J.P. MORGAN ACCEPTANCE CORPORATION II ABS-15G
Exhibit 99.21
Executive Summary
4.
Description of the Due Diligence Services
| 1. | Type of Assets Reviewed |
Inglet Blair, LLC (“IB”) performed certain due diligence review
services (the “Review”), as defined herein. The loans reviewed were originated from June 2025 to January 2026 and were collateralized
by residential real estate and multi-family properties purchased by the applicable mortgagors for the purpose of generating rental income
(the “Loans”). The Loans were acquired by JPMorgan Chase Bank, National Association (the “Client”) from lenders
and/or aggregators (in such capacity, the “Seller”), via bulk acquisition or reliance letter. The information provided below
represents the approach and methodology used at the time of original acquisition by the Seller. Each of the Loans was acquired by the
Seller from various lenders through a delegated correspondent channel.
| 2. | Sample Size of Assets Reviewed |
This report reflects 10 Loans selected by the Client to include in JPMMT
2026-NQM2 (the “Securitization”). Client did not disclose to IB if additional loans are included in the Securitization. While
the Client may have included additional loans in the Securitization, such loans were not subject to the Review referenced herein. IB reviewed
100% of the Loans provided by the Client and can only assume the sample size was 100%.
| 3. | Sample Size Determination |
The Client, in its sole discretion, determined the Loans to be reviewed
by IB. As noted in Section 2 above, Client provided IB with 10 Loans, all of which were reviewed by IB. Therefore, IB used no sampling
methodology in its Review.
| 4. | Information and Data Integrity |
IB was provided certain data elements (the “Tape Data”), which
were supplied by the Seller. The Seller aggregated the Tape Data from the various lenders. Each lender did not supply Seller with uniform
Tape Data; thus, individual Loan Tape Data may not have included all data elements as detailed below in this Section 4. IB subsequently
mapped and compared the Tape Data to information contained in each Loan file. When the data was provided, IB compared the following fields:
| Field Name |
| Amortization Type |
Total Debt to Income Ratio |
| Amortized Original Term |
First Payment Date |
| Appraised Value |
Interest Only Flag |
| ARM Initial Adjustment Period |
Lien Position |
| ARM Initial Rate Cap |
Loan Purpose |
| ARM Lookback Period |
Loan Term |
| ARM Margin |
Loan Type |
| ARM Maximum Interest Rate |
LTV |
| ARM Minimum Interest Rate |
Note Date |
| ARM Payment Change Frequency |
Occupancy |
| ARM Periodic Rate Cap |
Original Interest Rate |
| ARM Periodic Rate Cap at first Adjustment Down |
Original Principal and Interest |
| ARM Periodic Rate Cap at first Adjustment Up |
Original Principal Balance |
| ARM Rate Cap at first Adjustment Down |
Property Type |
| ARM Rate Cap at first Adjustment Up |
Representative Credit Score |
| ARM Rate Change Frequency |
Residual Income |
| ATR/QM Designation |
Sales Price |
| Borrower First Name |
Subject Address |
| Borrower Last Name |
Subject City |
| CLTV |
Subject State |
| Doc Type |
Subject Zip Code |
| Inglet Blair, LLC Deal Summary |
| JPMMT 2026-NQM2 |
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| 5. | Underwriting, Origination Practices and Conformity to Guidelines and/or Criteria |
Each Loan was reviewed to the applicable guideline, matrix and/or finding
report, produced by an Automated Underwriting System (“AUS”), as provided to IB. Depending on the applicable guideline requirements,
IB verified, recalculated and compared certain metrics and attributes:
| - | Debt Service Coverage Ratio
(“DSCR”) |
| - | Loan to Value (“LTV”)
/ Combined Loan to Value (“CLTV”) |
| - | Qualifying Principal, Interest,
Taxes and Insurance (“PITI”) payment |
To the extent prescribed by the applicable guidelines,
every Loan received an evaluation of the applicable borrower’s employment, income, assets and credit history as follows:
Employment and Income:
| - | Meets the guidelines and, as
applicable, regulatory documentation requirements |
| - | Creditor income calculations
are reasonable and as prescribed by the applicable guidelines |
| - | Ensure borrower(s) is/are currently
employed |
Assets
| - | Confirm asset source and documentation
requirements |
| - | Re-calculate gross, net and
liquid asset balances |
| - | Incorporate gift funds and sourcing
documentation |
| - | Confirm and calculate reserve
calculations |
Credit Report
| - | Determine representative Credit
Score and Methodology |
| - | Maximum amount of open tradelines |
| - | Mortgage/Rental payment history |
| - | Installment and Revolving payment
history |
| - | Bankruptcy and Foreclosure seasoning |
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Credit Application (FNMA Form 1003)
| - | Employer and employment status |
| - | Confirmation of loan purpose
and occupancy |
| - | Disposition and status of Real
Estate Owned (REO) |
| - | First time home buyer status |
| - | Citizenship and eligibility |
Title Review - For each Loan the title commitment
or, if present, final title policy was reviewed to confirm:
| - | Title interest – Fee Simple
or Leasehold |
| - | Tax liens, encumbrances, encroachments
and/or other title defects were satisfied or addressed |
Fraud Report – IB reviewed each Loan file for
the presence of a fraud report with all material findings addressed surrounding borrower name variances, social security number discrepancies,
subject-property occupancy or employment history.
