J.P. MORGAN ACCEPTANCE CORPORATION II ABS-15G
Exhibit 99.31
EXECUTIVE
SUMMARY
JPMMT 2026-NQM3
Overview
Maxwell Diligence Solutions, LLC (“MaxDiligence”),
a third-party diligence provider, performed certain due diligence services (the “Review”) described below on residential mortgage
loans acquired by JPMorgan Chase Bank, National Association (the “Client”).
The Review was conducted from August 2025 to November 2025 on mortgage
loans (the “Loans”) originated from July 2025 to November 2025.
The Review consisted of a population of 2 loans with an original
loan balance of $249,630.00.
Scope of Review
Credit Review
MaxDiligence 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 included the following (collectively, the
“Credit Review”):
| 1. | Review Initial & Final Application |
| a. | Check application for completeness. Determine whether the
information in the preliminary Loan application, final application, and all credit documents is consistent or reconciled. |
| b. | Validate Social Security/Taxpayer Identification number
is valid |
| c. | Compare data on final form 1003 with the data from verifications |
| d. | Form is complete, signed, dated, on or before loan consummation
date, and NMLS is complete |
| 2. | Review AUS Decision and Approval Conditions |
| a. | Underwriting decision is supported (manual underwrite credit
conditions have been satisfied prior to closing the approved Loan package) |
| b. | Validation of income calculations |
| c. | Validation of assets/funds to close |
| d. | Validation of debt-to-income ratio (“DTI”)
calculations. If applicable |
| e. | Validation of debt service coverage ratio (“DSCR”)
calculations |
| f. | Validation of LTV calculations |
| g. | Validation of payment shock calculations if applicable |
| i. | Review of hazard coverage and verification that sufficient
coverage was in place on subject and all premiums were included in DSCR calculation |
| ii. | Review of rental income and/or market rents and validation
of DSCR calculation, if applicable |
| 3. | Review Occupancy/Red Flags |
| a. | Validates Social Security number and year issued |
| b. | Verifies address information associated with the borrower
(s) |
| d. | Occupancy Red flags adequately addressed |
| 4. | Reverification of Borrower Original and Audit Credit
Report |
| a. | Validate names, social security number(s), and addresses |
| b. | “Doing business as” or “also known as”
names investigated and cleared |
| c. | Validate credit inquiries within 90 days have been properly
addressed |
| d. | Acceptable credit history and credit score requirements
in conformance with applicable guidelines |
| 5. | Reviews Fraud Report to compare vs loan documentation: |
| a. | Validates Social Security number and year issued |
| b. | Verifies address information associated with the Borrower
(s) |
| c. | Confirms OFAC clearances |
| d. | Reveals any potential bankruptcy filings |
| 6. | Review of Borrower Employment,
Income, and Asset Information |
| i. | Compare for conflicting information |
| ii. | Check dates for document expiration |
| iii. | Complete forms and documentation |
| iv. | Evaluate history and stability
of employment |
| i. | Review employment and income
by analyzing income documents and comparing against re-verification documents |
| ii. | W-2s and paystubs, if applicable |
| iii. | Transcripts (as applicable)
support income |
| iv. | Tax returns and profit and
loss statements, as applicable |
| v. | Bank statements or other alternate
income documents as required by the guidelines |
| vi. | Consistent/continuing employment,
if applicable |
| vii. | Lease agreements and market
rents, if applicable |
| i. | Confirm adequate funds to cover
required down payment and closing costs and reserves |
| ii. | Check dates for document expiration |
| iii. | Sufficient funds were sourced
and seasoned |
| iv. | Gift funds verified and met
guidelines |
| b. | Earnest money deposit verified |
| d. | Seller contributions are within guidelines |
| 8. | Hazard and Flood (if applicable) |
| a. | Verify sufficient coverage |
| b. | Verify coverage is for subject |
| c. | Validate all premiums are included in housing payment and
any required upfront premium is paid |
| 9. | Review Title Commitment/Policy |
| d. | Validate no encumbrances |
| 10. | Review Closing Documents |
| a. | Review security documents to ensure the Loan was closed
in accordance with approval and with all required signatures |
| b. | Correct and complete instruments |
| c. | Closing disclosure or Settlement Statements |
| 11. | Qualified Mortgage / Ability-to-Repay
Review |
Loans with application dates after January
10, 2014 and prior to October 1, 2022 are subject to the Qualified Mortgage (“QM”) rule and the Ability to Repay (“ATR”)
rule under Regulation Z of the Truth in Lending Act, as amended. Effective October 1, 2022, Loans with application dates on or after such
date must comply with the General QM Final Rule, as well as the ATR rule. For these Loans, MaxDiligence will (a) confirm that the creditor
provided a QM designation and (b) review the Loan for the eight (8) underwriting factors set forth Section 12(E)
| a. | MaxDiligence reviewed each
mortgage loan to determine each mortgage loan’s status under the QM and ATR rule requirements and assign a QM and ATR designation
as determined by MaxDiligence. MaxDiligence will note as a material exception if its QM and ATR designations do not confirm to the originator’s
original QM and ATR designations. Additionally, MaxDiligence will note if an originator’s mortgage loan designation was not provided.
