Exhibit 99.5 - Schedule 2
| Loan Number | Loan ID | Finding # | Last Name | Note Date | DD Start Date | DD Delivery Date | Audit Category | Audit Issue | Finding ID | Exception Finding | Remediation Status | Exception Rebuttal | Exception Response | Status Comment | Compensating Factors | SOL Expiration Date | Initial Findings Grade | Final Findings Grade | Initial Loan Grade | Final Loan Grade |
| XXXX | 2122681 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122681 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122681 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122681 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Missing | XXXX | The lender included retirement income in the amount of $XXXX per month; however, no documentation was provided to confirm income. Additional conditions may apply. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Pension doc Rebuttal 2 (XX/XX/XXXX XX:XXAM) Hello, please see attached Pension Retirement Income. Thank you, Rebuttal 3 (XX/XX/XXXX XX:XXAM) Hello, please see attached Pension Retirement Income |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation not received. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Documentation not received. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
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| XXXX | 2108247 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108247 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108247 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - LE/Revised LE Delivery Date (prior to consummation) | XXXX | The loan failed the Revised Loan Estimate delivery date test due to the following: The Loan Estimate was not received by the Co-Borrower at least four business days prior to the Consummation Date. The LE issued on XX/XX/XXXX was received by the co-borrower on XX/XX/XXXX. If disclosure was delivered electronically evidence of receipt as well as the consumer's E-consent is required. | Void | Response 1 (XX/XX/XXXX XX:XXAM) finding voided. |
1 | 1 | 2 | 2 | ||||
| XXXX | 2108247 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that cannot increase test. Because the loan failed the revised LE date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset as a result of the following increase: Discount Points on XX/XX/XXXX. The violation may be cured if documentation is provided showing the disclosure was delivered timely. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Void | Response 1 (XX/XX/XXXX XX:XXAM) finding voided. |
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| XXXX | 2108247 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108280 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108280 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108281 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loancontains the following fee or fees where 'compensation to' does not reflect aPayee on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108281 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108282 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108282 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108283 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108283 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108283 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108283 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108284 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108284 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122738 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate, HOA Certification, and HOA Master Insurance Fees. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122738 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Borrower - (EAD) Risk Category | XXXX | The Borrower is not a XXXX and the loan file is missing documentation to support the borrower's current EAD status. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see I-797A Forms confirming immigration status. Thank you Rebuttal 2 (XX/XX/XXXX XX:XXPM) Resent Immigration Docs |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation not received. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
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| XXXX | 2108285 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108285 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108286 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108286 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122739 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Rescission Test | XXXX | The funding date is before the third business day following consummation XX/XX/XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Fund date is XXXX/XXXX. Rebuttal 2 (XX/XX/XXXX XX:XXPM) Attached funding date doc Rebuttal 3 (XX/XX/XXXX XX:XXPM) Attached ALTA provided from title. attached is correct. |
Response 1 (XX/XX/XXXX XX:XXAM) Please provide documentation evidencing the stated funding date. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) The Note and RTC Notice are not evidence of when the loans proceeds officially disbursed. The loan closed on XX/XX/XXXX and according to the documents in the loan file funded on XX/XX/XXXX (prior to closing). Evidence of actual disbursement date is required. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) Response 4 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2122739 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - Closing Information/Disbursement Date | XXXX | The CD issued on XX/XX/XXXX does not reflect the correct Disbursement Date. Truth in XXXX (Regulation Z)12 CFR 1026.38(a)(3)(iii) | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122739 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122739 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2108287 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loancontains the following fee or fees where 'compensation to' does not reflect aPayee on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108287 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108248 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108248 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in XXXX The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108248 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108248 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108249 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108249 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108250 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108250 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108250 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX HOEPA higher-priced mortgage loan test. The loan is a higher-priced mortgage loan, as defined in the legislation. The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108250 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108250 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122740 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the addition to the following fees was not accepted: HOA Certificate Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached tolerance cure docs |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2122740 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - Missing/Insufficient | XXXX | The loan was missing current hazard insurance policy on the subject property reflecting sufficient coverage/replacement cost. The copy of the hazard insurance in the loan file is not completely legible. A legible copy is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached HOI with sufficient coverage |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
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| XXXX | 2108251 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108251 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108252 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108252 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122741 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122741 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122742 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fees was not accepted: Transfer Taxes. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached Resolution. |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2122742 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122743 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122743 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122744 | 1 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 3 | |||||
| XXXX | 2122744 | 2 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 3 | |||||
| XXXX | 2122744 | 3 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test.Because the loan failed the Initial LE date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset as a result of the following additions/increases: Recording Fee. The violation may be cured if documentation is provided showing the disclosure was delivered timely.A cost to cure in the amount of $XXXX is required. | XXXX | 3 | 3 | 3 | 3 | |||||
| XXXX | 2122744 | 4 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 3 | 3 | |||||
| XXXX | 2122744 | 5 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial LE/Delivery Date (from application) | XXXX | The loan failed the Initial Loan Estimate delivery date test (from application). The Initial LE issued on XX/XX/XXXX was not disclosed within XXXX days of the application date, XX/XX/XXXX. Truth in XXXX (Regulation Z)12 CFR 1026.19(e)(1)(iii)(A) | XXXX | 3 | 3 | 3 | 3 | |||||
| XXXX | 2122744 | 6 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that cannot increase test. Because the loan failed the Initial LE date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset as a result of the following additions/increases: Loan Origination, Credit Report, Flood Certification , XXXX, MERS, Property Condition report and Settlement fees. The violation may be cured if documentation is provided showing the disclosure was delivered timely.A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | XXXX | 3 | 3 | 3 | 3 | |||||
| XXXX | 2122744 | 7 of 7 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 3 | |||||
| XXXX | 2108254 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108254 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108255 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108255 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108320 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108320 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108321 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108321 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127790 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127790 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108322 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108322 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108322 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108322 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122745 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122745 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122746 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Property Condition Report. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122746 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108323 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. This loan has points and fees that exceed the points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. The following fees were included: Points-$XXXX, XXXX, XXXX, and Settlement/Closing Fee-$XXXX. If discount points are excludable please provide the undiscounted rate. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) discount fee exclusion worksheet |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2108323 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2108323 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122747 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - $35 Tolerance Threshold/Rescindable | XXXX | The loan failed the Rescission Finance Charge tolerance test. Per the special foreclosure rule under Regulation Z, for loans subject to the right of rescission the Finance Charge is considered inaccurate if the disclosed Finance Charge is understated by more than $XXXX. The final (last revised) CD issued on XX/XX/XXXX has a disclosed Finance Charge of $XXXX, which is less than the system calculated Finance Charge of $XXXX. The Finance Charge on the final CD is understated by $XXXX which is more than the allowable tolerance of $XXXX. The following fees were included in the Finance Charge calculation: Document Signing Fee $XXXX, XXXX $XXXX, Origination Fee $XXXX, MERS $XXXX, Prepaid Interest $XXXX and Settlement Fee $XXXX. A cost to cure in the amount of $XXXX is required. Additionally, rescission needs to be reopened. Truth in XXXX (Regulation Z) 12 CFR 1026.23(h)(2)(i) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see passing XXXX report |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122747 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122747 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Total of Payments Rescindable | XXXX | The loan failed the Rescission Total of Payments tolerance test. Per the special foreclosure rule under Regulation Z, for loans subject to the right of rescission the Total of Payments is considered inaccurate if the disclosed Total of Payments is understated by more than $XXXX. The final (last revised) CD issued on XX/XX/XXXX has a disclosed Total of Payments of $XXXX, which is less than the system calculated Total of Payments of $XXXX. The Total of Payments on the final CD is understated by $XXXX which is more than the allowable tolerance of $XXXX. A cost to cure in the amount of $XXXX is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached Passing XXXX Report |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122747 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the addition to the following fees was not accepted: XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) updated COC for signing fee |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122747 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122748 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122748 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test.A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Stamp/Tax Stamp. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund.A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) COC was in original upload - please advise why this was not accepted. Rebuttal 2 (XX/XX/XXXX XX:XXPM) trid fee correction |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding. The COC issued on XX/XX/XXXX states the reason for the increase is new information required additional services and mot considered valid without more details. A detailed reason/COC stating what new information/additional services caused the increase to the State Tax/Stamps is required to determine if the COC is valid. A cost to cure in the amount of $XXXX remains. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2122748 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2108324 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2108324 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fees was not accepted: Transfer Taxes. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) See attached tolerance cure docs |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2108324 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122749 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Non-Compliant | XXXX | The loan failed the Federal HPML APR test. Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in XXXX Rate Set was: XX/XX/XXXX. The loan is a non-compliant HPML due to the following: Evidence the appraisal was provided within XXXX days of consummation. | Acknowledged | Rebuttal 1 (XX/XX/XXXX XX:XXAM) XXXX. |
