Exhibit 99.02

 

 

 

 

OBX 2026-HYB1

 

Bank of America, N.A.

 

 

 

 

 

 

 

 

Opus Capital Markets Consultants, LLC

 

 

 

 

 

 5718 Westheimer Road – Suite 1000 | Houston, TX 77057 | www.opuscmc.com | 224.632.1300
 

 

 

 

Executive Narrative

 

April 27, 2026

 

Performed by

Opus Capital Markets Consultants, LLC

 

For

Bank of America, N.A

 

The report summarizes the results of a due diligence review performed on a pool of 284 loans provided by Bank of America, N.A.. (“Customer”) who provided Opus Capital Markets Consultants, LLC (“Consultant”) with a data tape, from which 100% of the loan sample was chosen and loaded into the LauraMac underwriting software. Consultant performed a detailed credit and compliance review of all loans.

 

As detailed herein, the pool contains one hundred fifty-three (153) QM: Safe Harbor APOR (APOR SH) loans, sixty-six (66) QM: Safe Harbor DTI (DTI SH) loans, forty-four (44) QM Risk: Loan does not meet QM requirements loans, eighteen (18) ATR/QM: Not Applicable loans and three (3) ATR Risk: Safe Harbor APOR did not document all ATR UW Factors (APOR SH) loans. All loans were re-underwritten in accordance with the lender guidelines provided in terms of Exhibit A

 

Consultant performed a title review on 284 loans. Title reports were ordered from a third party title company and reviewed by Opus in accordance with the statement of work as listed in the scope below of Exhibit A Item 2.

 

Consultant performed a payment history review on the loans within the Opus seasoned asset underwriting software. A payment history review was performed on 284 loans. The loans were reviewed in accordance with the statement of work as listed in the scope below of Exhibit A Item 3.

 

Consultant performed a modification review within the LauraMac underwriting software on 12 loans. The loans were reviewed in accordance with the statement of work as listed in the scope below Exhibit A Item 4

EXHIBIT A

 

1.Credit Review

 

Credit Qualification

 

A re-underwriting review will be conducted in order to verify that the requisite underwriting guidelines as specified by Client are met. Confirmation of the loan terms will be performed through recalculation and review of documentation contained in the loan file provided to the Consultant. The Credit Qualification review will consist of the following:

a)Guidelines: Determine whether each mortgage loan meets the requisite guideline requirements as specified by the Client. In lieu of specific requirements, Consultant should consider Regulation Z including Appendix Q if applicable. If the loan pre-dates the requirements of Regulation Z and Appendix Q, Consultant will consider Fannie Mae’s Single-Family guidelines.
b)Employment: Review the file documentation for minimum required level of employment, income and asset verifications pursuant to Client provided underwriting guidelines.
c)Income: Recalculate borrower(s) monthly gross income and verify calculations of income as used by the original loan underwriter at origination to determine compliance with the Client provided underwriting guidelines.
d)Assets: Confirm the presence of adequate asset documentation to comply with the Client provided underwriting guideline requirements for closing funds, reserves and borrower liquidity.
e)Debt Ratio: Recalculate the debt-to-income ratio and verify the ratio accuracy used by the loan underwriter at origination to determine compliance with Client provided underwriting guidelines and regulatory requirements.
f)Property Valuation: Analyze all appraisals and alternative value tools used to qualify the loan for integrity of comparable sales, completeness of data, eligibility of the appraiser and reasonableness of estimated value. Review the appraisal to determine the appraisal(s) meet the requirements of Client provided underwriting guidelines.
g)Loan-to-Value Ratio: Recalculate and verify the loan-to-value ratio and combined loan-to-value ratio were accurate at origination and meet Client provided underwriting guideline and regulatory requirements.
h)Credit History: Review the credit report to verify that the borrower(s) demonstrate adequate credit depth to comply with the Client provided underwriting guideline requirements.

 

 

 

 

i)Credit Scores: Verify that borrower(s) meet minimum credit score requirements of the Client provided underwriting guidelines.
j)Compensating Factors: Verify exceptions to the Client provided underwriting guidelines are documented and reasonable.

 

 

Document Review

 

A review of each loan file will be performed to confirm the presence of material documentation as applicable to the specifics of the loan transaction. The Document Review will consist of the following:

 

a) Collateral Docs

·Title Commitment / Policy: Verify the presence of the title commitment or final title policy. Confirm vested parties and the description of the property, liens and tax assessments.
·Mortgage Note / Security Instrument: Verify the presence of the mortgage note or security instrument. Confirm that the document has been executed by all borrowers and that all riders, addendums and endorsement are present and duly executed.
·Mortgage / Deed of Trust: Verify the presence of a copy Mortgage or Deed of Trust. Confirm that the documents have been executed by all required parties and that all riders, addendums and exhibits are present and duly executed. If the loan closed within 12 months of the review, Consultant will confirm the presence of a letter from the title company specifying the date the Mortgage / Deed Trust was sent for recording. If the closing did not occur within 12 months of the review and a copy of the recorded Mortgage /Deed of Trust is not contained in the loan file, the Client will submit a report from an independent document custodian verifying the presence of a recoded mortgage or a stamped / signed copy of the document stating the date the document was sent for recording.
·Conveyance Deed: Verify as applicable that a proper conveyance deed is present in the loan file. Confirm the proper transfer of ownership interest of the subject parties is detailed on the deed.

 

b) Closing Docs

·Final Hud-1 Settlement Statement: If required, verify the presence of a final HUD-1. Verify the completeness of required data and signatures or certification depending upon state compliance requirements.
·Final Truth-in-Lending Disclosure: If required, verify the presence of a final Truth-in-Lending Disclosure. Verify the completeness of required data and that all required signatures are present.
·Notice of Right to Cancel: If required based on the specifics of the loan transaction, confirm the presence and required execution of the Notice of Right to Cancel.
·Loan Estimate: If required verify the presence of the current Loan Estimate (LE) at the time of origination
·Closing Disclosure: If required verify the presence of the current Closing Disclosure (CD) at the time of origination.