MaxDiligence shall use the following designations: |
| i. | MaxDiligence utilizes the following
QM designations for applicable Loans: |
| a) | QM Safe-Harbor (also known
as General QM) (also known as General QM) |
| b) | QM Rebuttal Presumption (including
Higher-priced loans) |
| c) | Temporary QM (for all applications
prior to October 1, 2022) |
| ii. | MaxDiligence utilizes the following
ATR designations for applicable Loans: |
| b. | In order to determine the QM
designation, as applicable, MaxDiligence will review each Loan for the following: |
| i. | Use of any risky mortgage loan
features and terms (e.g. an interest only feature or negative amortization); |
| ii. | Do the “points and fees”
exceed the applicable QM threshold; |
| iii. | Was monthly payment calculated
appropriately; |
| iv. | Did the creditor considered
and verify income or assets at or before consummation; |
| v. | Did the creditor appropriately
considered debt obligations, alimony and child support; |
| vi. | For mortgage loan applications
prior to October 1, 2022, if the DTI ratio exceeded 43% (calculated in accordance with Appendix Q to Regulation Z). |
| vii. | For mortgage loan applications
on and after October 1, 2022, for which the annual percentage rate does not exceed the average prime offer rate for a comparable transaction
as of the date the interest rate is set by the amounts specified based on loan amount (adjusted annually on January 1 by the annual percentage
change in the Consumer Price Index for All Urban Consumers (CPI-U) that was reported on the preceding June 1) and the lien position of
the proposed credit: |
| a) | For a first-lien covered transaction
with a loan amount greater than or equal to $110,260 (indexed for inflation), 2.25 or more percentage points; or |
| b) | For a first-lien covered transaction
with a loan amount greater than or equal to $66,156 (indexed for inflation) but less than $110,260 (indexed for inflation), 3.5 or more
percentage points; or |
| c) | For a first-lien covered transaction
with a loan amount less than $66,156 (indexed for inflation), 6.5 or more percentage points; or |
| d) | For a first-lien covered transaction
secured by a manufactured home with a loan amount less than $110,260 (indexed for inflation), 6.5 or more percentage points; or |
| e) | For a subordinate-lien covered
transaction with a loan amount greater than or equal to $66,156 (indexed for inflation), 3.5 or more percentage points; or |
| f) | For a subordinate-lien covered
transaction with a loan amount less than $66,156 (indexed for inflation), 6.5 or more percentage points. |
| c. | Upon completion of Section
12(B) above, if a Loan is determined to be a QM loan, MaxDiligence will determine if the Loan is a Higher-Priced Mortgage Loan (“HPML”)
as defined by 12 CFR 1026.35: |
| i. | If the Loan is HPML, then the
Loan shall be designated as QM Rebuttal Presumption (Higher Priced); |
| ii. | If the Loan is not an HPML,
then the Loan shall be designated as QM Safe Harbor. |
| d. | Upon completion of Section
12(B) above, for each Loan that is designated as Non-QM, MaxDiligence then will determine whether the mortgage loan complies with the
ATR rule, in accordance with the Guidelines. |
| e. | MaxDiligence will evaluate
the Loan for ATR compliance based on the following eight factors and will verify such information using reasonably reliable third-party
records, at or before consummation: |
| i. | Income / Assets: Recalculate
borrower(s)’s monthly gross income, and validate funds required to close and required reserves, to confirm that the borrower has
current or reasonably expected income or assets (other than the value of the property that secures the Loan) that the borrower will rely
on to repay the Loan. Review Loan documentation for required level of income and asset verifications. |
| ii. | Employment: Review file documentation
for required level of employment. |
| iii. | Monthly Mortgage Payment: Confirm
that the correct program, qualifying rate, and terms were used to calculate projected monthly mortgage payment. |
| iv. | Simultaneous Loans: Ensure
that all concurrent Loans were included in the DTI calculation, to properly assess the ability to repay. |
| v. | Mortgage-Related Obligations:
Validate that the subject Loan’s monthly payment calculation includes principle, interest, taxes, and insurance, as well as other
costs related to the property such as homeowners’ association fees, private mortgage insurance, ground rental fees, etc. |
| vi. | Debts / Obligations: Validate
monthly recurring non-mortgage-related liabilities. |
| vii. | DTI / Residual Income - Validate
DTI or “residual income,” based upon all mortgage and non-mortgage obligations, calculated as a ratio of gross monthly income,
based on documentation provided in the file. |
| viii. | Credit History: Review credit
report for credit history and required credit depth, including any / all inquiries, and determine a representative credit score from the