Response 1 (XX/XX/XXXX XX:XXAM) The finding in question is aFederal HPML (XXXX) citation. A loan is defined as a Federal HPML loan if XXXX, the APR is more than XXXX% above the APOR (in this caseXXXX%). Therefore, the threshold is XXXX% and the loan has an APR of XXXX%.The original citation was labeled as a non-compliant Ev3, however since it is aQualified Mortgage, there is no appraisal requirement that needs to be met. Thefinding has been updated to XXXX, Ev1, and Acknowledged. (Acknowledged) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122749 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)) The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122749 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122750 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122750 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108325 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108325 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108326 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108326 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108327 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108327 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108327 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108327 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108352 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108352 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108352 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108353 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108353 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122751 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate and HOA Master Insurance Fees | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122751 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108354 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. The loan failed the origination fee test. (XXXX § XXXX-3301(e)(1)-(XXXX)) The loan has an origination fee that is greater than XXXX% of the loan's principal. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108354 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108354 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122752 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122752 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108355 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108355 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108355 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108355 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122753 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122753 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108357 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108357 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108358 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108358 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108359 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108359 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122754 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | FACTA Disclosure - Missing | XXXX | The XXXX's FACTA Disclosure (Notice to Home Loan Applicant/Credit Information Disclosure) is missing. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122754 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122754 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122754 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122755 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122755 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Other | XXXX | The investor guidelines allowed for an Ownership and Encumbrance in lieu of a title commitment. The O & E report provided had illegible information. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see the attached Title report |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2108288 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108288 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108289 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108289 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122756 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | ROR- Incorrect Form/Same creditor (H9) version required (circuits 2nd, 5th, 7th, 8th, 9th, 10th, District of Columbia) | XXXX | The consumer(s) was provided the incorrect RTC version. The consumer is refinancing with the original (same) creditor (-new advance of money with the same creditor). XXXX was provided; however, because the property is located in XXXX, model H-XXXX should have been used. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122756 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122757 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122757 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the addition to the following fees was not accepted: XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached COC. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122757 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122758 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122758 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122759 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122759 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122759 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX higher-priced mortgage loan test. (Title 9-A §8A-506(1)(I) as enacted by XXXX, Chapter 427) Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in the XXXX Consumer Credit Code Truth-in-Lending Provisions.The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122759 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108290 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108290 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122760 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122760 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108291 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108291 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108291 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108291 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108292 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108292 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108292 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108292 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108293 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108293 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122761 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122761 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108294 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108294 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122762 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122762 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108295 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108295 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108256 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108256 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122763 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122763 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Missing/Incomplete | XXXX | The title commitment/policy is incomplete/missing. The O&E Report from the title company in the loan file is not legible. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Title |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122764 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122764 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%.The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122764 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108258 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108258 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108258 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108258 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122765 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122765 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the addition to the following fees was not accepted: XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached documentation. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2122765 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2108259 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108259 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108260 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108260 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108260 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108260 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122766 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122766 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Insufficient Documentation | XXXX | The XXXX's conclusions on the adequacy and the stability of the applicant's income was not supported by documentation in the file. The loan file is missing income documentation as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Hello, Please see updated VOE Thank you, Rebuttal 2 (XX/XX/XXXX XX:XXPM) Hello, Please see VOE for XXXX Thank you, Rebuttal 3 (XX/XX/XXXX XX:XXPM) Hello, Per UW - VVOE-work# was XXXX calendar days or XXXX business days out from the Note/closing date- conventional/CES goes off of business days so all documents are in compliance with the guidelines Thank you, Rebuttal 4 (XX/XX/XXXX XX:XXPM) Docs provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation not received. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) VOE received does not contain income documentation. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) Income documentation is missing from the file. (XXXX) Response 4 (XX/XX/XXXX XX:XXPM) VOE, VOI, XXXX and income calc sheet provided. Income for both jobs supported. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122767 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122767 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Business Tax Returns | XXXX | Copies of signed federal business income tax returns (including all schedules) for XXXX were not documented in the loan file. The loan file also did not contain an IRS extension for XXXX if applicable, as required per the guidelines. The loan file did contain business tax returns for XXXX; however, the subject loan closed on XX/XX/XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached. |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2127800 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2127800 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Social Security/Pension | XXXX | The XXXX XXXX tax return provided to verify social security and retirement benefits; however, not signed by the borrower as required per the guidelines. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Attached XXXX XXXX |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2108261 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows:This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108261 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108261 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108262 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108262 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108262 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108262 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108263 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | FACTA Disclosure - Missing | XXXX | The FACTA Disclosure (Notice to Home Loan Applicant/Credit Information Disclosure) is missing for the Co-Borrower. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108263 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108263 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108263 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108328 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108328 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122768 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122768 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122769 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122769 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122770 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122770 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Missing/Incomplete | XXXX | The E&O Report for the title commitment/policy in the loan file is not legible. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) title |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122771 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122771 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | DTI - Exceeds Guidelines | XXXX | The DTI exceeds guidelines of XXXX% maximum. The coborrower's SSI was calculated as $XXXX at originations. SSI calculated at audit using the XXXX XXXX reflected SSI grossing up XXXX% by XXXX% is $XXXX. DTI at audit exceeds guidelines at XXXX%. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Hello, The tax transcripts, updated income calculation worksheet, Decision Logic and XXXX are attached. Borrowers&#XXXX; SS income was able to be grossed up and we now have a XXXX% DTI. |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122772 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122772 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122772 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122772 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Other | XXXX | Guidelines require the higher of the current insurance premium included in the mortgage payment or the premium as listed on the homeowner's insurance declarations page and higher of current property taxes or tax amount included in the mortgage payment. Reviewer unable to determine which is the higher. The mortgage statement for the subject property that provides a breakdown of the senior XXXX mortgage payment is missing from the loan file. Additional conditions may apply. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) See attached mortgage statement Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please see attached mortgage statement for the XXXXst |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation not received. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2108329 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108329 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108330 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108330 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108331 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108331 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108331 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108331 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108332 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108332 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108332 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108332 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122773 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122773 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122774 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122774 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108333 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108333 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122775 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Inaccurate | XXXX | The security instrument was not completed accurately. The name of the PUD development on the PUD Rider "XXXX" is inaccurate when compared to the title legal description "XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) See XXXX attached Rebuttal 2 (XX/XX/XXXX XX:XXPM) See XXXX attached |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation was not received. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122775 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Pay Stubs Missing | XXXX | The required pay stubs were not obtained from the applicant or were not properly retained in the file. The loan file was missing the paystubs and W2s for current employment. Without proper verification of income the DTI is XXXX%, which exceeds the maximum of XXXX%. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) See VOI docs attached |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122775 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Social Security/Pension | XXXX | Social security benefits were considered as effective income but sufficient supporting documentation was not found in the file. The loan file contained no awards letter, XXXX, tax returns, or bank statements reflecting SSI income. Without proper verification of income the DTI is XXXX%, which exceeds the maximum of XXXX%. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) See VOI docs attached |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2108334 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108334 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108334 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108334 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108335 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108335 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108335 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)) Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in the XXXX Financial Code. The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108335 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108335 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122776 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122776 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122777 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122777 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Property Type | XXXX | The subject loan does not meet Program Parameters for Property Type. A review of the appraisal reflects the subject property is zoned limited agriculture. Per the lender's guidelines agricultural zoned properties are ineligible. | Waived | Response 1 (XX/XX/XXXX XX:XXPM) Investor approved to waive based on compensating factors. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Investor reviewed and elects to waive. XXXX is XXXX acres. Noted Compensating factors: Subject property owned XXXX years, XXXX qualifying credit score, $XXXX monthly residual income. |
Comp factors - XXXX, Residual Income $XXXX and owned property XXXX years. | 3 | 2 | 3 | 2 | ||
| XXXX | 2108360 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the nonrefundable prepaid finance charge test. (XXXX. Code § XXXX-XXXX-XXXX-201(XXXX)) The loan's nonrefundable prepaid finance charge exceeds: XXXX% of the note amount or line of credit for loans on or after XXXX. The nonrefundable prepaid finance charge test includes the following fees: Flood Certification $XXXX, Origination Fee $XXXX, MERS Registration Fee $XXXX, Discount Points $XXXX, Prepaid Interest $XXXX, and Title Settlement/Closing Fee $XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108360 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108360 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127801 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127801 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108361 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108361 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122778 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. This loan has points and fees that exceed the points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. The following fees were included: Points-$XXXX, XXXX, XXXX, and Settlement/Closing Fee-$XXXX. If discount points are excludable please provide the undiscounted rate. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Hello, please see attached Bona Fide Discount Points. Thank you, |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122778 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2108362 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | FACTA Disclosure - Missing | XXXX | The FACTA Disclosure (Notice to Home Loan Applicant/Credit Information Disclosure) is missing. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108362 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108362 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122779 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. Because the loan failed the Initial LE date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset as a result of the following additions/increases: Discount Points, Origination Fee, Credit Report Fee, Flood Certificate, XXXX, MERS Registration, and Property Condition Report. The violation may be cured if documentation is provided showing the disclosure was delivered timely. A cost to cure in the amount of $XXXX is required. | XXXX | 3 | 3 | 3 | 3 | |||||
| XXXX | 2122779 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 3 | |||||
