Exhibit 99.1
Consolidated Analytics, Inc.
Form ABS Due Diligence 15-E
PRPM 2025-RCF4
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM ABS DUE DILIGENCE-15E
CERTIFICATION OF PROVIDER OF THIRD-PARTY DUE DILIGENCE SERVICES FOR ASSET-BACKED SECURITIES
Item 1: Identity of the person providing third-party due diligence services
Legal Name: Consolidated Analytics, Inc.
Business Name (If Different):
Principal Business Address: 1 MacArthur Place – Suite 100, Santa Ana, CA 92707
Item 2: Identity of the person who paid the person to provide due diligence services
Legal Name: BM-SC, LLC
Business Name (If Different):
Principal Business Address: 7114 E. Stetson Dr., Suite 250, Scottsdale, Arizona 85251
In connection therewith, Clients shall pay to Consolidated Analytics the greater of a fee totaling $2500.00 or $25 per loan, which fee the Clients acknowledge and agree shall be paid concurrently with the funding of the transaction in connection with which this letter is being delivered.
Item 3: Credit rating criteria
The third-party due diligence services are intended to generally comply with currently known rating agency criteria for newly originated mortgage loans.
Item 4: Description of the due diligence performed
See Attachment A.
Item 5: Summary of findings and conclusions of review
See Attachment B.
CERTIFICATION
The undersigned has executed this Form ABS Due Diligence 15E on behalf of, and on the authority of, the person identified in Item 1 of the Form. The undersigned, on behalf of the person, represents that the person identified in Item 1 of the Form conducted a thorough review in performing the due diligence described in Item 4 attached to this Form and that the information and statements contained in this Form, including Items 4 and 5 attached to this Form, which are part of this Form, are accurate in all significant respects.
Consolidated Analytics, Inc.
By: | ||
Date: |
Attachment A
Item 4: Description of the due diligence performed
PRPM 2025-RCF4
(1) Type of assets that were reviewed.
Consolidated Analytics, Inc. (“Consolidated Analytics”) performed certain due diligence services (the “Review”) described below on behalf of BM-SC, LLC (the “Client”). The Review was conducted from January 2022 through September 2023 on mortgage loans originated between January 2022 and September 2023.
(2) Sample size of the assets reviewed.
The Review consisted of a sample population of 8 loans with an aggregate principal balance of $10,204,029.00.
(3) Determination of the sample size and computation.
The sample population was determined and provided by Consolidated Analytics’ clients (as identified by Item 2). The Review was conducted consistent with the criteria for the nationally recognized statistical rating organizations DBRS, Inc. and Fitch Ratings, Inc., NRSRO(s), identified in Item 3 of the ABS Due Diligence-15E. Consolidated Analytics does not know the size of the overall securitization population and other third-party review (“TPR”) firms may have reviewed loans within the overall securitization population.
(4) Quality or integrity of information or data about the assets: review and methodology.
Consolidated Analytics compared data fields on the bid tape provided by the Clients to the data found in the actual mortgage loan file as captured by Consolidated Analytics. This comparison, when data was available, included the following data fields:
Application Date |
PITIA | Qualifying Total Debt Income Ratio |
Monthly Taxes | Monthly Insurance | Closing/Settlement Date |
Credit QM/ATR Designation | Qualifying Total Reserves Number of Months | Interest Rate |
Property Value | Total Qualified Assets Available | Borrower Appraisal Receipt Date |
Qualifying Total Monthly Liabilities | Borrower 1 Last Name | P&I |
Borrower 1 First Name | Original Interest Only Term | Number of Borrowers |
Qualifying All Borrower Residual Income | Total Liquid Assets Available For Close | First Payment Date |
Verified Doc Type | Property Address | All Borrower Total Income |
Original Appraised Property Value | Borrower 1 Qualifying Income | Sales Price |
Borrower 1 FTHB | Property City | Property Type |
Qualifying CLTV | Qualifying FICO | Cash Disbursement Date |
Cash out Include Debt Paid at Close | As-is Value | Borrower 1 Total Years Employment/S-E Verified |
Calculated DSCR | Property County | Min No |
Non QM Months Reserves | Borrower 1 SSN | Prepayment Penalty Total Term |
(5) Origination of the assets and conformity to stated underwriting or credit extension guidelines, standards, criteria or other requirements: review and methodology.
