J.P. MORGAN ACCEPTANCE CORPORATION II ABS-15G
Exhibit 99.36

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Opus Capital Markets
Consultants, LLC
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| 5718 Westheimer Road – Suite 1000 | Houston, TX 77057 | www.opuscmc.com | 224.632.1300 |
| Narrative JPMMT 2026-NQM3 |
Executive Narrative
May 4, 2026
Performed by
Opus Capital Markets Consultants, LLC
For
JPMorgan
The report summarizes the results of a due diligence review performed on
a pool of three hundred twenty-eight (328) loans, of which were purchased by JPMorgan Chase Bank, National Association, as successor by
merger to J.P. Morgan Mortgage Acquisition Corp. (“Customer”) from an originator (the “Originator”) who is a client
of Opus Capital Markets Consultants, LLC (“Consultant”) under a reliance letter, and for which the Originator provided Consultant
with a data tape, from which, in each case, 100% of the loan population 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 three hundred twenty-eight (328)
credit and compliance loans identified as sixteen (16) QM: Safe Harbor APOR (APOR SH) loans, eleven (11) Non-QM: Lender documented all
ATR UW Factors loans, six (6) ATR/QM: CDFI Lender Exempt, and two hundred ninety-five (295) ATR/QM: Exempt loans, of which two hundred
ninety-two (292) are DSCR loans and three (3) are Business Purpose loans. There are six (6) loans eligible for GSE delivery, each were
underwritten to the AUS provided in the loan file and were re-underwritten in accordance with the lender guidelines. The remaining three
hundred twenty-two (322) loans were re-underwritten in accordance with the lender guidelines described herein.
Credit Review
Credit Qualification
A re-underwriting review was conducted in order to verify that the requisite
underwriting guidelines as specified by Client are met. Confirmation of the loan terms was 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. |
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| 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
Document Review
A review of each loan file was 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.
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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. |
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| · | 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 applicable 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. |
1 These
“material” disclosures include, but are not limited to, 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).
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| 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 was 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; |
| 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; and |
| 14. | Documentation. Review of the following documents for regulatory
compliance: |
| a. | Final HUD-1 Settlement Statement (“HUD-1”),
if applicable |
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| i. | If the loan is in an escrow state, the HUD-1 was considered
final as follows: |
| 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 was 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 was 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
|
| 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 was 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. |
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| 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 amortizing 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 |
| 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
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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.
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): |
| o | Confirm the presence of the Servicing Transfer Disclosure form in file |
| o | Verify 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): |
| o | Confirm the presence of the Home Loan Tool Kit is in file for covered loans. |
| o | Confirm the Home Loan Tool Kit is provided within three general business
days of application |
| · | Affiliated Business Disclosure |
| o | Confirm the presence of the Affiliated Business Disclosure in file in the
event the lender has affiliated business arrangements |
| o | Confirm the Affiliated Business Disclosure provided within three general
business days of “Application” (Consultant reviews for this disclosure to be provided within three general business days,
as the lender will typically know at the time of application if borrower(s) was referred to affiliates for provision of third party services) |
| o | Confirm the Affiliated Business Disclosure is executed. |
| · | Initial Escrow Disclosure Statement |
| o | Confirm the presence of the Initial Escrow Disclosure Statement in file |
| o | Confirm 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
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. |
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| · | 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. |
| · | 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). |
| Narrative JPMMT 2026-NQM3 |
| · | 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 Service 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
|
| · | 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
|
| · | 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. |
| Narrative JPMMT 2026-NQM3 |
| · | Virginia Senate Bill 797 (2008), effective July 1, 2008 (uncodified). |
| · | 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. |
Flood Insurance Testing
National Flood Insurance Program (NFIP)
Each mortgage loan was 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 |
| 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. |
Misrepresentation
and Third-Party Review
Validate that fraud reports and independent third-party property valuations
reports are in the file. The review will consist of the following:
1) Misrepresentation Review and Valuation Review
Review on each loan to identify potential misrepresentations of income,
employment, identity, occupancy, transaction and appraisal misrepresentation or other areas of potential misrepresentation. The Misrepresentation
may include the following:
| · | Signatures: Validate signature consistency across documents. To the extent
imaged or hard copy files are provided, Consultant will utilize reasonable efforts to validate the consistency of signatures across documents. |
| · | Alerts: Assess credit report alerts for accuracy and potential issues. |
| · | Social Security Numbers: Compare SSN(s) across all file documents. |
| · | Document Integrity: Review for apparent alterations to loan documents. To
the extent imaged or hard copy files are provided, Consultant will utilize reasonable review of alterations to the loan documents. |
| · | Data Consistency: Review the documents contained in the loan file for consistency
of data. |
| · | Third Party Fraud Tools: To the extent a third party fraud tool is contained
in the loan file, the Consultant will ensure high level or critical warnings are reviewed and addressed.