Hazard and Flood Insurance – Each Loan was reviewed
to ensure that (i) each hazard policy limit met the applicable guideline requirement (ii) the property address was correct (iii) the premium
was accurately reflected in the DTI calculation and (iv) escrowed where required.
Similarly, where the flood certificate indicates the
property improvements were located in a flood zone, IB confirmed the coverage met the guideline requirements and, where applicable, the
premium escrowed.
Closing/Legal Documents – All Loans received
a review of the closing documentation. This includes the note, mortgage (and applicable riders), assignments, mortgage insurance certificates,
underwriter approvals, and HUD-1 or Closing Disclosure, as applicable, are executed by all applicable parties and generally convey the
terms of the Loan.
The information and findings provided herein were
based on the information provided in the loan file images presented at the time of review.
| 6. | Collateral Review and Methodology |
To establish reasonable support for the original appraised
value, each qualifying appraisal was accompanied by one of the following: (i) an existing desk review report provided by the originator
(or issuer), (ii) a second full appraisal (typically required by the guidelines) or (iii) a FNMA Collateral Underwriter (“CU”)
analysis with a score of 2.5 or less. In the event a loan did not contain any of the supplemental documentation, IB ordered an AVM, desk
review or field review to fulfill the requirement. If any of the supplemental material(s) had an estimate of value that was lower than
the original appraised value by 10% (or more), a field review (or suitable alternative) was obtained.
Each Loan was analyzed to confirm it was sufficiently collateralized by
real property, and each appraisal was audited to address the following FIRREA/USPAP rules and standards:
| a. | Was the appraisal prepared for a financial services institution? |
| b. | Does the appraisal state the definition of Market Value? |
| c. | Does the appraisal indicate the appraiser’s license or certification, number and expiration date? |
| d. | Does the appraisal disclose any extraordinary assumptions, hypothetical conditions? Does the appraisal include a statement of assumptions
and limiting conditions? |
| i. | If yes, do the items appear to be reasonable? |
| e. | Is a minimum 3-year subject sale history included? |
| f. | Does the report state the effective date of the appraisal? |
| g. | Does the appraisal summarize the process used to collect, confirm, and report data? |
| h. | Does the appraisal state the subject’s highest and best use? |
| i. | Does the appraisal clearly identify the real estate being appraised? |
| j. | Does the appraisal state the real property interest being appraised? |
| k. | Does the report contain sufficient information? |
| l. | Was the appraisal reported on a FNMA appraisal form? |
| i. | If yes, was the form materially complete? |
| m. | Which of the industry recognized methods of valuation were included that may have been utilized to support the institution's
decision to engage in the transaction? |
| i. | Direct Sales Comparison Approach, Cost Approach, or Income Approach? |
| ii. | If any of these approaches have been omitted or excluded, is there sufficient explanation provided as to why? |
| Inglet Blair, LLC Deal Summary |
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| 7. | Regulatory Compliance Review to Federal, State and Local Lending Laws |
All Loans deemed to be consumer purpose loans were submitted to an automated
regulatory compliance review the “TRID Review”. The system tested each applicable Loan for adherence to certain federal, state
and local consumer protection laws related to mortgage lending. For nine (9) business purpose loans, no TRID compliance testing was completed.
All applicable tests and disclosure reviews
were graded in accordance with the SFA RMBS 4.0 TRID Compliance Review Scope standard as described below.
