate/Term
649210256 XXX XXX XXX 1 18387577 compliance 2 (Missing Data) Unable to Original Lender was not able to be determined. Unable to determine if correct 9/XX/2011 9/XX/2014 IL Refinance - Primary No B B B B
determine if loan is a TILA rescission form was used. Rate/Term
same lender refi
649210256 XXX XXX XXX 1 18387578 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 9/XX/2011 IL Refinance - Primary No B B B B
Missing Signature on Arrangement Disclosure. implementing regulation, Regulation X, for these type of violations. Rate/Term
Affiliated Business
Arrangement Disclosure
649210256 XXX XXX XXX 1 18387579 credit 3 Missing Document: Credit 9/XX/2011 IL Refinance - Primary No D D D D
Report not provided Rate/Term
649210255 XXX XXX XXX 2 18387748 compliance 2 (Doc Error) GFE Error: 11/XX/2011 FL Refinance - Primary No B B B B
There is no evidence that Rate/Term
the interest rate was
locked prior to closing
649210255 XXX XXX XXX 2 18387749 compliance 2 (Missing Data) Last Rate Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario 11/XX/2011 FL Refinance - Primary No B B B B
Set Date between Creditor Application Date and Transaction Date used to determine rate Rate/Term
used for testing.
649210255 XXX XXX XXX 2 18387750 compliance 2 SAFE Act - NMLS Info Not Secure and Fair Enforcement for Mortgage Licensing Act: NMLSR information not Liability appears to be limited to originators/licensees. 11/XX/2011 FL Refinance - Primary No B B B B
in File present on loan application. Rate/Term
649210255 XXX XXX XXX 2 18387751 compliance 2 RESPA (2010) - Loan RESPA (2010): Loan Amount on Final GFE does not match Note. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 11/XX/2011 FL Refinance - Primary No B B B B
Amount on Final GFE implementing regulation, Regulation X, for these type of violations. Rate/Term
Inaccurate
649210255 XXX XXX XXX 2 18387752 compliance 2 RESPA (2010) - Initial RESPA (2010): Initial payment on GFE does not match actual payment on loan. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 11/XX/2011 FL Refinance - Primary No B B B B
Payment on GFE Inaccurate implementing regulation, Regulation X, for these type of violations. Rate/Term
649210255 XXX XXX XXX 2 18387753 compliance 2 RESPA - Initial Escrow RESPA: Initial escrow account statement does not match charges on HUD-1/Final RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 11/XX/2011 FL Refinance - Primary No B B B B
Account statement Closing Disclosure. implementing regulation, Regulation X, for these type of violations. Rate/Term
Inaccurate
649210255 XXX XXX XXX 2 18387754 compliance 2 RESPA Servicing RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 11/XX/2011 FL Refinance - Primary No B B B B
Disclosure: Servicing Statement. implementing regulation, Regulation X, for these type of violations. Rate/Term
Disclosure Statement
Missing
649210259 XXX XXX XXX 2 18387961 compliance 2 Federal FACTA Disclosure FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 2/XX/2012 TX Refinance - Primary No B B B B
Timing Test within a reasonably practicable time after using credit score. Rate/Term
649210259 XXX XXX XXX 2 18387962 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 2/XX/2012 TX Refinance - Primary No B B B B
Application Test an application date of 01/XX/2012 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date.
649210259 XXX XXX XXX 2 18387963 compliance 2 RESPA (2010) - 0% RESPA (2010): 0% tolerance violation for 803 fee without evidence of sufficient RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 2/XX/2012 TX Refinance - Primary No B B B B
Tolerance (Line 803) cure provided. implementing regulation, Regulation X, for these type of violations. Rate/Term
Without Cure
649210259 XXX XXX XXX 2 18387964 compliance 2 RESPA - Initial GFE Not Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 2/XX/2012 TX Refinance - Primary No B B B B
Provided Within 3 Loan Application Date. implementing regulation, Regulation X, for these type of violations. Rate/Term
Business Days of
Application
649210259 XXX XXX XXX 2 18387965 compliance 2 RESPA (2010) - Initial RESPA (2010): Initial payment on Final HUD-1 does not match actual payment on RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 2/XX/2012 TX Refinance - Primary No B B B B
Payment on Final HUD-1 loan. implementing regulation, Regulation X, for these type of violations. Rate/Term
Inaccurate
649210259 XXX XXX XXX 2 18387966 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 2/XX/2012 TX Refinance - Primary No B B B B
Affiliated Business Business Arrangement Disclosure to applicant within three (3) business days of implementing regulation, Regulation X, for these type of violations. Rate/Term
Arrangement Disclosure application due to missing information.
Not Provided Within 3
Business Days of
Application
649210259 XXX XXX XXX 2 18387967 compliance 2 RESPA Servicing Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 2/XX/2012 TX Refinance - Primary No B B B B
Disclosure: Servicing Loan Application Date. implementing regulation, Regulation X, for these type of violations. Rate/Term
Disclosure Statement Not
Provided Within 3
Business Days of
Application
649210259 XXX XXX XXX 2 18387968 compliance 2 TIL-MDIA - Initial TIL Unable to determine compliance with timing requirements due to missing Initial TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited as a defense to 2/XX/2012 2/XX/2013 TX Refinance - Primary No B B B B
Not Provided within 3 Loan Application Date. foreclosure. Assignee liability. Rate/Term
Business Days of
Application
649210259 XXX XXX XXX 2 18387969 compliance 2 RESPA (2010) - 0% RESPA (2010): 0% tolerance violation for 801 fee with evidence of cure provided RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 2/XX/2012 TX Refinance - Primary No B B B B
Tolerance (Line 801) With on Final HUD-1 implementing regulation, Regulation X, for these type of violations. Rate/Term
Cure
649210260 XXX XXX XXX 2 18388316 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 4/XX/2012 IL Refinance - Primary No B B B B
Application Test an application date of 03/XX/2012 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date.
649210260 XXX XXX XXX 2 18388317 compliance 2 SAFE Act - Individual LO Unable to test Individual Loan Originator license status due to missing 4/XX/2012 IL Refinance - Primary No B B B B
NMLS license status not information. Rate/Term
approved
649210260 XXX XXX XXX 2 18388318 compliance 2 SAFE Act - Individual LO Unable to test Loan Originator license due to missing information. Liability appears to be limited to originators/licensees. 4/XX/2012 IL Refinance - Primary No B B B B
not licensed at time of Rate/Term
application
649210260 XXX XXX XXX 2 18388319 compliance 2 RESPA - Initial GFE Not Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 4/XX/2012 IL Refinance - Primary No B B B B
Provided Within 3 Loan Application Date. implementing regulation, Regulation X, for these type of violations. Rate/Term
Business Days of
Application
649210260 XXX XXX XXX 2 18388320 compliance 2 RESPA (2010) - Initial RESPA (2010): Initial payment on GFE does not match actual payment on loan. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 4/XX/2012 IL Refinance - Primary No B B B B
Payment on GFE Inaccurate implementing regulation, Regulation X, for these type of violations. Rate/Term
649210260 XXX XXX XXX 2 18388321 compliance 2 RESPA Servicing Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 4/XX/2012 IL Refinance - Primary No B B B B
Disclosure: Servicing Loan Application Date. implementing regulation, Regulation X, for these type of violations. Rate/Term
Disclosure Statement Not
Provided Within 3
Business Days of
Application
649210260 XXX XXX XXX 2 18388322 compliance 2 TIL-MDIA - Initial TIL Unable to determine compliance with timing requirements due to missing Initial TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited as a defense to 4/XX/2012 4/XX/2013 IL Refinance - Primary No B B B B
Not Provided within 3 Loan Application Date. foreclosure. Assignee liability. Rate/Term
Business Days of
Application
649210260 XXX XXX XXX 2 18388323 compliance 2 SAFE Act - LO Company not Unable to test LO company NMLS license due to missing information. Liability appears to be limited to originators/licensees. 4/XX/2012 IL Refinance - Primary No B B B B
licensed at time of Rate/Term
application
649210260 XXX XXX XXX 2 18388324 compliance 2 SAFE Act - LO Company Unable to test LO company status due to missing information. 4/XX/2012 IL Refinance - Primary No B B B B
NMLS license status not Rate/Term
approved
649210258 XXX XXX XXX 2 18388885 compliance 2 RESPA (2010) - GFE column RESPA (2010) - GFE column on page 3 of Final HUD-1 does not match most recently RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 5/XX/2012 FL Refinance - Primary No B B B B
on HUD Comparison Chart disclosed GFE. implementing regulation, Regulation X, for these type of violations. Rate/Term
Inaccurate
649210258 XXX XXX XXX 2 18388886 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 5/XX/2012 FL Refinance - Primary No B B B B
Rate/Term
649210258 XXX XXX XXX 2 18388887 compliance 2 RESPA Servicing RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 5/XX/2012 FL Refinance - Primary No B B B B
Disclosure: Servicing Statement to applicant within three (3) business days of application. implementing regulation, Regulation X, for these type of violations. Rate/Term
Disclosure Statement Not
Provided Within 3
Business Days of
Application
649210258 XXX XXX XXX 2 18388888 credit 3 Missing Document: Valuation Type: Stated / Valuation Report Date: <empty> 5/XX/2012 FL Refinance - Primary No D D D D
Appraisal not provided Rate/Term
649210258 XXX XXX XXX 2 18388889 credit 3 Missing Document: 5/XX/2012 FL Refinance - Primary No C C C C
Mortgage Insurance Rate/Term
Certificate (MIC) not
provided
649210258 XXX XXX XXX 2 18388890 compliance 2 RESPA (2010) - 0% RESPA (2010): 0% tolerance violation for 1203 fee with evidence of cure provided RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 5/XX/2012 FL Refinance - Primary No B B B B
Tolerance (Line 1203) on Final HUD-1 implementing regulation, Regulation X, for these type of violations. Rate/Term
With Cure
649210258 XXX XXX XXX 2 18388891 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 5/XX/2012 FL Refinance - Primary No B B B B
Missing Signature on Arrangement Disclosure. implementing regulation, Regulation X, for these type of violations. Rate/Term
Affiliated Business
Arrangement Disclosure
649210261 XXX XXX XXX 2 18389018 credit 3 Missing Document: Valuation Type: Stated / Valuation Report Date: <empty> 6/XX/2012 FL Refinance - Investment No D D D D
Appraisal not provided Rate/Term
649210263 XXX XXX XXX 1 18389681 credit 3 Missing Document: Valuation Type: Stated / Valuation Report Date: <empty> 10/XX/2012 GA Refinance - Primary No D D D D
Appraisal not provided Rate/Term
649210263 XXX XXX XXX 1 18389682 compliance 2 RESPA (2010) - 0% RESPA (2010): 0% tolerance violation for 1203 fee without evidence of sufficient RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 10/XX/2012 GA Refinance - Primary No B B B B
Tolerance (Line 1203) cure provided. implementing regulation, Regulation X, for these type of violations. Rate/Term
Without Cure
649210264 XXX XXX XXX 2 18389750 compliance 2 (Missing Data) Last Rate Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario 10/XX/2012 FL Refinance - Primary No B B B B
Set Date between Creditor Application Date and Transaction Date used to determine rate Rate/Term
used for testing.