|
| Narrative JPMMT 2026-NQM3 |
Independent Third-Party Values
Review each loan to determine whether a third party valuation product
was required and if required, that the third party product value was compared to the original appraised value to identify a value variance
and apply the appropriate rating agency grade after reviewing the required valuation products. i) Consultant will perform the following
steps.
| · | Value is based on as-is condition or provides satisfactory completion of
all material conditions including inspections, licenses, and certifications (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 |
| · | Property is described as average or better condition |
| · | No apparent appraiser independence violation statements |
| · | Appraisal addresses any adverse comments |
| · | Appraisal is completed on appropriate GSE Forms |
| · | Appraisal contains required attachments |
| · | Appraiser was appropriately licensed at the time the appraisal was signed |
Valuation Waterfall and Products
Agency Eligible Loan Programs
| 2. | If AVM <90% of origination value: BPO |
| 3. | If BPO <90% of origination value: Stip for Seller to order Field Review/2055 or Appraisal. |
| · | If FHLMC Rep &Warrant Relief NOT Eligible for FNMA CU >2.5 |
| 1. | All: Desk Review (w/value conclusion) |
| 2. | If Desk Review < 90% of origination value: Stip for Seller to order a Filed Review/2055 of second appraisal. |
Jumbo Loan Programs
| · | If only 1 appraisal and no desk review: Stip for Seller to order a Desk
Review (w/value conclusion) |
| · | If guidelines required 2 appraisals, but only 1 appraisal provided; Stip
for Seller to order second appraisal |
| · | If desk review indicated a value lower than the appraisal; Stip for Seller
to order BPO and value reconciliation. |
Seasoned Loan Updated
| a) | Updated AVM: An Automated Valuation Model (“AVM”) was ordered on each property. If the resulting value of the AVM
is in aggregate less than 90% of the value reflected on the original appraisal, or if no results are returned, an Appraisal Desk Review
was ordered on the property. |
| b) | Appraisal Desk Review: If the resulting value for the PVO is less than 90% of the value reflected on the original appraisal,
or if no results are returned, a Broker Price Opinion (BPO) was ordered on the property. |
| c) | BPO: If the resulting value of the BPO is less than 90%of the value reflected on the original appraisal, an appraisal field
review may be ordered on the property |
The criteria set forth in this section titled “Valuation
Waterfall and Products”: are subject to change by RMC at any time.
Value Review Disclaimer
| · | The individuals performing the above procedures are not person providing
valuations for the purpose of the Uniform Standards of Professional Appraisal Practice (“USPAP”) or necessarily licensed as
appraiser under Federal or State law, and the services being performed do not constitute appraisal reviews for the purposes of USPAP or
Federal or State law. |
| · | Opus makes no representation or warranty as to the value of the mortgaged
property, notwithstanding that Opus may have reviewed the valuation information for reasonableness. |
| · | Opus is not an Appraisal Management Company (“AMC”) and therefore
does not opine on the actual value of the underlying property. |
| · | Opus is not a creditor within the meaning of the Equal Credit Opportunity
Act (“ECOA”) or other lending laws and regulations, and therefore Opus will not have and communications with or responsibility
to any individual concerning property valuations. |
Properties in FEMA declared disaster zones.
