J.P. MORGAN ACCEPTANCE CORPORATION II ABS-15G
Exhibit 99.11
Executive
Summary
4.
Description of the Due Diligence Services
| 1. | Type
of Assets Reviewed |
Inglet
Blair, LLC (“IB”) performed certain due diligence review services (the “Review”), as defined herein. The
loans reviewed were originated in April 2025 and were collateralized by residential real estate purchased by the applicable mortgagors
for the purpose of generating rental income (the “Loans”). The Loans were acquired by JPMorgan Chase Bank, National
Association (the “Client”) from lenders and/or aggregators (the “Seller”), via bulk acquisition or reliance
letter. The information provided below represents the approach and methodology used at the time of original acquisition by the
Seller. Each of the loans was acquired by the Seller from various lenders a lender through a delegated correspondent channel.
| 2. | Sample
Size of Assets Reviewed |
This
report reflects 2 loans selected by the Client to include in JPMMT 2025-LTV2 (the “Securitization”). Client did not
disclose to IB if additional loans are included in the Securitization. While the Client may have included additional loans in
the Securitization, such loans were not subject to the Review referenced herein. IB reviewed 100% of the Loans provided by the
Client and can only assume the sample size was 100%.
| 3. | Sample
Size Determination |
The
Client, in its sole discretion, determined the loans to be reviewed by IB. As noted in Section 2 above, Client provided IB with
2 loans, all of which were reviewed by IB. Therefore, IB used no sampling methodology in its Review.
| 4. | Information
and Data Integrity |
IB
was provided certain data elements (the “Tape Data”), which were supplied by the Seller. The Seller aggregated the
Tape Data from the various lenders. Each lender did not supply Seller with uniform Tape Data; thus, individual Loan Tape Data
may not have included all data elements as detailed below in this Section 4. IB subsequently mapped and compared the Tape Data
to information contained in each Loan file. When the data was provided, IB compared the following fields:
Field
Name |
Amortization
Type |
Total
Debt to Income Ratio |
Amortized
Original Term |
First
Payment Date |
Appraised
Value |
Interest
Only Flag |
ARM
Initial Adjustment Period |
Lien
Position |
ARM
Initial Rate Cap |
Loan
Purpose |
ARM
Lookback Period |
Loan
Term |
ARM
Margin |
Loan
Type |
ARM
Maximum Interest Rate |
LTV |
ARM
Minimum Interest Rate |
Note
Date |
ARM
Payment Change Frequency |
Occupancy |
ARM
Periodic Rate Cap |
Original
Interest Rate |
| Inglet
Blair, LLC Deal Summary
JPMMT 2025-LTV2
pg.
1 |
ARM
Periodic Rate Cap at first Adjustment Down |
Original
Principal and Interest |
ARM
Periodic Rate Cap at first Adjustment Up |
Original
Principal Balance |
ARM
Rate Cap at first Adjustment Down |
Property
Type |
ARM
Rate Cap at first Adjustment Up |
Representative
Credit Score |
ARM
Rate Change Frequency |
Residual
Income |
ATR/QM
Designation |
Sales
Price |
Borrower
First Name |
Subject
Address |
Borrower
Last Name |
Subject
City |
CLTV |
Subject
State |
Doc
Type |
Subject
Zip Code |
| 5. | Underwriting,
Origination Practices and Conformity to Guidelines and/or Criteria |
Each
Loan was reviewed to the applicable guideline, matrix and/or finding report, produced by an Automated Underwriting System (“AUS”),
as provided to IB. Depending on the applicable guideline requirements, IB verified, recalculated and compared certain metrics
and attributes:
| - | Debt
Service Coverage Ratio (“DSCR”) |
| - | Loan
to Value (“LTV”) / Combined Loan to Value (“CLTV”) |
| - | Qualifying
Principal, Interest, Taxes and Insurance (“PITI”) payment |
To
the extent prescribed by the applicable guidelines, every Loan received an evaluation of the applicable borrower’s employment,
income, assets and credit history as follows:
Employment
and Income:
| - | Meets
the guidelines and, as applicable, regulatory documentation requirements |
| - | Creditor
income calculations are reasonable and as prescribed by the applicable guidelines |
| - | Ensure
borrower(s) is/are currently employed |
Assets
| - | Confirm
asset source and documentation requirements |
| - | Re-calculate
gross, net and liquid asset balances |
| - | Incorporate
gift funds and sourcing documentation |
| - | Confirm
and calculate reserve calculations |
Credit
Report
| - | Determine
representative Credit Score and Methodology |
| - | Maximum
amount of open tradelines |
| - | Mortgage/Rental
payment history |
| - | Installment
and Revolving payment history |
| - | Bankruptcy
and Foreclosure seasoning |
| Inglet
Blair, LLC Deal Summary
JPMMT 2025-LTV2
pg.