| XXXX | 2122779 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial LE/Delivery Date (from application) | XXXX | The loan failed the Initial Loan Estimate delivery date test (from application). The Initial LE issued on XX/XX/XXXX was not disclosed within XXXX days of the application date, XX/XX/XXXX. Truth in XXXX (Regulation Z)12 CFR 1026.19(e)(1)(iii)(A) | XXXX | 3 | 3 | 3 | 3 | |||||
| XXXX | 2122779 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that cannot increase test. Because the loan failed the Initial LE date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset as a result of the following additions/increases: Settlement/Closing and Recording Fee. The violation may be cured if documentation is provided showing the disclosure was delivered timely. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | XXXX | 3 | 3 | 3 | 3 | |||||
| XXXX | 2122779 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 3 | |||||
| XXXX | 2122780 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122780 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122780 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)) Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in the XXXX Financial Code. The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122780 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood Certification Fee. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122780 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Other | XXXX | There are additional findings regarding the title commitment. The Ownership and Encumbrance Report included in the loan file is illegible. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) title |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2108363 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108363 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122782 | 1 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. Because the loan failed the Initial LE date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset. The violation may be cured if documentation is provided showing the disclosure was delivered timely. A cost to cure in the amount of $XXXX is required. | XXXX | 3 | 3 | 3 | 3 | |||||
| XXXX | 2122782 | 2 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 3 | 3 | |||||
| XXXX | 2122782 | 3 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial LE/Delivery Date (from application) | XXXX | The loan failed the Initial Loan Estimate delivery date test (from application). The Initial LE issued on XX/XX/XXXX was not disclosed within XXXX days of the application date, XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.19(e)(1)(iii)(A) | XXXX | 3 | 3 | 3 | 3 | |||||
| XXXX | 2122782 | 4 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that cannot increase test. Because the loan failed the Initial LE date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset. The violation may be cured if documentation is provided showing the disclosure was delivered timely. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | XXXX | 3 | 3 | 3 | 3 | |||||
| XXXX | 2122782 | 5 of 6 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | Borrower owns additional financed property on XXXX The mortgage statement on this property with XXXX was provided and indicated that taxes were not escrowed. Documentation to support the monthly tax liability were not provided. Total PITIA payment on this property could not be calculated. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see tax bill to complete the PITI calculation. Thank you |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 3 | |||
| XXXX | 2122782 | 6 of 6 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Missing/Incomplete | XXXX | The XXXX Owership and Encumbrance report for the subject property was partially illegible. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see legible title report. Thank you |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 3 | |||
| XXXX | 2122783 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. Because the loan failed the Initial LE date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset as a result of the following additions/increases: Recording Fee. The violation may be cured if documentation is provided showing the disclosure was delivered timely. A cost to cure in the amount of $XXXX is required. | XXXX | 3 | 3 | 3 | 3 | |||||
| XXXX | 2122783 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 3 | |||||
| XXXX | 2122783 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial LE/Delivery Date (from application) | XXXX | The loan failed the Initial Loan Estimate delivery date test (from application). The Initial LE issued on XX/XX/XXXX was not disclosed within XXXX days of the application date, XX/XX/XXXX. Truth in XXXX (Regulation Z)12 CFR 1026.19(e)(1)(iii)(A) | Upheld | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Attached COC |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The COC does not address that the Initial LE provided in the loan file issued on XX/XX/XXXX was not within XXXX days of application. If an LE was issued within XXXX days of the application please provide for review. (XXXX) |
XXXX | 3 | 3 | 3 | 3 | ||
| XXXX | 2122783 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that cannot increase test. Because the loan failed the Initial LE date, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset as a result of the following additions/increases: Discount Points, Loan Origination Fee, Credit Report Fee, Flood Certification Fee, XXXX, MERS Registration, Property Condition Report, and Settlement/Closing Fee. The violation may be cured if documentation is provided showing the disclosure was delivered timely. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Upheld | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Attached COC. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. Although the COC is valid, because the loan is failing the Initial LE timing violation, the COC is not considered valid. (XXXX) |
XXXX | 3 | 3 | 3 | 3 | ||
| XXXX | 2122783 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 3 | |||||
| XXXX | 2122784 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122784 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122784 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - Non-Borrower with Right to Rescind | XXXX | There is no evidence of an initial CD provided to the non-borrower. Per regulation, CD(s) must be provided to all who have the right to rescind. Truth in XXXX (Regulation Z) 12 CFR 1026.19(f)(1)(i), 12 CFR 1026.2(a)(11) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please re-review. TRID rules only require the CD to be provided to the borrower(s), not to non-borrowing spouses. |
Response 1 (XX/XX/XXXX XX:XXPM) TRID regulation Z requires the NBS to receive a CD at least XXXX days prior to closing; reviewing the CD issued on XX/XX/XXXX it was received by both the borrower and the NBS at least XXXX days prior to consummation satisfying the timing requirement. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122784 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122784 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122785 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122785 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122786 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Inaccurate | XXXX | The security instrument was not completed accurately. The PUD name "XXXX" on the PUD rider is inaccurate when compared to the legal description PUD name "XXXX". | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) I believe XXXX is the appropriate name. XXXX and XXXX are villages within XXXX , please see attached |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122786 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122786 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122787 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122787 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108364 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108364 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108364 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108364 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122788 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122788 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Missing | XXXX | The loan was qualified using pension income however the loan file is missing documentation needed to verify the pension income received. The pension benefit award letter is required to verify this income. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Please see attached Pension Award Letter. |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122789 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the high-cost home loan points and fees threshold test. (XXXX AB XXXX, § XXXX.) , (XXXX SB XXXX, § XXXX.)The total points and fees of this loan, which are $XXXX, exceed one of the following thresholds based on the total loan amount, which is $XXXX: The total points and fees exceed XXXX% of the total loan amount if the total loan amount is $XXXX or more. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached Bona Fide Discount Point Calculation and XXXX report. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122789 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122790 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122790 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122791 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122791 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122792 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee where 'compensation to' does not reflect a XXXX on the revised CD dated XX/XX/XXXX; Flood Certificate. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122792 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108366 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108366 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108366 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108366 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122793 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122793 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The guidelines indicate when the subject property has solar panels, Obtaining a copy of the fully executed documents with all addenda, amendments, and exhibits, as applicable to the solar lease or PPA is required. The subject property has solar panels (XXXX lease payment reflected on credit report), and the loan file is missing a copy of the solar lease or PPA as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) solar agreement |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122794 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122794 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Federal Debt | XXXX | Delinquent federal debt was indicated but it was either not adequately explained or was not properly documented in the file. The loan file contains an email from the Lender, which requires proof that the XXXX tax returns in the amount of $XXXX had been paid in full. The loan file contains no documentation that the taxes were paid. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Please see proof of payment on page XXXX of attached document. |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122795 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122795 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122796 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122796 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108367 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108367 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108367 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX HOEPA higher-priced mortgage loan test. The loan is a higher-priced mortgage loan, as defined in the legislation. The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108367 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108367 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122797 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122797 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Missing | XXXX | Income documents are missing from the loan file. Guidelines require a previous year XXXX and a paystub with XXXX days of earnings or a WVOE. The loan file contains a VVOE along with the lender's income report; however, XXXX's, paystubs or WVOE is missing from the loan file. Additional conditions may apply. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached WVOE. |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2108296 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108296 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122798 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122798 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108297 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108297 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122799 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122799 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122799 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)) Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in the XXXX Financial Code. The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122799 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122800 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122800 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108298 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108298 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108298 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108298 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127802 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2127802 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2127802 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2127802 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fees was not accepted: Property Condition Report and XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required, of which $XXXX was cured and $XXXX is still needed. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached refund pkg Rebuttal 2 (XX/XX/XXXX XX:XXPM) Fed Ex Tracking # XXXX shows delivered XX/XX/XXXX Rebuttal 3 (XX/XX/XXXX XX:XXPM) refund pkg reuploaded Rebuttal 4 (XX/XX/XXXX XX:XXPM) Resubmitted docs |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation was not received. Please re-submit. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Documentation was not received. Please re-submit. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) Documentation was not received. Please re-submit. (XXXX) Response 4 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2127802 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Other | XXXX | The loan application reflected the borrower was employed as a XXXX for XXXX years earning $XXXX per month. A VVOE/TWN was obtained on XX/XX/XXXX (Note date XX/XX/XXXX) which reflected the borrower's employment was Temporarily Inactive. Omitting the borrower's income would result in a DTI over the maximum allowed of XXXX%. Per the lender’s guidelines if the underwriter is made aware, through the employment and income verification process, that a borrower will be on temporary leave at the time of the closing of the mortgage loan and that borrower's income is needed to qualify for the loan, the lender must determine allowable income and confirm employment: By obtaining written confirmation from the borrower of their intent to return to work and document the borrower’s agreed-upon date of return from the employer. The loan file did not contain the required documentation. Additional conditions may apply. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see uploaded employment verification |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
4 | 1 | 3 | 2 | |||
| XXXX | 2122801 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepaymentrequirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122801 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122801 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122801 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Credit - Other | XXXX | There are additional observations that could impact the credit decision and/or quality of the loan. The subject property is located in a PUD Community; however, the loan file did not contain documentation evidencing the XXXX dues as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) see attached for HOA verification |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2108299 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108299 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108299 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX nonprime home loan test. The loan is a nonprime home loan, as defined in the legislation. The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108299 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108299 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108300 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108300 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108301 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108301 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122802 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122802 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122802 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: State Tax/Stamps. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) RESPA REFUND for review Rebuttal 2 (XX/XX/XXXX XX:XXAM) RESPA REFUND |