If a FEMA declared disaster occurs after the inspection date on the appraisal
in a property located in an area that is designated as IA (Individual Assistance) or IH (Individual and Household Assistance), Consultant
will review the file to determine if an exterior inspection to ensure:
| · | No apparent damage to the property |
| · | Property appears to be occupied |
| Narrative JPMMT 2026-NQM3 |
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
| · | Second Mortgage Lien Amount |
Rating
Agency Grading Criteria
Fitch Ratings Grading Criteria
Grading shall be provided for each exception, each exception category
and holistically for each loan. The methodology for the application of the RMBS grading as defined by Fitch in their current industry
publications as updated from time to time.
Moody’s Investor Services Grading Criteria
Grading shall be provided for each exception, each exception category
and holistically for each loan. The methodology for the application of the RMBS grading as defined by Moody’s in their current industry
publications as updated from time to time.
Kroll Bond Rating Agency LLC Grading Criteria
Grading shall be provided for each exception, each exception category
and holistically for each loan. The methodology for the application of the RMBS grading as defined by Kroll in their current industry
publications as updated from time to time.
S&P Global Ratings Grading Criteria
Grading shall be provided for each exception, each exception category
and holistically for each loan. The methodology for the application of the RMBS grading as defined by Standard & Poor’s in their
current industry publications and updated from time to time.
DBRS Morningstar Grading Criteria
Grading shall be provided for each exception, each exception category
and holistically for each loan. The methodology for the application of the RMBS grading as defined by DBRS in their current industry publications
and updated from time to time.
| Narrative JPMMT 2026-NQM3 |
Opus
Grading Criteria
1) Opus Grading Criteria
Grading shall be provided for each exception, each exception category
and holistically for each loan. The following grading is not intended for securitization reviews, and Opus will not issue a Rating Agency
Narrative, Reliance or Form ABS Due Diligence 15-E if Client elects to utilize the following grading criteria. The methodology for the
application of grading is defined by Opus and updated from time to time shall be determined as follows:
Opus Credit Grades
| · | Level 1 Credit Grade Definition: Loan was originated in accordance with
the mortgage loan originator underwriting guidelines without exception. |
| · | Level 2 Credit Grade Definition: Loan was originated in substantial compliance
with the originator’s underwriting guidelines and there are sufficient compensating factors for any exceptions. |
| · | Level 3 Credit Grade Definition: Loan was not originated in substantial
compliance with the originator’s underwriting guidelines and there are insufficient compensating factors for the exceptions or is
missing material documentation.
|
Opus Property Grades
| · | Level 1 Property Grade Definition: Property value appears to be within 10%
of original appraised amount and there are no material deficiencies in the appraisal process. |
| · | Level 2 Property Grade Definition: Property value appears to be within 10%
of original appraised amount, but minor issues in the appraisal process were identified. |
| · | Level 3 Property Grade Definition: Property value does not appear to fall
within 10% of the original appraised value and/or material deficiencies exist with respect to the appraisal process or the file is missing
material documentation.
|
Opus Compliance Grades
| · | Level 1 Compliance Grade Definition: Loan complies with all applicable laws
and regulations reviewed under the applicable scope of work. |
| · | Level 2 Compliance Grade Definition: There are minor issues regarding legal
and/or regulatory compliance but such issues do not represent risks to the enforceability of the borrower’s obligation under the
loan documents and will not result in assignee liability to the investor. |
| · | Level 3 Compliance Grade Definition: Loan is not in compliance with laws