 

c) Credit Docs

·Loan Application: Verify the presence and completeness of both the initial and final loan applications.
·Underwriting Worksheet: Verify the presence of the relative underwriting worksheet i.e. form 1008, FHA MCAW and VA’s Loan Analysis.
·Credit Report: Verify the presence of a credit report for each borrower. Confirm that the credit report was pulled within the timing requirements allowable per the Client provided underwriting guidelines.
·Housing Payment History: In the absence of housing payment histories on the borrower(s) credit report(s), verify that that the file contains a verification of rent or a verification of mortgage form.
·Letters of Explanation: When Letters of Explanation are required by the Client provided underwriting guidelines, verify the presence of any such letters exist in the loan file.
·Gift Letters: When Gift Letters are required by the Client provided underwriting guidelines, verify the presence of any such letters exist in the loan file.
·Income Documentation: Verify the presence of income and employment related documentation required by the Client provided underwriting guidelines for all borrowing parties contributing income to the debt ratio calculation.
·Asset Documentation: Verify the presence of asset documentation required by the Client provided underwriting guidelines in the loan file.
·Property Valuation Tools: Verify that each loan file contains adequate appraisal and other third-party valuation tools to satisfy the minimum required documentation under the relative Client provided underwriting guidelines.
·Proof of Insurance: Verify the presence of insurance certificates for mortgage, hazard and flood insurance on an as needed basis depending upon the specifics of the loan. Confirm that adequate coverage is present to meet the requirements of the Client provided underwriting guidelines.

 

 

 

 

Regulatory Compliance

 

For each Mortgage Loan, Consultant shall determine, to the extent possible and subject to caveats below, whether such Mortgage Loan at the time of origination complied with:

 

1.The “material”1 disclosure requirements of the federal Truth-in-Lending Act (“TILA”), as amended by the Home Ownership and Equity Protection Act (“HOEPA”) and Dodd-Frank, 15 U.S.C. § 1601 et seq. and implemented by Regulation Z, 12 C.F.R. Part 1026, including the material provisions relating to Higher-Priced Mortgage Loans in Regulation Z, 12 C.F.R. §§ 1026.35, and the early TIL disclosure provisions of the Mortgage Disclosure Improvement Act (“MDIA”), as implemented by Regulation Z, 12 C.F.R. §§ 1026.17 et seq; and as amended by the TILA-RESPA Integrated Disclosure (“TRID”) Rule, as set forth below:
a.For Right of Rescission
i.A review of the Notice of Right to Cancel, including a verification of the transaction date and expiration date, ensuring proper execution of the Notice of Right to Cancel by all required parties, verifying the disbursement date and determining if a full three (3) day rescission period was adequately provided to the borrower(s).
A.This review is also to be performed on transactions that are exempt from the rescission requirement but on which a Notice of Right to Cancel was provided.
B.A condition must be placed if the transaction is a refinance by the original creditor and the borrower was provided the Form H-8 rescission notice. Consultant will note in the condition whether there was a new advance that is subject to rescission per TILA/Regulation Z.
b.For TILs (Application Dates prior to 10/3/2015)
i.Confirm the initial TIL disclosure and final TIL disclosures were provided.
ii.Review and compare the initial and final TIL, and any re-disclosed TIL(s), with a report outlining any TILA violations, including a recalculation of disclosed finance charge, proper execution by all required parties, principal and interest calculations, proper completion of the interest rate and payment summary, recalculation of disclosed APR, and a review to determine disclosure differences were within the allowed tolerances and disclosures were provided within the required timeframes;
c.For TRID Disclosures (Application Dates on or after 10/3/2015)
i.Confirm the initial Loan Estimate (LE) was delivered within three (3) business days of application and seven (7) business days prior to consummation in accordance with Client’s Underwriting Guidelines;
ii.Review the required sections of each LE to ensure they were populated in accordance with the TRID Rules. (If the file reflects more than one LE was provided, each revised LE must have corresponding Change of Circumstance documentation. The 0% and 10% fee tolerance evaluations will be based on the fee amounts disclosed on the initial LE and any valid changes documented and disclosed after the initial LE;
iii.Confirm the Closing Disclosure (CD) confirm the borrower received the initial CD at least three (3) business days prior to consummation;
iv.Review the required sections of each CD to ensure they were populated in accordance with the TRID Rules. (Any fee tolerance issues to be cured at closing or within 60 days of loan consummation.)

 

2.Section 4 of the Real Estate Settlement Procedures Act (“RESPA”), 12 U.S.C. §2603 and 2604, as implemented by Regulation X, 12 C.F.R. Part 1024, and as amended by the TRID Rule;

 

3.The disclosure requirements and prohibitions of Section 50(a)(6), Article XVI of the Texas Constitution;

 

4.Confirmation that one of the following are in the loan file, per the Fair Credit Reporting Act: Consumer Credit Score Disclosure, Your Credit Score and the Price You Pay for Credit, or Notice to Home Loan Applicant;

 

5.Sections 1411 and 1412 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) amending TILA, as implemented by Regulation Z, 12 C.F.R. 1026.43: the general Ability to Repay underwriting standards (12 C.F.R. 1026.43(c)); refinancing of non-standard mortgages (12 C.F.R. 1026.43(d)); Qualified Mortgages (12 C.F.R. 1026.43(e) (including qualified mortgages as 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 Balloon-payment qualified mortgages made by certain creditors (12 C.F.R. 1026.43(f)) In accordance with “Ability to Repay and Qualified Mortgage Review” description below;

 

6.The Loan Originator Compensation and Prohibitions on Steering provisions of TILA, as implemented by Regulation Z, 12 C.F.R 1026.36;

 

 

1 These “material” disclosures include the required disclosures of the APR, the finance charge, the amount financed, the total number of payments, the payment schedule, and if the loan is subject to the Homeownership and Equity Protection Act (“HOEPA”), the disclosure requirements and prohibitions of that statute which are set forth in 12 C.F.R. §§ 1026.32(c) and (d).