649210264 XXX XXX XXX 2 18389751 compliance 2 SAFE Act - NMLS Info Not Secure and Fair Enforcement for Mortgage Licensing Act: NMLSR information not Liability appears to be limited to originators/licensees. 10/XX/2012 FL Refinance - Primary No B B B B
in File present on loan application. Rate/Term
649210264 XXX XXX XXX 2 18389752 compliance 2 RESPA (2010) - GFE RESPA (2010): GFE does not provide minimum ten (10) business day availability RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 10/XX/2012 FL Refinance - Primary No B B B B
Settlement charges Good for estimate of charges and terms for all other settlement charges. implementing regulation, Regulation X, for these type of violations. Rate/Term
Thru Date Less than 10
Days
649210264 XXX XXX XXX 2 18389753 compliance 2 RESPA (2010) - GFE column RESPA (2010) - GFE column on page 3 of Final HUD-1 does not match most recently RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 10/XX/2012 FL Refinance - Primary No B B B B
on HUD Comparison Chart disclosed GFE. implementing regulation, Regulation X, for these type of violations. Rate/Term
Inaccurate
649210264 XXX XXX XXX 2 18389754 compliance 2 RESPA - Initial GFE Not RESPA: Initial GFE not provided to Borrower(s) within three (3) business days of RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 10/XX/2012 FL Refinance - Primary No B B B B
Provided Within 3 Application Date. implementing regulation, Regulation X, for these type of violations. Rate/Term
Business Days of
Application
649210264 XXX XXX XXX 2 18389755 credit 3 Missing Document: Valuation Type: Stated / Valuation Report Date: <empty> 10/XX/2012 FL Refinance - Primary No D D D D
Appraisal not provided Rate/Term
649210265 XXX XXX XXX 2 18389788 compliance 2 SAFE Act - NMLS Info Not Secure and Fair Enforcement for Mortgage Licensing Act: NMLSR information not Liability appears to be limited to originators/licensees. 10/XX/2012 FL Refinance - Primary No B B B B
in File present on loan application. Rate/Term
649210265 XXX XXX XXX 2 18389789 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 10/XX/2012 FL Refinance - Primary No B B B B
Missing Signature on Arrangement Disclosure. implementing regulation, Regulation X, for these type of violations. Rate/Term
Affiliated Business
Arrangement Disclosure
649210265 XXX XXX XXX 2 18389790 compliance 2 RESPA Servicing RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 10/XX/2012 FL Refinance - Primary No B B B B
Disclosure: Servicing Statement to applicant within three (3) business days of application. implementing regulation, Regulation X, for these type of violations. Rate/Term
Disclosure Statement Not
Provided Within 3
Business Days of
Application
649210265 XXX XXX XXX 2 18389791 credit 3 Missing Document: Valuation Type: Stated / Valuation Report Date: <empty> 10/XX/2012 FL Refinance - Primary No D D D D
Appraisal not provided Rate/Term
649210266 XXX XXX XXX 1 18390282 credit 3 Missing Document: Valuation Type: Stated / Valuation Report Date: <empty> 3/XX/2013 IL Refinance - Primary No D D D D
Appraisal not provided Rate/Term
649210266 XXX XXX XXX 1 18390283 compliance 2 SAFE Act - Individual LO Unable to test Individual Loan Originator license status due to missing 3/XX/2013 IL Refinance - Primary No B B B B
NMLS license status not information. Rate/Term
approved
649210266 XXX XXX XXX 1 18390284 compliance 2 SAFE Act - Individual LO Unable to test Loan Originator license due to missing information. Liability appears to be limited to originators/licensees. 3/XX/2013 IL Refinance - Primary No B B B B
not licensed at time of Rate/Term
application
649210266 XXX XXX XXX 1 18390285 compliance 2 SAFE Act - Individual LO Secure and Fair Enforcement for Mortgage Licensing Act: Individual Loan Liability appears to be limited to originators/licensees. 3/XX/2013 IL Refinance - Primary No B B B B
NMLS does not match NMLS Originator NMLSR information on loan documents does not match NMLSR. Rate/Term
649210266 XXX XXX XXX 1 18390286 compliance 2 RESPA (2010) - 0% RESPA (2010): 0% tolerance violation for 802 fee without evidence of sufficient RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2013 IL Refinance - Primary No B B B B
Tolerance (Line 802) cure provided. implementing regulation, Regulation X, for these type of violations. Rate/Term
Without Cure
649210266 XXX XXX XXX 1 18390287 compliance 2 RESPA (2010) - 0% RESPA (2010): 0% tolerance violation for 803 fee without evidence of sufficient RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2013 IL Refinance - Primary No B B B B
Tolerance (Line 803) cure provided. implementing regulation, Regulation X, for these type of violations. Rate/Term
Without Cure
649210266 XXX XXX XXX 1 18390288 compliance 2 RESPA (2010) - GFE column RESPA (2010) - GFE column on page 3 of Final HUD-1 does not match most recently RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2013 IL Refinance - Primary No B B B B
on HUD Comparison Chart disclosed GFE. implementing regulation, Regulation X, for these type of violations. Rate/Term
Inaccurate
649210266 XXX XXX XXX 1 18390289 compliance 2 RESPA (2010) - Loan RESPA (2010): Loan Amount on Final GFE does not match Note. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2013 IL Refinance - Primary No B B B B
Amount on Final GFE implementing regulation, Regulation X, for these type of violations. Rate/Term
Inaccurate
649210266 XXX XXX XXX 1 18390290 compliance 2 RESPA (2010) - Initial RESPA (2010): Initial payment on GFE does not match actual payment on loan. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2013 IL Refinance - Primary No B B B B
Payment on GFE Inaccurate implementing regulation, Regulation X, for these type of violations. Rate/Term
649210266 XXX XXX XXX 1 18390291 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2013 IL Refinance - Primary No B B B B
Missing Signature on Arrangement Disclosure. implementing regulation, Regulation X, for these type of violations. Rate/Term
Affiliated Business
Arrangement Disclosure
649210266 XXX XXX XXX 1 18390292 compliance 2 TILA - Incorrect Right To Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing 3/XX/2013 3/XX/2016 IL Refinance - Primary No B B B B
Cancel Form Used - H-8 Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses Rate/Term
Used on Same Lender form should have been used. the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that
Refinance (Circuit 2, 5, creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for
7, 8, 9, 10 or DC) refinances involving the same creditor.
649209408 XXX XXX 2 18763477 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 4/XX/2004 MI Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209408 XXX XXX 2 18763478 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 4/XX/2004 MI Purchase Primary No B B B B 10/XX/2017
Missing Signature on Arrangement Disclosure. implementing regulation, Regulation X, for these type of violations.
Affiliated Business
Arrangement Disclosure
649209408 XXX XXX 2 18763479 compliance 2 ARM Disclosure Compliant TIL variable rate disclosure: ARM loan program disclosure does not match terms of TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2004 4/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
loan.
649209408 XXX XXX 2 18763480 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2004 4/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
649209408 XXX XXX 2 18763481 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2004 4/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209408 XXX XXX 2 18763482 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 4/XX/2004 4/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. transactions. Unlimited as a defense to foreclosure. Assignee liability.
649209682 XXX XXX 2 18763498 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 4/XX/2004 MI Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209682 XXX XXX 2 18763499 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL Itemization did not disclose the Title Courier fee of $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 4/XX/2004 4/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. $XXX and underdisclosed recording fees by $XXX as prepaid transactions. Unlimited as a defense to foreclosure. Assignee liability.
finance charges. Closing instructions indicate the Index
used was 1.109%. The closest Index available in our look-
back period is 1.16%.
649209301 XXX XXX 2 18763754 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 4/XX/2004 OH Refinance - Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX Rate/Term
inspection is dated prior
to the most recent FEMA
disaster.
649209301 XXX XXX 2 18763755 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2004 4/XX/2005 OH Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Rate/Term
649209529 XXX XXX 1 18763847 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2004 3/XX/2005 CO Refinance - Primary No B B B B 10/XX/2017
borrower within three (3) days of application. Cash-out -
Debt
Consolidation
649209529 XXX XXX 1 18763848 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2004 3/XX/2005 CO Refinance - Primary No B B B B 10/XX/2017
Timing CHARM Booklet, not provided to the borrower within three (3) days of application. Cash-out -
Debt
Consolidation
649209529 XXX XXX 1 18763849 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization did not disclose a recording service fee of $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 3/XX/2004 3/XX/2007 CO Refinance - Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. $XXX and a settlement closing fee $XXX as prepaid finance transactions. Unlimited as a defense to foreclosure. Assignee liability. Cash-out -
charges. Debt
Consolidation
649209685 XXX XXX 1 18763864 credit 3 Missing Document: Missing 3/XX/2004 SC Purchase Primary No C C C C 10/XX/2017
Final 1003
649209685 XXX XXX 1 18763865 compliance 2 South Carolina Home Loan South Carolina Home Loan: Borrower not provided with a document specifying the Exceptions occurring more than 6 years ago may be outside the states statute of limitations. Due to 3/XX/2004 3/XX/2010 SC Purchase Primary No B B B B 10/XX/2017
(Complaint Agency agency designated to receive complaints or inquiries about the origination and the potential remedies available to a court, this exception carries elevated risk to an assignee
Disclosure Not Provided) making of the loan. during the initial 6 years after occurrence of the violation. After the expiration of this 6 year
period, the exception retains risk for claims raised as a defense to foreclosure, but not at the same
level as during the initial 6 years for affirmative claims.
649209685 XXX XXX 1 18763866 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2004 3/XX/2005 SC Purchase Primary No B B B B 10/XX/2017
borrower.
649209685 XXX XXX 1 18763867 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2004 3/XX/2005 SC Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209685 XXX XXX 1 18763868 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine underdisclosure based on itemization of $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 3/XX/2004 3/XX/2005 SC Purchase Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. amount financed. transactions. Unlimited as a defense to foreclosure. Assignee liability.
649209685 XXX XXX 1 18763869 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 3/XX/2004 SC Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649210103 XXX XXX 1 18764147 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 6/XX/2006 MA Refinance - Primary Yes C C C C 10/XX/2017
most recent valuation Inspection Date: Cash-out -
inspection is dated prior Debt
to the most recent FEMA Consolidation
disaster.
649210103 XXX XXX 1 18764149 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2006 6/XX/2007 MA Refinance - Primary Yes B B B B 10/XX/2017
borrower within three (3) days of application. Cash-out -
Debt
Consolidation
649209465 XXX XXX 2 18764212 compliance 2 Michigan Consumer Michigan Consumer Mortgage Protection Act: Borrower Bill of Rights disclosure Assignee liability is unclear. Purchasers and assignees would not appear to be liable for violations 1/XX/2004 MI Refinance - Primary No B B B B 10/XX/2017
Mortgage Protection Act not provided to borrower at the time of application. of the Act, except to the extent involved I violations arising from servicing or collecting. Cash-out -
(Borrower Bill of Rights Other
Disclosure Not Provided
Timely)
649209465 XXX XXX 2 18764213 compliance 2 Michigan Consumer Caution Michigan Consumer Mortgage Protection Act: Consumer Caution and Home Ownership Assignee liability is unclear. Purchasers and assignees would not appear to be liable for violations 1/XX/2004 MI Refinance - Primary No B B B B 10/XX/2017
and Home Ownership Counseling Notice not provided to borrower at the time of application. of the Act, except to the extent involved I violations arising from servicing or collecting. Cash-out -
Counseling Notice Not Other
Provided Timely
649209465 XXX XXX 2 18764214 compliance 2 Michigan Consumer Michigan Consumer Mortgage Protection Act: List of HUD-approved credit 1/XX/2004 MI Refinance - Primary No B B B B 10/XX/2017
Mortgage Protection Act counseling agencies not provided to borrower. Cash-out -
(Counseling Agencies Other
List)
649209465 XXX XXX 2 18764215 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2004 1/XX/2005 MI Refinance - Primary No B B B B 10/XX/2017
borrower within three (3) days of application. Cash-out -
Other
649209465 XXX XXX 2 18764216 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2004 1/XX/2005 MI Refinance - Primary No B B B B 10/XX/2017
Timing CHARM Booklet, not provided to the borrower within three (3) days of application. Cash-out -
Other
649209465 XXX XXX 2 18764217 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Closing instructions indicate the Index used was 1.1%. The $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 1/XX/2004 1/XX/2007 MI Refinance - Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. closest Index available in our look-back period is 1.19%. transactions. Unlimited as a defense to foreclosure. Assignee liability. Cash-out -
Other
649209465 XXX XXX 2 18764218 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 1/XX/2004 MI Refinance - Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: Cash-out -
inspection is dated prior Other
to the most recent FEMA
disaster.
649209465 XXX XXX 2 18764219 compliance 2 (Doc Error) Initial GFE 1/XX/2004 MI Refinance - Primary No B B B B 10/XX/2017
not provided Cash-out -
Other
649209439 XXX XXX 2 18764243 credit 3 Missing Document: Flood 6/XX/2006 IN Purchase Primary Yes C C C C 10/XX/2017
Certificate not provided
649209439 XXX XXX 2 18764244 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 6/XX/2006 IN Purchase Primary Yes C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649209439 XXX XXX 2 18764245 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2006 6/XX/2007 IN Purchase Primary Yes B B B B 10/XX/2017
borrower within three (3) days of application.
649209439 XXX XXX 2 18764246 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2006 6/XX/2007 IN Purchase Primary Yes B B B B 10/XX/2017
Timing CHARM Booklet, not provided to the borrower within three (3) days of application.
649209485 XXX XXX 1 18764492 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 7/XX/2006 MI Purchase Second Home No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209324 XXX XXX 2 18764744 credit 3 Missing Document: Flood 5/XX/2006 UT Purchase Primary No C C C C 10/XX/2017
Certificate not provided
649209324 XXX XXX 2 18764745 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 5/XX/2006 UT Purchase Primary No B B B B 10/XX/2017
Application Test an application date of 4/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2005.