credit report. |
| f. | Upon completion of Section
12(E) above, MaxDiligence will assign an ATR designation. |
Property Review
MaxDiligence performed a “Property Review,”
which included the following:
| a. | MaxDiligence’s review included a review of the valuation
materials utilized during the origination of the applicable loan and in confirming the value of the underlying property. MaxDiligence’s
review will include verifying the appraisal report: |
| b. | On the appropriate appraisal form: |
| i. | All elements of appraisal are present |
| ii. | Ensure all applicable Loan documents match appraisal information |
| iii. | Property is acceptable collateral for Loan program |
| iv. | Completed by an appraiser that was actively licensed to
perform the valuation |
| v. | Completed such that the named client on the appraisal report
is the lender or a related entity that is permitted to engage the lender per Title XI of FIRREA, or if the appraisal was performed for
another lender, the file contains a transfer letter from the original lender |
| vi. | The original appraisal report is made and signed prior
to the final approval of the mortgage loan application; Any revisions, if made known to MaxDiligence, to the original report are documented
and dated completed and dated within the guideline’s restrictions, |
| vii. | The original appraisal is ‘As is' or Inspection received
including all inspections, licenses, and certificates (including certificates of occupancy) to be made or issued with respect to all occupied
portions of the mortgaged property and with respect to the use and occupancy of the same, have been made or obtained from the appropriate
authorities. |
| viii. | Determine whether the appraised value is supported at or
within 10% variance based on a third-party valuation product. If a third-party valuation product is in file but notes a variance above
10% or an inconclusive value, MaxDiligence recommended a BPO or field review be ordered. |
| ix. | With regard to the use of comparable properties, MaxDiligence’s
review will (a) reviewed the relative comparable data (gross and net adjustments, sale dates and distance from subject property) and ensure
that such comparable properties are within standard appraisal guidelines; (b) confirmed the property value and square footage of the subject
property was bracketed by comparable properties, (c) verified that comparable properties used are similar in size, style, and location
to the subject, and (d) checked for the reasonableness of adjustments when reconciling value between the subject property and comparable
properties. |
| x. | Other aspects of MaxDiligence’s review included (i)
verifying that the address matched the mortgage note, ((ii) if requested, noting whether the property zip code was declared a FEMA disaster
area after the valuation date and notifying the Client of same, (iii) confirming the appraisal report does not include any apparent environmental
problems, (iv) confirming the appraisal notes the current use of the property is legal or legal non-conforming (grandfathered), (v) reviewing
pictures to ensure (a) that the property is in average or better condition and any repairs are noted where required and (b) that the subject
property is the one for which the valuation was ordered and that there are no negative external factors; and (vi) confirming that the
value product that was used as part of the origination decision conforms with rating agency requirements. |
| c. | If more than one valuation was provided, MaxDiligence will
confirm consistency among the valuation products and if there are discrepancies that could not be resolved, MaxDiligence created an exception,
and work with the client on the next steps which may include ordering of additional valuation products such as collateral desktop reviews,
broker’s price opinions, and full appraisals, if needed. If the property valuation products included in MaxDiligence’s review
result in a variance of more than 10% then the client was notified of such variance. |
| d. | MaxDiligence confirmed to the extent possible, that the
appraiser and the appraisal made by such appraiser both satisfied the requirements of Title XI of FIRREA. Specifically, MaxDiligence will
review the appraisal for conformity to industry standards, including ensuring the appraisal was complete, that the comparable properties
and adjustments were reasonable and that pictures were provided and were accurate. |
| e. | In addition, MaxDiligence accessed the ASC database to
verify that the appraiser, and if applicable the appraiser’s supervisor, were licensed and in good standing at the time the appraisal
was completed. |
Compliance Review
“Compliance Review” means
that MaxDiligence reviewed each Loan to determine, as applicable and subject to the limitations below, whether the Loan complied with
the applicable Federal, State, and local regulatory requirements, each as amended. A Compliance Review shall not apply to business purpose
loans.