| - | Federal Truth in Lending Act–
Regulation Z |
| o | Consumer Handbook on Adjustable
Rate Mortgages (1026.19(b)(1)) |
| · | Confirm acknowledgement of receipt
by the borrower or documentary evidence disclosure was delivered to the borrower(s) |
| o | Your Home Loan Toolkit (1026.19(g)(1)) |
| · | Confirm acknowledgement of receipt
by the borrower or documentary evidence disclosure was delivered to the borrower(s) |
| · | Provided within 3 business days
of application |
| o | Federal High-cost (1026.32) |
| · | Identify points and fees and/or
APR threshold test failures |
| · | Prepayment Penalty restrictions |
| o | Higher-priced Mortgage Loans
(1026.35) |
| · | APR Threshold with the corresponding
appraisal and escrow requirements |
| o | Right of Rescission (1026.23) |
| · | Review accuracy, timing and
content of disclosure(s) |
| · | Confirm all requisite consumers
received notice and correct form |
| o | Qualified Mortgage Rule (1026.43(e)) |
| · | Perform points and fees test
to confirm 3% threshold |
| · | Adherence to Appendix Q and
DTI below 43% or Temp QM |
| · | Application Dates of 1/10/2014
to 2/28/2021 |
| · | Adherence to Appendix Q and
DTI below 43% and/or Temp QM and/or APR/APOR threshold testing |
| · | Application Dates of 3/1/2021
to 6/30/2021 |
| · | Adherence to Appendix Q and
DTI below 43% and/or APR/APOR threshold testing |
| · | Application Dates of 7/1/2021
to 9/30/2022 |
| · | APR/APOR threshold testing |
| · | Application Dates on or after
10/1/2022* |
| o | Subject to any guidance updates
from regulators |
| · | Loan does not contain “risky
feature” (IO, Negative Amortization, etc.) |
| · | Contain a valid and approved
AUS, as applicable |
| · | Ability-to-Repay (“ATR”)
(1026.43(c)(2) – IB reviewed each Loan for the applicable mortgagor’s ability to repay; however, there is no representation
or warranty, implied or otherwise, that a court (or other administrative/legislative authority) will agree with the determination. IB
objectively confirmed the following eight (8)-factors had been considered and, where applicable, documented: |
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| · | (i) The consumer's
current or reasonably expected income or assets, other than the value of the dwelling, including any real property attached to the dwelling,
that secures the loan; |
| · | (ii) If the creditor relies
on income from the consumer's employment in determining repayment ability, the consumer's current employment status; |
| · | (iii) The consumer's
monthly payment on the covered transaction, calculated in accordance with paragraph (c)(5) of this section; |
| · | (iv) The consumer's
monthly payment on any simultaneous loan that the creditor knows or has reason to know will be made, calculated in accordance with paragraph
(c)(6) of this section; |
| · | (v) The consumer's
monthly payment for mortgage-related obligations; |
| · | (vi) The consumer's
current debt obligations, alimony, and child support; |
| · | (vii) The consumer's
monthly debt-to-income ratio or residual income in accordance with paragraph (c)(7) of this section; and |
| · | (viii) The consumer's
credit history. |
| • | Initial
LE was provided within three (3) business days of application as provided by the broker or creditor and loan does not consummate within
seven (7) business days of receipt |
| • | Provided
within three (3) business days of a valid Change of Circumstance |
| • | Complete
in all material respects |
| • | Confirm
the “In 5 Years” calculation is not over disclosed |
| o | Final Closing Disclosure (“CD”) |
| • | Confirm
creditor provided CD no later than three (3) business days of consummation and confirm all relevant fields are complete |
| • | Ensure
technical requirements are met – Rounding, Alphabetization, Number of Fees per category and title fees properly labeled |
| · | Recalculation of the Finance Charge, Amount Financed, Total
of Payments (“TOP”), and Total Interest Payments (“TIP”) |
| · | Projected Payments - Re-calculation of Principal and Interest
payment(s), verified escrow and insurance payments, interest only periods and final balloon payments are present and displayed in the
correct number of columns |
| · | Adjustable Interest Rate and Adjustable Payment Tables are
present, complete and accurate, if applicable |
| · | No fee charged for preparation of LE or CD |
| · | Fee descriptions conform with clear and conspicuous standard |
| · | Loan terms match that of the subject loan – balance,
rate, term, prepayment penalty |
| · | Loan Disclosures section is complete – Late Payment
matches the note and the escrow section is consistent within the disclosure |
o
Fee and Tolerance Testing - Zero and ten percent (10.0%)
tolerance testing, including the presence, timing and a validation of a change of circumstance and corresponding fee changes
o
Evidence Service Provider List and Your Home Loan Toolkit,
if applicable, were provided or present in the loan file
o
LE and CD form(s) provided to the borrower are consistent
across the loan process
o
NMLS ID is present on the loan application, note, security
instrument, LE and CD, as applicable
o
Items not tested, include but are not limited to:
| · | Categorization of fees in the appropriate section |
| · | Accuracy of information for fields not expressly stated
above |
| · | Presence and accuracy of the Seller’s Transaction
columns on the Seller’s columns |
| o | State High-cost and Predatory
lending regulations |
| · | Special Information Booklet |
| · | Notice of Servicing Transfer |
| · | Affiliated Business Arrangement
Disclosure |
| · | Homeownership Counseling Disclosures |
| o | Equal Credit Opportunity Act |
| · | Presence, acknowledgement and
timing of the Right to Receive Copy of Appraisal Disclosure |
| Inglet Blair, LLC Deal Summary |
| JPMMT 2026-NQM2 |
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Structured Finance Association (“SFA”)
organized and led an initiative to establish a framework for Third-Party Reviewer’s (“TPR”) to evaluate and grade loans
subject to the Know Before You Owe Act, also commonly referred to as TILA-RESPA Integrated Disclosure (“TRID”). While all
grades and conclusions are established in good faith, the grading scheme materiality and impact for certain exceptions may change from
time to time, and thus, all reports contain Interpretation Risk. Under no circumstance should the Client, any potential investors or other
individual party solely rely on the interpretations made by IB, SFA, or its outside counsel.