Response 1 (XX/XX/XXXX XX:XXPM) The referenced documentation was not received. Please provide cure documents for review. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2122802 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2108302 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108302 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108303 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108303 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108303 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108303 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108380 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108380 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122803 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122803 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122804 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: HOA Certification and HOA Master Insurance Fees. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122804 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Appraisal - Other | XXXX | The subject property is an "Attached Condo" unit. The AVM in file reflects the subject property as a "Detached SFR". | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Corrected AVM attached |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2108381 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108381 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108382 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108382 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108382 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108382 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108383 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108383 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122805 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122805 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows:The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122805 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee where 'compensation to' does not reflect a XXXX on the revised CD dated XX/XX/XXXX; Flood Certificate. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122805 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Missing/Incomplete | XXXX | The title commitment is missing. The loan file is missing the required Owner and Encumbrance Report (O&E). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached Rebuttal 2 (XX/XX/XXXX XX:XXPM) I have attached a copy of Title for your review. Final title comes as a trailing. |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation not received. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2108384 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108384 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108384 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108384 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122806 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: State Tax/Stamps. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) REFUND/PCCD uploaded Rebuttal 2 (XX/XX/XXXX XX:XXPM) check included |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation was not received. Please re-submit. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2122806 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2108385 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108385 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122807 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: XXXX Fee $XXXX and a Title - Settlement/Closing Fee of $XXXX. The loan fails the prohibited fees test by $XXXX. (MRS § 408.052(XXXX); 408.233(XXXX) | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122807 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Other | XXXX | The loan is required to obtain an Ownership and Encumbrance report for the subject property. The loan file contains an Ownership and Encumbrance report; however, the report is illegible. There is not another report or similar report obtained in the loan file as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) title |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2108386 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108386 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108386 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)) Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in the XXXX Financial Code. The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108386 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108386 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122808 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fees where 'compensation to' does not reflect a XXXX on the revised CD; XXXX and XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122808 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108387 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108387 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108387 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX XXXX CMR XXXX higher-priced mortgage loan test. (XXXX XXXX CMR XXXX) Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in the Code ofMassachusetts Regulations. The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108387 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108387 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108304 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108304 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108304 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108304 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108305 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108305 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108305 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108305 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108306 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108306 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108307 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108307 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108308 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108308 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108308 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108308 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108309 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108309 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108309 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX nonprime home loan test. The loan is a nonprime home loan, as defined in the legislation. For more information please see the XXXX Nonprime Home Loan Article section of the full XXXX report. The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108309 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood Certification Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108309 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122811 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122811 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: Without evidence of receipt, it is assumed that the disclosure dated XX/XX/XXXX was mailed, and therefore not received by the consumer XXXX business days prior to the consummation date, XX/XX/XXXX. If disclosure was delivered electronically, evidence of receipt as well as the consumer's E-consent is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Attached |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2122811 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | HELOC - Closure Letter | XXXX | Loan file does not contain evidence to verify HELOC Closure as required. The payoff letter for the HELOC is present in the loan file and contains a closure option; however, the closure was not signed as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) attached statement Rebuttal 2 (XX/XX/XXXX XX:XXPM) here is signed HELOC close out letter Rebuttal 3 (XX/XX/XXXX XX:XXPM) Please advise what is needed to clear the defect. The defect states “Loan file does not contain evidence to verify HELOC Closure as required. The payoff letter for the HELOC is present in the loan file and contains a closure option; however, the closure was not signed as required.” Do you need something showing loan from XXXX was PIF? Will the final CD not work. It shows that payoff amount o do you need the payoff letter signed? If so can it be esigned? Please advise. Rebuttal 4 (XX/XX/XXXX XX:XXPM) I have attached the Mortgage Release. Will this clear? |
Response 1 (XX/XX/XXXX XX:XXPM) Statement does not confirm HELOC closure. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Closure letter did not upload. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) Evidence that the HELOC account is Closed is required. Paid off and closed are XXXX separate items. (XXXX) Response 4 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
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| XXXX | 2108310 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108310 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122812 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122812 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122812 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX HOEPA higher-priced mortgage loan test. Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122812 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127803 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Discount PointsThe loan fails the prohibited fees test by $XXXX. (XXXX RCW §31.04.105) | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2127803 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Borrower - Residency Alien Documentation | XXXX | The borrower indicates Non- Permanent Resident Alien status, however, the file contains no evidence documenting status as legally. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) As per guideline, Unexpired Passport or Visa is acceptable if borrower is in non permanent resident status. Please see attached guidelines. Rebuttal 2 (XX/XX/XXXX XX:XXPM) the visa shows the employers info, which matches? what else are you looking for? |
Response 1 (XX/XX/XXXX XX:XXPM) The Primary Borrower does not have sufficient credential to prove she can be lawfully employed with XXXX. A Visa, preferably H1B with XXXX as XXXX, is required. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) H1B Visa provided is sufficient. (Resolved) |
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| XXXX | 2127803 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Credit - Other | XXXX | There are additional observations that could impact the credit decision and/or quality of the loan. The loan application and credit report reflect an account with XXXX; however the loan file does not contain the contract agreement documentation to determine if owned or leased etc as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached Solar Agreement |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2108311 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108311 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122813 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122813 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122813 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122813 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108264 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108264 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108265 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108265 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122814 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122814 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108266 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108266 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122815 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122815 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108267 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108267 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108268 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108268 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108269 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108269 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122816 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122816 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122816 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Verification - Employment History | XXXX | The loan file contains a WVOE verified on XX/XX/XXXX that shows the borrower is currently inactive. The lenders calculation worksheet contains a note stating that it “appears” that the borrower is a seasonal employee, however the loan file does not contain verification of that fact from the employer. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see explanation of seasonal employment. Thank you! |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
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| XXXX | 2122817 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122817 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test.A valid change of circumstance was not provided in the loan file. Therefore, the addition to the following fees was not accepted: XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund.A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) attached COC Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please see attached COC. I forgot to click on upload last time |
Response 1 (XX/XX/XXXX XX:XXPM) The referenced documentation was not received. Please provide XXXX for review. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2122817 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122818 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122818 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122819 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. (12 CFR 1026.43(e)(3) The loan amount is less than $XXXX but at least $XXXX, and the transaction's total points and fees is $XXXX, which exceeds $XXXX. The QM Points and Fees Test includes the following fees; Closing Protection Fee $XXXX, Lien Search $XXXX, Loan Origination $XXXX, XXXX Fee $XXXX, Title - Settlement Fee $XXXX, and Title - Document Preparation Fee $XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached. Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please see attached. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The QM Excludable Bona Fide Discount Rate Calculation worksheet provided does not disclose the Undiscounted Rate. Please provide the Undiscounted Rate foe testing. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2122819 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122820 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122820 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122821 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee where 'compensation to' does not reflect a XXXX on the revised CD dated XX/XX/XXXX; Flood Certificate. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122821 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108271 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108271 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122822 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122822 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122822 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122822 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108336 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108336 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108337 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepaymentrequirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108337 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108337 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122823 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Note - Trust Not Executed | XXXX | Title to the Property is held in a Trust, but the Trust Document is not properly executed. Unable to determine if signatures on Note are accurate. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Our policy on a trust is that the borrower sign his /her name only nothing else |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122823 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Trust Not Executed | XXXX | Title to the Property is held in a Trust, but the Trust Document is not properly executed. Unable to determine if signatures on the Security Instrument are accurate. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Our policy on a trust is that the borrower sign his /her name only nothing else |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122823 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122823 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122824 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | ROR- Incorrect Form/Same creditor (H9) version required (circuits 2nd, 5th, 7th, 8th, 9th, 10th, District of Columbia) | XXXX | The consumer(s) was provided the incorrect RTC version. The consumer is refinancing with the original (same) creditor (-new advance of money with the same creditor). XXXX was provided; however, because the property is located in XXXX, model H-XXXX should have been used. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122824 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108338 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108338 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108339 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108339 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108340 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108340 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108341 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108341 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122825 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122825 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122826 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122826 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122826 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX HOEPA higher-priced mortgage loan test. The loan is a higher-priced mortgage loan, as defined in the legislation. The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122826 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122826 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108342 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108342 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108343 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108343 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127804 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Government Recording Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Can you please provide a breakdown of how $XXXX was calculated? Rebuttal 2 (XX/XX/XXXX XX:XXPM) updated COC |