 

 

 

 

7.The requirements for Higher-Price Mortgage Loans, as implemented by Regulation Z, 12 C.F.R. 1026.35;

 

8.The appraisal and valuation requirements of TILA and the Equal Credit Opportunity Act, as implemented by Regulation Z, 12 C.F.R. 1026.35 and Regulation B, 12 C.F.R. 1002.14, respectively;

 

9.The counseling requirements of TILA, as implemented by Regulation Z, 12 C.F.R. 1026.36(k) and RESPA, as implemented by Regulation X, 12 C.F.R. 1024.20;

 

10.The escrow requirements of TILA and RESPA, as implemented by Regulation Z, 12 C.F.R 1026.35, and Regulation X, 12 C.F.R 1024.17, respectively;

 

11.The disclosure requirements and prohibitions of any applicable state, county and municipal laws and ordinances, as amended, that have been enacted to regulate so-called “predatory lending”:

 

12.Consultant shall confirm that any mortgage property located in an area identified on a flood hazard map or flood insurance rate map issued by the Federal Emergency Management Agency as having special flood hazards is subject to a qualified flood insurance policy that appears to be is in effect.

 

13.For any loans designated as TILA exemption, Consultant shall review the loan file for evidence that the primary purpose of the loan was for commercial or business purposes, including, but not limited to a business purpose certification.

 

14.Documentation. Review of the following documents for regulatory compliance:
a.Final HUD-1 Settlement Statement (“HUD-1”), if applicable
i.If the loan is in an escrow state, the HUD-1 will be considered final as follows:
A.HUD-1 is marked Final;
i.If HUD-1 is not marked Final, it must be stamped certified by the closing agent.
ii.There should be no markings indicating that the HUD-1 is estimated.
B.HUD-1 is signed by all parties (including closing agent) or stamped certified by the closing agent; and
C.If HUD-1 is stamped, the HUD-1 / stamp should be signed or initialed by the closing agent; if the stamp does not contain the signature or initials, it must identify the name of the closing agent.
b.Final Truth in Lending Disclosure (“TIL”), if applicable
c.Loan Estimate, if applicable
i.The Loan Estimate in will be considered delivered based on the date issued, subject to the three-day mailing rule unless the file contains documentation indicating earlier receipt. The loan file may contain one or more Loan Estimates with the latest one provided up until three business days prior to the issuance of an initial Closing Disclosure.
d.Closing Disclosure, if applicable
i.The Closing Disclosure in the loan file will be considered delivered based on the date issued, subject to the three-day mailing rule unless the file contains documentation indicating earlier receipt. The loan file may contain one or more Closing Disclosures with the latest one provided up until the consummation date being considered the Final with any delivered post consummation considered as a corrected Closing Disclosure.
e.Notice of Right to Cancel (if applicable)
f.Initial TIL, if applicable
g.Good Faith Estimate (“GFE”), if applicable
h.Note
i.Mortgage/Deed of Trust
j.FACTA disclosures
k.Third Party Fees
i.Third party fees on the HUD-1 or Closing Disclosure if applicable referred to as HUD-1/Closing Disclosure, must be shown as paid to the third-party provider. A condition must be set if a third-party fee is paid to the lender, investor, etc. or the payee is blank.
ii.CONSULTANT will condition for evidence in the file indicating that a charge on the HUD-1/Closing Disclosure exceeds the actual cost to the borrower (i.e. cost printed / stamped on the face of the document showing an amount less than the charge on the HUD-1/Closing Disclosure). Variations of less than $1 are deemed to be within reasonable limits and are not to be reported.
iii.Any refunds that are provided to the borrower must be accompanied by a revised HUD-1/Closing Disclosure to show the final, accurate charges to the borrower.

 

Each loan reviewed will be assigned a Compliance condition grade in accordance with the Rating Agency Criteria as more fully described in Section 2(f).

 

 

 

 

Consultant will not make a determination as to whether the loans comply with federal, state or local laws, constitutional provisions, regulations or ordinances that are not expressly enumerated above. Furthermore, the findings reached by Consultant are dependent upon its receipt of complete and accurate data regarding the loans from loan originators and other third parties upon which Consultant is relying in reaching such findings.

 

Ability to Repay and Qualified Mortgage Review

 

1.For Agency Eligible Loans Only: Consultant reviews applicable loans for compliance with the Qualified Mortgage (QM) rule requirements set forth in Regulation Z (12 C.F.R. 1026.43 et seq.) based upon the loan’s designation (Safe Harbor QM, Rebuttable Presumption QM, Exempt). Consultant determines the loan’s status under the QM rule requirements and assigns a due diligence loan designation. Consultant notes as a material exception if the due diligence findings do not confirm the same loan designation. Additionally, Consultant notes if a loan designation was not provided. Consultant will verify if each loan meets the requirements for a QM under § 1026.43(e)(2)—whether the loan is a safe harbor QM under § 1026.43(e)(1)(i) or a rebuttable presumption QM under § 1026.43(e)(1)(ii). Consultant will verify the presence of documentation for lender determination of QM and indicating factors in its ability-to-repay determination, including how the originator applied its policies and procedures in verification. For loans applications taken on or after June 1, 2021, Consultant will verify whether the loan meets the requirements of the revised general QM definition effective March 1, 2021.

 

2.For loans for which applications were received prior to July 1, 2021, if a loan was designated as QM and identified as eligible for guarantee, purchase, or insurance by an applicable agency as permitted under the QM final rule, Consultant reviews the loan to determine whether, based on available information in the loan file the loan satisfied (i), (ii) and (iii) in the paragraph (3)(a)(i) below and reviews the Automated Underwriting System output within the file to confirm agency eligibility.

