---

a)

Rescission (§1026.23, §1026.15):

i)

failure to provide the right of rescission notice;

ii)

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

iii)

errors in the right of rescission notice;

iv)

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

v)

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

vi)

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

vii)

with respect to applicable exception remediation measures, confirm that a letter of explanation, a refund if applicable, new corrected material disclosures and a new notice of right to cancel was provided.

b)

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

i)

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

ii)

proper execution by all required parties;

iii)

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

iv)

timing of initial and re-disclosed TIL(s).

c)

Home Equity Plans Disclosures (§§1026.6, 40) as applicable:

i)

failure to provide the applicable home equity initial and account opening disclosures; and

ii)

failure to provide the applicable home equity initial and account opening disclosures in a timely manner.

d)

Tolerances (§§1026.18, 22 23, and 38):

i)

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

ii)

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

iii)

inaccurate Total of Payments outside of applicable tolerance by comparing disclosed Total of Payments to re-calculated Total of Payments.

e)

High-cost Mortgage (§§1026.31, 32 and 34):

i)

points and fees threshold test;

ii)

APR threshold test;

iii)

prepayment penalty threshold test; and

iv)

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

f)

Higher-priced Mortgage Loan (§1026.35):

i)

APR threshold test; and

ii)

compliance with the escrow account and appraisal requirements as applicable.

g)

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

i)

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

ii)

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

iii)

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

(1)

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

h)

Homeownership counseling (§1026.36):

i)

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

i)

Mandatory Arbitration Clauses (§1026.36):

i)

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

j)

Prohibition on Financing Credit Insurance (§1026.36):

i)

determine if the creditor financed, directly or indirectly, any premiums or fees for credit insurance.

k)

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

i)

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

ii)

verify the data against the NMLSR database, as available.

a)

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

i)

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

ii)

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

iii)

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

iv)

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

v)

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

b)

Final HUD-1/A Settlement Statement (HUD) (§1024.8) as applicable for loans with application dates prior to October 3, 2015:

i)

confirm current applicable HUD form was provided;

ii)

determination that the mortgage loan file contains the final HUD;

iii)

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

iv)

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

c)

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

i)

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

ii)

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

iii)

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

d)

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

i)

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

ii)

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

iii)

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

iv)

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

v)

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

vi)

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

vii)

confirm the Affiliated Business Arrangement Disclosure is executed;

viii)

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

ix)

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

x)

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

a)

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

i)

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

ii)

confirm the initial LE date indicates it was delivered or placed in the mail within three (3) business days of application;

iii)

confirm that certain sections of each LE determined to carry assignee liability under the SFA Compliance Review Scope were accurately completed and that information was reflected in the appropriate locations, which, in certain instances, was based solely on the information disclosed on the LE;

iv)

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

v)

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

vi)

capture whether a settlement service provider list (“SSPL”) was provided (in instances when a consumer is given an opportunity to shop for services).  Failure to provide SSPL is not cited separately under SFA compliance review scope, however, absence of SSPL from loan file is treated as not provided and impacts fee tolerance categories as prescribed by regulation.

vii)

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

viii)

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

b)

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

i)

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

ii)

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

iii)

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

iv)

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

v)

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

vi)

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

vii)

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

c)

Your Home Loan Toolkit (§1026.19):

i)

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

ii)

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

a)

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

b)

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

c)

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

d)

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

1.)

for loans with an application date, defined in accordance with § 1026.2(a)(3)(ii), prior to 3/1/2021, at the time of consummation, if the debt-to-income ratio exceeds 43% (calculated in accordance with Appendix Q to Regulation Z). This portion of the Review includes a recalculation of all income and liabilities with attention to the appropriate documentation of each source,

2.)

for loans with an application date, defined in accordance with § 1026.2(a)(3)(ii), on or after 3/1/2021, but before 10/1/2022, submitted with a loan designation of Safe Harbor QM, Higher Priced QM, Safe Harbor QM (43-Q), or Higher Priced QM (43-Q), whether at the time of consummation, the debt-to-income ratio exceeds 43% (calculated in accordance with Appendix Q to Regulation Z). This portion of the Review includes a recalculation of all income and liabilities with attention to the appropriate documentation of each source, or

3.)

for loans with an application date, defined in accordance with § 1026.2(a)(3)(ii), taken on or after 3/1/2021, submitted with a loan designation of Safe Harbor QM (APOR), or Higher Priced QM (APOR), “Revised QM”, whether the APR exceeds the average prime offer rate by 2.25 or more percentage points, (additional thresholds applicable for lower loan balances, subordinate lien covered transactions and certain manufactured homes loan

amounts), and whether the loan does not meet the credit guidelines without a documented exception and compensating factors.