The below Compliance Review is applicable
to Loans with an application date on or after October 3, 2015, which are subject to the TILA/RESPA Integrated Disclosure Rule (“TRID”).
With regard to TRID testing, MaxDiligence implemented the TRID scope of review as detailed in (i) Section III -Regulatory Compliance of
the SFA RMBS TRID Grid 4.0 Compliance Review Scope published by the Structured Finance Association (formerly SFIG) (the "SFA RMBS
Compliance Review Scope") and (ii) outside counsel’s interpretations of the published regulations as of the date of review
of each mortgage loan. On an ongoing basis, MaxDiligence reviews updated interpretations of TRID through informal guidance provided by
the Consumer Financial Protection Bureau (“CFPB”), such CFPB guidance may cause changes in the review scope and severity of
TRID related exceptions, including applicable cures. While MaxDiligence continues to make a good faith effort to identify material TRID
exceptions and apply the appropriate grading, the implementation of new regulations (including TRID) that impact residential mortgages
carries certain interpretive risk and continues to evolve, impacting the review scope and exception severity.
| a. | Reviewed the initial LE and
confirmed (i) the correct form was used; (ii) all sections of the Initial LE are completed; and (iii) the initial LE accurately reflects
the information provided to MaxDiligence. |
| b. | If there is a revised LE, confirmed
(i) that there is a “valid reason” for the revised LE; and (ii) that the revised LE was issued within three (3) days of the
change. |
| c. | Determined which LE in the
file is the “final binding” LE for the purpose of Tolerance Testing. A revised LE that is issued after the CD, or that does
not state a valid reason will not be used for the purposes of Tolerance Testing. All revised LEs issued to the consumer will be reviewed
for accuracy of terms. |
| d. | Confirmed initial LE was delivered
within three (3) business days from the application date, and at least seven (7) business days prior to the consummation date. |
| e. | Confirmed revised LE was delivered
within three (3) business days from date of the “valid reason” giving rise to the Revised LE, and at least four (4) business
days prior to the consummation date. |
| f. | Confirmed that certain sections
of each LE determined to carry assignee liability were accurately completed and that information was reflected in the appropriate locations |
| 2. | Closing Disclosures (“CDs”) |
| a. | Reviewed the CD and confirmed
(i) the correct form was used; (ii) all sections of the CD are completed; and (iii) the CD accurately reflected the information provided
to MaxDiligence. |
| b. | If a subsequent CD is issued,
confirmed (i) that there was a valid reason for the change; (ii) that the CD was issued within three (3) days of the change; and (iii)
whether the reason for the change requires a new 3-day waiting period prior to the consummation date. |
| c. | Confirmed initial CD, and any
subsequent CD with material changes (i.e. changes that require a new waiting period), was received at least three (3) business days prior
to the consummation date. With respect to applicable exception remediation measures for numerical exceptions, confirm that a letter of
explanation, as well as a refund as applicable, was delivered or placed in the mail no later than sixty (60) days after discovery of the
exception establishing the need for a revised CD or with respect to exception remediation measures for non-numerical exceptions, that
a corrected CD was delivered or placed in the mail no later than sixty (60) days after consummation. |
| 3. | Federal Truth in Lending
Act (“TILA”), as implemented by Regulation Z, 12 C.F.R. Part 1026, as set forth below: |
Rescission
| a. | Failure to provide the right
of rescission notice; |
| b. | failure to provide the right
of rescission notice in a timely manner and to the correct consumer(s); |
| c. | errors in the right of rescission
notice; |
| d. | failure to provide the correct
form of right of rescission notice; |
| e. | failure to provide the three
(3) business days rescission period; and |
| f. | any material disclosure violation
on a rescindable loan that gives rise to the right of rescission under TILA, which means the required disclosures of the annual percentage
rate, the finance charge, the amount financed, the total of payments, the payment schedule, the HOEPA disclosures; |
| 4. | Tolerance Testing. Compared
the fees disclosed in the final binding LE to those in the final CD, and confirmed that final CD fees are within the permitted tolerances.