Consolidated Analytics performed a “Credit Review” to verify compliance with guidelines in effect at the time of loan origination, or other guidelines provided by Clients prior to review, and ensure the characteristics used by the underwriter are supported by the file documentation; and determine whether any loans outside of those guidelines contain legitimate and approved exceptions with compensating factors.
The Credit Review attempted to confirm the following:
A. QM or ATR Validation / Review of 8 Key Underwriting Factors
1. | Income / Assets |
a. | Validate borrower(s) monthly gross income |
b. | Validate funds required to close, required reserves |
c. | Review file documentation for required level of income and asset verifications |
2. | Employment Status |
a. | Review file documentation for required level of employment |
3. | Monthly Mortgage Payment |
a. | Confirm program, qualifying rate, terms |
4. | Simultaneous Loans |
a. | Validate all concurrent loans are included in the DTI to properly assess the ability to repay |
5. | Mortgage Related Obligations: PITI, HOA, PMI, etc. |
a. | Validate subject loan monthly payment (PITI) and associated obligations |
6. | Debts / Obligations |
a. | Validate monthly recurring liabilities |
7. | DTI and/or Residual Income |
a. | Validate debt-to-income ratio (DTI) based upon income and debt documentation provided in the file |
b. | Documentation meets Appendix Q requirements for QM Loans |
8. | Credit History |
a. | Review credit report for credit history and required credit depth including any / all inquiries |
b. | Determine representative credit score from credit report |
9. | Validate loan-to-value (LTV) and combined loan-to-value |
10. | Review borrower's occupancy |
11. | Validation through third party resource of the subject properties most recent twelve (12) month sales history |
12. | Confirm sufficient evidence in loan file, by reviewing the underwriter’s decision to approve the loan based upon the borrows income, debt, and credit history, to support borrower's willingness and ability to repay the debt |
13. | Confirm that Final 1003 is sufficiently completed |
14. | Provide Audit 1008 with accurate data based on file documentation |
15. | Confirm Loan Approval conditions were met |
16. | Review condominium questionnaire to verify all information is complete, prepared by an authorized representative, and address any red flags that may deem condominium project ineligible |
17. | General QM for any loans originated under the GQM Rule |
1. | Pricing Thresholds: |
a. | Pricing for First Lien Loans: |
i. | 2.25% for a first-lien covered transaction with a loan amount greater than or equal to the applicable dollar amount threshold; and |
ii. | 3.5% for a first-lien covered transaction with a loan amount greater than or equal to the applicable dollar amount threshold; and |
iii. | 6.5% for a first-lien covered transaction with a loan amount less than the applicable dollar amount threshold. |
b. | Pricing for Subordinate Lien Loans: |
i. | 3.5% for a subordinate-lien covered transaction with a loan amount greater than or equal to the applicable dollar amount threshold; and |
ii. | 6.5% for a subordinate-lien covered transaction with a loan amount less than the applicable dollar amount threshold |
c. | Pricing for Manufactured Homes: |
i. | 2.25% for a first-lien covered transaction secured by a manufactured home with a loan amount equal to or greater than the applicable dollar amount threshold; and |
ii. | 6.5% for a covered transaction secured by a manufactured home with a loan amount less than the applicable dollar amount threshold. |
2. | Consider Income and Assets: |
i. | Consumer’s current or reasonably expected income or assets (other than the value of the dwelling that secures the loan; |
ii. | The consumer’s debt obligations, alimony, child support; and |
iii. | The monthly DTI or residual income. |
3. | Verification of Income and Assets: |
a. | Verification in compliance with one of the “safe harbor” guidelines will meet the QM verification requirement. A creditor is allowed to “mix and match” provisions of the different guidelines rather than only apply one guideline per loan. |
The specific guidelines that the CFPB is designating for the safe harbor are: The GQM Rule provides that if the creditor verifies the consumer’s income or assets, debt obligations, alimony, child support, and monthly DTI or residual income by meeting the standards of certain specified third-party underwriting manuals, then a creditor is presumed to have complied with the verification requirement. These specified manuals are:
i. | Chapters B3-3 through B3-6 of the Fannie Mae Single Family Selling Guide, published June 3, 2020; |
ii. | Sections 5102 through 5500 of the Freddie Mac Single-Family Seller/Servicer Guide, published June 10, 2020; |
iii. | Sections II.A.1 and II.A.4-5 of the Federal Housing Administration’s Single Family Housing Policy Handbook, issued October 24, 2019; |
iv. | Chapter 4 of the U.S. Department of Veterans Affairs’ Lenders Handbook, revised February 22, 2019; |
v. | Chapter 4 of the U.S. Department of Agriculture’s Field Office Handbook for the Direct Single Family Housing Program, revised March 15, 2019; and |
vi. | Chapters 9 through 11 of the U.S. Department of Agriculture’s Handbook for the Single Family Guaranteed Loan Program, revised March 19, 2020. |
(6) Value of collateral securing the assets: review and methodology.
