Exhibit 99.2

 

EXECUTIVE SUMMARY

third party due diligence review

Overview

Consolidated Analytics, Inc (“Consolidated Analytics”), performed certain due diligence services (the “Review”) described below on newly originated residential mortgage loans acquired by Sutton Funding LLC through a bulk purchase. The review included a total of 427 newly originated residential mortgage loans, in connection with the securitization identified as BARC 2025-NQM5 (the “Securitization”). The Review was conducted from April 2025 through August 2025 on mortgage loans originated between April 2025 and August 2025.

Scope of Review

Credit Review

Consolidated Analytics performed a “Credit Review” to verify compliance with guidelines in effect at the time of loan origination, or other guidelines provided by Client 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
i.Income / Assets
·Validate borrower(s) monthly gross income
·Validate funds required to close, required reserves
·Review file documentation for required level of income and asset verifications
ii.Employment Status
·Review file documentation for required level of employment
iii.Monthly Mortgage Payment
·Confirm program, qualifying rate, terms
iv.Simultaneous Loans
·Validate all concurrent loans are included in the DTI to properly assess the ability to repay
v.Mortgage Related Obligations: PITI, HOA, PMI, etc.
·Validate subject loan monthly payment (PITI) and associated obligations
vi.Debts / Obligations
·Validate monthly recurring liabilities
vii.DTI and/or Residual Income
·Validate debt-to-income ratio (DTI) based upon income and debt documentation provided in the file
·Documentation meets Appendix Q requirements for QM Loans
viii.Credit History
·Review credit report for credit history and required credit depth including any / all inquiries
·Determine representative credit score from credit report
b.Validate loan-to-value (LTV) and combined loan-to-value
c.Review borrower's occupancy
d.Validation through third party resource of the subject properties most recent twelve (12) month sales history

 

 

 

 

e.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
f.Confirm that Final 1003 is sufficiently completed
g.Provide Audit 1008 with accurate data based on file documentation
h.Confirm Loan Approval conditions were met
i.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
j.General QM for any loans originated under the GQM Rule

 

i.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 applicable dollar amount threshold.

 

ii.Consider Income and Assets:
oConsumer’s current or reasonably expected income or assets (other than the value of the dwelling that secures the loan;
oThe consumer’s debt obligations, alimony, child support; and
oThe monthly DTI or residual income.

 

iii.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.

Compliance Review

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 Client 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.

Valuation Review

Consolidated Analytics performed a “Valuation Review,” which included the following:

a.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. Should an area of concern be identified with the condition of the property, Consolidated Analytics will alert Client.
b.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.
c.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.
d.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.
e.Review adjustments (line item, net and gross adjustments) to ensure they are reasonable.
f.Ensure that the appraisal conforms to the guidelines provided from the Client.
g.Review appraisal to ensure all required documents were included.
h.Review location map provided within the appraisal for external obsolescence.
i.Ensure highest and best use and zoning complies with guidelines.
j.Confirm there are no marketability issues that affect the subject property.
k.Ensure subject property does not suffer any functional obsolescence.
l.Where applicable, determine if the file did not contain the appraisal or other valuation method and a review could not be performed.
m.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 (427 loans in total):

Twenty-one (21) loans had a Secondary Appraisal, zero (0) loans had AVMs, and four hundred twenty-five (425) loans had a Desktop Review. Consolidated Analytics has independent access to the Desktop Reviews ordered by the Aggregator.

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.

Four (4) loans had a Field Review or BPO, and zero (0) loans had a Full Appraisal Review, all of which supported value.

Product totals may not sum due to multiple products for each loan

TAPE INTEGRITY REVIEW RESULTS SUMMARY

Of the one hundred thirty-six (427) mortgage loans reviewed, eighty-seven (87) unique mortgage loans (20.37% by loan count) had a total of ninety-four (94) different tape discrepancies across seven (7) 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
Borrower 1 FTHB 39 41.49%
Borrower 1 Citizen 37 39.36%
Qualifying FICO 9 9.57%
Property Type 5 5.32%
Application Date 2 2.13%
Prepayment Penalty Total Term 1 1.06%
Prepayment Penalty Flag 1 1.06%
Grand Total 94 100.00%

  

 

 

Summary of Results

OVERALL RESULTS SUMMARY

Final Loan Grades

Overall Loan Results: (S&P)  
Event Grade Loan Count Original Principal Balance Percent of Sample
Event  Grade A 415 $256,125,896.00 97.19%
Event  Grade B 12 $9,484,750.00 2.81%
Event  Grade C 0 $0.00 0%
Event  Grade D 0 $0.00 0%
Total Sample 427 $265,610,646.00 100.00%

 

Credit Results: (S&P)
Event Grade Loan Count Percent of Sample
Event  Grade A 424 99.30%
Event  Grade B 3 0.70%
Event  Grade C 0 0%
Event  Grade D 0 0%
Total Sample 427 100.00%

  

Compliance Results:
Event Grade Loan Count Percent of Sample
Event  Grade A 421 98.59%
Event  Grade B 6 1.41%
Event  Grade C 0 0%
Event  Grade D 0 0%
Total Sample 427 100.00%

 

 

 

 

Valuation Results:
Event Grade Loan Count Percent of Sample
Event  Grade A 424 99.30%
Event  Grade B 3 0.70%
Event  Grade C 0 0%
Event  Grade D 0 0%
Total Sample 427 100.00%