Response 1 (XX/XX/XXXX XX:XXPM) The Recording fee increased from $XXXX to $XXXX on the CD issued on XX/XX/XXXX without a valid COC. The COC provided does not state a reason for the increase. A cot to cure in the amount of $XXXX remains. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2127804 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2108368 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108368 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108369 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108369 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122827 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Recording fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX of which $XXXX was reimbursed at closing a remaining cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached PCCD, XXXX label, LOE, and Disclosure Tracking. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2122827 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2108370 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108370 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108371 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee.. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108371 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122828 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | ROR - Timing | XXXX | This loan failed the TILA right of rescission test. Closed-end ( 12 CFR §1026.23(a)(3) , transferred from 12 CFR §226.23(a)(3) ), Open-end ( 12 CFR §1026.15(a)(3) , transferred from 12 CFR §226.15(a)(3) ). The funding date, XX/XX/XXXX, is before the third business day following when the RTC Notice was provided to the consumer on XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.23(b)(1)(v), (a) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached PCCD. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122828 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122828 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122829 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122829 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Insufficient Documentation | XXXX | The XXXX's conclusions on the adequacy and the stability of the applicant's income was not supported by documentation in the file. The loan application reflected the borrower receives XXXX Disability benefits and the co-borrower receives retirement income both in addition to the social security income; however, the loan file did not contain documentation of the borrower's XXXX Disability benefits or the co-borrowers retirement income as required. As a result the DTI increased from XXXX% to XXXX%, which exceeds the maximum guidelines of XXXX%. ***Additional conditions may apply *** | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see supporting income docs attached. |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122830 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122830 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122830 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122831 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122831 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122831 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122831 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | DTI - Exceeds Guidelines | XXXX | The DTI exceeds Originator Guidelines. The origination underwriter excluded a revolving debt with XXXX reflecting a balance of XXXX and a monthly payment of $XXXX per the credit report. According to the final XXXX, this debt was to be paid at close. The final closing disclosure does not reflect this debt as having been paid in full at closing and the loan file does not contain any evidence of a prior to closing payment in full. As a result the audit DTI is XXXX% which exceeds the maximum allowed DTI of XXXX%. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Soft pull of credit shows the minimum payment is now only $XXXX which brings the DTI under XXXX%. |
Response 1 (XX/XX/XXXX XX:XXAM) XXXX is XXXX months after closing. Investor exception required. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Investor approved to waive based on compensating factors. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Investor reviewed and elects to waive. Noted Compensating factors: Subject property owned XXXX years, Stable employment XXXX years, 0x30 mortgage history for XXXX months. |
Comp factors - Owned property XXXX years, stable employment XXXX years and 0x30 mortgage history for XXXX months. | 3 | 2 | 3 | 2 | |
| XXXX | 2122832 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122832 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122833 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122833 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122833 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX, XXXX search | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122833 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the addition to the following fees was not accepted: XXXX, LE XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Please see attached copy of refund docs. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2122833 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122682 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122682 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108372 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108372 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122683 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122683 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122683 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122683 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108373 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108373 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108374 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108374 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122684 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122684 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122684 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122684 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122685 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122685 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122685 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Property Condition Report. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached copy of refund docs. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2122685 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Insufficient Documentation | XXXX | The XXXX's conclusions on the adequacy and the stability of the applicant's income was not supported by documentation in the file. The borrower receives SS and Pension income; however, the loan file did not contain documentation of the Pension income as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached Pension/Retirement Income. |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2108375 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108375 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%.The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108375 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108375 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108312 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108312 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108312 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108312 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108313 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108313 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108314 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108314 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108314 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108314 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122686 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122686 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX, HOA Certification Fee, and HOA Master Insurance Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122686 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122687 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122687 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Social Security/Pension | XXXX | Social security and/or pension benefits were considered as effective income but sufficient supporting documentation was not found in the file. The XXXX pension statement is missing from the loan file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached XXXX Pension Statement. |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2108315 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108315 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108316 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108316 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108316 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108316 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108317 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108317 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122688 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122688 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Missing/Incomplete | XXXX | The O&E Report and/or title commitment/policy in the loan file is not legible. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached. |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122689 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122689 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Other | XXXX | The O&E report in file is not legible. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached legible O&E. |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2108318 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108318 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108318 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122690 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Recording Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) See attached PCCD |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2122690 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122690 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2108319 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108319 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108319 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108319 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122691 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | ROR- Incorrect Form/Same creditor (H9) version required (3rd circuit and CA) | XXXX | The consumer(s) was provided the incorrect RTC version. The consumer is refinancing with the original (same) creditor (new advance of money with the same creditor). XXXX was provided; however, because the property is located in XXXX, model H-XXXX should have been used. Truth in XXXX (Regulation Z)12 CFR 1026.23(b)(1)(v), (a) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached corrected RTC documents Rebuttal 2 (XX/XX/XXXX XX:XXAM) Rescission period ended. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding. The Updated ROR for the loan transaction was issued and the borrower has until midnight on XX/XX/XXXX to rescind. The exception can not be resolved until the recession period ends. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) The re-opened rescission expired at midnight on XX/XX/XXXX clearing the exception. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2122691 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2108272 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108272 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122692 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - Closing Information/Disbursement Date | XXXX | The CD issued on XX/XX/XXXX does not reflect the correct Disbursement Date. Truth in XXXX (Regulation Z) 12 CFR 1026.38(a)(3)(iii). | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122692 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122692 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108273 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108273 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122693 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | ROR- Incorrect Form/Same creditor (H9) version required (3rd circuit and CA) | XXXX | The consumer(s) was provided the incorrect RTC version. The consumer is refinancing with the original (same) creditor (new advance of money with the same creditor). XXXX was provided; however, because the property is located in XXXX, model H-XXXX should have been used. Truth in XXXX (Regulation Z)12 CFR 1026.23(b)(1)(v), (a) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached corrected RTC docs Rebuttal 2 (XX/XX/XXXX XX:XXAM) Rescission period ended. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding. The Updated ROR for the loan transaction was issued and the borrower has until midnight on XX/XX/XXXX to rescind. The exception can not be resolved until the recession period ends. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) The re-opened rescission expired at midnight on XX/XX/XXXX clearing the exception. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2122693 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122694 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 4 | 1 | |||||
| XXXX | 2122694 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Other | XXXX | Borrower was qualified using self employment income. According to guidelines complete, signed federal income tax returns for the most recent one or XXXX years is required. The XXXX provided in the loan file was not signed. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached signed XXXX. Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please see attached Signed XXXX. |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation not received. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
4 | 1 | 4 | 1 | |||
| XXXX | 2108274 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108274 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108275 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108275 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows:The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108275 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122696 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the nonrefundable prepaid finance charge test. (XXXX. Code § XXXX-XXXX-XXXX-201(XXXX)). The loan's nonrefundable prepaid finance charge exceeds: XXXX% of the note amount or line of credit for loans on or after XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122696 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122696 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122697 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122697 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: Without evidence of receipt, it is assumed that the disclosure dated XX/XX/XXXX was mailed, and therefore not received by the consumer XXXX business days prior to the consummation date, XX/XX/XXXX. If disclosure was delivered electronically, evidence of receipt as well as the consumer's E-consent is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Intial disc & disc tracking Rebuttal 2 (XX/XX/XXXX XX:XXPM) intial cd + tracking Rebuttal 3 (XX/XX/XXXX XX:XXPM) Intial CD + disc tracking attached |
Response 1 (XX/XX/XXXX XX:XXAM) Documents were not received. Please re-submit. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The CD provided is not for the borrower/loan. Please provide the Initial CD for review. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122697 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the addition to the following fees was not accepted: XXXX fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) see coc Rebuttal 2 (XX/XX/XXXX XX:XXPM) refund attached Rebuttal 3 (XX/XX/XXXX XX:XXPM) coc attached |
Response 1 (XX/XX/XXXX XX:XXAM) Documents were not received. Please re-submit. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The CD cure provided is not for the borrower/loan. Please provide cure for review. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122697 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2108276 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108276 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122698 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122698 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122699 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122699 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122700 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122700 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108277 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108277 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108277 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108277 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122701 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122701 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of XXXXCFR §XXXX(e)(XXXX)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see BF worksheet. Thank you Rebuttal 2 (XX/XX/XXXX XX:XXPM) Hello, Yes, this is an HPML loan, which is acceptable. We have a full appraisal in the file which is the requirement if loan is HPML. Thank you! |