a)

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

i)

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

ii)

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

iii)

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

iv)

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

◾

Initial application (1003);

◾

Underwriting summary / loan approval (1008);

◾

Credit report;

◾

Income and employment documentation;

◾

4506T;

◾

Asset documentation;

◾

Sales contract;

◾

Hazard and/or flood insurance policies;

◾

Copy of note for any junior liens;

◾

Appraisal;

◾

Title/Preliminary Title;

◾

Final 1003;

◾

Changed circumstance documentation;

◾

Right of Rescission Disclosure;

◾

Mortgage/Deed of Trust;

◾

Note;

◾

Mortgage Insurance;

◾

Tangible Net Benefit Disclosure;

◾

Subordination Agreement;

◾

FACTA disclosures;

◾

Notice of Special Flood Hazards;

◾

Initial and final GFE’s;

◾

HUD from sale of previous residence;

◾

Final HUD-1;

◾

Initial TIL;

◾

Final TIL;

◾

Loan Estimates;

◾

Closing Disclosures; and

◾

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

l)

Rescission (§1026.23; §1026.15):

i)

failure to provide the right of rescission notice;

ii)

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

iii)

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

iv)

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

v)

missing or incorrect rescission expiration date on rescission notice;

vi)

“I wish to cancel” section of rescission notice is signed by borrower;

vii)

any material disclosure violation on a rescindable mortgage loan that gives rise to the right of rescission under TILA, which means, for closed end transactions, the required disclosures of the annual percentage rate, the finance charge, the amount financed, the total of payments, the payment schedule, the HOEPA disclosures, or those related to prepayment penalties on covered transactions, and for open-end transactions, the information that must be provided to satisfy the requirements in §1026.6 with regard to the method of determining the finance charge and the balance upon which a finance charge will be imposed, the annual percentage rate, the amount or method of determining the amount of any membership or participation fee that may be imposed as part of the plan, and the payment information described in §1026.40(d)(5)(i) and (ii) that is required under §1026.6(e)(2); and

viii)

with respect to applicable exception remediation measures, confirm that a letter of explanation, a refund if applicable, new corrected material disclosures and a new notice of right to cancel was provided.

m)

Tolerances (§§1026.18, 22 and 23):

i)

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

ii)

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

iii)

inaccurate Total of Payments outside of applicable tolerance by comparing disclosed Finance Charge to re-calculated Total of Payments

n)

Payment Tables (§1026.18, §1026.38):

i)

inaccurate disclosure of applicable payment tables on page 1 of the TIL or CD

o)

TILA Section 130(b) Corrections and Other Remediations

i)

with respect to applicable exception remediation measures, confirm the remediation was performed in accordance with regulatory and/or statutory requirements, and, where applicable, the SFA Compliance Review Scope methodology (in an attempt to establish a best practices approach to pre-securitization due diligence, as it applies to TILA RESPA Integrated Disclosure testing, the Structured Finance Association (“SFA”) has a working group that consists of industry participants including third party review providers and law firms who agreed to a standardized approach to remediation considerations).

p)

High-cost Mortgage (§§1026.31, 32,and 34):

i)

points and fees threshold test;

ii)

APR threshold test;

iii)

prepayment penalty threshold test; and

iv)

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

q)

Higher-priced Mortgage Loan (§1026.35):

i)

APR threshold test; and

ii)

compliance with the escrow account and appraisal requirements as applicable.

r)

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

iv)

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

v)

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

vi)

if requested by the client, review the presence of the mortgage loan option disclosure and to determine if the Steering Safe Harbor provisions were satisfied.

s)

Homeownership counseling (§1026.36(k)):

ii)

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

t)

Mandatory Arbitration Clauses (§1026.36(h)):

ii)

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

u)

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

ii)

determine if the creditor financed, directly or indirectly, any premiums or fees for credit insurance.

v)

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

iii)

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

iv)

verify the data against the NMLSR database, as available.

e)

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

f)

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

g)

Qualified Mortgages (QM) (12 C.F.R. 1026.43(e) (including qualified mortgages as separately defined by the Department of Housing and Urban Development (24 C.F.R. 201 and 203 et seq.); the Department of Veterans Affairs (38 C.F.R. Part 36 et seq.); and the U.S. Department of Agriculture (7 CFR Part 3555);

h)

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

i)

Prepayment penalty restrictions (12 C.F.R. 1026.43(g)).