649209316 XXX XXX 1 18764797 compliance 2 Missing Document: Missing Yes 12/XX/2003 OH Refinance - Primary No B B B B 10/XX/2017
Lender's Initial 1003 Cash-out -
Other
649209316 XXX XXX 1 18764798 compliance 3 Missing Final HUD-1: No Missing Final HUD-1. No document containing fees provided. Any applicable Yes 12/XX/2003 OH Refinance - Primary No D D D D 10/XX/2017
Document Used For Fee Federal, State or Local compliance testing is unreliable. Cash-out -
Testing Other
649209316 XXX XXX 1 18764799 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using Yes 12/XX/2003 OH Refinance - Primary No B B B B 10/XX/2017
Application No Fees an application date of 11/XX/2003 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Other
for testing was 6/XX/2003. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
649209316 XXX XXX 1 18764800 compliance 2 ARM Disclosure Compliant TIL variable rate disclosure: ARM loan program disclosure does not match terms of TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 12/XX/2003 12/XX/2004 OH Refinance - Primary No B B B B 10/XX/2017
loan. Cash-out -
Other
649209316 XXX XXX 1 18764801 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 12/XX/2003 12/XX/2004 OH Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649209316 XXX XXX 1 18764802 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable Yes 12/XX/2003 12/XX/2006 OH Refinance - Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. transactions. Unlimited as a defense to foreclosure. Assignee liability. Cash-out -
Other
649209316 XXX XXX 1 18764803 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX Yes 12/XX/2003 OH Refinance - Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: Cash-out -
inspection is dated prior Other
to the most recent FEMA
disaster.
649209316 XXX XXX 1 18764804 credit 2 Final Title Policy is Yes 12/XX/2003 OH Refinance - Primary No B B B B 10/XX/2017
missing. No evidence of Cash-out -
title was found in file. Other
649209809 XXX XXX 2 18764990 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 11/XX/2003 MA Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209809 XXX XXX 2 18764991 compliance 2 ARM Disclosure Status Unable to determine if loan file contains ARM Disclosure due to missing Date Sent or Date Signed were not provided. TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2003 11/XX/2004 MA Purchase Primary No B B B B 10/XX/2017
information.
649209490 XXX XXX 1 18765094 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2006 6/XX/2007 MA Refinance - Primary Yes B B B B 10/XX/2017
borrower within three (3) days of application. Cash-out -
Other
649209490 XXX XXX 1 18765095 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2006 6/XX/2007 MA Refinance - Primary Yes B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649209822 XXX XXX 1 18765175 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 5/XX/2006 TX Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649209822 XXX XXX 1 18765176 credit 2 Final Title Policy is 5/XX/2006 TX Purchase Primary No B B B B 10/XX/2017
missing. No evidence of
title was found in file.
649209822 XXX XXX 1 18765177 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2006 5/XX/2007 TX Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
649209822 XXX XXX 1 18765178 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2006 5/XX/2007 TX Purchase Primary No B B B B 10/XX/2017
Timing CHARM Booklet, not provided to the borrower within three (3) days of application.
649209377 XXX XXX 2 18765247 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 2/XX/2004 WI Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649209377 XXX XXX 2 18765248 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2004 2/XX/2005 WI Purchase Primary No B B B B 10/XX/2017
borrower.
649209377 XXX XXX 2 18765249 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2004 2/XX/2005 WI Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209766 XXX XXX 2 18765294 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 4/XX/2006 NH Purchase Primary No B B B B 10/XX/2017
Missing Signature on Arrangement Disclosure. implementing regulation, Regulation X, for these type of violations.
Affiliated Business
Arrangement Disclosure
649209766 XXX XXX 2 18765295 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 4/XX/2006 NH Purchase Primary No B B B B 10/XX/2017
Affiliated Business Disclosure to applicant within three (3) business days of application. implementing regulation, Regulation X, for these type of violations.
Arrangement Disclosure
Not Provided Within 3
Business Days of
Application
649209766 XXX XXX 2 18765296 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2006 4/XX/2007 NH Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209766 XXX XXX 2 18765297 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2006 4/XX/2007 NH Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
649209766 XXX XXX 2 18765298 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 4/XX/2006 NH Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649209965 XXX XXX 2 18765627 compliance 2 Federal FACTA Disclosure FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure No 3/XX/2008 CA Purchase Primary No B B B B 10/XX/2017
Timing Test within a reasonably practicable time after using credit score.
649209965 XXX XXX 2 18765628 compliance 3 Missing Final HUD-1: Missing Final HUD-1: HUD-1 Not Signed or Stamped used for any applicable No 3/XX/2008 CA Purchase Primary No D D D D 10/XX/2017
HUD-1 Not Signed or Federal, State or Local compliance testing.
Stamped Used For Fee
Testing
649209965 XXX XXX 2 18765629 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or No 3/XX/2008 CA Purchase Primary No B B B B 10/XX/2017
Missing Signature on Arrangement Disclosure. implementing regulation, Regulation X, for these type of violations.
Affiliated Business
Arrangement Disclosure
649209965 XXX XXX 2 18765630 credit 3 Missing Document: Missing No 3/XX/2008 CA Purchase Primary No C C C C 10/XX/2017
Final 1003
649209965 XXX XXX 2 18765631 compliance 2 (Doc Error) Initial GFE No 3/XX/2008 CA Purchase Primary No B B B B 10/XX/2017
not provided
649209965 XXX XXX 2 18765632 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using No 3/XX/2008 CA Purchase Primary No B B B B 10/XX/2017
Application Test an application date of 2/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 2/XX/2008.
649209965 XXX XXX 2 18765633 compliance 2 RESPA Disclosure - Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or No 3/XX/2008 CA Purchase Primary No B B B B 10/XX/2017
Affiliated Business Loan Application Date. implementing regulation, Regulation X, for these type of violations.
Arrangement Disclosure
Not Provided Within 3
Business Days of
Application
649209965 XXX XXX 2 18765634 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA No 3/XX/2008 3/XX/2009 CA Purchase Primary No B B B B 10/XX/2017
Loan Application Date.
649209965 XXX XXX 2 18765635 compliance 2 CHARM Booklet Disclosure Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA No 3/XX/2008 3/XX/2009 CA Purchase Primary No B B B B 10/XX/2017
Timing Loan Application Date.
649209547 XXX XXX 2 18765886 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2006 4/XX/2007 NJ Refinance - Primary Yes B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Cash-out -
Debt
Consolidation
649209547 XXX XXX 2 18765887 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 4/XX/2006 NJ Refinance - Primary Yes C C C C 10/XX/2017
most recent valuation Inspection Date: Cash-out -
inspection is dated prior Debt
to the most recent FEMA Consolidation
disaster.
649209412 XXX XXX 1 18765903 compliance 2 Acknowledgement of FDPA Notification Rule: Creditor did not retain record of borrower's receipt of Liability for violations cannot be transferred to a subsequent purchaser of a loan. 10/XX/2003 NY Purchase Second Home No B B B B 10/XX/2017
Borrower Receipt of Notice of Special Flood Hazard Disclosure.
Notice of Special Flood
Hazard Disclosure Missing
649209412 XXX XXX 1 18765904 compliance 2 Notice of Special Flood FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Liability for violations cannot be transferred to a subsequent purchaser of a loan. 10/XX/2003 NY Purchase Second Home No B B B B 10/XX/2017
Hazard Disclosure Not Disclosure within a reasonable time prior to closing.
Provided Timely
649209412 XXX XXX 1 18765905 compliance 3 Disparity in Occupancy The mortgage loan file contains documenting evidence the consumer intends to 10/XX/2003 NY Purchase Second Home No C C C C 10/XX/2017
occupy the subject property as their primary residence. (Compliance testing
performed based on the Occupancy Type of Second Home)
649209412 XXX XXX 1 18765906 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 10/XX/2003 NY Purchase Second Home No B B B B 10/XX/2017
Application Test an application date of 9/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 8/XX/2003.
649209412 XXX XXX 1 18765907 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization did not disclose the following fees as $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 10/XX/2003 10/XX/2004 NY Purchase Second Home No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. prepaid finance charges: $XXX Application Fee, $XXX Attorney transactions. Unlimited as a defense to foreclosure. Assignee liability.
Fee, $XXX Funding Fee, $XXX Processing Fee.
649209412 XXX XXX 1 18765908 compliance 2 (Doc Error) Initial GFE 10/XX/2003 NY Purchase Second Home No B B B B 10/XX/2017
not provided
649209412 XXX XXX 1 18765909 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 10/XX/2003 NY Purchase Second Home No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209424 XXX XXX 2 18765928 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 9/XX/2003 MI Refinance - Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX Cash-out -
inspection is dated prior Other
to the most recent FEMA
disaster.
649209424 XXX XXX 2 18765929 compliance 2 Michigan Consumer Michigan Consumer Mortgage Protection Act: List of HUD-approved credit 9/XX/2003 MI Refinance - Primary No B B B B 10/XX/2017
Mortgage Protection Act counseling agencies not provided to borrower. Cash-out -
(Counseling Agencies Other
List)
649209424 XXX XXX 2 18765930 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2003 9/XX/2004 MI Refinance - Primary No B B B B 10/XX/2017
borrower within three (3) days of application. Cash-out -
Other
649209966 XXX XXX 2 18765987 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2006 3/XX/2007 MN Refinance - Primary No B B B B 10/XX/2017
borrower within three (3) days of application. Cash-out -
Other
649209966 XXX XXX 2 18765988 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2006 3/XX/2007 MN Refinance - Primary No B B B B 10/XX/2017
Timing CHARM Booklet, not provided to the borrower within three (3) days of application. Cash-out -
Other
649209471 XXX XXX 2 18765992 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 8/XX/2003 GA Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209471 XXX XXX 2 18765993 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2003 8/XX/2004 GA Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209471 XXX XXX 2 18765994 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 8/XX/2003 8/XX/2004 GA Purchase Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. itemization of amount financed. transactions. Unlimited as a defense to foreclosure. Assignee liability.
649209702 XXX XXX 2 18766024 credit 2 Final Title Policy is 2/XX/2008 AZ Purchase Investment No B B B B 10/XX/2017
missing. No evidence of
title was found in file.
649209504 XXX XXX 2 18766078 credit 3 Missing Document: Flood 2/XX/2006 MA Purchase Primary Yes C C C C 10/XX/2017
Certificate not provided
649209504 XXX XXX 2 18766079 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 2/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
649209504 XXX XXX 2 18766080 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 2/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
Application Test an application date of 2/XX/2006 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 2/XX/2006.
649209504 XXX XXX 2 18766081 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2006 2/XX/2007 MA Purchase Primary Yes B B B B 10/XX/2017
Loan Application Date.
649209504 XXX XXX 2 18766082 compliance 2 CHARM Booklet Disclosure Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2006 2/XX/2007 MA Purchase Primary Yes B B B B 10/XX/2017
Timing Loan Application Date.
649209504 XXX XXX 2 18766083 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 2/XX/2006 MA Purchase Primary Yes C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209504 XXX XXX 2 18766084 credit 2 Final Title Policy is 2/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
missing. No evidence of
title was found in file.
649209709 XXX XXX 1 18766196 credit 3 Missing Document: Flood 3/XX/2006 NH Refinance - Second Home No C C C C 10/XX/2017
Certificate not provided Cash-out -
Other
649209709 XXX XXX 1 18766197 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 3/XX/2006 NH Refinance - Second Home No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX Cash-out -
inspection is dated prior Other
to the most recent FEMA
disaster.
649209709 XXX XXX 1 18766198 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 3/XX/2006 NH Refinance - Second Home No B B B B 10/XX/2017
Application Test an application date of 2/XX/2006 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Other
for testing was 1/XX/2006.
649209667 XXX XXX 2 18766291 credit 3 Missing Document: 2/XX/2006 PA Purchase Investment No C C C C 10/XX/2017
Mortgage Insurance
Certificate (MIC) not
provided
649209526 XXX XXX 2 18766733 credit 3 Missing Document: Flood 1/XX/2006 CT Purchase Primary No C C C C 10/XX/2017
Certificate not provided
649209526 XXX XXX 2 18766734 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 1/XX/2006 CT Purchase Primary No B B B B 10/XX/2017
649209526 XXX XXX 2 18766735 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 1/XX/2006 CT Purchase Primary No B B B B 10/XX/2017
Application Test an application date of 12/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 7/XX/2005.
649209526 XXX XXX 2 18766736 compliance 2 RESPA Disclosure - Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 1/XX/2006 CT Purchase Primary No B B B B 10/XX/2017
Affiliated Business Loan Application Date. implementing regulation, Regulation X, for these type of violations.
Arrangement Disclosure
Not Provided Within 3
Business Days of
Application
649209526 XXX XXX 2 18766737 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2006 1/XX/2007 CT Purchase Primary No B B B B 10/XX/2017
Loan Application Date.