Please be advised that IB is not a law firm,
does not employ personnel who are licensed to practice law and the exceptions, observations and conclusions provided by IB are not legal
opinions. IB relies upon the advice of outside counsel, informal advice of regulators and industry practice to determine materiality.
| TRID Tested |
No. of Loans |
% of Population |
| No |
9 |
90.00% |
| Yes |
1 |
10.00% |
| Total |
10 |
100% |
| 8. | Any Other Type of Review |
There was no other review performed.
| Inglet Blair, LLC Deal Summary |
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5.
Summary of Finding and Conclusions of Review
The following tables represent the final NRSRO
overall and component grades. The Overall grade is comprised of the lowest of the component grades.
| NRSRO Final Grade |
No. of Loans |
% of Population |
| A |
3 |
30.00% |
| B |
7 |
70.00% |
| Total |
10 |
100% |
| |
|
|
| NRSRO Final Credit Grade |
No. of Loans |
% of Population |
| A |
3 |
30.00% |
| B |
7 |
70.00% |
| Total |
10 |
100% |
| |
|
|
| NRSRO Final Compliance Grade |
No. of Loans |
% of Population |
| A |
10 |
100.00% |
| B |
0 |
0.00% |
| Total |
10 |
100% |
| |
|
|
| NRSRO Final Property Grade |
No. of Loans |
% of Population |
| A |
10 |
100.00% |
| B |
0 |
0.00% |
| Total |
10 |
100% |
The following tables represent certain key
attributes of the Loans and their frequency amongst the loan population.
| Amortization Type |
No. of Loans |
% of Population |
| Fixed Rate |
10 |
100.00% |
| Total |
10 |
100% |
| |
|
|
| Lien Position |
No. of Loans |
% of Population |
| 1st |
10 |
100.00% |
| Total |
10 |
100% |
|
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|
|
|
|
| Purpose |
No. of Loans |
% of Population |
|
Cash Out: Other/Multipurpose/
Unknown purpose |
1 |
10.00% |
| Other-than-first-time Home Purchase |
7 |
70.00% |
|
Rate/Term Refinance -- Borrower
initiated |
2 |
20.00% |
| Total |
10 |
100% |
| Property Type |
No. of Loans |
% of Population |
| Single Family Detached (non-PUD) |
5 |
50.00% |
dPUD (PUD with “de minimus” monthly
HOA dues |
1 |
10.00% |
PUD (Only for use with Single-Family
Detached Homes with PUD riders) |
1 |
10.00% |
| 3 Family |
1 |
10.00% |
| 4 Family |
2 |
20.00% |
| Total |
10 |
100% |
| |
|
|
| LTV |
No. of Loans |
% of Population |
| 00.01- 10.00 |
0 |
0.00% |
| 10.01- 20.00 |
0 |
0.00% |
| 20.01- 30.00 |
0 |
0.00% |
| 30.01- 40.00 |
0 |
0.00% |
| 40.01- 50.00 |
0 |
0.00% |
| 50.01- 60.00 |
2 |
20.00% |
| 60.01- 70.00 |
0 |
0.00% |
| 70.01- 80.00 |
7 |
70.00% |
| 80.01- 90.00 |
1 |
10.00% |
| 90.01- 100.00 |
0 |
0.00% |
| Total |
10 |
100% |
| |
|
|
| CLTV |
No. of Loans |
% of Population |
| 00.01- 10.00 |
0 |
0.00% |
| 10.01- 20.00 |
0 |
0.00% |
| 20.01- 30.00 |
0 |
0.00% |
| 30.01- 40.00 |
1 |
8.33% |
| 40.01- 50.00 |
0 |
0.00% |
| 50.01- 60.00 |
1 |
8.33% |
| 60.01- 70.00 |
4 |
33.33% |
| 70.01- 80.00 |
6 |
50.00% |
| 80.01- 90.00 |
0 |
0.00% |
| 90.01- 100.00 |
0 |
0.00% |
| Total |
12 |
100% |
| Inglet Blair, LLC Deal Summary |
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