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 315
Missing verification of taxes, insurance, and/or HOA fees for non-subject property 16
The Deed of Trust is Incomplete 11
Missing Business Entity Formation Document 11
The Deed of Trust is Not Executed 9
Satisfactory Chain of Title not Provided 7
Rent Loss Insurance Missing 7
Hazard Insurance Policy is Partial 7
Income and Employment Do Not Meet Guidelines 6
Borrower 1 3rd Party VOE Prior to Close Missing 5
The Total Hazard Coverage is LESS than the Required Coverage Amount 5
The Final 1003 is Incomplete 4
The Note is Incomplete 4
Property Title Issue 3
Missing legal documents for senior or subordinate lien 3
Business Purpose Affidavit/Disclosure Missing 3
Audited DTI Exceeds Guideline DTI 3
Missing Taxpayer First Act Disclosure 3
Missing Property Tax Cert 2
Missing Personal Guaranty 2
Hazard Insurance Effective Date is after the Disbursement Date 2
Third Party Fraud Report not Provided 2
Purchase Contract is Incomplete 2
Missing Verification of Subject Property Taxes, Insurance, HOA or Other Payments 2
Audited Reserves are less than Guideline Required Reserves (Dollar Amount) 2
Housing History Does Not Meet Guideline Requirements 2
Cash Out Does Not Meet Guideline Requirements 1
Borrower 1 Photo Identification not provided 1
Fraud Report Shows Uncleared Alerts 1
Fraud: Potential Occupancy/Current Address Issues identified in the file 1
Purchase Contract is Missing 1
Asset 5 Does Not Meet Guideline Requirements 1
Flood Certificate Partially Provided 1

 

 

 

 

    Audited HCLTV Exceeds Guideline HCLTV 1
Borrower 1 Personal Bank Statements Missing 1
HO-6 Insurance Policy is Missing 1
Borrower 1 Tax Returns Not Signed 1
HO6 Master Insurance Policy is Missing 1
Borrower Non-US Citizen Identification Document Missing 1
Asset 2 Does Not Meet Guideline Requirements 1
Collections, liens or judgments not paid at closing 1
Audited Interested Party Contribution Exceeds Guideline Program Maximum 1
Title Document is Partially Present 1
Audited LTV Exceeds Guideline LTV 1
Borrower 1 CPA Letter Missing 1
Missing evidence of self employment 1
Missing VOM or VOR 1
Missing Lease Agreement 1
No evidence of required debt payoff 1
Asset Documents are Incomplete 1
Borrower 2 3rd Party VOE Prior to Close Missing 1
Missing Letter of Explanation (Credit) 1
Borrower information on 1003 is incomplete 1
Missing Letter of Explanation (Income) 1
Audited CLTV Exceeds Guideline CLTV 1
Missing operating income statement form 216 1
Citizenship Does Not Meet Guideline Requirements 1
Assets do not meet guideline requirements 1
Flood Certificate Missing 1
Borrower 1 Award Letter Missing 1
Title Coverage is Less than Subject Lien 1
Missing rent comparable schedule form 1007 1
Title Document Missing 1
Missing Tax Cert 1
Borrower 1 Business Bank Statements Missing 1
Total Credit Grade (A) Exceptions: 477
B Audited CLTV Exceeds Guideline CLTV 2
Audited LTV Exceeds Guideline LTV 2
Audited HCLTV Exceeds Guideline HCLTV 2
Missing Business Entity Formation Document 1
Asset 6 Does Not Meet Guideline Requirements 1
Total Credit Grade (B) Exceptions: 8

 

 

 

 

Compliance A No Compliance Findings 370
Higher-Priced Mortgage Loan Test 30
CA AB 260 Higher-Priced Mortgage Loan Test 4
MD COMAR Higher-Priced Mortgage Loan Test 3
Missing Initial Escrow Disclosure 3
eSigned Documents Consent is Missing 3
Revised Loan Estimate Delivery Date Test (prior to consummation) 3
Intent to Proceed is Missing 3
TRID: Missing Closing Disclosure 3
Initial Closing Disclosure Delivery Date Test 2
The Note is Not Executed 2
Homeownership Counseling Disclosure Is Missing 2
Missing Power of Attorney 2
Missing Required Affiliated Business Disclosure 2
Lender Credits That Cannot Decrease Test 2
The Final 1003 is Not Executed 1
Non-Borrower Title Holder Did Not Receive Right of Rescission Form 1
Final CD: Closing Date is missing or inaccurate 1
Final CD: Disbursement Date is missing or inaccurate 1
Loan Originator NMLS is Not Valid 1
Charges That Cannot Increase Test 1
Incorrect rescission model used - RTC form model H-8 used for Same Lender or Lender Affiliate Refinance 1
Mortgage Riders incomplete / inaccurate 1
Evidence of Appraisal Delivery to Borrower not Provided or Late (12 CFR  1002.14(a)(1)) 1
Loan Originator Company NMLS is Not Valid 1
Total Compliance Grade (A) Exceptions: 444
B Charges That Cannot Increase Test 5
Incorrect rescission model used - RTC form model H-8 used for Same Lender or Lender Affiliate Refinance 1
Total Compliance Grade (B) Exceptions: 6
Property A No Property Findings 413
Property/Appraisal General 8
Third Party Valuation Product Not Provided within 10% Tolerance 2
Property Issue(s) are Present 2
UCDP Summary Report is Missing 1
Appraisal is Missing 1

 

 

 

 

    Condo project is ineligible 1
Second Appraisal is Missing 1
Total Property Grade (A) Exceptions: 429
B HOA Questionnaire is Incomplete 1
Third Party Valuation Product Not Provided within 10% Tolerance 1
Property/Appraisal General 1
Total Property Grade (B) Exceptions: 3

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.