649209526 XXX XXX 2 18766738 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2006 1/XX/2007 CT Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209526 XXX XXX 2 18766739 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 1/XX/2006 CT Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649209526 XXX XXX 2 18766740 credit 3 Missing Document: 1/XX/2006 CT Purchase Primary No C C C C 10/XX/2017
Mortgage Insurance
Certificate (MIC) not
provided
649209715 XXX XXX 2 18766779 credit 3 Missing Document: Missing Final loan application not found in package 5/XX/2002 OH Refinance - Primary No C C C C 10/XX/2017
Final 1003 Rate/Term
649209715 XXX XXX 2 18766780 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX Loan package from 2002- no inspection from 2006 available 5/XX/2002 OH Refinance - Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: Rate/Term
inspection is dated prior
to the most recent FEMA
disaster.
649209715 XXX XXX 2 18766781 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2002 5/XX/2003 OH Refinance - Primary No B B B B 10/XX/2017
borrower. Rate/Term
649209715 XXX XXX 2 18766782 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2002 5/XX/2003 OH Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Rate/Term
649209715 XXX XXX 2 18766783 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine as the file did not contain an $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 5/XX/2002 5/XX/2005 OH Refinance - Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. itemization of amount financed. transactions. Unlimited as a defense to foreclosure. Assignee liability. Rate/Term
649209715 XXX XXX 2 18766785 compliance 2 TILA Rescission - Truth in Lending Act: Subject loan transaction disbursed on 5/XX/2002, prior to TILA ROR - 3yrs for rescindable transactions. 5/XX/2002 5/XX/2005 OH Refinance - Primary No B B B B 10/XX/2017
Disbursement Date Less three (3) business days from transaction date of 5/XX/2002. Rate/Term
than 3 Business Days From
Transaction Date
649209329 XXX XXX 1 18766801 credit 3 Missing Document: Flood 12/XX/2005 PA Purchase Primary No C C C C 10/XX/2017
Certificate not provided
649209329 XXX XXX 1 18766802 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 12/XX/2005 PA Purchase Primary No B B B B 10/XX/2017
649209329 XXX XXX 1 18766803 compliance 2 ARM Disclosure Compliant TIL variable rate disclosure: ARM loan program disclosure does not match terms of TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2005 12/XX/2006 PA Purchase Primary No B B B B 10/XX/2017
loan.
649209329 XXX XXX 1 18766804 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2005 12/XX/2006 PA Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209329 XXX XXX 1 18766805 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 12/XX/2005 PA Purchase Primary No B B B B 10/XX/2017
Application Test an application date of 12/XX/2005 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 12/XX/2005.
649209329 XXX XXX 1 18766806 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2005 12/XX/2006 PA Purchase Primary No B B B B 10/XX/2017
Loan Application Date.
649209355 XXX XXX 2 18766870 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 1/XX/2006 OH Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209355 XXX XXX 2 18766871 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 1/XX/2006 OH Purchase Primary No B B B B 10/XX/2017
649209355 XXX XXX 2 18766872 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2006 1/XX/2007 OH Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209837 XXX XXX 1 18767101 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2005 12/XX/2006 MA Refinance - Primary Yes B B B B 10/XX/2017
borrower within three (3) days of application. Cash-out -
Home
Improvement
649209837 XXX XXX 1 18767102 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2005 12/XX/2006 MA Refinance - Primary Yes B B B B 10/XX/2017
Timing CHARM Booklet, not provided to the borrower within three (3) days of application. Cash-out -
Home
Improvement
649209837 XXX XXX 1 18767103 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 12/XX/2005 MA Refinance - Primary Yes C C C C 10/XX/2017
most recent valuation Inspection Date: Cash-out -
inspection is dated prior Home
to the most recent FEMA Improvement
disaster.
649209594 XXX XXX 1 18767473 compliance 2 (Doc Error) Initial GFE 3/XX/2006 FL Purchase Primary No B B B B 10/XX/2017
not provided
649209594 XXX XXX 1 18767474 credit 3 Missing Document: Flood 3/XX/2006 FL Purchase Primary No C C C C 10/XX/2017
Certificate not provided
649209594 XXX XXX 1 18767475 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 3/XX/2006 FL Purchase Primary No B B B B 10/XX/2017
649209594 XXX XXX 1 18767476 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 3/XX/2006 FL Purchase Primary No B B B B 10/XX/2017
Application Test an application date of 2/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 12/XX/2005.
649209502 XXX XXX 1 18767585 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 1/XX/2006 IL Refinance - Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX Rate/Term
inspection is dated prior
to the most recent FEMA
disaster.
649209502 XXX XXX 1 18767586 compliance 2 High Cost Indicator Flag Loan does not exceed any high cost thresholds, however, documentation indicating High Risk Home Loan Disclosure found in file 1/XX/2006 IL Refinance - Primary No B B B B 10/XX/2017
loan was originated as a high cost loan found in file. Rate/Term
649209502 XXX XXX 1 18767587 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2006 1/XX/2007 IL Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Rate/Term
649209502 XXX XXX 1 18767588 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2006 1/XX/2007 IL Refinance - Primary No B B B B 10/XX/2017
borrower within three (3) days of application. Rate/Term
649209502 XXX XXX 1 18767589 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization did not disclose a Tax Service Fee of $XXX $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 1/XX/2006 1/XX/2009 IL Refinance - Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. as prepaid finance charges. transactions. Unlimited as a defense to foreclosure. Assignee liability. Rate/Term
649209805 XXX XXX 1 18768061 credit 3 Missing Document: Missing 11/XX/2007 CA Refinance - Primary No C C C C 10/XX/2017
Final 1003 Rate/Term
649209805 XXX XXX 1 18768062 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 11/XX/2007 CA Refinance - Primary No B B B B 10/XX/2017
Missing Signature on Arrangement Disclosure. implementing regulation, Regulation X, for these type of violations. Rate/Term
Affiliated Business
Arrangement Disclosure
649209805 XXX XXX 1 18768063 compliance 2 ARM Disclosure Compliant TIL variable rate disclosure: ARM loan program disclosure does not match terms of TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2007 11/XX/2008 CA Refinance - Primary No B B B B 10/XX/2017
loan. Rate/Term
649209805 XXX XXX 1 18768064 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2007 11/XX/2008 CA Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Rate/Term
649209805 XXX XXX 1 18768065 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 11/XX/2007 11/XX/2010 CA Refinance - Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. transactions. Unlimited as a defense to foreclosure. Assignee liability. Rate/Term
649209805 XXX XXX 1 18768066 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 11/XX/2007 CA Refinance - Primary No B B B B 10/XX/2017
Application Test an application date of 10/XX/2007 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2007.
649209805 XXX XXX 1 18768067 compliance 2 RESPA Disclosure - Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 11/XX/2007 CA Refinance - Primary No B B B B 10/XX/2017
Affiliated Business Loan Application Date. implementing regulation, Regulation X, for these type of violations. Rate/Term
Arrangement Disclosure
Not Provided Within 3
Business Days of
Application
649209805 XXX XXX 1 18768068 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2007 11/XX/2008 CA Refinance - Primary No B B B B 10/XX/2017
Loan Application Date. Rate/Term
649209570 XXX XXX 1 18768088 credit 3 Missing Document: Missing 10/XX/2005 IL Purchase Primary No C C C C 10/XX/2017
Final 1003
649209570 XXX XXX 1 18768089 credit 3 Missing Document: Flood 10/XX/2005 IL Purchase Primary No C C C C 10/XX/2017
Certificate not provided
649209570 XXX XXX 1 18768090 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 10/XX/2005 IL Purchase Primary No B B B B 10/XX/2017
Application Test an application date of 9/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 9/XX/2005.
649209570 XXX XXX 1 18768091 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL Itemization only disclosed Closing fee in the amount of $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 10/XX/2005 10/XX/2006 IL Purchase Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. $XXX, however, final HUD reflects $XXX. transactions. Unlimited as a defense to foreclosure. Assignee liability.
649209570 XXX XXX 1 18768092 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 10/XX/2005 IL Purchase Primary No B B B B 10/XX/2017
649209570 XXX XXX 1 18768093 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2005 10/XX/2006 IL Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209570 XXX XXX 1 18768094 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 10/XX/2005 IL Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209570 XXX XXX 1 18768095 compliance 2 (Doc Error) Initial GFE 10/XX/2005 IL Purchase Primary No B B B B 10/XX/2017
not provided
649209550 XXX XXX 1 18768128 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2005 10/XX/2006 MA Refinance - Primary Yes B B B B 10/XX/2017
borrower within three (3) days of application. Cash-out -
Other
649209550 XXX XXX 1 18768129 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 10/XX/2005 MA Refinance - Primary Yes C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX Cash-out -
inspection is dated prior Other
to the most recent FEMA
disaster.
649209550 XXX XXX 1 18768130 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2005 10/XX/2006 MA Refinance - Primary Yes B B B B 10/XX/2017
Timing CHARM Booklet, not provided to the borrower within three (3) days of application. Cash-out -
Other
649209704 XXX XXX 2 18768276 credit 3 Missing Document: Missing 12/XX/1999 IN Refinance - Primary No C C C C 10/XX/2017
Final 1003 Cash-out -
Other
649209704 XXX XXX 2 18768277 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/1999 12/XX/2000 IN Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649209704 XXX XXX 2 18768278 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 12/XX/1999 IN Refinance - Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: Cash-out -
inspection is dated prior Other
to the most recent FEMA
disaster.
649209909 XXX XXX 2 18768303 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX FEMA disaster was after the original loan closing date 10/XX/2005 MA Refinance - Primary Yes C C C C 10/XX/2017
most recent valuation Inspection Date: Cash-out -
inspection is dated prior Debt
to the most recent FEMA Consolidation
disaster.
649209909 XXX XXX 2 18768304 compliance 2 FACTA Disclosure Missing Unable to determine FACTA Credit Score Disclosure was provided due to missing There is no Assignee Liability. 10/XX/2005 MA Refinance - Primary Yes B B B B 10/XX/2017
information. Cash-out -
Debt
Consolidation
649209909 XXX XXX 2 18768305 compliance 2 ARM Disclosure Compliant TIL variable rate disclosure: ARM loan program disclosure does not match terms of TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2005 10/XX/2006 MA Refinance - Primary Yes B B B B 10/XX/2017
loan. Cash-out -
Debt
Consolidation
649209909 XXX XXX 2 18768306 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2005 10/XX/2006 MA Refinance - Primary Yes B B B B 10/XX/2017
borrower within three (3) days of application. Cash-out -
Debt
Consolidation
649209909 XXX XXX 2 18768307 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2005 10/XX/2006 MA Refinance - Primary Yes B B B B 10/XX/2017
Timing CHARM Booklet, not provided to the borrower within three (3) days of application. Cash-out -
Debt
Consolidation
649209448 XXX XXX 2 18768506 credit 3 Missing Document: Missing 9/XX/2005 FL Purchase Second Home No C C C C 10/XX/2017
Final 1003
649209448 XXX XXX 2 18768507 credit 3 Missing Document: Flood 9/XX/2005 FL Purchase Second Home No C C C C 10/XX/2017
Certificate not provided
649209448 XXX XXX 2 18768508 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 9/XX/2005 FL Purchase Second Home No C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649209280 XXX XXX 2 18768602 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 10/XX/1999 SC Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649209280 XXX XXX 2 18768603 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/1999 10/XX/2000 SC Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
649209280 XXX XXX 2 18768604 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/1999 10/XX/2000 SC Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209911 XXX XXX 1 18768976 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 1/XX/2005 IL Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209911 XXX XXX 1 18768977 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 1/XX/2005 IL Purchase Primary No B B B B 10/XX/2017
649209911 XXX XXX 1 18768978 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2005 1/XX/2006 IL Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209911 XXX XXX 1 18768979 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL Itemization did not disclose a Settlement Closing fee of $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 1/XX/2005 1/XX/2006 IL Purchase Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. $XXX, email fee of $XXX and a Illinois Policy fee of $XXX as transactions. Unlimited as a defense to foreclosure. Assignee liability.
total prepaid finance charges.
649209911 XXX XXX 1 18768980 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2005 1/XX/2006 IL Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
649209902 XXX XXX 2 18769063 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 1/XX/2005 WI Refinance - Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX Rate/Term
inspection is dated prior
to the most recent FEMA
disaster.
649209902 XXX XXX 2 18769064 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2005 1/XX/2006 WI Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Rate/Term
649209902 XXX XXX 2 18769065 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 1/XX/2005 1/XX/2008 WI Refinance - Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. itemization of amount financed. transactions. Unlimited as a defense to foreclosure. Assignee liability. Rate/Term
649209919 XXX XXX 1 18769096 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2007 9/XX/2008 NV Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
649209919 XXX XXX 1 18769097 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2007 9/XX/2008 NV Purchase Primary No B B B B 10/XX/2017
Timing CHARM Booklet, not provided to the borrower within three (3) days of application.