Consolidated Analytics performed a “Valuation Review,” which included the following:
1. | Review original appraisal, determination that property is in "average" condition or better, or property requires cosmetic improvements (as defined by the appraiser) that do not affect habitability |
2. | Review appraisal, determination that property is completely constructed and appraisal is on an “as is basis,” or property is identified as not completely constructed by originating appraiser. |
3. | Review and determine if the appraisal report was performed on appropriate GSE forms and if the appraiser indicated in the body of the subject appraisal that the appraisal conforms to USPAP standards. |
4. | Review and determine the relevance of the comparable properties and ensure that a rational and reliable value was provided and supported as of the effective date of the Origination Appraisal. |
5. | Review adjustments (line item, net and gross adjustments) to ensure they are reasonable. |
6. | Ensure that the appraisal conforms to the guidelines provided from the Client |
7. | Review appraisal to ensure all required documents were included. |
8. | Review location map provided within the appraisal for external obsolescence. |
9. | Ensure highest and best use and zoning complies with guidelines. |
10. | Confirm there are no marketability issues that affect the subject property. |
11. | Ensure subject property does not suffer any functional obsolescence. |
12. | Where applicable, determine if the file did not contain the appraisal or other valuation method and a review could not be performed. |
13. | Additional valuation products were not required when the CU score provided was 2.5 or below or the appraisal LCA risk score was eligible for Collateral Rep and Warranty relief. In the event the CU score was greater than 2.5 or the LCA score was not eligible for R&W relief, an additional valuation product was obtained to confirm value was supported within 10% tolerance. In some instances, based on guidance from the seller, CDA’s were ordered on loans that had an acceptable CU score or R&W eligibility. |
Consolidated Analytics applied a cascade methodology to determine if the original appraised value was reasonably supported when compared to an independent third party valuation product.
For loans reviewed in a post-close valuation review scenario (8 loans in total):
Two (2) loans had a Secondary Appraisal, zero (0) loans had AVMs, and seven (7) loans had a Desktop Review.
If a loan with an AVM or Desktop Review fell outside of a -10% tolerance, was inconclusive, or a PIW was present, then a Field Review, a Broker Price Opinion (BPO) along with a Reconciliation of the values or a 2nd Appraisal was completed. There were zero (0) occurrences of this.
Zero (0) loans had a Field Review or BPO, two (2) loans had a Second Desk Review, and zero (0) loans had a Full Appraisal Review.
Product totals may not sum due to multiple products for each loan.
(7) Compliance of the originator of the assets with federal, state and local laws and regulations: review and methodology.