Response 1 (XX/XX/XXXX XX:XXPM) The Bona Fide Discount Point calculation worksheet was reviewed and tested. The loan is still failing the QM APR threshold. The disclosed Loan APR is XXXX%. The threshold APR is XXXX%. The loan APR exceeds the threshold by XXXX%. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) This finding is not related to the state or federal HPML fails. This finding is in relation to the designation of the loan status and whether it is a Qualified Mortgage or not. The Lender did not designate a QM status on the data tape therefore the loan was treated as if the lender designated it as a Qualified Mortgage. Since the loan exceeds the QM APR Lending Policy thresholds it was cited as an Ev3 finding. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) Loan originated an Non-QM. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122701 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)) Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in the XXXX Financial Code. The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122701 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122701 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2108278 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108278 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122702 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122702 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108279 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108279 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108344 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108344 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108344 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108344 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122703 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122703 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122703 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122703 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Missing/Incomplete | XXXX | The title commitment/policy is incomplete/missing. The Owner and Encumbrance Report provided in the loan file is incomplete/ illegible. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) title attached Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please be specific as to what is wrong with the title. I uploaded this already Rebuttal 3 (XX/XX/XXXX XX:XXPM) Please see attached title. I forgot to click upload last time |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation not received. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) We did not receive it in rebuttal. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122704 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee where 'compensation to' does not reflect a XXXX on the revised CD; Title - Doc Preparation Fee. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122704 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fees was not accepted: Loan Discount Point Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached Trid Cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2122704 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122705 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122705 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Other/Missing | XXXX | The coborrower’s loan application reflected pension income. Per the lender’s guidelines this income can be verified with copies of signed federal income tax returns. The XXXX tax return was not signed by borrowers. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Pension Documentation |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122706 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate, HOA Certificate, and HOA Master Insurance Fees. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122706 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Other | XXXX | The subject loan does not meet Program Parameters. The CD reflects the mortgage with XXXX in the amount of $XXXX was paid off at closing. A review of the O&E Report reflects this mortgage dated XX/XX/XXXX was in first XXXX position. Per the lender’s guidelines proceeds from the CES may not be used to pay off first mortgages. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) copy of first mortgage with XXXX statement/payment history and statement / coupon for XXXXnd and title report to confirm XXXX is in first lien. Rebuttal 2 (XX/XX/XXXX XX:XXPM) copy of updated title from the first mortgage that confirms the XXXX loan is in first position and the XXXX is in second position. |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received does not confirm the XXXX was in the 2nd position at the time of payoff. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122707 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122707 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122707 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)). Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in the XXXXFinancial Code. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122707 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122707 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108345 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108345 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122708 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122708 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Transfer Taxes. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Attached is the COC showing the additional $XXXX added to the transfer tax. Final tax on CD is $XXXX between the State and Intangible taxes. Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please review attached COC. Rebuttal 3 (XX/XX/XXXX XX:XXPM) Please see attached refund package with refund letter, check, XXXX label and PCCD> |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding. The COC issued on XX/XX/XXXX states the reason for the increase is new information was provided, this is not a valid reason without more details. A detailed reason/COC stating what new information caused the increase to the Transfer Taxes is required. A cost to cure in the amount of $XXXX remains. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding. The COC issued on XX/XX/XXXX with more information has been reviewed and does not provide a valid reason for the increase, the E& O report is not a valid reason for the increase, the fee should have been known at time of application. A cost to cure in the amount of $XXXX remains. (XXXX) Response 3 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2122708 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2108346 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the nonrefundable prepaid finance charge test. (XXXX. Code § XXXX-XXXX-XXXX-201(XXXX)) The loan's nonrefundable prepaid finance charge exceeds: XXXX% of the note amount or line of credit for loans on or after XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108346 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108346 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122709 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122709 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122710 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122710 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122710 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)) Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in the XXXX Financial Code. The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122710 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122710 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127805 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127805 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127805 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108347 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108347 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122711 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122711 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108348 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee where 'compensation to' does not reflect a XXXX on the revised CD dated XX/XX/XXXX; Flood Certificate. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108348 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108349 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108349 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122712 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122712 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122713 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122713 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Final Application - Missing | XXXX | The final loan application is missing page XXXX of XXXX which provides the co-borrowers information. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Page XXXX of XXXX |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122714 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122714 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122714 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood Certification Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122714 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122715 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122715 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122715 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood Certification Fee. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122715 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The application lists significant debts that were not verified on the credit report and not independently verified. The file is missing the mortgage statement/information for the first mortgage with XXXX on the subject property in order to confirm the PI payment. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached Mortgage statement |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122716 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the addition to the following fee was not accepted: Title-Search Fee on the revised CD issued XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached PCCD |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122716 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122717 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122717 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | HELOC - Closure Letter | XXXX | Loan file does not contain evidence to verify HELOC Closure as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) please see attached payoff Rebuttal 2 (XX/XX/XXXX XX:XXPM) closeout letter attached |
Response 1 (XX/XX/XXXX XX:XXPM) Please provide evidence of account closure. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122718 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood Certification Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122718 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122719 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | ROR- Incorrect Form/Same creditor (H9) version required (circuits 2nd, 5th, 7th, 8th, 9th, 10th, District of Columbia) | XXXX | The consumer(s) was provided the incorrect RTC version. The consumer is refinancing with the original (same) creditor (-new advance of money with the same creditor). XXXX was provided; however, because the property is located in XXXX, model H-XXXX should have been used. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122719 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122719 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: Without evidence of receipt, it is assumed that the disclosure dated, XX/XX/XXXX, was mailed and therefore not received by the consumer XXXX business days prior to the consummation date, XX/XX/XXXX. If disclosure was delivered electronically, evidence of receipt as well as the consumer's E-consent is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Attached disc tracking & initial disc |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122719 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122720 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122720 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Missing/Incomplete | XXXX | The O&E Report and/or title commitment/policy in the loan file is not legible. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) title attached |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122721 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122721 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | HELOC - Closure Letter | XXXX | Loan file does not contain evidence to verify HELOC Closure as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PAYOFF FOR 2ND lOAN Rebuttal 2 (XX/XX/XXXX XX:XXPM) SIGNED CLOSE OUT LETTER |
Response 1 (XX/XX/XXXX XX:XXAM) The authorization to close is not signed. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122722 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Incomplete | XXXX | The following section of the Security Instrument (Mortgage/Deed of Trust) is incomplete: The development name reflected on the PUD Rider is inconsistent with the development name reflected in the legal description and the previous PUD rider. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) LOI to Re-Record Rebuttal 2 (XX/XX/XXXX XX:XXAM) PUD DOCUMENTATION Rebuttal 3 (XX/XX/XXXX XX:XXAM) DOT for review |
Response 1 (XX/XX/XXXX XX:XXPM) The referenced documentation was not received. Please provide for review. The Letter of Intent cannot be used to cure the exception, re-recording the document is the cure. Please provide evidence when the documents have been recorded. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Letter of Intent cannot be used to cure the exception, re-recording the document is the cure. Please provide evidence when the documents have been recorded. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122722 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122722 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VVOE Salaried/Missing | XXXX | A VVOE is missing from the loan file. The loan file is missing a VVOE dated within XXXX business days of the note date for the borrower as required per guidelines. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) VOE |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122723 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122723 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122724 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122724 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108350 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee where 'compensation to' does not reflect a XXXX on the revised CD dated XX/XX/XXXX; Flood Certificate. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108350 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108351 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108351 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122725 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122725 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108376 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the nonrefundable prepaid finance charge test. (XXXX. Code § XXXX-XXXX-XXXX-201(XXXX)) The loan's nonrefundable prepaid finance charge exceeds: XXXX% of the note amount or line of credit for loans on or after XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108376 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108376 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122726 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122726 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127806 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127806 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122727 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122727 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122727 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122728 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where'compensation to' does not reflect a XXXX on the revised CD. Flood CertificateFee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122728 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108377 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108377 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108377 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX XXXX CMR XXXX higher-priced mortgage loan est. (XXXX XXXX CMR XXXX) Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in the Code of XXXX Regulations. The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2108377 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108377 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122729 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Name Discrepancy | XXXX | Security Instrument - Name Discrepancy. The loan file does not include documentation confirming the vested interest on the Security Instrument or the Borrower's ownership of the subject property. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Please see attached O&E report. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122729 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Missing/Incomplete | XXXX | The title commitment is missing. The loan file did not contain a copy of the Owner and Encumbrance (O&E) report. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Please see attached O&E report. |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2108378 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108378 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127791 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127791 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127792 | 1 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2127792 | 2 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2127792 | 3 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: XXXX and Title-Settlement/Closing Fee paid to the an Affiliate of the Lender. The loan fails the prohibited fees test by $XXXX. The loan is a second lien and charges fees that are not specifically permitted under MRS § XXXX et seq. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2127792 | 4 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: The Closing Disclosure was not received by the borrower at least three business days prior to the Consummation Date. The CD issued on XX/XX/XXXX was signed and dated at consummation, XX/XX/XXXX. If disclosure was delivered electronically evidence of receipt as well as the consumer's E-consent is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) see attached Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please see attached Rebuttal 3 (XX/XX/XXXX XX:XXPM) cd XXXX-XXXX-XXXX attached |
Response 1 (XX/XX/XXXX XX:XXPM) The referenced documentation was not received. Please provide for review. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is notsufficient to cure the finding. The disclosure tracker has been providedreflecting a CD was issued on XX/XX/XXXX. The actual document, CD XX/XX/XXXX needs to be provided to verify it was complete and for accurate testing. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2127792 | 5 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that cannot increase test. Because the loan failed the initial CD delivery date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset as a result of the following increase: Discount Points on the Initial CD issued XX/XX/XXXX. The violation may be cured if documentation is provided showing the disclosure was delivered timely. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) see attached for discount point increase Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please see attached Rebuttal 3 (XX/XX/XXXX XX:XXPM) CD XXXX-XXXX-XXXX attached |