649209555 XXX XXX 2 18769222 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 9/XX/2005 NY Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649209555 XXX XXX 2 18769223 credit 3 Missing Document: Flood 9/XX/2005 NY Purchase Primary No C C C C 10/XX/2017
Certificate not provided
649209555 XXX XXX 2 18769224 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 9/XX/2005 NY Purchase Primary No B B B B 10/XX/2017
Application Test an application date of 8/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 8/XX/2005.
649209555 XXX XXX 2 18769225 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2005 9/XX/2006 NY Purchase Primary No B B B B 10/XX/2017
Loan Application Date.
649209555 XXX XXX 2 18769226 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2005 9/XX/2006 NY Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209683 XXX XXX 1 18769300 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 3/XX/2003 MI Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209683 XXX XXX 1 18769301 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 3/XX/2003 MI Purchase Primary No B B B B 10/XX/2017
Application Test an application date of 2/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 9/XX/2002.
649209683 XXX XXX 1 18769302 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2003 3/XX/2004 MI Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209588 XXX XXX 2 18769326 compliance 2 Notice of Special Flood FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Liability for violations cannot be transferred to a subsequent purchaser of a loan. 8/XX/2005 FL Purchase Second Home No B B B B 10/XX/2017
Hazard Disclosure Not Disclosure within a reasonable time prior to closing.
Provided Timely
649209588 XXX XXX 2 18769327 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 8/XX/2005 FL Purchase Second Home No B B B B 10/XX/2017
Application Test an application date of 7/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 2/XX/2005.
649209856 XXX XXX 1 18769394 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 8/XX/2005 MA Purchase Primary Yes C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649209856 XXX XXX 1 18769395 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2005 8/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
borrower within three (3) days of application.
649209856 XXX XXX 1 18769396 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2005 8/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
Timing CHARM Booklet, not provided to the borrower within three (3) days of application.
649209711 XXX XXX 2 18769436 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 4/XX/1999 IN Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649209711 XXX XXX 2 18769437 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/1999 4/XX/2000 IN Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
649209711 XXX XXX 2 18769438 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/1999 4/XX/2000 IN Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209913 XXX XXX 2 18769483 credit 3 Missing Document: Flood 8/XX/2005 IL Refinance - Primary No C C C C 10/XX/2017
Certificate not provided Rate/Term
649209913 XXX XXX 2 18769484 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 8/XX/2005 IL Refinance - Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX Rate/Term
inspection is dated prior
to the most recent FEMA
disaster.
649209913 XXX XXX 2 18769485 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization did not disclose a courier fee of $XXX and a $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 8/XX/2005 8/XX/2008 IL Refinance - Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. tax pick up fee of $XXX as prepaid finance charge transactions. Unlimited as a defense to foreclosure. Assignee liability. Rate/Term
649209913 XXX XXX 2 18769486 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 8/XX/2005 IL Refinance - Primary No B B B B 10/XX/2017
Application Test an application date of 7/XX/2005 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date. The final date used
for testing was 7/XX/2005.
649209913 XXX XXX 2 18769487 compliance 2 RESPA Disclosure - Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 8/XX/2005 IL Refinance - Primary No B B B B 10/XX/2017
Affiliated Business Loan Application Date. implementing regulation, Regulation X, for these type of violations. Rate/Term
Arrangement Disclosure
Not Provided Within 3
Business Days of
Application
649209913 XXX XXX 2 18769488 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2005 8/XX/2006 IL Refinance - Primary No B B B B 10/XX/2017
Loan Application Date. Rate/Term
649209913 XXX XXX 2 18769489 compliance 2 CHARM Booklet Disclosure Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2005 8/XX/2006 IL Refinance - Primary No B B B B 10/XX/2017
Timing Loan Application Date. Rate/Term
649209464 XXX XXX 2 18769763 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 9/XX/2005 MA Purchase Primary Yes C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209464 XXX XXX 2 18769764 credit 3 Missing Document: Flood 9/XX/2005 MA Purchase Primary Yes C C C C 10/XX/2017
Certificate not provided
649209464 XXX XXX 2 18769765 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 9/XX/2005 MA Purchase Primary Yes B B B B 10/XX/2017
649209464 XXX XXX 2 18769766 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2005 9/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
borrower within three (3) days of application.
649209464 XXX XXX 2 18769767 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2005 9/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
Timing CHARM Booklet, not provided to the borrower within three (3) days of application.
649209464 XXX XXX 2 18769768 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Under-disclosure appears to be due to lender selecting an $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 9/XX/2005 9/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. index value not available in lookback period specified by transactions. Unlimited as a defense to foreclosure. Assignee liability.
Note. Variance indicated of $XXX/mo over 84 months after
first adjustment and $XXX/mo over final 240 of loan term,
649209393 XXX XXX 1 18769784 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 10/XX/2005 NV Purchase Second Home No B B B B 10/XX/2017
649209710 XXX XXX 1 18770072 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2003 2/XX/2004 WI Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
649209584 XXX XXX 2 18770212 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 8/XX/2007 SC Purchase Primary No B B B B 10/XX/2017
649209584 XXX XXX 2 18770213 compliance 2 South Carolina Home Loan South Carolina Home Loan: Borrower not provided with a document specifying the Exceptions occurring more than 6 years ago may be outside the states statute of limitations. Due to 8/XX/2007 8/XX/2013 SC Purchase Primary No B B B B 10/XX/2017
(Complaint Agency agency designated to receive complaints or inquiries about the origination and the potential remedies available to a court, this exception carries elevated risk to an assignee
Disclosure Not Provided) making of the loan. during the initial 6 years after occurrence of the violation. After the expiration of this 6 year
period, the exception retains risk for claims raised as a defense to foreclosure, but not at the same
level as during the initial 6 years for affirmative claims.
649209584 XXX XXX 2 18770214 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2007 8/XX/2008 SC Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
649209584 XXX XXX 2 18770215 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2007 8/XX/2008 SC Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209890 XXX XXX 1 18770448 credit 3 Missing Document: Missing 3/XX/2005 MA Refinance - Primary Yes C C C C 10/XX/2017
Final 1003 Rate/Term
649209890 XXX XXX 1 18770449 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 3/XX/2005 MA Refinance - Primary Yes C C C C 10/XX/2017
most recent valuation Inspection Date: Rate/Term
inspection is dated prior
to the most recent FEMA
disaster.
649209890 XXX XXX 1 18770450 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 3/XX/2005 MA Refinance - Primary Yes B B B B 10/XX/2017
Affiliated Business Disclosure to applicant within three (3) business days of application. implementing regulation, Regulation X, for these type of violations. Rate/Term
Arrangement Disclosure
Not Provided Within 3
Business Days of
Application
649209890 XXX XXX 1 18770451 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2005 3/XX/2006 MA Refinance - Primary Yes B B B B 10/XX/2017
borrower within three (3) days of application. Rate/Term
649209890 XXX XXX 1 18770452 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2005 3/XX/2006 MA Refinance - Primary Yes B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Rate/Term
649209890 XXX XXX 1 18770453 compliance 2 TILA Rescission - Truth in Lending Act: Subject loan transaction disbursed on 3/XX/2005, prior to TILA ROR - 3yrs for rescindable transactions. 3/XX/2005 3/XX/2009 MA Refinance - Primary Yes B B B B 10/XX/2017
Disbursement Date Less three (3) business days from transaction date of 3/XX/2005. Rate/Term
than 3 Business Days From
Transaction Date
649209890 XXX XXX 1 18770454 compliance 2 TILA Notice of Right to Truth in Lending Act: Actual Date(s) on Notice of Right to Cancel occurs prior TILA ROR - 3yrs for rescindable transactions. 3/XX/2005 3/XX/2009 MA Refinance - Primary Yes B B B B 10/XX/2017
Cancel Expiration Date to expected date(s). Rate/Term
Prior or equal to
Disbursement Date
649209904 XXX XXX 1 18770536 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 7/XX/2005 SC Refinance - Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX Rate/Term
inspection is dated prior
to the most recent FEMA
disaster.
649209880 XXX XXX 2 18770721 credit 3 Missing Document: Flood 7/XX/2005 FL Purchase Primary No C C C C 10/XX/2017
Certificate not provided
649209880 XXX XXX 2 18770722 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 7/XX/2005 FL Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209880 XXX XXX 2 18770723 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 7/XX/2005 FL Purchase Primary No B B B B 10/XX/2017
649209880 XXX XXX 2 18770724 compliance 2 Notice of Special Flood FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Liability for violations cannot be transferred to a subsequent purchaser of a loan. 7/XX/2005 FL Purchase Primary No B B B B 10/XX/2017
Hazard Disclosure Not Disclosure within a reasonable time prior to closing.
Provided Timely
649209880 XXX XXX 2 18770725 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 7/XX/2005 FL Purchase Primary No B B B B 10/XX/2017
Application Test an application date of 6/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 6/XX/2005.
649209880 XXX XXX 2 18770726 compliance 2 ARM Disclosure Status Unable to determine if loan file contains ARM Disclosure due to missing TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2005 7/XX/2006 FL Purchase Primary No B B B B 10/XX/2017
information.
649209880 XXX XXX 2 18770727 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2005 7/XX/2006 FL Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209745 XXX XXX 2 18770918 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 7/XX/2007 IN Refinance - Investment Yes C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX Cash-out -
inspection is dated prior Other
to the most recent FEMA
disaster.
649209519 XXX XXX 1 18771414 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2007 8/XX/2008 CT Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209519 XXX XXX 1 18771415 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 8/XX/2007 CT Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209771 XXX XXX 2 18771663 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 6/XX/2007 IL Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209771 XXX XXX 2 18771664 credit 3 Missing Document: Flood 6/XX/2007 IL Purchase Primary No C C C C 10/XX/2017
Certificate not provided
649209771 XXX XXX 2 18771665 credit 3 Missing Document: 6/XX/2007 IL Purchase Primary No C C C C 10/XX/2017
Mortgage Insurance
Certificate (MIC) not
provided
649209771 XXX XXX 2 18771666 compliance 2 ARM Disclosure Compliant TIL variable rate disclosure: ARM loan program disclosure does not match terms of TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 IL Purchase Primary No B B B B 10/XX/2017
loan.
649209771 XXX XXX 2 18771667 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 IL Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
649209771 XXX XXX 2 18771668 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 IL Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209771 XXX XXX 2 18771669 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 6/XX/2007 6/XX/2008 IL Purchase Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. itemization of amount financed. transactions. Unlimited as a defense to foreclosure. Assignee liability.
649209503 XXX XXX 2 18771788 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX No 7/XX/2007 GA Refinance - Investment No C C C C 10/XX/2017
most recent valuation Inspection Date: Rate/Term
inspection is dated prior
to the most recent FEMA
disaster.
649209503 XXX XXX 2 18771789 credit 3 Missing Document: Flood No 7/XX/2007 GA Refinance - Investment No C C C C 10/XX/2017
Certificate not provided Rate/Term
649209503 XXX XXX 2 18771790 compliance 3 Missing Final HUD-1: Missing Final HUD-1: HUD-1 Not Signed or Stamped used for any applicable No 7/XX/2007 GA Refinance - Investment No D D D D 10/XX/2017
HUD-1 Not Signed or Federal, State or Local compliance testing. Rate/Term
Stamped Used For Fee
Testing
649209503 XXX XXX 2 18771791 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using No 7/XX/2007 GA Refinance - Investment No B B B B 10/XX/2017
Application Test an application date of 6/XX/2007 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date. The final date used
for testing was 6/XX/2007.
649209872 XXX XXX 1 18771936 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 5/XX/2005 MA Purchase Primary Yes C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649209872 XXX XXX 1 18771937 compliance 2 Acknowledgement of FDPA Notification Rule: Creditor did not retain record of borrower's receipt of Liability for violations cannot be transferred to a subsequent purchaser of a loan. 5/XX/2005 MA Purchase Primary Yes B B B B 10/XX/2017
Borrower Receipt of Notice of Special Flood Hazard Disclosure.
Notice of Special Flood
Hazard Disclosure Missing
649209872 XXX XXX 1 18771938 compliance 2 Notice of Special Flood FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Liability for violations cannot be transferred to a subsequent purchaser of a loan. 5/XX/2005 MA Purchase Primary Yes B B B B 10/XX/2017
Hazard Disclosure Not Disclosure within a reasonable time prior to closing.
Provided Timely
649209872 XXX XXX 1 18771939 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 5/XX/2005 MA Purchase Primary Yes B B B B 10/XX/2017
Application Test an application date of 5/XX/2005 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 5/XX/2005.