Confirmed the total of payments are considered accurate as defined by Regulation Z. Confirmed finance charge tolerances are correct. |
| 5. | Subsequent Changes.
Reviewed the file to determine (i) whether there is evidence that certain changes or errors (per the regulation) were discovered subsequent
to closing, (ii) and whether the Loan originator followed the prescribed cure. Test for evidence such as a copy of the refund check, or
a corrected, post-consummation CD (“PCCD”), and (iii) with respect to applicable exception remediation measures for
numerical exceptions, confirm that a letter of explanation, as well as a refund as applicable, was delivered or placed in the mail no
later than sixty (60) days after discovery of the exception establishing the need for a revised CD or with respect to exception remediation
measures for non-numerical exceptions, that a corrected CD was delivered or placed in the mail no later than sixty (60) days after consummation.
|
| 6. | Loan Toolkit (§1026.19): |
| a. | Confirmed the presence of Your
Home Loan Toolkit in the mortgage loan file or that the mortgage loan file contains documentary evidence that the disclosure was provided
to the borrower; and |
| b. | Confirmed Your Home Loan Toolkit
was delivered or placed in the mail not later than three (3) business days after receipt of application. |
| a. | High-cost Mortgage (§§1026.31,
32 and 33): |
| i. | Points and fees threshold test;
|
| iii. | Prepayment penalty test; and |
| iv. | Compliance with the disclosure
requirements, limitation on terms and prohibited acts or practices in connection with a high-cost mortgage. |
| b. | Higher-priced Mortgage Loan
(§1026.35): |
| i. | APR threshold test; and |
| ii. | Compliance with the escrow
account and appraisal requirements. |
| c. | With respect to brokered mortgage
loans, the Prohibitions and Restrictions related to Loan Originator Compensation and Steering (§1026.36): |
| i. | Reviewed relevant documentation
to determine if compensation to a Loan Originator was based on a term of the transaction; |
| ii. | Reviewed relevant document
to determine if there was dual compensation; and |
| iii. | Reviewed the presence of the
mortgage loan option disclosure and to determine if the Steering Safe Harbor provisions were satisfied. |
| · | Note: Where available, MaxDiligence
reviewed the relevant documents in the mortgage loan file and, as necessary, attempted to obtain the mortgage loan originator compensation
agreement and/or governing policies and procedures of the mortgage loan originator. In the absence of the mortgage loan originator compensation
agreement and/or governing policies and procedures, MaxDiligence’s review was limited to formal general statements of entity compliance
provided by the mortgage loan originator, if any. These statements, for example, were in the form of a letter signed by the seller correspondent/mortgage
loan originator or representations in the mortgage loan purchase agreement between the Client and seller correspondent; |
| d. | Homeownership counseling
(§1026.36): |
| i. | Determined if the creditor
obtained proof of homeownership counseling in connection with a mortgage loan to a first-time homebuyer that contains a negative amortization
feature. |
| e. | Mandatory Arbitration Clauses
(§1026.36): |
| i. | Determined if the terms of
the mortgage loan require arbitration or any other non-judicial procedure to resolve any controversy or settle any claims arising out
of the transaction. |
| f. | Prohibition on Financing
Credit Insurance (§1026.36): |
| i. | Determined if the creditor
financed, directly or indirectly, any premiums or fees for credit insurance in jurisdictions where it is prohibited. |
| g. | Nationwide Mortgage Licensing
System (NMLS) & Registry ID on Loan Documents (§1026.36): |
