
| 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:
|
| o |
Consumer’s current or reasonably expected income or assets (other than the value of the dwelling that secures the loan);
|
| o |
The consumer’s debt obligations, alimony, child support; and
|
| o |
The 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.
|
| 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.
|
| 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 HighCost 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
|
| 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 guideline from the seller, CDA’s were ordered on loans that had an
acceptable CU score or R&W eligibility.
|
|
Fields Reviewed
|
Discrepancy Count
|
Percentage
|
|
Total Qualified Assets Post-Close
|
46
|
58.23%
|
|
Loan Purpose
|
9
|
11.39%
|
|
Total Closing Costs
|
6
|
7.59%
|
|
Borrower 1 FTHB
|
3
|
3.80%
|
|
Borrower 1 Self-Employment Flag
|
2
|
2.53%
|
|
Primary Appraised Property Value
|
2
|
2.53%
|
|
Borrower 3 Qualifying Income
|
1
|
1.27%
|
|
Interest Only Flag
|
1
|
1.27%
|
|
Cash out Include Debt Paid at Close
|
1
|
1.27%
|
|
Borrower 1 SSN
|
1
|
1.27%
|
|
Borrower 2 Citizen
|
1
|
1.27%
|
|
Subject Property Type
|
1
|
1.27%
|
|
Borrower 1 First Name
|
1
|
1.27%
|
|
Borrower 1 Last Name
|
1
|
1.27%
|
|
Borrower 1 Citizen
|
1
|
1.27%
|
|
Borrower 2 Origination FICO
|
1
|
1.27%
|
|
Borrower 2 SSN
|
1
|
1.27%
|
|
Grand Total
|
79
|
100.00%
|
|
Overall Loan Results:
|
|
||
|
Event Grade
|
Loan Count
|
Original Principal Balance
|
Percent of Sample
|
|
Event Grade A
|
185
|
$246,961,258.00
|
88.94%
|
|
Event Grade B
|
22
|
$28,232,190.00
|
10.58%
|
|
Event Grade C
|
1
|
$1,028,000.00
|
0.48%
|
|
Event Grade D
|
0
|
$0.00
|
0%
|
|
Total Sample
|
208
|
$276,221,448.00
|
100.00%
|
|
Credit Results:
|
|||
|
Event Grade
|
Loan Count
|
Percent of Sample
|
|
|
Event Grade A
|
207
|
99.52%
|
|
|
Event Grade B
|
1
|
0.48%
|
|
|
Event Grade C
|
0
|
0%
|
|
|
Event Grade D
|
0
|
0%
|
|
|
Total Sample
|
208
|
100.00%
|
|
|
|
|||
|
Compliance Results:
|
|||
|
Event Grade
|
Loan Count
|
Percent of Sample
|
|
|
Event Grade A
|
186
|
89.42%
|
|
|
Event Grade B
|
21
|
10.10%
|
|
|
Event Grade C
|
0
|
0%
|
|
|
Event Grade D
|
0
|
0%
|
|
|
Total Sample
|
208
|
100.00%
|
|
|
Valuation Results:
|
|||
|
Event Grade
|
Loan Count
|
Percent of Sample
|
|
|
Event Grade A
|
208
|
100.00%
|
|
|
Event Grade B
|
0
|
0%
|
|
|
Event Grade C
|
0
|
0%
|
|
|
Event Grade D
|
0
|
0%
|
|
|
Total Sample
|
208
|
100.00%
|
|
|
Exception Type
|
Exception Level Grade
|
Exception Category
|
Total
|
|
Credit
|
A
|
No Credit Findings
|
108
|
|
HMDA Data Tape Not Provided
|
77
|
||
|
Borrower 1 Credit Report is Incomplete
|
14
|
||
|
AUS Partially Provided
|
7
|
||
|
Borrower 1 3rd Party VOE Prior to Close Missing
|
7
|
||
|
The Total Hazard Coverage is LESS than the Required Coverage Amount
|
6
|
||
|
Title Coverage is Less than Subject Lien
|
5
|
||
|
Missing verification of taxes, insurance, and/or HOA fees for non-subject property
|
4
|
||
|
Audited DTI Exceeds AUS DTI
|
4
|
||
|
Income and Employment Do Not Meet Guidelines
|
3
|
||
|
Audited DTI Exceeds Guideline DTI
|
3
|
||
|
The Final 1003 is Missing
|
3
|
||
|
Audited Reserves are less than Guideline Required Reserves (Dollar Amount)
|
2
|
||
|
Borrower 1 W2/1099 Missing
|
2
|
||
|
Assets do not meet guideline requirements
|
2
|
||
|
Borrower 1 Executed 4506-T Missing
|
2
|
|
Borrower 2 Photo Identification not provided
|
2
|
||
|
Audited LTV Exceeds AUS LTV
|
2
|
||
|
Purchase Contract is Incomplete
|
1
|
||
|
Borrower 1 Paystubs Missing
|
1
|
||
|
Condo Rider is Missing
|
1
|
||
|