2 |
Credit
Application (FNMA Form 1003)
| - | Employer
and employment status |
| - | Confirmation
of loan purpose and occupancy |
| - | Disposition
and status of Real Estate Owned (REO) |
| - | First
time home buyer status |
| - | Citizenship
and eligibility |
Title
Review - For each Loan the title commitment or, if present, final title policy was reviewed to confirm:
| - | Title
interest – Fee Simple or Leasehold |
| - | Tax
liens, encumbrances, encroachments and/or other title defects were satisfied or addressed |
Fraud
Report – IB reviewed each Loan file for the presence of a fraud report with all material findings addressed surrounding
borrower name variances, social security number discrepancies, subject-property occupancy or employment history.
Hazard
and Flood Insurance – Each Loan was reviewed to ensure that (i) each hazard policy limit met the applicable guideline requirement
(ii) the property address was correct (iii) the premium was accurately reflected in the DTI calculation and (iv) escrowed where
required.
Similarly,
where the flood certificate indicates the property improvements were located in a flood zone, IB confirmed the coverage met the
guideline requirements and, where applicable, the premium escrowed.
Closing/Legal
Documents – All Loans received a review of the closing documentation. This includes the note, mortgage (and applicable riders),
assignments, mortgage insurance certificates, underwriter approvals, and HUD-1 or Closing Disclosure, as applicable, are executed
by all applicable parties and generally convey the terms of the Loan.
The
information and findings provided herein were based on the information provided in the loan file images presented at the time
of review.
| 6. | Collateral
Review and Methodology |
To
establish reasonable support for the original appraised value, each qualifying appraisal was accompanied by one of the following:
(i) an existing desk review report provided by the originator (or issuer), (ii) a second full appraisal (typically required by
the guidelines) (iii) a FNMA Collateral Underwriter (“CU”) analysis with a score of 2.5 or less. In the event a loan
did not contain any of the supplemental documentation, IB ordered an AVM, desk review or field review to fulfill the requirement.
If any of the supplemental material(s) had an estimate of value that was lower than the original appraised value by 10% (or more),
a field review (or suitable alternative) was obtained.
Each
Loan was analyzed to confirm it was sufficiently collateralized by real property, and each appraisal was audited to address the
following FIRREA/USPAP rules and standards:
| a. | Was
the appraisal prepared for a financial services institution? |
| b. | Does
the appraisal state the definition of Market Value? |
| c. | Does
the appraisal indicate the appraiser’s license or certification, number and expiration
date? |
| d. | Does
the appraisal disclose any extraordinary assumptions, hypothetical conditions? Does the
appraisal include a statement of assumptions and limiting conditions? |
| i. | If
yes, do the items appear to be reasonable? |
| e. | Is
a minimum 3-year subject sale history included? |
| f. | Does
the report state the effective date of the appraisal? |
| g. | Does
the appraisal summarize the process used to collect, confirm, and report data? |
| h. | Does
the appraisal state the subject’s highest and best use? |
| i. | Does
the appraisal clearly identify the real estate being appraised? |
| Inglet
Blair, LLC Deal Summary
JPMMT 2025-LTV2
pg.
3 |
| j. | Does
the appraisal state the real property interest being appraised? |
| k. | Does
the report contain sufficient information? |
| l. | Was
the appraisal reported on a FNMA appraisal form? |
| i. | If
yes, was the form materially complete? |
| m. | Which
of the industry recognized methods of valuation were included that may have been utilized
to support the institution’s decision to engage in the transaction? |
| i. | Direct
Sales Comparison Approach, Cost Approach, or Income Approach? |
| ii. | If
any of these approaches have been omitted or excluded, is there sufficient explanation
provided as to why? |
| 7. | Regulatory
Compliance Review to Federal, State and Local Lending Laws |
All
Loans deemed to be consumer purpose loans were submitted to an automated regulatory compliance review. The system tested each
applicable Loan for adherence to certain federal, state and local consumer protection laws related to mortgage lending.
All
applicable tests and disclosure reviews were graded in accordance with the SFA RMBS 3.0 TRID Compliance Review Scope standard
as described below.