Response 1 (XX/XX/XXXX XX:XXPM) The COC has been provided; however; the receipt to cure the timing violation has not been provided. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding. The disclosure tracker has been provided reflecting a CD was issued on XX/XX/XXXX. The actual document, CD XX/XX/XXXX, needs to be provided to verify it was complete and for accurate testing. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2127792 | 6 of 6 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122730 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122730 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122731 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122731 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122732 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122732 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122733 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122733 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122734 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122734 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - Missing/Insufficient | XXXX | The current hazard insurance in the file reflects a premium of $XXXX. Loan transmittal reflects monthly insurance of $XXXX, or $XXXX annually. The file contains an email XX/XX/XXXX from the insurance agent reflecting a paid receipt provided but due to dwelling increase there is an amount due. Paid receipt and additional amount due missing from the file to confirm the annual premium. Further the policy does not reflect XXXX as 2nd mortgagee. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached. |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122735 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122735 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122735 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122736 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122736 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127793 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - Revised CD Delivery Date (No Waiting Period) | XXXX | This loan failed the revised Closing Disclosure delivery date test (no waiting period required) due to the following: Without evidence of receipt, it is assumed that the disclosure dated, XX/XX/XXXX-XXXX, was mailed, and therefore not received by the consumer prior to the consummation date, XX/XX/XXXX. If disclosure was delivered electronically, evidence of receipt as well as the consumer's E-consent is required. Truth in XXXX (Regulation Z) 12 CFR 1026.19(f)(2)(i) | Upheld | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Attached disclosure tracking Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please be advise that the CD’s issue date of XX/XX/XXXX, do not need a viewed date because they were executed by the borrower. Please clear. Rebuttal 3 (XX/XX/XXXX XX:XXPM) Please note: Per Disclosure Tracking, borrower’s received their CD’s on XX/XX/XXXX XXXX. 1st CD went out at XXXX:38am , borrower wet signed on XX/XX/XXXX XXXX. 2nd CD went out at XXXX:09pm, the only thing that changed was the payoff for XXXX, this was received on XX/XX/XXXX XXXX. Loan didn’t disburse until XX/XX/XXXX We are within TRID Guidelines. Please escalade to clear or waive. Thank you. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The Disclosure Tracker provided does not disclose when the borrower received/viewed the CD XX/XX/XXXX (XXXX). Please provide evidence of receipt for review. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. There were two CD issued on XX/XX/XXXX. The CD XX/XX/XXXX (XXXX) was wet signed. The CD XX/XX/XXXX (XXXX) requires receipt. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The 2nd CD was issued prior to closing taking place. Although the change was minor, there was a change. Per regulation, borrower is to receive changes that are known before closing, to be received by the borrower no later than closing. Disbursement date is not a factor. Closing is considered when the mortgage was signed/notarized. (XXXX) Response 4 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. A new XXXX day waiting period was not required and is not in question. However a change in payoff that was known on XXXX/XXXX (prior to closing) is required to be received by the borrower(s) no later than closing (XXXX/XXXX). Therefore the second CD issued on XXXX/XXXX at XXXX:09pm not being received until after closing occurred, is an issue. See 1026.19(f)(2)(i) (XXXX) |
XXXX | 3 | 3 | 3 | 3 | ||
| XXXX | 2127793 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee | Acknowledged | 2 | 2 | 3 | 3 | |||||
| XXXX | 2127793 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 3 | |||||
| XXXX | 2122737 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122737 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122834 | 1 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | FACTA Disclosure - Missing | XXXX | The FACTA Disclosure (Notice to Home Loan Applicant/Credit Information Disclosure) is missing. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122834 | 2 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | HOC - Missing | XXXX | The Homeownership Counseling Disclosure (HOC) is missing. Real Estate Settlement Procedures Act (Regulation X)12 CFR 1024.20(a) | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122834 | 3 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122834 | 4 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: The Closing Disclosure was not received by the borrower at least three business days prior to the Consummation Date. The CD issued on XX/XX/XXXX was signed and dated at consummation, XX/XX/XXXX. If disclosure was delivered electronically evidence of receipt as well as the consumer's E-consent is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) This closing CD does not have to be delivered to the borrower XXXX days prior to closing The initial CD must be delivered to borrower XXXX days prior to closing. The initial CD was XXXX/XXXX Per the Disclosure Tracking, borrower eConsent on XXXX/XXXX Rebuttal 2 (XX/XX/XXXX XX:XXAM) Please see attached CD dated XXXX/XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding. The disclosure tracker has been provided reflecting a CD was issued on XX/XX/XXXX. The actual document, CD XX/XX/XXXX, needs to be provided to verify it was complete. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122834 | 5 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - LE/Missing | XXXX | The initial and/or any revised Loan Estimate is missing. As a result, a full review for compliance with timing and tolerance requirements could not be performed. Truth in XXXX (Regulation Z)12 CFR 1026.19(e)(1)(i) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Attached are all XXXX and LE COCs |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122834 | 6 of 7 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Missing | XXXX | The loan file is missing income documents; there is no way to determine if the borrower meets the DTI requirements. The guidelines required a written verification of employment covering a XXXX-year period, or the most recent paystub and the prior XXXX years of W-XXXX forms. The loan file did not contain any documentation supporting the qualifying income as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see all VOEs and VOIs attached. |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122834 | 7 of 7 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VVOE Salaried/Missing | XXXX | A VVOE is required within XXXX Business Days of the Note Date. The loan file does not contain a VVOE confirming the borrower's employment as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached VOE - also all VOEs and VOIs. |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122835 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122835 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122836 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122836 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122836 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122836 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122837 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122837 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122838 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122838 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122839 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122839 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122840 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122840 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122840 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: HOA Master Insurance Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122840 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122841 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122841 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122842 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122842 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127794 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127794 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122843 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122843 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122845 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122845 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Other | XXXX | The O&E Report/Title Commitment provided was not legible. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Attached Title legit Rebuttal 2 (XX/XX/XXXX XX:XXPM) Attached Title report |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation not received. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2127795 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Missing Signature | XXXX | The Security Instrument and XXXX-XXXX Rider was not fully executed by all required parties. The signature and XXXX acknowledgment for XXXX was missing. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) DOT ALL PAGES - Rider DOES NOT HAVE A NOTARY PAGE - Notary attests on page XXXX for ENTIRE doc and ALL signatures |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2127795 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fees was not accepted: Appraisal fee and XXXX fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required of which $XXXX was reimbursed at closing, there is a remaining cost to cure of $XXXX required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX increased due to learning of this being a COMPLEX PROPERTY - The LEs were properly updated and disclosure was properly made - The attached COC for the LE change is attached. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2127795 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122846 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122846 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122846 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122846 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122847 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122847 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2108379 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2108379 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122848 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Note - Trust Not Executed | XXXX | Title to the Property is held in a Trust, but the Trust Document is not properly executed. Unable to determine if signatures on Note are accurate. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122848 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Trust Not Executed | XXXX | Title to the Property is held in a Trust, but the Trust Document is not properly executed. Unable to determine if signatures on the Security Instrument are accurate. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122848 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122848 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122849 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122849 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122849 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood Certification Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122849 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122850 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122850 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122850 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122850 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122851 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122851 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122851 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122851 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122852 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122852 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122853 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122853 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122854 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122854 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Property Condition Report, CD XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached PCCD and tracking |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2122854 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122855 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122855 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122856 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122856 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127796 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. HOA Certification Fee and HOA Master Insurance Fee. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2127796 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: HOA Certification Fee, CD XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) TRID CURE |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2127796 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2127797 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2127797 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2127797 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Incomplete | XXXX | The following section of the Security Instrument (Mortgage/Deed of Trust) is incomplete: There was no acknowledgement by the notary on who appeared before them and how their identity was verified. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Recorded DOT attached - The XXXX pages are correct attesting to each signature - This is a standard DOT document for this product and state. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2127797 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. HOA Certification Fee, HOA Master Insurance Fee. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2127797 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122857 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122857 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122857 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Other | XXXX | There are additional findings regarding the title commitment. The required Ownership and Encumbrance report is illegible. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see title. Thank you |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122858 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122858 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122859 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122859 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122860 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood Certification Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122860 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122861 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122861 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122862 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122862 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122862 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where'compensation to' does not reflect a XXXX on the revised CD. Flood CertificateFee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122862 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122863 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood Certification Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122863 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122864 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122864 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122865 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122865 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122866 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122866 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122867 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122867 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122868 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122868 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122868 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122868 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122870 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert and XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122870 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test.A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fees was not accepted: XXXX search. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund.A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached. Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please see attached. |
