EXECUTIVE SUMMARY
THIRD PARTY DUE DILIGENCE REVIEW
 
Overview
 
Consolidated Analytics, Inc (“Consolidated Analytics”), a third-party due diligence provider, performed the review described below on newly originated residential mortgage loans purchased by Redwood Residential Acquisition Corporation. The review included a total of 632 newly originated residential mortgage loans, in connection with the securitization identified as SEMT 2026-INV3 (the “Securitization”). The Review was conducted from December 2025 through April 2026 on mortgage loans originated between September 2025 and March 2026.
 
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:
 

 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.

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 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
 
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 guideline 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 (632 loans in total):
 
One (1) loan had a Secondary Appraisal, one hundred seventy-one (171) loans had an AVM, and sixty-nine (69) loans had a Desktop Review.
 
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.  There were twenty-nine (29) occurrences of this.
 
Ten (10) loans had a Field Review or BPO, zero (0) loans had a Second Desk Review, and zero (0) loans had a Full Appraisal Review.
 
Product totals may not sum due to multiple products for each loan
 
TAPE INTEGRITY REVIEW RESULTS SUMMARY
 
Of the six hundred thirty-two (632) mortgage loans reviewed, ten (10) unique mortgage loans (1.58% by loan count) had a total of ten (10) discrepancies across five (5) 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
Property Attachment Type
4
40.00%
Property Type
3
30.00%
Loan Amount
1
10.00%
Subject Property Type
1
10.00%
Refinance Purpose
1
10.00%
Grand Total
10
100.00%

 

 
 
Summary of Results
 
OVERALL RESULTS SUMMARY
 
Final Loan Grades
 
Overall Loan Results:
  
Event Grade
Loan Count
Original Principal Balance
Percent of Sample
Event Grade A
515
$188,341,306.40
81.49%
Event Grade B
117
$42,099,945.00
18.51%
Event Grade C
0
$0.00
0%
Event Grade D
0
$0.00
0%
Total Sample
632
$230,441,251.40
100.00%

 
Credit Results:
Event Grade
Loan Count
Percent of Sample
Event Grade A
618
97.78%
Event Grade B
14
2.22%
Event Grade C
0
0%
Event Grade D
0
0%
Total Sample
632
100.00%

 
Compliance Results:
Event Grade
Loan Count
Percent of Sample
Event Grade A
588
93.04%
Event Grade B
44
6.96%
Event Grade C
0
0%
Event Grade D
0
0%
Total Sample
632
100.00%

 
Valuation Results:
Event Grade
Loan Count
Percent of Sample
Event Grade A
564
89.24%
Event Grade B
68
10.76%
Event Grade C
0
0%
Event Grade D
0
0%
Total Sample
632
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
492
Missing verification of taxes, insurance, and/or HOA fees for non-subject property
31
HO6 Master Insurance Policy is Missing
19
Audited DTI Exceeds AUS DTI
8
Borrower 1 3rd Party VOE Prior to Close Missing
8
Rent Loss Insurance Missing
7
Borrower 1 Photo Identification not provided
6
Missing VOM or VOR
5
Missing Verification of Subject Property Taxes, Insurance, HOA or Other Payments
4
Missing Verification of Mortgage
4
Title Document Missing
4
Verification of Borrower Liabilities Missing or Incomplete
4
Hazard Insurance Policy is Missing
3
Borrower 2 3rd Party VOE Prior to Close Missing
3
Income and Employment Do Not Meet Guidelines
3
Borrower 1 W2/1099 Missing
3
The Initial 1003 is Missing
3
Asset Qualification Does Not Meet Guideline Requirements
2
Audited Reserves are less than AUS Required Reserves (Dollar Amount)
2
Borrower 2 Photo Identification not provided
2
HO-6 Insurance Policy is Missing
2
Borrower 2 W2/1099 Missing
2
Title Document is Partially Present
2
Borrower 1 IRS Transcripts Missing
1
The Total Hazard Coverage is LESS than the Required Coverage Amount
1
The Deed of Trust is Incomplete
1
Audited AUS Interested Party Contribution Exceeds Guideline Program Maximum
1
Hazard Insurance Policy is Partial
1
Verification of Rent (VOR)/Verification of Mortgage (VOM) Document is incomplete
1
Borrower 1 Paystubs Missing
1
Income 4 Months Income Verified is Missing
1
Borrower Non-US Citizen Identification Document Missing
1
Income 5 Months Income Verified is Missing
1
Audited DTI Exceeds Guideline DTI
1
Flood Insurance Expiration Date is before the Disbursement Date
1
Asset 3 Missing
1
Title Coverage is Less than Subject Lien
1
Property Title Issue
1
Borrower 2 Paystubs Missing
1