and regulations reviewed under the applicable scope of work or the loan is missing material documentation. |
REDACTED
INFORMATION
| · | Property Address, City, County, MSA, Zip |
| · | Account Number, including Originator and Servicer Loan Number |
| · | Names of Borrowers or any other Individuals |
| · | Company and Entity Names |
| · | Financial Institution Names |
| · | Any Location Information (other than state), including City, County, MSA
and Zip |
| · | Account Numbers of any type |
| · | Insurance Policy Numbers |
| · | Foreclosure Action dates and Case Numbers |
| Narrative JPMMT 2026-NQM3 |
| · | Bankruptcy Action dates and Case Numbers |
| · | Any reference that would allow the identification of the location of a property
(e.g. neighborhood, body of water, schools, major highways) |
DSCR Loan Review
A re-underwriting review was conducted
in order to verify that the requisite underwriting guidelines as specified by Client (the “Underwriting Guidelines”)
were met. Confirmation of the loan terms were performed through recalculation and review of documentation contained in the loan file provided
to the Consultant. The Credit Qualification review guidelines consisted of the following:
Borrower Underwriting:
| · | Borrower Liquidity: Review and confirm borrower’s liquidity
position adheres to Underwriting Guidelines. |
| · | Credit / Background Check: Review and confirm each guarantor and/or
owner of the borrowing entity requirements meet Underwriting Guidelines, including OFAC. |
| · | Property management questionnaire: Review the questionnaire to confirm
management experience meets Underwriting Guidelines. |
| · | Borrowing Entity: Confirm the entity is in good standing and duly
formed (if applicable documents are in the file). Verify the individual signing on behalf of the organization has the authority to bind
the entity (if applicable documents are in the file). |
| · | Loan-to-Value (LTV)/Loan-to-Cost (LTC) Limits: Confirm the LTV/LTC
meets Underwriting Guidelines per Underwriting Guidelines. |
| · | Permitted Loan Terms: Confirm the loan terms are eligible per the
Underwriting Guidelines. |
| · | Property Requirements and Market Requirements: Confirm the loan Property
and Market Requirements are eligible per the Underwriting Guidelines. |
| · | DSCR—ensure components of Debt Service Coverage Ratio are identified
correctly: Recalculation of DSCR |
Title Insurance Requirements are
met per Guidelines only as follows
Confirm Loss payee language must
be present and required insurance policies and coverage amounts meet the Underwriting Guidelines.
| · | Condominium Eligibility: Confirm Condo Master Policy is present and
meets the Underwriting Guidelines |
| · | Property Insurance: Confirm each mortgaged property has a policy
in place and proper coverage amount in adherence to the Underwriting Guidelines. |
| · | Preliminary/Commitment Title: Review and confirm first lien holder
position, validate no loan file discrepancies, delinquent taxes, and/or additional liens at time of consummation. |
Credit Document Check
| · | Loan Application: Verify the presence and completeness of both the initial
and final loan applications. |
| · | 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. |
| · | 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. |
| Narrative JPMMT 2026-NQM3 |
| · | 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. |
Compliance
| · | No compliance testing for the DSCR review. |
| Narrative JPMMT 2026-NQM3 |
Pool Details


| Narrative JPMMT 2026-NQM3 |
Tape Discrepancies

Multiple Loans to One Borrower: TPR firm reviewed common identifiers
for all loans in the population and confirmed there were twenty-one (21) obligors with multiple loans in the pool.
Property Inspection Waivers: One (1) loan contained a Property Inspection
Waiver (PIW). An AVM was obtained as a secondary product to confirm the value indicated on the PIW. An initial property value
grade of a “C” was assigned to the PIW loan. If the secondary product supported the value indicated on the PIW, a final property
grade of a “B” was assigned.
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 |
| Narrative JPMMT 2026-NQM3 |
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 |
| Narrative JPMMT 2026-NQM3 |
| 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
May 4, 2026.