 

3.For Non-Agency Eligible Loans: Consultant reviews applicable loans for compliance with the Ability to Repay (ATR) but not Qualified Mortgage (QM) rule requirements set forth in Regulation Z (12 C.F.R. 1026.43 et seq.).

a. Qualified Mortgage:

i.For QM (Safe Harbor or HPCT) designated loans, Consultant reviews the loan to determine whether, based on available information in the loan file: (i) the loan contains risky loan features and terms (e.g. an interest only feature or negative amortization), (ii) the “points and fees” exceed the applicable QM threshold, (iii) the monthly payment was calculated appropriately. Consultant reviews to the applicable consider and verify requirements under the QM rule depending on whether the QM was originated under the original general QM definition or the revised general QM definition effective March 1, 2021.
ii.For each QM designated loan that satisfied the applicable requirements enumerated above, Consultant then determines whether the loan is a Safe Harbor QM or Higher Priced QM by comparing the loan’s actual annual percentage rate, as recalculated, to the applicable average prime offer rate plus a certain percentage. For QM designated loans originated under the revised general QM definition effective March 1, 2021, Consultant also determines whether the loan exceeds the pricing thresholds for QM loans.

b. Ability to Repay:

i.The ability to repay portion of the review for non-agency eligible loans only will focus on the eight factors detailed in the ATR Rule as detailed below for non-agency eligible loans. The Consultant will review the loan file to determine if the creditor verified and considered each of the eight factors utilizing reasonably reliable third-party documentation at or before consummation.
1.Current or reasonably expected income or assets that the consumer will rely on to repay the loan.
2.Current employment status
3.Monthly mortgage payment for subject loan using the introductory or fully indexed rate, whichever is higher, and monthly, fully amortized payments that are substantially equal
4.Monthly payment on any simultaneous loans secured by the subject property.
5.Monthly payments for property taxes and hazard/flood insurance and certain other costs related to the property such as homeowner’s association fees or ground rent.
6.Debts, alimony, and child support obligations
7.Monthly debt-to-income ratio or residual income
8.Credit history
ii.For loans designated as agency eligible, Consultant will not review for compliance with the requirements of Appendix Q or General Ability to Repay.
iii.Consultant reviews loans to determine their conformity with the ATR/QM factors above and is not rendering an independent assessment or analysis. Consultant’s review is based on information contained in the loan file at the time it is provided to Consultant, and only reflects information as of that point in time and does not mean any regulator, judicial or agency will agree with the Consultant’s conclusion.

 

 

 

 

a)Regulatory Compliance Disclaimer

 

Please be advised that Consultant will not make a determination as to whether loans complied with federal, state or local laws, constitutional provisions, regulations or ordinances that are not expressly enumerated herein. There can be no assurance that the review uncovered all issues relating to the origination of the mortgage loans, their compliance with applicable law and regulation and the original appraisals relating of the mortgaged properties or uncovered all relevant factors that could affect the future performance of the mortgage loans. Furthermore, the findings reached by Consultant are dependent upon its receiving complete and accurate data regarding the mortgage loans from loans originators and other third parties upon which Consultant is relying in reaching such findings.

 

Please be further advised that Consultant does not employ personnel who are licensed to practice law in various jurisdictions, and the findings set forth in the reports prepared by Consultant do not constitute legal advice or opinions. They are recommendations or conclusions based on information provided to Consultant. All final decisions as to whether to purchase or enter into a transaction related to any individual mortgage loan or the mortgage loans in the aggregate, any investment strategy and any legal conclusions, including potential liability related to the purchase or other transaction involving any such loans, shall be made solely by the Client, or other agreed upon party, that has engaged Consultant to prepare its reports pursuant to its instructions and guidelines. Client, or other agreed upon party, acknowledges and agrees that the scoring models applied by Consultant are designed to identify potential risk and the Client, or other agreed upon party, assumes sole responsibility for determining the suitability of the information for its particular use.

 

b)Seasoning And Certain Compliance Exceptions

 

Pursuant to the applicable NRSRO criteria, Consultant graded certain compliance exceptions as non-material based on seasoning of the mortgage loan. Certain mortgage loans were seasoned beyond the applicable period under TILA in which affirmative claims could be brought by a consumer. The time period is not limited for claims, other than recession, which are raised as a defense to foreclosure. Information contained in any Consultant reports related to the applicable statute of limitations for certain claims may not be accurate or reflect the most recent controlling case law. Further, a particular court in a particular jurisdiction may extend, not enforce or otherwise allow claims beyond the statute of limitations identified in the report based on certain factors, including the facts and circumstances of an individual loan.

 

Additional Disclosures and Requirements:

 

Consultant will confirm compliance with current documentation and timing requirements in effect at origination of the Mortgage Loan including:

·Servicing Transfer Disclosure (for applications prior to 10/03/2015):
oConfirm the presence of the Servicing Transfer Disclosure form in file
oVerify the Servicing Transfer Disclosure was provided to the borrower(s) within three general business days of “Application”

 

·Special Information Booklet (for applications prior to 10/03/2015)/ Home Loan Tool Kit (for applications on or after 10/03/2015):
oConfirm the presence of the Home Loan Tool Kit is in file for covered loans.
oConfirm the Home Loan Tool Kit is provided within three general business days of application

 

·Initial Escrow Disclosure Statement
oConfirm the presence of the Initial Escrow Disclosure Statement in file
oConfirm the Initial Escrow Disclosure Statement was provided at closing or within 45-days after settlement

 

Equal Credit Opportunity Act (Regulation B)

 

·Confirm the lender has provided the borrower a disclosure of the right to receive a copy of appraisals within three (3) business days of application. This disclosure requirement may be met by disclosure on the Loan Estimate pursuant to 12 CFR § 1026.27(m)(1).
·Confirm that the lender has provided (delivered) copies of appraisals and all other written valuations (as disclosed to the borrower on the HUD-1 and/or contained in the Mortgage Loan File) to the borrower at least three (3) business days prior to consummation Opus uses the following test: Was appraisal/valuation documentation processed at least six (6) days prior to account opening/ consummation date (3 day rule plus 3 days mailing time)?
·For a borrower that has waived the 3-business day disclosure requirement, confirm that the borrower has either (1) signed the waiver at least three (3) business days prior to consummation or (2) has signed an acknowledgment that the waiver occurred at least three (3) business days prior to consummation. Additionally, confirm that the lender has provided copies of appraisals and other written valuations at or prior to consummation.