   
SCIF Document Missing
1
Missing final HUD-1 from sale of non-subject property
1
The Final 1003 is Incomplete
1
Missing income documentation
1
The Note is Incomplete
1
Missing Letter of Explanation (Credit)
1
ATR: Reasonable Income or Assets Not Considered
1
Approval/Underwriting Summary Partially Provided
1
Income/Employment General
1
Missing Credit Report Supplement
1
Housing History Does Not Meet Guideline Requirements
1
Approval/Underwriting Summary Not Provided
1
Income 3 Months Income Verified is Missing
1
Total Credit Grade (A) Exceptions:
648
B
Title Coverage is Less than Subject Lien
7
Borrower 1 Paystubs Missing
2
Borrower 1 IRS Transcripts Missing
2
Borrower 2 IRS Transcripts Missing
2
Borrower information on 1003 is incomplete
1
Income documentation does not meet guidelines
1
Housing History Does Not Meet Guideline Requirements
1
Audited DTI Exceeds AUS DTI
1
Borrower 1 W2/1099 Missing
1
Borrower 2 W2/1099 Missing
1
Borrower 2 Paystubs Missing
1
Total Credit Grade (B) Exceptions:
20
Compliance
A
No Compliance Findings
429
Revised Loan Estimate Delivery Date Test (prior to consummation)
21
Charges That Cannot Increase Test
17
Qualified Mortgage Safe Harbor Threshold
10
Initial Closing Disclosure Delivery Date Test
5
Qualified Mortgage Lending Policy Points and Fees Test
4
Missing Required Affiliated Business Disclosure
4
Final CD: Loan Disclosures Assumption incomplete or inaccurate
3
NJ First Lien Prohibited Fees Test
3
Lender Credits That Cannot Decrease Test
2
Charges That In Total Cannot Increase More Than 10% Test
2
TILA Finance Charge Test
2
TILA Post-Consummation Revised Closing Disclosure Finance Charge Test
2
Evidence of Appraisal Delivery to Borrower not Provided or Late (12 CFR  1002.14(a)(1))
2
Post-Consummation Cure Reimbursement and Revised Closing Disclosure Delivery Date Test
2

   
TRID "Section B. Services You Cannot Shop For / Services Borrower Did Not Shop For" Validation Test
1
Final CD: Contact Information (page 5) is incomplete
1
Federal Undiscounted Rate Validation Test
1
Regulation § 1026.43(c)(2)(vi) failure - The consumer's current debt obligations, alimony, and child support or other debt obligations were not confirmed and included in the DTI or excluded per lender guidelines.
1
Escrow Waiver is Missing
1
NC Rate Spread Home Loan Test
1
Total Compliance Grade (A) Exceptions:
514
B
Evidence of Appraisal Delivery to Borrower not Provided or Late (12 CFR  1002.14(a)(1))
18
Lender Credits That Cannot Decrease Test
9
Charges That Cannot Increase Test
7
Charges That In Total Cannot Increase More Than 10% Test
5
Qualified Mortgage Safe Harbor Threshold
2
RESPA Homeownership Counseling Organizations Disclosure Date Test
1
Qualified Mortgage Lending Policy Points and Fees Test
1
eSigned Documents Consent is Missing
1
Intent to Proceed is Missing
1
Homeownership Counseling Disclosure Is Missing
1
Total Compliance Grade (B) Exceptions:
46
Property
A
No Property Findings
429
Third Party Valuation Product Not Provided within 10% Tolerance
186
Property/Appraisal General
6
Condo Approval Missing
2
Appraisal is Missing
1
Property Issue(s) are Present
1
Subject property appraisal is not on an as-is basis (Primary Value)
1
FEMA Declared Disaster Dated Prior to the Note Date, After Appraisal Date
1
Appraisal incomplete (missing map, layout, pages, etc.)
1
FEMA Post Disaster Inspection Report not Provided
1
Total Property Grade (A) Exceptions:
629
B
Property Inspection Waiver Used at Origination
67
Condo Approval Missing
1
Total Property Grade (B) Exceptions:
68


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.