(i)

the mortgage loan contains risky mortgage loan features and terms (e.g. an interest only feature, negative amortization, or loan term exceeding 30 years),

(ii)

the “points and fees” exceed the applicable QM threshold,

(iii)

the monthly payment was calculated appropriately,

(iv)

the creditor considered and verified income or assets at or before consummation,

(v)

the creditor appropriately considered debt obligations, alimony and child support, and

(vi)

based on the application date, defined in accordance with 1026.2(a)(3)(ii), and the loan designation provided on the subject loan:

1.

Temporary QM (Agency/GSE Salable) – Loans submitted with a loan designation of Temporary SHQM (GSE/Agency Eligible) or Temporary HPQM (GSE/Agency Eligible)

a.

If loan application date is prior to 7/1/2021 or loan was purchased/securitized on or before 8/31/21, the loan will be evaluated to confirm it is salable to the GSEs.

b.

If loan application date is on or after 7/1/2021 or loan was purchased/securitized after 8/31/21 - an exception indicating loan is not eligible to be GSE Temp QM will  be cited based on the GSE requirement for loan applications on or after 7/1/2021 to meet General QM (APOR) pricing based criteria to be salable,

2.

QM Based on Appendix Q – Loans submitted with a loan designation of Safe Harbor QM, Higher Priced QM, Safe Harbor QM (43-Q), or Higher Priced QM (43-Q)

a.

If the loan application date is prior to 3/1/2021 – determine whether at the time of consummation, the debt-to-income ratio exceeds 43% (calculated in accordance with Appendix Q to Regulation Z)

b.

If the loan application date is on or after 3/1/2021, but before 10/1/2022 – determine whether at the time of consummation, the debt-to-income ratio exceeds 43% (calculated in accordance with Appendix Q to Regulation Z)

3.

QM Based on APOR (Pricing-Based) – Loans with an application date on or after 3/1/2021, submitted with a loan designation of Safe Harbor QM (APOR), or Higher Priced

QM (APOR), the QM considerations will be based on whether the APR exceeds the average prime offer rate by 2.25 or more percentage points (additional thresholds applicable for lower loan balances, subordinate lien covered transactions and certain manufactured homes loan amounts), and whether the loan does not meet the creditor’s guidelines without a documented exception and compensating factors.

•	Option 1:  VSH via reference to guidelines explicitly enumerated in the regulation (June 2020 GSE Guides)

o

Lender identifies that loan utilizes one of the GSE June 2020 guidelines specified in the regulation to meet VSH

o

For loans identified by lender to have VSH status, SitusAMC will determine documentation variances that would cause one to question the VSH attestation from the lender.  If variances are identified, loan would not be identified by SitusAMC to meet the VSH documentation requirements (i.e., SitusAMC will report loan as not having met VSH).

o

AUS adherence will not be used to evaluate the VSH indicator.

•	Option 2:  VSH via reference to subsequent versions of GSE Guides affirmed to be “substantially similar” to guides explicitly enumerated in the regulation

o

Lender identifies (source and publication date) and provides a set of GSE guides (other than one of the June 2020 guidelines specified in the regulation) utilized to meet VSH

o

Lender provides affirmation that guides used meet VSH requirements as revised version complies with verification standards or is substantially similar to the guides enumerated in the regulation commentary under 1026.43(e)

o

The determination and affirmation that the guides used are substantially similar would be the responsibility of the lender and/or aggregator.  SitusAMC will not evaluate or make a determination as to whether the guidelines used by the lender are “substantially similar” to the explicitly enumerated underwriting guidelines.

o

For loans identified by lender to have VSH status, SitusAMC will determine documentation variances that would cause one to question the VSH attestation from the lender.  If variances are identified, loan would not be identified by SitusAMC to meet the VSH documentation requirements (i.e., SitusAMC will report loan as not having met VSH).

o

AUS adherence will not be used to evaluate the VSH indicator

•	Option 3:  VSH via proprietary guides

o

Lender identifies and provides a set of proprietary (non-GSE guides) underwriting guides utilized to meet VSH

o

Lender provides worksheet/AUS connecting the loan level review components to enumerated guides

o

Lender provides affirmation that guides used meet VSH requirements as guides comply with verification standards in the guides enumerated in the regulation commentary under 1026.43(e)

o

The determination and affirmation that the guides used are substantially similar would be the responsibility of the lender and/or aggregator.  SitusAMC will not evaluate or make a determination as to whether the guidelines used by the lender are in line with the standards in the enumerated underwriting guidelines.