| i. | Reviewed for presence of mortgage
loan originator organization and individual mortgage loan originator name and NMLSR ID, as applicable, on the credit application, note
or mortgage loan contract, security instrument, Loan Estimate and Closing Disclosure; and |
| ii. | Verified the data against the
NMLSR database, as available. |
| a. | Additional RESPA/Regulation
X Disclosures and Requirements (§1024.6, 15, 17, 20, and 33): |
| i. | Confirmed the presence of the
Servicing Disclosure Statement form in the mortgage loan file; |
| ii. | Verified the Servicing Disclosure
Statement was provided to the borrower(s) within three (3) business days of application; |
| iii. | Confirmed the presence of the
Your Home Loan Toolkit/Special Information Booklet in the mortgage loan file or that the mortgage loan file contains documentary evidence
that the disclosure was provided to the borrower; |
| iv. | Confirmed the Your Home Loan
Toolkit /Special Information Booklet was provided within three (3) business days of application; |
| v. | Confirmed the presence of the
CHARM booklet when applicable; |
| vi. | Confirmed that the CHARM booklet
was issued within three (3) business days of application; |
| vii. | Confirmed the presence of the
Affiliated Business Arrangement Disclosure in the mortgage loan file in the event the lender has affiliated business arrangements; |
| viii. | Confirmed the Affiliated Business
Arrangement Disclosure was provided no later than three (3) business days of application; |
| ix. | Confirmed the Affiliated Business
Arrangement Disclosure is executed; |
| x. | Confirmed the presence of the
Initial Escrow Disclosure Statement in the mortgage loan file and proper timing; |
| xi. | Confirmed that the creditor
provided the borrower a list of homeownership counselling organizations within three (3) business days of application; and |
| xii. | Confirmed that the list of
homeownership counselling organizations was obtained no earlier than 30 days prior to when the list was provided to the mortgage loan
applicant. |
| 9. | ECOA: The Equal Credit
Opportunity Act, as implemented by Regulation B, 12 C.F.R. Part 1002, as set forth below: |
| a. | Providing Appraisals and
Other Valuations (12 C.F.R. 1002.14): |
| i. | Timing and content of the right
to receive copy of appraisal disclosure; |
| ii. | Charging of a fee for a copy
of the appraisal or other written valuation; |
| iii. | Timing of creditor providing
a copy of each appraisal or other written valuation; and |
| b. | iv)
With respect to a borrower that has waived the three (3) Business Day disclosure requirement, confirm that (a) the borrower has signed
the waiver or other acknowledgment at least three (3) business days prior to consummation; and (b) that the lender has provided copies
of appraisals and other written valuations at or prior to consummation. |
| i. | The disclosure requirements
and prohibitions of Section 50(a)(6), Article XVI of the Texas Constitution and associated regulations; |
| b. | Fed/State/Local Predatory Lending: |
| i. | The disclosure requirements
and prohibitions of state, county and municipal laws and ordinances with respect to “high-cost” mortgage loans, “covered”
mortgage loans, “higher-priced” mortgage loans, “home” mortgage loans or any other similarly designated mortgage
loan as defined under such authorities, or subject to any other laws that were enacted to combat predatory lending, as may have been amended
from time to time; |
| c. | Prepay Penalties and Late Fees: |
| i. | Federal and state specific
late charge and prepayment penalty provisions. |
| 11. | Exclusions. MaxDiligence
did not test: |
| a. | Loan types that are excluded from compliance with TRID. |
| b. | Technical formatting of disclosures.