Consolidated Analytics performed a “Compliance Review” to determine, as applicable, to the extent possible and subject to the caveats below, whether the loan complies with applicable regulatory requirements as noted below, each as amended, restated and/or replaced from time to time. The Compliance Review included the following:
a. | Test Loan Estimate(s) for accuracy and completeness as well as timing requirements as required by TRID Regulations |
b. | Test Closing Disclosure(s) for accuracy and completeness as well as timing requirements as required by TRID Regulations |
c. | Tolerance Testing |
i. | Compare Loan Estimate and Closing Disclosures |
ii. | Identify Tolerance Violations and applicable cost to cure |
d. | Comprehensive review of Closing Disclosure to determine transaction accuracy |
e. | Recalculation of APR and Finance Charge |
f. | Testing of: |
i. | Federal High Cost Mortgage provisions |
ii. | Federal Higher Priced Mortgage Loans provisions |
iii. | Local and/or State Anti-predatory and High Cost provisions |
iv. | HOEPA Points and Fees |
g. | Determine whether specified federal disclosures were provided timely based upon comparison of the application date to the dates on such disclosures |
i. | Service Provider List |
ii. | Home Ownership Counselling Disclosure |
iii. | ARM Disclosure |
h. | Compliance with QM as it relates to: |
i. | APR Test |
ii. | Points & Fees Test |
iii. | Prepayment Penalty Test |
iv. | Product Eligibility Testing |
i. | Notice of Right to Cancel (Rescission) Review |
i. | Confirm transaction date, expiration date, and disbursement date |
ii. | Confirm document is properly executed by all required parties to the transaction |
iii. | Confirm the correct Right of Rescission document was executed for the transaction type |
j. | Confirm through NMLS the loan originator and originating firm's license status was active and properly disclosed on appropriate loan documents |
k. | Check the Loan participants against the exclusionary list provided by Clients or by the purchaser of the Loan(s) |
l. | Review closing documents to ensure that the Mortgage Loan information is complete, accurate, and consistent with other documents; Confirm collateral documents have been recorded or sent for recording |
The Compliance Review did not include any federal, state or local laws, constitutional provisions, regulations or ordinances that are not expressly enumerated above. Furthermore, the findings reached by Consolidated Analytics are dependent upon its receiving complete and accurate data regarding the loans from loan originators and other third parties upon which Consolidated Analytics is relying in reaching such findings.
(8) Other: review and methodology.
Not applicable.
Attachment B
Item 5: Summary of findings and conclusions of review
Summary of Results
OVERALL RESULTS SUMMARY
Final Loan Grades
Overall Loan Results: | |||
Event Grade | Loan Count | Original Principal Balance | Percent of Sample |
Event Grade A | 8 | $10,204,029.00 | 100.00% |
Event Grade B | 0 | $0.00 | 0.00% |
Event Grade C | 0 | $0.00 | 0.00% |
Event Grade D | 0 | $0.00 | 0.00% |
Total Sample | 8 | $10,204,029.00 | 100.00% |
Credit Results: | ||
Event Grade | Loan Count | Percent of Sample |
Event Grade A | 8 | 100.00% |
Event Grade B | 0 | 0.00% |
Event Grade C | 0 | 0.00% |
Event Grade D | 0 | 0.00% |
Total Sample | 8 | 100.00% |
Compliance Results: | ||
Event Grade | Loan Count | Percent of Sample |
Event Grade A | 8 | 100.00% |
Event Grade B | 0 | 0.00% |
Event Grade C | 0 | 0.00% |
Event Grade D | 0 | 0.00% |
Total Sample | 8 | 100.00% |
Valuation Results: | ||
Event Grade | Loan Count | Percent of Sample |
Event Grade A | 8 | 100.00% |
Event Grade B | 0 | 0.00% |
Event Grade C | 0 | 0.00% |
Event Grade D | 0 | 0.00% |
Total Sample | 8 | 100.00% |
Exception Category Summary
The table below summarizes the individual exceptions which carried an associated “A”, “B”, “C”, or “D” level exception grade. One loan may have carried more than one exception. In such cases, the exception with the lowest grade would drive the loan grade for that particular area of the review. The overall loan grade is the lowest grade for any one particular review scope (ex. a loan with a Compliance Grade of “B”, a Credit Grade of “A”, and a Property Grade of “A” would receive an overall Loan Grade of “B”).