 

 

 

 

Fair Credit Report Act (Regulation V)

·Confirm that the lender has provided the borrower the risk-based pricing notice (as required by 12 CFR § 1022.73) or credit score disclosure (as required by 12 CFR § 1022.74(d)), as applicable; (a) If the lender has provided the risk-based pricing notice, confirm the disclosure was provided before consummation, but not earlier than the approval decision was communicated to the consumer; and (b) If the lender has provided the credit score disclosure, confirm the disclosure was provided before consummation.
·Confirm that the lender has provided a copy of the disclosure of credit score and the Notice to Home Loan Applicant (as required by 15 U.S.C. § 1681g) before consummation.

 

High-Cost, State & Local Anti-Predatory Regulations

 

In addition to federal thresholds, Consultant will review the anti-predatory lending statutes in the following states and local municipalities, as applicable, as well as any additional applicable regulations implemented during the Term of this SOW.

 

·Arkansas Home Loan Protection Act, Ark. Stat. Ann. § 23-53-101 et seq.
·California Anti-Predatory Lending Statute, Cal. Fin. Code § 4970 et seq.
·California Higher-Priced Mortgage Loan Statute, Cal. Fin. Code §4995 et seq.
·Colorado Consumer Equity Protection Act, Colo, Rev. Stat. § 5-3.5-101 et seq.
·Connecticut Abusive Home Loan Lending Practices Act, Conn. Stat. Ann. §36a- 746 et seq., as amended from time to time.
·Connecticut Nonprime Home Loans Statute, Conn. Gen. Stat. §§ 36a-760 et seq. (as originally enacted and as amended by Senate Bill 949).
·District of Columbia Home Loan Protection Act, D.C. Official Code § 26-1151.01 et seq., as implemented by 20 D.C. Municipal Reg § 2000.1 et seq.
·Florida Fair Lending Act, Fla. Stat. Ann. § 494.0078 et seq. (for loans closed before July 1, 2014).
·Georgia Fair Lending Act, Ga. Stat. Ann. § 7-6A-1 et seq. (as originally enacted by House Bill 02-1361 and as modified by Senate Bill 03-53).
·Idaho Residential Mortgage Practices Act, Idaho Code § 26-3101 et seq.
·Illinois High Risk Home Loan Regulations, 38 Ill. Admin. Code §345.10 et seq.
·Illinois High Risk Home Loan Act, Public Act. 93-0561 (2003) codified at 815, ILCS §§ 137/5 et seq., and as amended by SB 1692 (2012), effective January 10, 2014.
·Illinois Predatory Lending Database Program, Public Act 95-0691 (SB 1167).
·City of Chicago, Illinois, Anti-Predatory Lending Ordinance, Chicago Municipal Code, §§ 2-32-440; 2-32-455; 2-92-325; 4-4-155; 8-4-325.
·Cook County, Illinois, Anti-Predatory Lending Ordinance, Cook County Code of Ordinances § 34-341.
·Cook County, Illinois, Anti-Predatory Lending Pilot Program, Illinois House Bill 4050 (2005).
·Indiana Home Loan Practices Act, as amended by HB 1179 (2005), Ind. Code §24-9-1 et seq.
·Section 16a-3-308a of the Kansas Consumer Credit Code, Kan. Stat. Ann. §16a.101 et seq.
·Kansas Consumer Credit Code
·Kentucky Anti-Predatory Lending Statute, Ky. Rev. Stat. § 360.100 et seq.
·Maine, An Act to Enhance Consumer Protections in Relation to Certain Mortgages (for loans closed prior to September 27, 2011), Me. Rev. Stat. Ann. Tit. 9-A, §§ 8-103(1); 8-206(8);8-206A, as amended by Legislative Documents 1869 (2007), 2125 (2008) and 1439 (2009).
·Maine Consumer Credit Code - Truth-in-Lending, (for loans closed on or after September 27, 2011), Me. Rev. Stat. Ann. tit. 9-A, §§ 8-501 et seq., as amended from time to time.
·Maryland Commercial Law, Md. Code Ann., Com. Law §§ 12-124.1; 12-127; 12- 409.1; 12-1029.
·Maryland Regulations for Higher Priced Mortgage Loans, as promulgated under the Maryland Mortgage Lender Law, Md. Code Ann., Fin. Instit. Code §§ 11-501 et seq.; Md. Code Regs. §§ 09.03.06.01 et seq.

 

 

 

 