|
| c. | Other Post-consummation disclosures,
including Escrow Closing Notice; and Mortgage servicing transfer and partial payment notices. |
| d. | For Loans made by an FDIC-supervised
institution or servicer, extended or renewed on or after January 1, 2016, whether prohibited fees were collected prior to the initial
LE being issued |
| e. | Whether any fee is a “bona
fide” fee for third-party services |
| f. | Whether the loans comply with
all federal, state or local laws, constitutional provisions, regulations or ordinances that are not expressly enumerated above. |
Summary of Results
OVERALL RESULTS SUMMARY
The Guidelines listed below were used as a benchmark with respect to credit
and property reviews for grading purposes. The loans were assigned an initial grade after the initial review. The final grade was determined
after additional documentations were provided to satisfy outstanding conditions. When Guideline exceptions were provided, reviewers reviewed
to ensure compensating factors were also provided and documented.
| - | AD Mortgage Jumbo Blue Underwriting Guidelines |
| - | Better Mortgage JP Morgan CIB Residential Purchase Criteria |
| - | FIMC Debt Service Coverage Ratio (DSCR) Non-QM Final |
| - | Northpointe Bank – Section 600 – Expanded Portfolio |
| - | UWM Prime Jumbo Overlays |
After giving consideration to the grading criteria
of the relevant NRSROs, 100% of the loans received an Overall “A” grade.
Final Loan Grades
| Rating
Agency Final Overall Grade Summary |
| |
| Overall |
# of Mortgage Loans |
% of Mortgage Loans |
| A |
2 |
100.0% |
| B |
0 |
0.0% |
| C |
0 |
0.0% |
| D |
0 |
0.0% |
| Total |
2 |
100.0% |
| |
| Final Credit Grade Summary |
| Credit |
# of Mortgage Loans |
% of Mortgage Loans |
| A |
2 |
100.00% |
| B |
0 |
0.00% |
| C |
0 |
0.00% |
| D |
0 |
0.00% |
| Total |
2 |
100.00% |
| |
| Final Property Grade Summary |
| Property |
# of Mortgage Loans |
% of Mortgage Loans |
| A |
2 |
100.00% |
| B |
0 |
0.00% |
| C |
0 |
0.00% |
| D |
0 |
0.00% |
| Total |
2 |
100.00% |
| |
|
|
|
|
|
|
|
|
| Final Compliance Grade Summary[i] |
| Compliance |
# of Mortgage Loans |
% of Mortgage Loans |
| A |
2 |
100.00% |
| B |
0 |
0.00% |
| C |
0 |
0.00% |
| D |
0 |
0.00% |
| Total |
2 |
100.00% |
| |
|
|
|
|
|
|
|
|
[i]
Business Purpose Loans/Investment Properties for which a compliance
review was not completed were given an “A” grade
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 (i.e., a loan with a Credit Grade of “A”, Compliance
Grade of “B”, and a Valuation Grade of “A” would receive an overall Loan Grade of “B”).
| Exception Type |
Exception Level Grade |
Exception Category |
Total |
| Credit |
A |
Hazard Insurance Coverage is less than all Subject Lien(s) |
1 |
| Missing Flood Insurance Policy |
1 |
| |
|
Total Credit Grade (A) Exceptions |
2 |
| Property |
A |
Value - Value is supported within -10% of original appraisal amount |
2 |
| |
|
Total Property Grade (A) Exceptions |
2 |
| Compliance |
A |
No Compliance Tests Performed |
2 |
| The Deed of Trust is Incomplete |
1 |
| |
|
Total Compliance Grade (A) Exceptions |
3 |
TAPE INTEGRITY REVIEW RESULTS SUMMARY
As part of the Credit and Property Reviews, MaxDiligence captured data
from the source documents and compared it to a data tape provided by Client. MaxDiligence provided Client a Data Discrepancy Report which
shows the differences between the tape data and the data captured by MaxDiligence during the diligence process.
Of the 2 Loans reviewed, 1 unique Loan (by loan count)
had a total of 1 different tape discrepancies across 1 data fields (some Loans may have had more than one). A blank or zero value on the
data tape when an actual value was captured by MaxDiligence was not treated as a data variance.
| Field Label |
Loans With Discrepancy |
Total Times Compared |
% Variance (by possible exceptions) |
| Loan Type |
1 |
2 |
50% |
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 rental 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 (desk reviews, 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, or other eligible forms based on lender/investor requirements. |
| 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, or other eligible forms based on lender/investor requirements. |
| D |
The file was missing the appraisal or there was not sufficient valuation documentation to perform a review. |