Exception Type | Exception Level Grade |
Exception Category | Total |
Credit | A | No Credit Findings | 8 |
Total Credit Grade (A) Exceptions: | 8 | ||
Compliance | A | No Compliance Findings | 7 |
TILA Right of Rescission Test | 1 | ||
Reimbursement Amount Test | 1 | ||
Total Compliance Grade (A) Exceptions: | 9 | ||
Property | A | No Property Findings | 1 |
Total Property Grade (A) Exceptions: | 1 |
TAPE INTEGRITY REVIEW RESULTS SUMMARY
Of the 8 mortgage loans reviewed, eight (8) unique mortgage loans (100.00% by loan count) had a total of eighteen (18) tape discrepancies across six (6) data fields. A blank or zero value on the data tape when an actual value was captured by Consolidated Analytics was not treated as a data variance.
Fields Reviewed | Discrepancy Count | Percentage |
Months Reserves | 7 | 38.89% |
Closing Date | 4 | 22.22% |
Liquid Cash Reserves | 4 | 22.22% |
All Borrower Total Income | 1 | 5.56% |
Origination Date | 1 | 5.56% |
Most Recent FICO Date | 1 | 5.56% |
Grand Total | 18 | 100.00% |
Event Grade Definitions
Final Loan Grade | |
A | Loan meets Credit, Compliance, and Valuation Guidelines |
B | The loan substantially meets published Client/Seller guidelines and/or eligibility in the validation of income, assets, or credit, is in material compliance with all applicable laws and regulations, and the value and valuation methodology is supported and substantially meets published guidelines. |
C | The loan does not meet the published guidelines and/or violates one material law or regulation, and/or the value and valuation methodology is not supported or did not meet published guidelines. |
D | Loan is missing documentation to perform a sufficient review. |
Credit Event Grades | |
A | The loan meets the published guidelines without any exceptions. The employment, income, assets and occupancy are supported and justifiable. The borrower’s willingness and ability to repay the loan is documented and reasonable. |
B | The loan substantially meets the published guidelines but reasonable compensating factors were considered and documented for exceeding published guidelines. The employment, income, assets and occupancy are supported and justifiable. The borrower’s willingness and ability to repay the loan is documented and reasonable. |
C | The loan does not substantially meet the published guidelines. There are not sufficient compensating factors that justify exceeding the published guidelines. The employment, income, assets or occupancy are not supported and justifiable. The borrower’s willingness and ability to repay the loan were not documented or are unreasonable. |
D | There was not sufficient documentation to perform a review or the credit file was not furnished. |
Compliance Event Grades | |
A | The loan is in compliance with all applicable laws and regulations. The legal documents accurately reflect the agreed upon loan terms and are executed by all applicable parties. |
B | The loan is in material compliance with all applicable laws and regulations. The legal documents accurately reflect the agreed upon loan terms and are executed by all applicable parties. Client review required. |
C | The loan violates one material law or regulation. The material disclosures are absent or the legal documents do not accurately reflect the agreed upon loan terms or all required applicants did not execute the documents. |
D | There was not sufficient documentation to perform a review or the required legal documents were not furnished. |
Valuation Event Grades | |
A | The value is supported within 10% of the original appraisal by the AVM or there are other supporting documents in the originators loan file package (CDA, Field Review or Second Appraisal). The appraisal was performed on an "as-is" basis and the property is complete and habitable at origination. The appraiser was appropriately licensed and used GSE approved forms. |
B | The value is not supported within 10% of the original appraisal by the AVM and there are no other valuation support documents in the loan file provided by the Seller. The valuation methodology substantially meets the published guidelines but reasonable compensating factors were considered and documented for exceeding guidelines. The appraisal was performed on an "as-is" basis and the property is complete and habitable. The appraiser was appropriately licensed and used GSE approved forms. |
C | The value is not supported within 10% of the original appraisal. The valuation methodology did not meet the published guidelines and there were not sufficient compensating factors for exceeding published guidelines. The property is in below “average” condition or the property is not complete or requires significant repairs. The appraisal was not performed on an “as is” basis. The appraiser was not appropriately licensed or did not use GSE approved forms. |
D | The file was missing the appraisal or there was not sufficient valuation documentation to perform a review. |