649209872 XXX XXX 1 18771940 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 5/XX/2005 5/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. transactions. Unlimited as a defense to foreclosure. Assignee liability.
649209486 XXX XXX 1 18772106 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2004 12/XX/2005 MA Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649209486 XXX XXX 1 18772107 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2004 12/XX/2005 MA Refinance - Primary No B B B B 10/XX/2017
borrower within three (3) days of application. Cash-out -
Other
649209486 XXX XXX 1 18772108 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization did not disclose an attorney fee of $XXX a $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 12/XX/2004 12/XX/2008 MA Refinance - Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. processing fee of $XXX and a courier fee of $XXX as prepaid transactions. Unlimited as a defense to foreclosure. Assignee liability. Cash-out -
finance charge Other
649209486 XXX XXX 1 18772109 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 12/XX/2004 MA Refinance - Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX Cash-out -
inspection is dated prior Other
to the most recent FEMA
disaster.
649209496 XXX XXX 1 18772395 credit 3 Missing Document: Flood 8/XX/2002 VA Purchase Primary No C C C C 10/XX/2017
Certificate not provided
649209496 XXX XXX 1 18772396 credit 3 Missing Document: Missing 8/XX/2002 VA Purchase Primary No C C C C 10/XX/2017
Final 1003
649209496 XXX XXX 1 18772397 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX NA 8/XX/2002 VA Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209496 XXX XXX 1 18772398 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2002 8/XX/2003 VA Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
649209496 XXX XXX 1 18772399 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2002 8/XX/2003 VA Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209769 XXX XXX 1 18772553 credit 3 Missing Document: Missing 5/XX/2005 MA Purchase Primary Yes C C C C 10/XX/2017
Final 1003
649209769 XXX XXX 1 18772554 credit 3 Missing Document: Flood 5/XX/2005 MA Purchase Primary Yes C C C C 10/XX/2017
Certificate not provided
649209769 XXX XXX 1 18772555 credit 3 FEMA Disaster Issue: 5/XX/2005 MA Purchase Primary Yes C C C C 10/XX/2017
Property is located in a
FEMA Disaster area and
has not been inspected.
649209769 XXX XXX 1 18772556 compliance 2 (Doc Error) Initial GFE 5/XX/2005 MA Purchase Primary Yes B B B B 10/XX/2017
not provided
649209769 XXX XXX 1 18772557 compliance 2 (Missing Data) Flood Federal Compliance - (Missing Data) Flood Hazard Zone: Special Flood Hazard Zone 5/XX/2005 MA Purchase Primary Yes B B B B 10/XX/2017
Hazard Zone indicator was not provided. The applicable flood zone related testing cannot be
performed.
649209769 XXX XXX 1 18772558 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2005 5/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
borrower.
649209769 XXX XXX 1 18772559 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2005 5/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209769 XXX XXX 1 18772560 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 5/XX/2005 MA Purchase Primary Yes B B B B 10/XX/2017
Application Test an application date of 4/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2004.
649209769 XXX XXX 1 18772561 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 5/XX/2005 MA Purchase Primary Yes C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649209782 XXX XXX 2 18772571 compliance 2 Federal FACTA Disclosure FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 4/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
Timing Test within a reasonably practicable time after using credit score.
649209782 XXX XXX 2 18772572 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2005 4/XX/2006 MI Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
649209782 XXX XXX 2 18772573 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 4/XX/2005 MI Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209782 XXX XXX 2 18772574 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2005 4/XX/2006 MI Purchase Primary No B B B B 10/XX/2017
Timing CHARM Booklet, not provided to the borrower within three (3) days of application.
649209971 XXX XXX 2 18772721 credit 3 Missing Document: Flood 5/XX/2007 CA Purchase Primary No C C C C 10/XX/2017
Certificate not provided
649209971 XXX XXX 2 18772722 compliance 2 (Missing Data) Flood Federal Compliance - (Missing Data) Flood Hazard Zone: Special Flood Hazard Zone 5/XX/2007 CA Purchase Primary No B B B B 10/XX/2017
Hazard Zone indicator was not provided. The applicable flood zone related testing cannot be
performed.
649209971 XXX XXX 2 18772723 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2007 5/XX/2008 CA Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
649209971 XXX XXX 2 18772724 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2007 5/XX/2008 CA Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209574 XXX XXX 1 18773084 credit 3 Missing Document: Missing 1/XX/2005 CA Refinance - Primary No C C C C 10/XX/2017
Final 1003 Cash-out -
Other
649209574 XXX XXX 1 18773085 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 1/XX/2005 CA Refinance - Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX Cash-out -
inspection is dated prior Other
to the most recent FEMA
disaster.
649209574 XXX XXX 1 18773086 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 1/XX/2005 CA Refinance - Primary No B B B B 10/XX/2017
Application Test an application date of 1/XX/2005 which is 0 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Other
for testing was 1/XX/2005.
649209574 XXX XXX 1 18773087 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2005 1/XX/2006 CA Refinance - Primary No B B B B 10/XX/2017
Loan Application Date. Cash-out -
Other
649209574 XXX XXX 1 18773088 compliance 2 CHARM Booklet Disclosure Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2005 1/XX/2006 CA Refinance - Primary No B B B B 10/XX/2017
Timing Loan Application Date. Cash-out -
Other
649209524 XXX XXX 1 18773394 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 4/XX/2005 MA Purchase Primary Yes C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209524 XXX XXX 1 18773395 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2005 4/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
borrower within three (3) days of application.
649209524 XXX XXX 1 18773396 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2005 4/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
Timing CHARM Booklet, not provided to the borrower within three (3) days of application.
649209963 XXX XXX 2 18773662 credit 3 Missing Document: Flood 4/XX/2007 MN Refinance - Primary No C C C C 10/XX/2017
Certificate not provided Cash-out -
Other
649209963 XXX XXX 2 18773663 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 4/XX/2007 MN Refinance - Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX Cash-out -
inspection is dated prior Other
to the most recent FEMA
disaster.
649209963 XXX XXX 2 18773664 compliance 2 (Missing Data) Flood Federal Compliance - (Missing Data) Flood Hazard Zone: Special Flood Hazard Zone 4/XX/2007 MN Refinance - Primary No B B B B 10/XX/2017
Hazard Zone indicator was not provided. The applicable flood zone related testing cannot be Cash-out -
performed. Other
649209963 XXX XXX 2 18773665 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2007 4/XX/2008 MN Refinance - Primary No B B B B 10/XX/2017
borrower within three (3) days of application. Cash-out -
Other
649209963 XXX XXX 2 18773666 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2007 4/XX/2008 MN Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649209963 XXX XXX 2 18773667 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 4/XX/2007 4/XX/2010 MN Refinance - Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. itemization of amount financed transactions. Unlimited as a defense to foreclosure. Assignee liability. Cash-out -
Other
649209506 XXX XXX 2 18773668 credit 3 Missing Document: Flood 3/XX/2007 CT Purchase Investment No C C C C 10/XX/2017
Certificate not provided
649209506 XXX XXX 2 18773669 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 3/XX/2007 CT Purchase Investment No B B B B 10/XX/2017
Application Test an application date of 3/XX/2007 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 3/XX/2007.
649209506 XXX XXX 2 18773670 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 3/XX/2007 CT Purchase Investment No C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649209572 XXX XXX 2 18773787 credit 3 Missing Document: Flood 4/XX/2007 NJ Refinance - Primary Yes C C C C 10/XX/2017
Certificate not provided Cash-out -
Other
649209572 XXX XXX 2 18773788 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 4/XX/2007 NJ Refinance - Primary Yes B B B B 10/XX/2017
Cash-out -
Other
649209572 XXX XXX 2 18773789 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2007 4/XX/2008 NJ Refinance - Primary Yes B B B B 10/XX/2017
borrower within three (3) days of application. Cash-out -
Other
649209572 XXX XXX 2 18773790 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine underdisclosure due to missing $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 4/XX/2007 4/XX/2010 NJ Refinance - Primary Yes B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. itemization of amount financed. transactions. Unlimited as a defense to foreclosure. Assignee liability. Cash-out -
Other
649209572 XXX XXX 2 18773791 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 4/XX/2007 NJ Refinance - Primary Yes C C C C 10/XX/2017
most recent valuation Inspection Date: Cash-out -
inspection is dated prior Other
to the most recent FEMA
disaster.
649209572 XXX XXX 2 18773792 compliance 2 (Doc Error) Initial GFE 4/XX/2007 NJ Refinance - Primary Yes B B B B 10/XX/2017
not provided Cash-out -
Other
649209572 XXX XXX 2 18773793 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2007 4/XX/2008 NJ Refinance - Primary Yes B B B B 10/XX/2017
Timing CHARM Booklet, not provided to the borrower within three (3) days of application. Cash-out -
Other
649209266 XXX XXX 2 18773994 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 5/XX/2005 OH Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649209266 XXX XXX 2 18773995 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 5/XX/2005 OH Purchase Primary No B B B B 10/XX/2017
649209266 XXX XXX 2 18773996 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2005 5/XX/2006 OH Purchase Primary No B B B B 10/XX/2017
borrower.
649209266 XXX XXX 2 18773997 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2005 5/XX/2006 OH Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209266 XXX XXX 2 18773998 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 5/XX/2005 OH Purchase Primary No B B B B 10/XX/2017
Application Test an application date of 4/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2004.
649209726 XXX XXX 2 18774183 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2005 3/XX/2006 OH Refinance - Primary No B B B B 10/XX/2017
borrower. Rate/Term
649209726 XXX XXX 2 18774184 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2005 3/XX/2006 OH Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Rate/Term
649209726 XXX XXX 2 18774185 compliance 2 (Doc Error) Initial GFE 3/XX/2005 OH Refinance - Primary No B B B B 10/XX/2017
not provided Rate/Term
649209726 XXX XXX 2 18774186 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 3/XX/2005 OH Refinance - Primary No B B B B 10/XX/2017
Rate/Term
649209726 XXX XXX 2 18774187 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine reason for under disclosure due to $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 3/XX/2005 3/XX/2008 OH Refinance - Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. missing itemization of amount financed. transactions. Unlimited as a defense to foreclosure. Assignee liability. Rate/Term
649209726 XXX XXX 2 18774188 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 3/XX/2005 OH Refinance - Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: Rate/Term
inspection is dated prior
to the most recent FEMA
disaster.
649209308 XXX XXX 1 18774306 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 3/XX/2007 IN Purchase Primary Yes C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209308 XXX XXX 1 18774307 credit 3 Missing Document: Flood 3/XX/2007 IN Purchase Primary Yes C C C C 10/XX/2017
Certificate not provided
649209308 XXX XXX 1 18774308 credit 3 Missing Document: Missing 3/XX/2007 IN Purchase Primary Yes C C C C 10/XX/2017
Final 1003
649209308 XXX XXX 1 18774309 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 3/XX/2007 IN Purchase Primary Yes B B B B 10/XX/2017
Application Test an application date of 3/XX/2007 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 3/XX/2007.
649209308 XXX XXX 1 18774310 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 IN Purchase Primary Yes B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209690 XXX XXX 1 18774318 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 2/XX/2005 MO Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209690 XXX XXX 1 18774319 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2005 2/XX/2006 MO Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
649209690 XXX XXX 1 18774320 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2005 2/XX/2006 MO Purchase Primary No B B B B 10/XX/2017
Timing CHARM Booklet, not provided to the borrower within three (3) days of application.
649209964 XXX XXX 1 18774397 credit 3 Missing Document: Flood No 2/XX/2005 AZ Purchase Primary No C C C C 10/XX/2017
Certificate not provided
649209964 XXX XXX 1 18774398 credit 3 Missing Document: Missing No 2/XX/2005 AZ Purchase Primary No C C C C 10/XX/2017
Final 1003
649209964 XXX XXX 1 18774399 compliance 2 (Doc Error) Initial GFE No 2/XX/2005 AZ Purchase Primary No B B B B 10/XX/2017
not provided
649209964 XXX XXX 1 18774400 compliance 3 Missing Final HUD-1: No Missing Final HUD-1. No document containing fees provided. Any applicable No 2/XX/2005 AZ Purchase Primary No D D D D 10/XX/2017
Document Used For Fee Federal, State or Local compliance testing is unreliable.
Testing
649209964 XXX XXX 1 18774401 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using No 2/XX/2005 AZ Purchase Primary No B B B B 10/XX/2017
Application No Fees an application date of 1/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 8/XX/2004. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
649209964 XXX XXX 1 18774402 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA No 2/XX/2005 2/XX/2006 AZ Purchase Primary No B B B B 10/XX/2017
borrower.