·Massachusetts High-Cost Mortgage Regulations, 209 CMR Parts 32 and 40, as amended from time to time.
·Massachusetts Predatory Home Loan Practices Act, M.G.L. Chapter 183C, §§ 1 et seq.
·Massachusetts “Borrower’s Interest” Standard, M.G.L. Chapter 183, §28C.
·Massachusetts Mortgage Lender and Broker Regulations, 940 CMR §800 (15-17).
·Massachusetts Regulations for Higher Priced Mortgage Loans, 209 CMR §§ 32.00 et. seq., as amended from time to time.
·Massachusetts Subprime ARMs to First Time Homebuyers, M.G.L. Chapter 184, §17B.5.
·Michigan Consumer Mortgage Protection Act, Mich. Stat. Ann. § 445-1631 et seq.
·Minnesota Mortgage Originator and Servicer Licensing Act, § 58.137 et seq. (S.F. 2988 (2002)), as amended by House File 1004 (2007) and Senate File 988 (2007).
·Nebraska Mortgage Bankers Registration and Licensing Act, Neb. Stat § 45-702 et seq.
·Nevada Anti-Predatory Lending Law, Assembly Bill No. 284 (2003) and Amended by Assembly Bill No. 440 (2007), codified as NRS § 598D.010 et seq.
·New Jersey Home Ownership Security Act of 2002, NJ Stat. Ann. § C:46:10B-22 et seq., as amended from time to time.
·New Mexico Home Loan Protection Act, Senate Bill 449 (Regular Session 2003), codified at NM Rev. Stat. § 58-21A-1 et seq. and as amended from time to time.
·New York High-Cost Home Loan Regulations, 3 NYCCR Part 41 (2001).
·New York High-Cost Home Loan Act, N.Y. Bank. L. Ch. 626., as codified in NY Bank. Law § 6-l, and as implemented by 3 NYCCR Part 41 as amended from time to time.
·New York Subprime Home Loans Statute, NY Bank. Law § 6-m.
·North Carolina Anti-Predatory Lending Law, N.C. Gen. Stat. §§ 24-1.1A to 24- 10.2 and North Carolina Amendments to Anti-Predatory Lending Law, N.C. Gen. Stat. §§ 24-9; 24-1.1(E)(a); 24-10.2(a), as amended from time to time.
·Ohio Anti-Predatory Lending Statute, HB 386 as amended by Senate Bill 185 (2006), and as codified in various sections of the Ohio Code.
·Ohio Consumer Sales Practices Act, Ohio Rev. Code Ann. §1345.01, as implemented by Ohio Admin. Rules § 109 4-3-01 et seq.
·City of Cleveland Heights, Ohio, Anti-Predatory Lending Ordinance, Ordinance No. 72-2003 (PSH), Mun. Code §§ 757.01 et seq.
·Summit County, Ohio, Anti-Predatory Lending Ordinance, Ordinance No. 2004- 618, Muni. Code §§ 201.01 et seq.
·Oklahoma Anti-Predatory Lending Law, House Bill No. 1574 (2003), as codified in various sections of Title 14A of the Oklahoma Consumer Credit Code.
·Oklahoma Higher-Priced Mortgage Loans Law, Okla. Admin. Code §§ 160:45-9- 1 et seq.
·Pennsylvania Consumer Equity Protection Act, 63 Pa. Cons. Stat. Ann. § 456.501 et seq.
·Rhode Island Home Loan Protection Act, R.I. Gen. L. 34-25.1-2 et seq, as implemented by Emergency Banking Regulation 3 (2006) and Final Banking Regulation 3 (2007) and amended by Senate Bill 371 (2007).
·City of Providence, Rhode Island, Anti-Predatory Lending Ordinance, Chapter 2006-33, Ordinance No. 245.
·South Carolina High-Cost and Consumer Home Loans Act, S.C. Code § 37-23-10 et seq.
·Tennessee Home Loan Protection Act, Tenn. H.R. 3597 (2006), as codified at Tenn. Code Ann. §§ 45-20-101 et seq.
·Texas High-Cost Home Loan Statute, Tx. Fin. Code Ann. § 343.201 et seq.
·Section 50(a)(6), Article XVI of the Texas Constitution
·Section 50(f)(2), Article XVI of the Texas Constitution
·Utah Residential Mortgage Practices Amendments, Utah Code Ann. § 61-2c-102 et seq.
·Utah High-Cost Home Loan Act, Utah Code § 61-2d-101 et seq.
·Vermont Interest Act, 9 V.S.A. § 104, implemented by Regulation B-98-2.
·Virginia Mortgage Lender and Broker Act (for loans originated prior to July 1, 2003), Va. Code Ann. §§ 6.1-413; 6.1-422; 6.1-428.

 

 

 

 

·Virginia Mortgage Lender and Broker Act (for loans originated on or after July 1, 2003, to September 30, 2010, as amended), Va. Code Ann. §§ 6.1-411, 6.1-422.1, 6.1-425.1 and 6.1-425.2.
·Virginia Mortgage Lender and Broker Act (for loans originated on or after October 1, 2010), Va. Code Ann. §§ 6.2-1600 et seq., as amended from time to time.
·Virginia Senate Bill 797 (2008), effective July 1, 2008 (uncodified).
·Washington House Bill 2770, Mortgage Lending Ownership
·West Virginia Residential Mortgage Lender, Broker and Servicer Act, W.Va. Code § 31-17 et seq.
·Wisconsin Responsible High-Cost Mortgage Lending Act, Wis. Stat. § 428.202, as implemented by Wis. Admin. Code DFI-Bkg 46.01 et seq.
·Wyoming Credit Code

 

Flood Insurance Testing

 

National Flood Insurance Program (NFIP)

Each mortgage loan will be reviewed to ensure adherence to flood insurance coverage requirements as outlined under the NFIP, including identification of flood zones and subsequent policy documentation for evidence of adequate coverage amounts.

Homeowner’s Flood Affordability Act (HFIAA)

Each mortgage loan made by an FDIC-supervised institution or servicer acting on its behalf shall require the escrow of all premiums and fess for flood insurance for any designated loan secured by residential improved real estate or a mobile home, made, increased, extended or renewed on or after January 1, 2016.

Frequency – Payable with same frequency as payments designated for the loans

Exceptions

·Loan is an extension of credit primarily for business, commercial or agricultural purposes
·Loan is in a subordinate position to a senior lien secured by the same residential improved real estate or mobile for which the borrower has obtained flood insurance
·Flood Insurance coverage for the residential real estate is provided by a policy that
a.Meets requirements
b.Provided by a condominium association, cooperative or other applicable group and
c.The premium for which is paid by the condominium associate, cooperative, homeowners association, or other group as a common expense.

 

Data Compare

 

Client will provide a data tape with the following data fields and Consultant will compare the field to the applicable source document and report any variance

 

·Appraised Value
·CLTV
·DTI
·FICO
·Interest Only
·Interest Rate
·Loan Term
·Loan Purpose
·LTV
·Occupancy
·Original Balance
·Property Address
·Property City
·Property State
·Property Type
·Sales Price

 

 

 

 

·Second Mortgage Lien Amount
·Self Employed
·Units
·Zip Code
·Loan Type
·QM Status

 

2.Title Review

 

Title Review

To the extent required by the Client, Consultant can perform a title review and perform the following

Procedures:

·Review updated title report (One Owner O&E report) to identify judgments / liens / encumbrances (pre and post origination) which would impact the lien position of the subject mortgage.

 

·Confirm subject mortgage is recorded.

 

·Review Schedule B: Ensure any liens recorded prior to the mortgage recordation date are listed as exceptions on the final title policy.

 

·Super lien Homeowners’ Association (HOA) liens.