| - | Federal
Truth in Lending Act– Regulation Z |
| ○ | Consumer
Handbook on Adjustable Rate Mortgages (1026.19(b)(1)) |
| ● | Confirm
acknowledgement of receipt by the borrower or documentary evidence disclosure was delivered
to the borrower(s) |
| ○ | Your
Home Loan Toolkit (1026.19(g)(1)) |
| ● | Confirm
acknowledgement of receipt by the borrower or documentary evidence disclosure was delivered
to the borrower(s) |
| ● | Provided
within 3 business days of application |
| ○ | Federal
High-cost (1026.32) |
| ● | Identify
points and fees and/or APR threshold test failures |
| ● | Prepayment
Penalty restrictions |
| ○ | Higher-priced
Mortgage Loans (1026.35) |
| ● | APR
Threshold with the corresponding appraisal and escrow requirements |
| ○ | Right
of Rescission (1026.23) |
| ● | Review
accuracy, timing and content of disclosure(s) |
| ● | Confirm
all requisite consumers received notice and correct form |
| ○ | Qualified
Mortgage Rule (1026.43(e)) |
| ● | Perform
points and fees test to confirm 3% threshold |
| ● | Adherence
to Appendix Q and DTI below 43% or Temp QM |
| ● | Application
Dates of 1/10/2014 to 2/28/2021 |
| ● | Adherence
to Appendix Q and DTI below 43% and/or Temp QM and/or APR/APOR threshold testing |
| ● | Application
Dates of 3/1/2021 to 6/30/2021 |
| ● | Adherence
to Appendix Q and DTI below 43% and/or APR/APOR threshold testing |
| ● | Application
Dates of 7/1/2021 to 9/30/2022 |
| ● | APR/APOR
threshold testing |
| ● | Application
Dates on or after 10/1/2022* |
| ○ | Subject
to any guidance updates from regulators |
| ● | Loan
does not contain “risky feature” (IO, Negative Amortization, etc.) |
| ● | Contain
a valid and approved AUS, as applicable |
| ● | Ability-to-Repay
(“ATR”) (1026.43(c)(2) – IB reviewed each Loan for the applicable mortgagor’s ability to repay; however,
there is no representation or warranty, implied or otherwise, that a court (or other administrative/legislative authority) will
agree with the |
| Inglet
Blair, LLC Deal Summary
JPMMT 2025-LTV2
pg.
4 |
determination.
IB objectively confirmed the following eight (8)-factors had been considered and, where
applicable, documented:
| ● | (i)
The consumer‘s current or reasonably expected income or assets, other than the
value of the dwelling, including any real property attached to the dwelling, that secures
the loan; |
| ● | (ii)
If the creditor relies on income from the consumer‘s employment in determining
repayment ability, the consumer‘s current employment status; |
| ● | (iii)
The consumer‘s monthly payment on the covered transaction, calculated in accordance
with paragraph (c)(5) of this section; |
| ● | (iv)
The consumer‘s monthly payment on any simultaneous loan that the creditor knows
or has reason to know will be made, calculated in accordance with paragraph (c)(6) of
this section; |
| ● | (v)
The consumer‘s monthly payment for mortgage-related obligations; |
| ● | (vi)
The consumer‘s current debt obligations, alimony, and child support; |
| ● | (vii)
The consumer‘s monthly debt-to-income ratio or residual income in accordance with
paragraph (c)(7) of this section; and |
| ● | (viii)
The consumer‘s credit history. |
| ● | Initial
LE was provided within three (3) business days of application as provided by the broker
or creditor and loan does not consummate within seven (7) business days of receipt |
| ● | Provided
within three (3) business days of a valid Change of Circumstance |
| ● | Complete
in all material respects |
| ● | Confirm
the “In 5 Years” calculation is not over disclosed |
| ○ | Final
Closing Disclosure (“CD”) |
| ● | Confirm
creditor provided CD no later than three (3) business days of consummation and confirm
all relevant fields are complete |
| ● | Ensure
technical requirements are met – Rounding, Alphabetization, Number of Fees per
category and title fees properly labeled |
| ● | Recalculation
of the Finance Charge, Amount Financed, Total of Payments (“TOP”), and Total
Interest Payments (“TIP”) |
| ● | Projected
Payments - Re-calculation of Principal and Interest payment(s), verified escrow and insurance
payments, interest only periods and final balloon payments are present and displayed
in the correct number of columns |
| ● | Adjustable
Interest Rate and Adjustable Payment Tables are present, complete and accurate, if applicable |
| ● | No
fee charged for preparation of LE or CD |
| ● | Fee
descriptions conform with clear and conspicuous standard |
| ● | Loan
terms match that of the subject loan – balance, rate, term, prepayment penalty |
| ● | Loan
Disclosures section is complete – Late Payment matches the note and the escrow
section is consistent within the disclosure |
| ○ | Fee
and Tolerance Testing - Zero and ten percent (10.0%) tolerance testing, including the
presence, timing and a validation of a change of circumstance and corresponding fee changes |
| ○ | Evidence
Service Provider List and Your Home Loan Toolkit, if applicable, were provided or present
in the loan file |
| ○ | LE
and CD form(s) provided to the borrower are consistent across the loan process |
| ○ | NMLS
ID is present on the loan application, note, security instrument, LE and CD, as applicable |
| ○ | Items
not tested, include but are not limited to: |
| ● | Categorization
of fees in the appropriate section |
| Inglet
Blair, LLC Deal Summary
JPMMT 2025-LTV2
pg.