649209964 XXX XXX 1 18774403 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA No 2/XX/2005 2/XX/2006 AZ Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209964 XXX XXX 1 18774404 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. No 2/XX/2005 2/XX/2006 AZ Purchase Primary No B B B B 10/XX/2017
Assignee liability.
649209820 XXX XXX 2 18774516 credit 3 Missing Document: 11/XX/2004 MN Refinance - Primary No C C C C 10/XX/2017
Mortgage Insurance Cash-out -
Certificate (MIC) not Debt
provided Consolidation
649209820 XXX XXX 2 18774517 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2004 11/XX/2005 MN Refinance - Primary No B B B B 10/XX/2017
borrower within three (3) days of application. Cash-out -
Debt
Consolidation
649209820 XXX XXX 2 18774518 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2004 11/XX/2005 MN Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Cash-out -
Debt
Consolidation
649209820 XXX XXX 2 18774519 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 11/XX/2004 MN Refinance - Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: Cash-out -
inspection is dated prior Debt
to the most recent FEMA Consolidation
disaster.
649210105 XXX XXX 2 18774648 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 12/XX/2004 NC Refinance - Second Home No C C C C 10/XX/2017
most recent valuation Inspection Date: Rate/Term
inspection is dated prior
to the most recent FEMA
disaster.
649209499 XXX XXX 2 18774675 credit 3 Missing Document: Flood 3/XX/2007 AZ Purchase Primary No C C C C 10/XX/2017
Certificate not provided
649209499 XXX XXX 2 18774676 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 AZ Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
649209499 XXX XXX 2 18774677 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 AZ Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209326 XXX XXX 1 18774989 compliance 2 Federal FACTA Disclosure FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 3/XX/2007 SC Purchase Primary No B B B B 10/XX/2017
Timing Test within a reasonably practicable time after using credit score.
649209326 XXX XXX 1 18774990 compliance 2 Notice of Special Flood FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Liability for violations cannot be transferred to a subsequent purchaser of a loan. 3/XX/2007 SC Purchase Primary No B B B B 10/XX/2017
Hazard Disclosure Not Disclosure within a reasonable time prior to closing.
Provided Timely
649209326 XXX XXX 1 18774991 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 3/XX/2007 SC Purchase Primary No B B B B 10/XX/2017
Application Test an application date of 2/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 12/XX/2006.
649209326 XXX XXX 1 18774992 compliance 2 South Carolina CHL Unable to determine compliance with timing requirements due to missing Initial Exceptions occurring more than 6 years ago may be outside the states statute of limitations. Due to 3/XX/2007 3/XX/2013 SC Purchase Primary No B B B B 10/XX/2017
Complaint Agency Loan Application Date. the potential remedies available to a court, this exception carries elevated risk to an assignee
Disclosure Timing Test during the initial 6 years after occurrence of the violation. After the expiration of this 6 year
period, the exception retains risk for claims raised as a defense to foreclosure, but not at the same
level as during the initial 6 years for affirmative claims.
649209326 XXX XXX 1 18774993 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 SC Purchase Primary No B B B B 10/XX/2017
Loan Application Date.
649209326 XXX XXX 1 18774994 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 SC Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209326 XXX XXX 1 18774995 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 3/XX/2007 SC Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209512 XXX XXX 1 18775011 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 3/XX/2005 NC Purchase Primary No B B B B 10/XX/2017
649209512 XXX XXX 1 18775012 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2005 3/XX/2006 NC Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
649209512 XXX XXX 1 18775013 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2005 3/XX/2006 NC Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209512 XXX XXX 1 18775014 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 3/XX/2005 3/XX/2006 NC Purchase Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. Itemization of Amount Financed. transactions. Unlimited as a defense to foreclosure. Assignee liability.
649209484 XXX XXX 2 18775239 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 11/XX/2004 MA Refinance - Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: Cash-out -
inspection is dated prior Other
to the most recent FEMA
disaster.
649209484 XXX XXX 2 18775240 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2004 11/XX/2005 MA Refinance - Primary No B B B B 10/XX/2017
borrower within three (3) days of application. Cash-out -
Other
649209484 XXX XXX 2 18775241 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2004 11/XX/2005 MA Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649209551 XXX XXX 1 18775400 compliance 2 Notice of Special Flood Unable to determine compliance of Notice of Special Flood Hazard Disclosure due Liability for violations cannot be transferred to a subsequent purchaser of a loan. 10/XX/2004 NY Refinance - Primary No B B B B 10/XX/2017
Hazard Disclosure Missing to missing information. Cash-out -
Other
649209551 XXX XXX 1 18775401 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 10/XX/2004 NY Refinance - Primary No B B B B 10/XX/2017
Application Test an application date of 9/XX/2004 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Other
for testing was 9/XX/2004.
649209551 XXX XXX 1 18775402 compliance 2 ARM Disclosure Status Unable to determine if loan file contains ARM Disclosure due to missing TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2004 10/XX/2005 NY Refinance - Primary No B B B B 10/XX/2017
information. Cash-out -
Other
649209551 XXX XXX 1 18775403 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2004 10/XX/2005 NY Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649209551 XXX XXX 1 18775404 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 10/XX/2004 NY Refinance - Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: Cash-out -
inspection is dated prior Other
to the most recent FEMA
disaster.
649209388 XXX XXX 2 18775408 compliance 3 Missing Final HUD-1: Missing Final HUD-1: HUD-1 Not Signed or Stamped used for any applicable Yes 4/XX/2002 AZ Refinance - Primary No D D D D 10/XX/2017
HUD-1 Not Signed or Federal, State or Local compliance testing. Rate/Term
Stamped Used For Fee
Testing
649209388 XXX XXX 2 18775409 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 4/XX/2002 4/XX/2003 AZ Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Rate/Term
649209388 XXX XXX 2 18775410 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable Yes 4/XX/2002 4/XX/2005 AZ Refinance - Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. itemization of amount financed. transactions. Unlimited as a defense to foreclosure. Assignee liability. Rate/Term
649209645 XXX XXX 1 18775566 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 9/XX/2004 PA Purchase Investment No C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649209915 XXX XXX 1 18775859 credit 3 Missing Document: Flood Not in file 12/XX/2006 CA Refinance - Primary No C C C C 10/XX/2017
Certificate not provided Rate/Term
649209915 XXX XXX 1 18775860 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2006 12/XX/2007 CA Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Rate/Term
649209915 XXX XXX 1 18775861 credit 3 Missing Document: Missing 12/XX/2006 CA Refinance - Primary No C C C C 10/XX/2017
Final 1003 Rate/Term
649209915 XXX XXX 1 18775862 compliance 2 Notice of Special Flood FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Liability for violations cannot be transferred to a subsequent purchaser of a loan. 12/XX/2006 CA Refinance - Primary No B B B B 10/XX/2017
Hazard Disclosure Not Disclosure within a reasonable time prior to closing. Rate/Term
Provided Timely
649209915 XXX XXX 1 18775863 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 12/XX/2006 CA Refinance - Primary No B B B B 10/XX/2017
Application Test an application date of 11/XX/2006 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date. The final date used
for testing was 9/XX/2006.
649209915 XXX XXX 1 18775864 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2006 12/XX/2007 CA Refinance - Primary No B B B B 10/XX/2017
Loan Application Date. Rate/Term
649209915 XXX XXX 1 18775865 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine the fee under disclosure due to missing $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 12/XX/2006 12/XX/2009 CA Refinance - Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. the itemization of amount financed. transactions. Unlimited as a defense to foreclosure. Assignee liability. Rate/Term
649209926 XXX XXX 2 18775877 credit 3 Missing Document: Missing 9/XX/2004 FL Purchase Primary No C C C C 10/XX/2017
Final 1003
649209926 XXX XXX 2 18775879 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 9/XX/2004 FL Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649209926 XXX XXX 2 18775881 compliance 2 ARM Disclosure Compliant TIL variable rate disclosure: ARM loan program disclosure does not match terms of TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2004 9/XX/2005 FL Purchase Primary No B B B B 10/XX/2017
loan.
649209926 XXX XXX 2 18775882 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2004 9/XX/2005 FL Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
649209926 XXX XXX 2 18775883 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2004 9/XX/2005 FL Purchase Primary No B B B B 10/XX/2017
Timing CHARM Booklet, not provided to the borrower within three (3) days of application.
649209926 XXX XXX 2 18775885 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Settlement fee of $XXX Courier Fee of $XXX and Wire Fee of $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 9/XX/2004 9/XX/2005 FL Purchase Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. $XXX not included in finance charges per TIL itemization. transactions. Unlimited as a defense to foreclosure. Assignee liability.
649209846 XXX XXX 2 18776133 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 12/XX/2006 MA Refinance - Primary Yes C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX Rate/Term
inspection is dated prior
to the most recent FEMA
disaster.
649209846 XXX XXX 2 18776134 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2006 12/XX/2007 MA Refinance - Primary Yes B B B B 10/XX/2017
Timing CHARM Booklet, not provided to the borrower within three (3) days of application. Rate/Term
649209798 XXX XXX 2 18776345 credit 3 Missing Document: Flood 11/XX/2006 CA Refinance - Primary No C C C C 10/XX/2017
Certificate not provided Cash-out -
Other
649209798 XXX XXX 2 18776348 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2006 11/XX/2007 CA Refinance - Primary No B B B B 10/XX/2017
borrower within three (3) days of application. Cash-out -
Other
649209798 XXX XXX 2 18776350 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2006 11/XX/2007 CA Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649209798 XXX XXX 2 18776351 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 11/XX/2006 CA Refinance - Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: Cash-out -
inspection is dated prior Other
to the most recent FEMA
disaster.
649209798 XXX XXX 2 18776352 compliance 2 TILA - Incorrect Right To Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing 11/XX/2006 11/XX/2009 CA Refinance - Primary No B B B B 10/XX/2017
Cancel Form Used - H-8 Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses Cash-out -
Used on Same Lender form should have been used. the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that Other
Refinance (Circuit 2, 5, creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for
7, 8, 9, 10 or DC) refinances involving the same creditor.
649209701 XXX XXX 1 18776364 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2006 12/XX/2007 IL Purchase Primary No B B B B 10/XX/2017
borrower.
649209701 XXX XXX 1 18776365 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2006 12/XX/2007 IL Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209701 XXX XXX 1 18776366 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 12/XX/2006 IL Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649209678 XXX XXX 1 18776375 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 8/XX/2004 VT Refinance - Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX Cash-out -
inspection is dated prior Other
to the most recent FEMA
disaster.
649209678 XXX XXX 1 18776376 compliance 2 (Doc Error) Initial GFE 8/XX/2004 VT Refinance - Primary No B B B B 10/XX/2017
not provided Cash-out -
Other
649209678 XXX XXX 1 18776377 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 8/XX/2004 VT Refinance - Primary No B B B B 10/XX/2017
Application Test an application date of 7/XX/2004 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Other
for testing was 4/XX/2004.
649209678 XXX XXX 1 18776378 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2004 8/XX/2005 VT Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649209582 XXX XXX 2 18776423 compliance 2 Michigan Consumer Michigan Consumer Mortgage Protection Act: List of HUD-approved credit 8/XX/2004 MI Refinance - Primary No B B B B 10/XX/2017
Mortgage Protection Act counseling agencies not provided to borrower. Cash-out -
(Counseling Agencies Other
List)
649209716 XXX XXX 1 18777014 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 7/XX/2004 SC Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649209716 XXX XXX 1 18777015 compliance 2 South Carolina Home Loan South Carolina Home Loan: Borrower not provided with a document specifying the Exceptions occurring more than 6 years ago may be outside the states statute of limitations. Due to 7/XX/2004 7/XX/2010 SC Purchase Primary No B B B B 10/XX/2017
(Complaint Agency agency designated to receive complaints or inquiries about the origination and the potential remedies available to a court, this exception carries elevated risk to an assignee
Disclosure Not Provided) making of the loan. during the initial 6 years after occurrence of the violation. After the expiration of this 6 year
period, the exception retains risk for claims raised as a defense to foreclosure, but not at the same
level as during the initial 6 years for affirmative claims.
649209716 XXX XXX 1 18777016 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2004 7/XX/2005 SC Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
649209716 XXX XXX 1 18777017 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2004 7/XX/2005 SC Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209314 XXX XXX 2 18777046 credit 3 Missing Document: Missing 10/XX/2006 FL Refinance - Primary No C C C C 10/XX/2017
Final 1003 Cash-out -
Home
Improvement
649209314 XXX XXX 2 18777047 credit 3 Missing Document: Flood 10/XX/2006 FL Refinance - Primary No C C C C 10/XX/2017
Certificate not provided Cash-out -
Home
Improvement
649209314 XXX XXX 2 18777048 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2006 10/XX/2007 FL Refinance - Primary No B B B B 10/XX/2017
borrower within three (3) days of application. Cash-out -
Home
Improvement
649209314 XXX XXX 2 18777049 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2006 10/XX/2007 FL Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Cash-out -
Home
Improvement
649209627 XXX XXX 2 18777265 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 11/XX/2006 TX Refinance - Second Home No C C C C 10/XX/2017
most recent valuation Inspection Date: Cash-out -
inspection is dated prior Other
to the most recent FEMA
disaster.