 

oFor the purpose of the review the following states are subject to HOA super liens

 

§AL, AK, CO, CT, DC, DE, FL, HI, IL, MA, MD, MN, MO, NV, NH, NJ, OR, PA, RI, TN, VA, VT, WA and WV.

 

3.Payment History Review

 

Payment History

Prior to the start of each review Client and Consultant will mutually agree on the look back period and capture the agreed upon history (12, or 24 months). Consultant will capture and report a payment string and monthly net cash flows. Monthly net cash flows are defined as all cash collected net of reversals.

 

4.Modification Review (12 loans)

Modification Review

·Consultant will perform the following for each modified loan
oInventory the complete current modification in place
§Identify and report if missing or incomplete and how the modification is incomplete
oReport the number of modifications in the file including the current modification in place
oCapture all the modification data from the current modification in place
§See Table 1 for modification data

 

Table 1 Modification Table

For the current modification, the vendor will identify the following information, where relevant.

Modification Reason Rate Change Frequency (a) Negative Amortization Percentage
Balance Initial Rate Cap (a) Principal Reduction Amount (“PRA”)
Modification Date Initial Rate Maximum (a) PRA Anniversary Date
Program Type Initial Floor (a) Step Rate Flag
First Payment Date Initial Rate Minimum (a) Step Rate 1-10 (as applicable)
Maturity Date First Payment Adjustment Date (a) Step First Pmt. Date 1-10 (as applicable)
Term First Rate Change (a) Step P&I Amount 1-10 (as applicable)
Amortization Type Next Payment Adjustment Date (a) Extension Flag
Amortization Term Next Rate Adjustment Date (a) Extension Date
Balloon Indicator (Y/N) Periodic Rate Cap (a) Period Extended

 

 

 

 

Initial Interest Rate Periodic Rate Floor (a) Deferment Flag (Y/N)
Initial P&I Amount Lifetime Rate Cap (a) Deferment Date
Payment Frequency Lifetime Rate Floor (a) Amount Deferred
Mod Type (Fixed/ARM/GPM) Lifetime Minimum Rate (a) Deferred Balance (principal, interest, other)
Interest Only Flag (Y/N) Lifetime Maximum Rate (a)

Capitalized Amount

(advances, interest arrearages, suspense)

Index (a) Interest Only Indicator (Y/N) Accruing Balance
Margin (a) Interest Only Term Modification PITIA
Payment Change Frequency (a) Neg Am Indicator (Y/N) Pre-Mod Rate, balance, & PI

 

If a temporary modification is present, the vendor will collect the following data point concerning the temporary modification:

Status Maturity Date Interest Only Term
Temp-to-Perm Option Amount Forgiven Original P&I
First Payment Date ARM or Fixed Original Rate
End Date Interest Only Flag (Y/N) Original Balance

 

The vendor will also:

·Inventory the complete current modification in place;
·Identify and report if missing or incomplete and how its incomplete;
·Report the # of modifications in the file including the current modification in place; and
·Confirm the current Interest Rate (on the tape provided) is consistent with the current modification in place.

 

During the course of the review, the vendor will compare information provided by the client in a review data tape to information collected by the vendor. Variances will be identified and verified where possible. In addition, the vendor will also perform a data reconciliation process with the servicer and Client.

 

 

 

Pool Details

 

Purpose    
Type Count % of Pool    
Cash out Refi 57 20.07%    
Purchase 79 27.82%    
Rate / Term Refi 148 52.11%  
Total 284 100.00%  
         
Property Type
Type Count % of Pool
Single Family Detached 158 55.63%
Co-op 0 0.00%
Condo, Low Rise 16 5.63%
Condo, High Rise 2 0.70%
PUD 100 35.21%
1 Family Attached 6 2.11%
2 Family 2 0.70%
3 Family 0 0.00%
4 Family 0 0.00%
Total 284 100.00%

 

 

 

 

           
Occupancy
Type Count % of Pool
Primary Residence 279 98.24%
Second Home 5 1.76%
Investment Property 0 0.00%
Total 284 100.00%
         
Product Type
Type Count % of Pool
Fixed 0 0.00%
ARM 284 100.00%
Total 284 100.00%

 

 

 

Tape Discrepancies

 

Data Element Count Accuracy
Borrower 1 Last Name 2 99.30%
Borrower 1 Self-Employment Flag 13 95.42%
Borrower 2 Self-Employment Flag 4 98.59%
Interest Only Flag 10 96.48%
Interest Rate 1 99.65%
Number of Units 1 99.65%
Primary Appraised Property Value 58 79.58%
Property Address 4 98.59%
Property City 1 99.65%
Property Zip Code 1 99.65%
Qualifying CLTV 194 31.69%
Qualifying FICO 41 85.56%
Qualifying LTV 192 32.39%
Total Loans 284  

 

Multiple Loans to One Borrower: TPR firm reviewed common identifiers for all loans in the population and confirmed there were three (3) obligors with multiple loans in the pool.

 

Property Inspection Waivers: No loans had a Property Inspection Waiver.

 

This is a seasoned loans pool, no valuation waterfall required. Current BPOs were provided, but not considered in the valuation waterfall.

 

 

 

 

 

Payment History Review Summary

 

Opus reviewed the servicer provided payment history for each loan to establish payment activity and develop a payment delinquency string. Opus reviewed each payment transaction and determined how it impacted the contractual due dates on the loans in the portfolio. The focus of the review was to determine monthly cash flows and level of delinquency through creation of a payment string. The as of date for all loans reviewed in the 12 month review period was November 30, 2025

 

Opus compared the servicer supplied delinquency string to the recreated string and identified no discrepancies as noted in the table below. Based upon the analysis, Opus determined that the majority of the loans were found to be performing.

 

Delinquency String Analysis
  Count Percent
Delinquency String without Discrepancy 284 100.00%
Total 284 100.00%

 

Current Delinquency Status
  Count Percent
Current 284 100.00%
30 0 0.00%
Total 284 100.00%

 

Delinquency String

 

Opus utilizes the MBA method of defining delinquency status. Below is a table that represents the delinquency coding methodology used during the analysis.