| Narrative JPMMT 2026-NQM3 |
Loans Reviewed (328)
| 305054677 |
305051372 |
305047089 |
305046134 |
305026500 |
305061085 |
305057549 |
| 305054924 |
305051371 |
305046000 |
305043004 |
305039415 |
305061077 |
305057548 |
| 305074629 |
305038998 |
305045971 |
305038739 |
305034452 |
305057863 |
305057546 |
| 305045967 |
305029082 |
305042043 |
305036830 |
305029093 |
305057528 |
305057544 |
| 305056905 |
304869322 |
305034611 |
305030327 |
305024430 |
305056845 |
305053750 |
| 304898965 |
304898968 |
304848988 |
305042288 |
305024311 |
305053415 |
305053430 |
| 304898050 |
305029691 |
305039403 |
305042287 |
304898985 |
305051380 |
305051449 |
| 305051151 |
305029270 |
304899076 |
305037881 |
304889827 |
305047909 |
305047868 |
| 305042048 |
305027332 |
304909733 |
304891144 |
305029135 |
305046014 |
305038776 |
| 305055885 |
305026599 |
304902324 |
305078467 |
305024787 |
305032482 |
305037871 |
| 305064038 |
304897423 |
305038535 |
305073506 |
305013582 |
305031449 |
305043808 |
| 304911580 |
304889341 |
305033638 |
305070039 |
305013581 |
305030647 |
305030283 |
| 304904430 |
305057968 |
305029169 |
305069724 |
305013280 |
305039425 |
305030199 |
| 305060823 |
305059682 |
305027360 |
305069076 |
304909033 |
305060739 |
305030148 |
| 305042279 |
305057848 |
305027154 |
305067563 |
304898973 |
305056664 |
305029924 |
| 305057777 |
305057523 |
305027037 |
305065474 |
304898181 |
305053764 |
305029906 |
| 305056847 |
305042644 |
305026598 |
305064135 |
304897422 |
305053606 |
304904452 |
| 304874817 |
305067560 |
305026595 |
305057680 |
304889879 |
305050070 |
305030274 |
| 305070043 |
305064145 |
305023784 |
305056347 |
305035589 |
305030356 |
305029916 |
| 305065536 |
305059689 |
305013360 |
305037870 |
305033672 |
305030331 |
305036269 |
| 305060668 |
305056849 |
304908705 |
305034535 |
305031688 |
305030106 |
305060718 |
| 305054831 |
305054929 |
304904457 |
305039421 |
305030624 |
304894708 |
305053697 |
| 305053427 |
305032544 |
304875241 |
305030476 |
305026441 |
305030617 |
305059705 |
| 305051357 |
305039388 |
305046010 |
305030441 |
305024444 |
305029557 |
305056356 |
| 305047520 |
304898980 |
305046006 |
305030159 |
304909032 |
305050763 |
305054990 |
| 305042045 |
305054651 |
305064046 |
305030078 |
304897449 |
305042296 |
305054589 |
| 305039392 |
305076205 |
305063739 |
304866589 |
304897077 |
305029874 |
305053483 |
| 305027514 |
305070041 |
305061010 |
305040473 |
305047505 |
305029230 |
305051375 |
| 304993657 |
305070038 |
305057938 |
305037864 |
305044960 |
304909608 |
305030935 |
| 304909815 |
305067561 |
305057527 |
304904593 |
305042217 |
305077120 |
305027173 |
| 305057522 |
305066750 |
305057526 |
305036768 |
305064143 |
305076278 |
305029062 |
| 305047864 |
305057941 |
305054925 |
304897601 |
305064032 |
305075887 |
304899065 |
| 305029236 |
305057547 |
305052323 |
305061537 |
305063380 |
305073575 |
304898971 |
| 305031469 |
305054682 |
305047103 |
305060656 |
305062322 |
305072092 |
304867433 |
| 305062313 |
305051378 |
305046017 |
305060654 |
305061538 |
305071224 |
305044897 |
| 305061543 |
305047464 |
305041937 |
305059748 |
305060720 |
305070111 |
305041934 |
| 305031477 |
305037868 |
305034674 |
305057542 |
305057858 |
305069108 |
305038716 |
| 305029115 |
305030401 |
305044573 |
305056830 |
305057681 |
305069093 |
305038037 |
| 304869291 |
305030160 |
305039457 |
305056674 |
305056362 |
305067582 |
305034617 |
| 305030038 |
305029971 |
305067581 |
305054985 |
305056340 |
305067562 |
305036547 |
| 305069136 |
304875288 |
305064047 |
305054838 |
305054926 |
305067107 |
305046015 |
| 305061542 |
305012671 |
305057551 |
305054833 |
305053489 |
305066752 |
305037858 |
| 305061014 |
305025031 |
305056363 |
305053696 |
305051873 |
305066749 |
305069734 |
| 305057710 |
305061013 |
305055828 |
305052638 |
305051441 |
305066745 |
305062373 |
| 305038990 |
305060999 |
305053432 |
305050808 |
305047091 |
305063697 |
305062317 |
| 305037867 |
305060663 |
305050111 |
305047466 |
305046106 |
305062330 |
305061630 |
| 305061193 |
305060996 |
305060710 |
305059708 |
305059700 |
305057550 |
|
If you have any questions, please contact Uriah Clavier
at Uriah.Clavier@opuscmc.com
| Narrative JPMMT 2026-NQM3 |