o

For loans identified by lender to have VSH status, SitusAMC will determine documentation variances that would cause one to question the VSH attestation from the lender.  If variances are identified, loan would not be identified by SitusAMC to meet the VSH documentation requirements (i.e., SitusAMC will report loan as not having met VSH).

o

AUS adherence will not be used to evaluate the VSH indicator

•

The lender/seller’s VSH Indicator;

•

Whether SitusAMC evaluated the VSH indicator provided by the lender/seller;

•

Which of the above 3 options was employed to evaluate the VSH indicator;

•

Whether SitusAMC identified a variance to indicator based on due diligence review; and

•

Whether loan met VSH based on option selected

i)

the consumer's current or reasonably expected income or assets;

ii)

if the creditor relied on income from the consumer's employment in determining repayment ability (the consumer's current employment status);

iii)

the consumer's monthly payment;

iv)

the consumer's monthly payment on any simultaneous loan that the creditor knows or has reason to know will be made;

v)

the consumer's monthly payment for mortgage-related obligations;

vi)

the consumer's current debt obligations, alimony, and child support;

vii)

the consumer's monthly debt-to-income ratio or residual income; and

viii)

the consumer's credit history.

◾

Initial application (1003);

◾

Underwriting summary/loan approval (1008);

◾

Credit report;

◾

Income and employment documentation;

◾

Asset documentation;

◾

Sales contract;

◾

Hazard and/or flood insurance policies;

◾

Copy of note for any junior liens;

◾

Appraisal;

◾

Title/Preliminary Title;

◾

Final 1003;

◾

Changed circumstance documentation;

◾

Right of Rescission Disclosure;

◾

Mortgage/Deed of Trust;

◾

Note;

◾

Mortgage Insurance;

◾

Tangible Net Benefit Disclosure;

◾

Subordination Agreement;

◾

Notice of Special Flood Hazards;

◾

Initial and final GFE’s;

◾

HUD/Closing Disclosure from sale of previous residence;

◾

Final HUD-1;

◾

Initial TIL;

◾

Final TIL;

◾

Loan Estimates;

◾

Closing Disclosures; and

◾

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

administering the Applicable Law that was part of the review have broad discretionary powers which may permit such authorities, among other things, to withdraw exemptions accorded by statute or regulation, to impose additional requirements or to reach a conclusion that is not consistent with the results set forth in the Report. All decisions as to whether to issue, purchase, hold, sell or otherwise transact in securities backed by the mortgage loans reviewed in this Report, any investment strategy and any legal conclusions, including the potential liability related to the purchase or other transaction involving any such securities, shall be made solely by the parties to or investors in the transaction. The results set forth in this Report do not constitute tax or investment advice.  The scoring models in this Report are designed to identify potential risk in the securities backed by the mortgage loans reviewed, and each party or investor assumes sole responsibility for determining the suitability of the information for its particular use. SitusAMC does not make any representation or warranty (express or implied) as to the value of any mortgage loan or mortgage loan’s collateral that has been reviewed by SitusAMC.

Summary of findings and conclusions of review

OVERALL RESULTS SUMMARY

After giving consideration to the grading criteria of the relevant NRSROs, under the applicable Fitch rating criteria, 90.57% of the pool received an overall “A” grade, 9.12% received an overall “B” grade and 0.31% received an overall “C” grade.  Under the applicable DBRS rating criteria, 90.66% of the pool received an overall “A” grade, 9.03% received an overall “B” grade and 0.31% received an overall “C” grade. Under the applicable Kroll rating criteria, 90.57% of the pool received an overall “A” grade, 9.12% received an overall “B” grade and 0.31% received an overall “C” grade.

¹Secondary property valuation was not part of the property review scope for these second lien mortgage loans. As a result, the reported Kroll and DBRS property review grades have been defaulted to “NA”.  Defaulting the Kroll and DBRS property review grades to “NA” does not affect the Kroll or DBRS overall loan grades.

EXCEPTION CATEGORY SUMMARY

The table below summarizes the individual exceptions which carried an associated “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”).

DATA INTEGRITY REVIEW RESULTS SUMMARY

Of the 2,249 mortgage loans reviewed, 1,933 unique mortgage loans (85.95% by number) had a total of 3,380 different tape discrepancies across 18 data fields (some mortgage loans may have had more than one data delta). A blank or zero value on the data tape when an actual value was captured by AMC was treated as a data variance.

ADDITIONAL SUMMARY

Some % of Loans may not add to 100% due to rounding