5 |
| ● | Accuracy
of information for fields not expressly stated above |
| ● | Presence
and accuracy of the Seller’s Transaction columns on the Seller’s columns |
| ○ | State
High-cost and Predatory lending regulations |
| ● | Special
Information Booklet |
| ● | Notice
of Servicing Transfer |
| ● | Affiliated
Business Arrangement Disclosure |
| ● | Homeownership
Counseling Disclosures |
| ○ | Equal
Credit Opportunity Act |
| ● | Presence,
acknowledgement and timing of the Right to Receive Copy of Appraisal Disclosure |
Structured
Finance Association (“SFA”) organized and led an initiative to establish a framework for Third-Party Reviewer’s
(“TPR”) to evaluate and grade loans subject to the Know Before You Owe Act, also commonly referred to as TILA-RESPA
Integrated Disclosure (“TRID”). While all grades and conclusions are established in good faith, the grading scheme
materiality and impact for certain exceptions may change from time to time, and thus, all reports contain Interpretation Risk.
Under no circumstance should the Client, any potential investors or other individual party solely rely on the interpretations
made by IB, SFA, or its outside counsel.
Please
be advised that IB is not a law firm, does not employ personnel who are licensed to practice law and the exceptions, observations
and conclusions provided by IB are not legal opinions. IB relies upon the advice of outside counsel, informal advice of regulators
and industry practice to determine materiality.
TRID
Tested |
No.
of Loans |
%
of Population |
Yes |
2 |
100.00% |
Total |
2 |
100% |
| 8. | Any
Other Type of Review |
There
was no other review performed.
| Inglet
Blair, LLC Deal Summary
JPMMT 2025-LTV2
pg.
6 |
5.
Summary of Finding and Conclusions of Review
The
following tables represent the final NRSRO overall and component grades. The Overall grade is comprised of the lowest of the component
grades.
NRSRO
Final Grade |
No.
of Loans |
%
of Population |
A |
2 |
100.00% |
Total |
2 |
100% |
|
|
|
NRSRO
Final Credit Grade |
No.
of Loans |
%
of Population |
A |
2 |
100.00% |
Total |
2 |
100% |
|
|
|
NRSRO
Final Compliance Grade |
No.
of Loans |
%
of Population |
A |
2 |
100.00% |
Total |
2 |
100% |
|
|
|
NRSRO
Final Property Grade |
No.
of Loans |
%
of Population |
A |
2 |
100.00% |
Total |
2 |
100% |
The
following tables represent certain key attributes of the Loans and their frequency amongst the loan population.
Amortization
Type |
No.
of Loans |
%
of Population |
Fixed
Rate |
2 |
100.00% |
Total |
2 |
100% |
|
|
|
Lien
Position |
No.
of Loans |
%
of Population |
1st |
2 |
100.00% |
Total |
2 |
100% |
|
|
|
Purpose |
No.
of Loans |
%
of Population |
Other-than-first-time
Home Purchase |
2 |
100.00% |
Total |
2 |
100% |
| Inglet
Blair, LLC Deal Summary
JPMMT 2025-LTV2
pg.
7 |
Property
Type |
No.
of Loans |
%
of Population |
PUD
(Only for use with Single-Family
Detached
Homes with PUD riders) |
2 |
100.00% |
Total |
2 |
100% |
|
|
|
LTV |
No.
of Loans |
%
of Population |
00.01-
10.00 |
0 |
0.00% |
10.01-
20.00 |
0 |
0.00% |
20.01-
30.00 |
0 |
0.00% |
30.01-
40.00 |
0 |
0.00% |
40.01-
50.00 |
0 |
0.00% |
50.01-
60.00 |
0 |
0.00% |
60.01-
70.00 |
0 |
0.00% |
70.01-
80.00 |
2 |
100.00% |
80.01-
90.00 |
0 |
0.00% |
90.01-
100.00 |
0 |
0.00% |
Total |
2 |
100% |
|
|
|
CLTV |
No.
of Loans |
%
of Population |
00.01-
10.00 |
0 |
0.00% |
10.01-
20.00 |
0 |
0.00% |
20.01-
30.00 |
0 |
0.00% |
30.01-
40.00 |
0 |
0.00% |
40.01-
50.00 |
0 |
0.00% |
50.01-
60.00 |
0 |
0.00% |
60.01-
70.00 |
0 |
0.00% |
70.01-
80.00 |
2 |
100.00% |
80.01-
90.00 |
0 |
0.00% |
90.01-
100.00 |
0 |
0.00% |
Total |
2 |
100% |
| Inglet
Blair, LLC Deal Summary
JPMMT 2025-LTV2
pg.
8 |