Hazard Insurance Policy is Partial
|
1
|
||
|
Other Property Insurance Policy Missing
|
1
|
||
|
Verification of Borrower Liabilities Missing or Incomplete
|
1
|
||
|
The Deed of Trust is Missing
|
1
|
||
|
Title Document Missing
|
1
|
||
|
Audited Reserves are less than Guideline Required Reserves (Number of Months)
|
1
|
||
|
Income 8 Months Income Verified is Missing
|
1
|
||
|
Borrower 2 W2/1099 Missing
|
1
|
||
|
Audited Reserves are less than AUS Required Reserves (Dollar Amount)
|
1
|
||
|
Purchase Contract does not Match Final CD
|
1
|
||
|
Borrower 2 Executed 4506-T Missing
|
1
|
||
|
Second Home Rider is Missing
|
1
|
||
|
Missing Letter of Explanation (Income)
|
1
|
||
|
The Final 1003 is Incomplete
|
1
|
||
|
Missing required ARM Rider
|
1
|
||
|
The Initial 1003 is Missing
|
1
|
||
|
Missing US Patriot Act Disclosure or ID
|
1
|
||
|
Hazard Insurance Effective Date is after the Disbursement Date
|
1
|
||
|
Missing Verification of Subject Property Taxes, Insurance, HOA or Other Payments
|
1
|
||
|
Missing income documentation
|
1
|
||
|
Asset Qualification Does Not Meet Guideline Requirements
|
1
|
||
|
Housing History Does Not Meet Guideline Requirements
|
1
|
||
|
Total Credit Grade (A) Exceptions:
|
278
|
||
|
B
|
Title Coverage is Less than Subject Lien
|
1
|
|
|
Total Credit Grade (B) Exceptions:
|
1
|
||
|
Compliance
|
A
|
No Compliance Findings
|
98
|
|
Charges That Cannot Increase Test
|
14
|
||
|
Charges That In Total Cannot Increase More Than 10% Test
|
11
|
||
|
ARM Disclosure Not Provided Within 3 Days of Application Date
|
11
|
||
|
Initial Loan Estimate Delivery Date Test (from application)
|
10
|
||
|
eSigned Documents Consent is Missing
|
9
|
||
|
Final CD: Loan Disclosures Assumption incomplete or inaccurate
|
7
|
|
CHARM Booklet is Missing
|
6
|
||
|
Revised Loan Estimate Delivery Date Test (prior to consummation)
|
6
|
||
|
ARM Disclosure is Missing
|
5
|
||
|
Missing Required Affiliated Business Disclosure
|
4
|
||
|
Lender Credits That Cannot Decrease Test
|
3
|
||
|
RESPA Homeownership Counseling Organizations Disclosure Date Test
|
3
|
||
|
Evidence of Appraisal Delivery to Borrower not Provided or Late (12 CFR 1002.14(a)(1))
|
2
|
||
|
TILA Right of Rescission Test
|
2
|
||
|
Revised Loan Estimate Delivery Date and Changed Circumstances Date Test
|
1
|
||
|
Right of Rescission is Missing
|
1
|
||
|
TRID: Missing Closing Disclosure
|
1
|
||
|
Initial Closing Disclosure Delivery Date Test
|
1
|
||
|
Revised Closing Disclosure Delivery Date Test (Waiting Period Required) Test
|
1
|
||
|
Initial Loan Estimate Delivery Date Test (prior to consummation)
|
1
|
||
|
Total Compliance Grade (A) Exceptions:
|
197
|
||
|
B
|
Charges That Cannot Increase Test
|
11
|
|
|
Lender Credits That Cannot Decrease Test
|
4
|
||
|
Charges That In Total Cannot Increase More Than 10% Test
|
4
|
||
|
Qualified Mortgage Safe Harbor Threshold
|
1
|
||
|
Evidence of Appraisal Delivery to Borrower not Provided or Late (12 CFR 1002.14(a)(1))
|
1
|
||
|
Total Compliance Grade (B) Exceptions:
|
21
|
||
|
C
|
ARM Disclosure Not Provided Within 3 Days of Application Date
|
1
|
|
|
Total Compliance Grade (C) Exceptions:
|
1
|
||
|
Property
|
A
|
No Property Findings
|
128
|
|
Third Party Valuation Product Not Provided within 10% Tolerance
|
5
|
||
|
Condo Approval Missing
|
1
|
||
|
The appraiser was not licensed (Primary Value)
|
1
|
||
|
Unsupported adjustments or comps
|
1
|
||
|
Appraisal is Expired
|
1
|
||
|
Property/Appraisal General
|
1
|
||
|
Total Property Grade (A) Exceptions:
|
138
|
|
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.
|