649209627 XXX XXX 2 18777266 credit 3 Missing Document: Missing 11/XX/2006 TX Refinance - Second Home No C C C C 10/XX/2017
Final 1003 Cash-out -
Other
649209627 XXX XXX 2 18777267 credit 3 Missing Document: Flood 11/XX/2006 TX Refinance - Second Home No C C C C 10/XX/2017
Certificate not provided Cash-out -
Other
649209531 XXX XXX 2 18777317 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2006 10/XX/2007 CA Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649209531 XXX XXX 2 18777318 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 10/XX/2006 CA Refinance - Primary No B B B B 10/XX/2017
Application Test an application date of 9/XX/2006 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Other
for testing was 4/XX/2006.
649209531 XXX XXX 2 18777319 compliance 2 RESPA Disclosure - Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 10/XX/2006 CA Refinance - Primary No B B B B 10/XX/2017
Affiliated Business Loan Application Date. implementing regulation, Regulation X, for these type of violations. Cash-out -
Arrangement Disclosure Other
Not Provided Within 3
Business Days of
Application
649209531 XXX XXX 2 18777320 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2006 10/XX/2007 CA Refinance - Primary No B B B B 10/XX/2017
Loan Application Date. Cash-out -
Other
649209276 XXX XXX 2 18777441 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2002 3/XX/2003 UT Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Cash-out -
Debt
Consolidation
649209276 XXX XXX 2 18777442 compliance 2 ARM Disclosure Status Unable to determine if loan file contains ARM Disclosure due to missing TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2002 3/XX/2003 UT Refinance - Primary No B B B B 10/XX/2017
information. Cash-out -
Debt
Consolidation
649209845 XXX XXX 2 18777462 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 10/XX/2006 IN Refinance - Primary Yes B B B B 10/XX/2017
Application Test an application date of 9/XX/2006 which is 1 months prior to consummation. A Rate/Term
lookback was performed to determine this application date. The final date used
for testing was 4/XX/2006.
649209845 XXX XXX 2 18777463 compliance 2 RESPA Disclosure - Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 10/XX/2006 IN Refinance - Primary Yes B B B B 10/XX/2017
Affiliated Business Loan Application Date. implementing regulation, Regulation X, for these type of violations. Rate/Term
Arrangement Disclosure
Not Provided Within 3
Business Days of
Application
649209845 XXX XXX 2 18777464 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2006 10/XX/2007 IN Refinance - Primary Yes B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Rate/Term
649209845 XXX XXX 2 18777465 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Final TIL payment stream reflects MI dropping off after 76 $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 10/XX/2006 10/XX/2009 IN Refinance - Primary Yes B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. months, however the HUD reflects MI dropping off after 77 transactions. Unlimited as a defense to foreclosure. Assignee liability. Rate/Term
months.
649209845 XXX XXX 2 18777466 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 10/XX/2006 IN Refinance - Primary Yes C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX Rate/Term
inspection is dated prior
to the most recent FEMA
disaster.
649209845 XXX XXX 2 18777467 compliance 2 (Doc Error) Initial GFE 10/XX/2006 IN Refinance - Primary Yes B B B B 10/XX/2017
not provided Rate/Term
649209874 XXX XXX 1 18777634 credit 3 Missing Document: Missing 5/XX/2004 FL Purchase Primary No C C C C 10/XX/2017
Final 1003
649209874 XXX XXX 1 18777635 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 5/XX/2004 FL Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209874 XXX XXX 1 18777636 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 5/XX/2004 FL Purchase Primary No B B B B 10/XX/2017
Application Test an application date of 4/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2003.
649209795 XXX XXX 2 18777750 credit 3 Missing Document: Missing 10/XX/2006 CT Purchase Primary No C C C C 10/XX/2017
Final 1003
649209795 XXX XXX 2 18777751 credit 3 Missing Document: Flood 10/XX/2006 CT Purchase Primary No C C C C 10/XX/2017
Certificate not provided
649209795 XXX XXX 2 18777752 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 10/XX/2006 CT Purchase Primary No B B B B 10/XX/2017
Application Test an application date of 9/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 9/XX/2006.
649209795 XXX XXX 2 18777753 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2006 10/XX/2007 CT Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209795 XXX XXX 2 18777754 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 10/XX/2006 CT Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649209795 XXX XXX 2 18777755 compliance 2 (Doc Error) Initial GFE 10/XX/2006 CT Purchase Primary No B B B B 10/XX/2017
not provided
649209523 XXX XXX 1 18777771 credit 3 Missing Document: Flood 10/XX/2006 CT Refinance - Primary No C C C C 10/XX/2017
Certificate not provided Cash-out -
Other
649209523 XXX XXX 1 18777772 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 10/XX/2006 CT Refinance - Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX Cash-out -
inspection is dated prior Other
to the most recent FEMA
disaster.
649209523 XXX XXX 1 18777773 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 10/XX/2006 CT Refinance - Primary No B B B B 10/XX/2017
Cash-out -
Other
649209523 XXX XXX 1 18777774 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2006 10/XX/2007 CT Refinance - Primary No B B B B 10/XX/2017
borrower within three (3) days of application. Cash-out -
Other
649209523 XXX XXX 1 18777775 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2006 10/XX/2007 CT Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649209376 XXX XXX 2 18777811 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 10/XX/2006 AL Refinance - Second Home No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX Cash-out -
inspection is dated prior Other
to the most recent FEMA
disaster.
649209376 XXX XXX 2 18777812 compliance 2 Acknowledgement of FDPA Notification Rule: Creditor did not retain record of borrower's receipt of Liability for violations cannot be transferred to a subsequent purchaser of a loan. 10/XX/2006 AL Refinance - Second Home No B B B B 10/XX/2017
Borrower Receipt of Notice of Special Flood Hazard Disclosure. Cash-out -
Notice of Special Flood Other
Hazard Disclosure Missing
649209376 XXX XXX 2 18777813 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 10/XX/2006 AL Refinance - Second Home No B B B B 10/XX/2017
Application Test an application date of 9/XX/2006 which is 1 months prior to consummation. A Cash-out -
lookback was performed to determine this application date. The final date used Other
for testing was 9/XX/2006.
649209568 XXX XXX 2 18777993 credit 3 Missing Document: Flood 9/XX/2006 CA Refinance - Investment No C C C C 10/XX/2017
Certificate not provided Rate/Term
649209568 XXX XXX 2 18777994 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 9/XX/2006 CA Refinance - Investment No B B B B 10/XX/2017
Application Test an application date of 9/XX/2006 which is 0 months prior to consummation. A Rate/Term
lookback was performed to determine this application date. The final date used
for testing was 9/XX/2006.
649209568 XXX XXX 2 18777995 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 9/XX/2006 CA Refinance - Investment No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX Rate/Term
inspection is dated prior
to the most recent FEMA
disaster.
649209849 XXX XXX 2 18778108 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 5/XX/2004 MI Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209849 XXX XXX 2 18778109 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2004 5/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
borrower.
649209849 XXX XXX 2 18778110 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2004 5/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209849 XXX XXX 2 18778111 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL Itemiizatikon does not list the Origination fee of $XXX. $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 5/XX/2004 5/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. As well it shows the Closing fee of $XXX and the $XXX transactions. Unlimited as a defense to foreclosure. Assignee liability.
aplication fee as being paid by someone other than the
borrower. The payment stream is also off at month 121.
The TIL stream has the amount of $XXX for 60 months.
However, the calculated stream shows it for 79 months.
649209687 XXX XXX 1 18778193 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 5/XX/2004 FL Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649209687 XXX XXX 1 18778194 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2004 5/XX/2005 FL Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209687 XXX XXX 1 18778195 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization did not disclose a Processing Fee of $XXX a $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 5/XX/2004 5/XX/2005 FL Purchase Primary No B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. Settlement Fee of $XXX and a Courier Fee of $XXX as prepaid transactions. Unlimited as a defense to foreclosure. Assignee liability.
finance charges.
649209687 XXX XXX 1 18778196 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 5/XX/2004 FL Purchase Primary No B B B B 10/XX/2017
Application Test an application date of 4/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 4/XX/2004.
649209687 XXX XXX 1 18778197 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2004 5/XX/2005 FL Purchase Primary No B B B B 10/XX/2017
Loan Application Date.
649209923 XXX XXX 1 18778274 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2004 10/XX/2005 NJ Purchase Primary Yes B B B B 10/XX/2017
borrower within three (3) days of application.
649209923 XXX XXX 1 18778275 compliance 2 TIL APR Tolerance Truth In Lending Act: Final TIL APR of X.XX% is underdisclosed from calculated Under disclosure due to lender used an index outside the TILA APR - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions. 10/XX/2004 10/XX/2005 NJ Purchase Primary Yes B B B B 10/XX/2017
Irregular Transaction APR of X.XX% outside of 0.125% tolerance. look back period per the closing instructions Unlimited as a defense to foreclosure. Assignee liability.
649209923 XXX XXX 1 18778276 compliance 2 Final TIL Finance Charge Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Under disclosure due to lender used an index outside the $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable 10/XX/2004 10/XX/2005 NJ Purchase Primary Yes B B B B 10/XX/2017
Under Disclosed calculated Finance Charge of $XXX in the amount of $XXX. look back period per the closing instructions transactions. Unlimited as a defense to foreclosure. Assignee liability.
649209923 XXX XXX 1 18778277 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2004 10/XX/2005 NJ Purchase Primary Yes B B B B 10/XX/2017
Timing CHARM Booklet, not provided to the borrower within three (3) days of application.
649209923 XXX XXX 1 18778278 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 10/XX/2004 NJ Purchase Primary Yes C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649209794 XXX XXX 2 18778332 credit 3 Missing Document: Flood 9/XX/2006 MA Purchase Primary Yes C C C C 10/XX/2017
Certificate not provided
649209794 XXX XXX 2 18778333 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2006 9/XX/2007 MA Purchase Primary Yes B B B B 10/XX/2017
borrower.
649209794 XXX XXX 2 18778334 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2006 9/XX/2007 MA Purchase Primary Yes B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209794 XXX XXX 2 18778335 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 9/XX/2006 MA Purchase Primary Yes C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.
649210106 XXX XXX 1 18778522 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 8/XX/2006 MA Purchase Primary Yes C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX
inspection is dated prior
to the most recent FEMA
disaster.
649210106 XXX XXX 1 18778523 compliance 2 Missing Initial Loan No evidence of application date located in file. Compliance tests were run using 8/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
Application Test an application date of 7/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 2/XX/2006.
649210106 XXX XXX 1 18778524 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2006 8/XX/2007 MA Purchase Primary Yes B B B B 10/XX/2017
Loan Application Date.
649210106 XXX XXX 1 18778525 compliance 2 CHARM Booklet Disclosure Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2006 8/XX/2007 MA Purchase Primary Yes B B B B 10/XX/2017
Timing Loan Application Date.
649210098 XXX XXX 2 18778529 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 8/XX/2006 RI Refinance - Primary No C C C C 10/XX/2017
most recent valuation Inspection Date: XX/XX/XXXX Cash-out -
inspection is dated prior Other
to the most recent FEMA
disaster.
649210098 XXX XXX 2 18778530 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2006 8/XX/2007 RI Refinance - Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower. Cash-out -
Other
649210098 XXX XXX 2 18778531 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2006 8/XX/2007 RI Refinance - Primary No B B B B 10/XX/2017
borrower within three (3) days of application. Cash-out -
Other
649209389 XXX XXX 2 18778577 compliance 2 RESPA Disclosure - RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or 4/XX/2004 MI Purchase Primary No B B B B 10/XX/2017
Affiliated Business Disclosure to applicant within three (3) business days of application. implementing regulation, Regulation X, for these type of violations.
Arrangement Disclosure
Not Provided Within 3
Business Days of
Application
649209389 XXX XXX 2 18778578 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2004 4/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
649209389 XXX XXX 2 18778579 compliance 2 CHARM Booklet Disclosure TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2004 4/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
Status CHARM Booklet, not provided to the borrower.
649209389 XXX XXX 2 18778580 credit 3 FEMA Disaster Issue: The Disaster Date: XX/XX/XXXX 4/XX/2004 MI Purchase Primary No C C C C 10/XX/2017
most recent valuation Inspection Date:
inspection is dated prior
to the most recent FEMA
disaster.