 

Delinquency
String		 Delinquency Level Range
0 Current
1 30 – 59 Days
2 60 – 89 Days
3 90 – 119 Days
4 120 – 149 Days
5 150 – 179 Days
6 180 – 209 Days
7 210 – 239 Days
8 240 – 269 Days
9 270+ Days

 

 

 

 

 

 

 

 

 

 

 

 

Loan Grading Definitions

 

 

Credit

 

S&P Moody’s Fitch Kroll DBRS Definition
A A A  A  A Loan conforms to all applicable guidelines, no conditions noted
B B B  B  B Loan does not meet every applicable credit guideline.  However, most of the loan characteristics are within the guidelines and there are documented and significant compensating factors
C C C  C  C The loan does not meet every applicable credit guideline, and most of the loan characteristics are outside of guidelines; or there are weak or no compensating factors
D D D  D  D The loan file is missing critical documentation required to perform the review

 

 

Compliance

 

S&P Moody’s Kroll DBRS Definition
A A A A The loan was originated in compliance with applicable federal, state, and local predatory and high cost, TILA, and Regulation Z laws and regulations
B B B B The loan was originated in compliance with applicable federal, state, and local predatory and high cost, TILA, and Regulation Z laws and regulations; however, minor evidentiary issue(s) exist
C C C C The includes material violation(s) with applicable federal, state, and local predatory and high cost, TILA, and Regulation Z laws and regulations
D D D D The loan file is missing critical documentation required to perform the review

 

 

 

Fitch Definition
A The loan was originated in compliance with applicable federal, state, and local predatory and high cost, TILA, and Regulation Z laws and regulations
B The loan is in compliance with all applicable laws and regulations and a benefit to the borrower is present and documented
C The includes material violation(s) with applicable federal, state, and local predatory and high cost, TILA, and Regulation Z laws and regulations
D The loan file is missing critical documentation required to perform the review

 

 

 

Property Valuation

 

Moody’s Fitch Kroll DBRS Definition
A A  A  A Value is within a 10% variance of third party product. Appraisal meets lender guidelines. Subject property is 100% complete. Property condition is average or better. Standard GSE form was utilized. Appraiser is licensed. Appraisal is complete.
B B  B  B Meets all terms for an A, but property requires cosmetic or minor repairs that do not affect value or habitability
C C  C  C Any of the following items: Origination value and third party valuation product value has a variance of 10% or greater, cannot validate value, property is incomplete, property condition is less than average, GSE form was not utilized, and/or the appraisal and/or does not meet guidelines
D D  D  D The loan file was missing the appraisal and/or other valuations products needed to complete the review

 

 

 

S&P Definition
A First Level Review Value is within a 10% variance to the original appraisal. Appraisal meets lender guidelines. Subject property is 100% complete. Property condition is average or better. Standard GSE form was utilized. Appraiser is licensed. Appraisal is complete.
B First Level Review Value is greater than a 10% variance to the original appraisal but the second level review value is within 10% variance of the original appraised value. In addition, property requires cosmetic or minor repairs that do not affect value or habitability
C Any of the following items: Second Level Review Value is greater than a 10% variance to the original appraisal, cannot validate value, property is incomplete, property condition is less than average, GSE form was not utilized, and/or the appraisal and/or does not meet guidelines
D The loan file was missing the appraisal and/or other valuations products needed to complete the review

 

 

 

 

 

 

 

 

 

 

Loan Review Findings

 

The following summarizes Consultant’s initial and final loan securitization and event grades assigned to the final reviewed loan pool and reported in the Agency Grading Report dated April 29, 2026. Grades provided are for the Credit and Compliance Review. There are no grades for the Title, Payment History or Modification Reviews.

  

Overall Grade Summary    
 Kroll and Moody’s NRSRO Grade # of Loans % of Loans
A 150 52.82%
B 124 43.66%
C 10 3.52%
D 0 0.00%
     
Compliance Grade Summary    
 Kroll and Moody’s NRSRO Grade # of Loans % of Loans
A 177 62.32%
B 97 34.15%
C 10 3.52%
D 0 0.00%
     
Credit Grade Summary    
 Kroll and Moody’s NRSRO Grade # of Loans % of Loans
A 212 74.65%
B 72 25.35%
C 0 0.00%
D 0 0.00%
     
Property Grade Summary    
 Kroll and Moody’s NRSRO Grade # of Loans % of Loans
A 284 0.00%
B 0 0.00%
C 0 0.00%
D 0 0.00%

 

 

 

Loans Reviewed (284)

 

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YX6PW86TQ8YA QQPU9AR7UYX6 8UQ95U98Q5W5 AW7QTUWPP8YP 98PYVRAWV55R YA9AXY7WVYRW
R8S69WYUUPYY VYRU8V56XYRS P77QUP5RPVQ9 9YQYX5R7VU6T W5S79QQ96YX8 QUPUUPPSP7UT
YU8X5SVXRU6Y Q8YUXQPP98V9 795P65A6VV87 TSYTPU6X8QXW WA8YUQVX6QVT UQW9XY7XYUX8
ST9YA788YX9V AVT5WX9ST55A P58V5QAWU5PS UTU888AV6RRT P8XVWT9SXQT7 VX67AQ76TY5V
U5RS7PVQWWST 85TQ6VWPWTQX AT766PY7TUSS PRUVRXSX89UY 99UXRPSV9QRQ  
RYYR5556YRW8 X9TSTTTW6XWX 8QPAPX9RA6YX Y7XPW88RWAUA 9AA798YRV8P9  

 

 

 

 

QYAXP7P5868P VA8UUT7QAQTY STQ9YYX7URWU QX99AAPPX8YP 5SXS5R6YAQ8A  
9XRQPSVYWVA5 SUP9YVS76U88 YW5WPRUQ9WWP TWSX768AWP7T XXRU8SPYYAR6  

 

 

 

If you have any questions, please contact Uriah Clavier at Uriah.Clavier@opuscmc.com