Response 1 (XX/XX/XXXX XX:XXAM) The COC provided gives a reason of lock/re-lock as the reason for the addition of a lien search fee. This is not a valid reason for this fee. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2122870 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122871 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122871 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122872 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122872 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127798 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2127798 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Occupancy Status | XXXX | The intent and/or status of the borrower's occupancy is not supported in the file. Subject loan was submitted with property being a primary residence. Application states borrower has lived at subject address for XXXX years but income docs, HOI and Fraud report list a different address for borrowers and there is a lease in file that the borrowers have been renting a property since XX/XX/XXXX. Tax Transcripts also show borrowers have been collecting rental income for last XXXX years and HOI policy on subject is a landlord policy. Please provide letter of explanation as to how subject is a primary residence but borrower's live elsewhere. Subject to additional review upon explanation. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see the attached loe from brws regarding additional addresses referenced. Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please the attached from the borrower Rebuttal 3 (XX/XX/XXXX XX:XXPM) LOE provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Explanation does not refute the subject landlord policy and usage of the subject as a rental property. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Explanation confirms the subject is Investment and the XXXX% CLTV exceeds the XXXX% CLTV maximum. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) LOE provided with details of moving around since pandemic. Makes sense and supports property as primary residence. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122873 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Closing Disclosure/Missing | XXXX | There is no evidence of a complete, Closing Disclosure provided in the loan file. As a result the following reviews could not be performed: TILA Accuracy, MDIA, XXXX, XXXX, QM XXXX, XXXX, XXXX, tolerance violation review, and final Closing Disclosure accuracy. Truth in XXXX (Regulation Z)12 CFR 1026.19(f)(1)(i) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached both CDs |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122873 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122874 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122874 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Note - Trust Not Executed | XXXX | Title to the Property is held in a Trust, but the Trust Document is not properly executed. Unable to determine if signatures on Note are accurate. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached executed Trust Certificate Rebuttal 2 (XX/XX/XXXX XX:XXAM) Please see attached Trust Certification |
Response 1 (XX/XX/XXXX XX:XXPM) Documents not received. Please resubmit. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122874 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122874 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee where'compensation to' does not reflect a XXXX on the revised CD datedXX/XX/XXXX; Flood Certificate. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122874 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122875 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122875 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122876 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | ROR - Missing | XXXX | There is no evidence in the file that the Right to Cancel Notice was provided to the borrower and/or all consumers with a right to rescind. Truth in XXXX (Regulation Z)12 CFR 1026.23(b), (a)(1) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) RTC ATTACHED |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122876 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122877 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122877 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122879 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122879 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122880 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122880 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122881 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122881 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122881 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122881 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122882 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122882 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122883 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122883 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122884 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122884 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122885 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood Certification Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122885 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122886 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122886 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122887 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122887 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122888 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Inaccurate | XXXX | The security instrument was not completed accurately. The Vested Interest on the Security Instrument cannot be verified as accurate due to Title Commitment missing from the loan file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached. |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122888 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122888 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Appraisal - Appraisal Missing | XXXX | The loan file did not contain an appraisal or any other approved valuation product as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached Title, Flood, and XXXX |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122888 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Flood Certificate - Missing | XXXX | The flood certificate is missing. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached. |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122888 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Missing/Incomplete | XXXX | The title commitment/ O & E is missing from the loan file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122889 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122889 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122889 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122890 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122890 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122891 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122891 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122892 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122892 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122893 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122893 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122894 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122894 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122895 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122895 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122896 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | ROR- Incorrect Form/Same creditor (H9) version required (circuits 2nd, 5th, 7th, 8th, 9th, 10th, District of Columbia) | XXXX | The consumer(s) was provided the incorrect RTC version. The consumer is refinancing with the original (same) creditor (-new advance of money with the same creditor). XXXX was provided; however, because the property is located in XXXX, model H-XXXX should have been used. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122896 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122897 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122897 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122898 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood Certification Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122898 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122900 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | ROR - Timing | XXXX | The XXXX does not provide the borrower with XXXX business days to rescind the transaction. The rescission date is XXXX business days after the consummation date, the date the borrower receives the Final TIL/HUD-XXXX, or the date the borrower receives the Notice of Right to Cancel, whichever occurs last. The rescission date noted on the Right to Cancel Notice, XX/XX/XXXX is less than three business days from the consummation date, XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.23(b)(1)(v), (a). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please clear condition as there is XXXX business days before closing. See attached from manager. Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please see attached PCCD |
Response 1 (XX/XX/XXXX XX:XXPM) Please provide evidence of the funding date. The Final CD issued on XX/XX/XXXX discloses the CD XXXX/XXXX/ XXXX as the finding date. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122900 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122900 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122901 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122901 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122902 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122902 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122902 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122903 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | State Rules Violation | XXXX | This loan failed the high-cost home loan points and fees threshold test. (XXXX AB XXXX, § XXXX.), (XXXX SB XXXX, § XXXX.)The total points and fees of this loan, which are $XXXX, exceed the following threshold based on the total loan amount, which is $XXXX: the total points and fees exceed XXXX% of the total loan amount if the total loan amount is $XXXX or more. Fees included in the test: Application fee $XXXX, Points $XXXX and Settlement/closing fee $XXXX. If the points are bona fide, please provide the Undiscounted Rate. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached Bona Fide Discount Point Calculation. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122903 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122904 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122904 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122905 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122905 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122906 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122906 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122907 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122907 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122908 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122908 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122909 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122909 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122909 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122910 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX and the calculated APR XXXX, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122910 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ) The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122910 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122910 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122911 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122911 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122912 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122912 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122913 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122913 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127815 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2127815 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Assets - Cash to Close | XXXX | The file did not contain evidence the borrower had the proper amount of funds required to close. The Closing Disclosure reflected the Borrower was required to bring $XXXX to closing; however, the loan file did not contain any asset documentation. Therefore, the borrower was short the required funds to close in the amount of $XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see the attached FINAL PCCD- the borrowers received cash- no proof of assets needed. |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122914 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122914 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122915 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | ROR- Incorrect Form/Same creditor (H9) version required (circuits 2nd, 5th, 7th, 8th, 9th, 10th, District of Columbia) | XXXX | The consumer(s) was provided the incorrect RTC version. The consumer is refinancing with the original (same) creditor (-new advance of money with the same creditor). XXXX was provided; however, because the property is located in XXXX, model H-XXXX should have been used. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122915 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122915 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122916 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122916 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122917 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. The sum of all discount points is greater than XXXX% of the original principal amount. Discount points means any charges, whether or not actually denominated as "discount points," that are paid by the seller or the buyer of residential real property to a residential mortgage lender or that are deducted and retained by a residential mortgage lender from the proceeds of the residential mortgage. "Discount points" does not include the costs associated with settlement services as defined in RESPA. | Acknowledged | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Disagree - attached is the Bonafide discount point calculation |
Response 1 (XX/XX/XXXX XX:XXPM) This is a state regulation citation, not high cost. The statute states any discounts points charged that exceed XXXX% and does not allow for exclusion for points being bona fide. However, this is an Ev2 citation and therefore the original and final strength has been updated from Ev3 to Ev2 and acknowledged per guidelines. (Acknowledged) |
2 | 2 | 2 | 2 | |||
| XXXX | 2122917 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood certification fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122917 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122918 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122918 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122919 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood Certification Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122919 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122920 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122920 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122920 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122920 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | Theloan file is missing documentation to support the omission of XXXX for $XXXX/XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached for verification Rebuttal 2 (XX/XX/XXXX XX:XXPM) Doc provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Closed end loan disclosure received does not omit the referenced debt. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Supplemental credit report provided and reflects account was closed. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122921 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122921 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122922 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122922 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122923 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122923 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122924 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122924 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122924 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)) The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122924 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood certificate fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122924 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122925 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122925 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Other | XXXX | There are additional findings regarding the title commitment. The required Ownership and Encumbrance Report for the subject property is illegible. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) TITLE attached |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122926 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122926 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122929 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122929 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122930 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122930 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122930 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122930 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122931 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122931 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127816 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2127816 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | DTI - Exceeds Guidelines | XXXX | The DTI exceeds Originator Guidelines. The borrowers were qualified with a DTI of XXXX%. The XXXX was qualified with monthly schedule C income of $XXXX. The loan file did not disclose how the borrower’s income was calculated. However, a review of the borrowers’ tax returns revealed the borrower’s actual average self-employment income was $XXXX per month. In addition, loan application disclosed the ownership of a 2nd home with a monthly housing payment of $XXXX, which was not included in the borrowers’ DTI. The loan file did not contain documentation justifying the omission of this debt. Therefore, the borrowers’ DTI was XXXX%. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Please attached XXXX for income & omission of 2nd home payment. Page XXXX-XXXX of original upload shows proof the daughter pays the XXXX account Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please updated SSI, Income worksheet & XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) Payment by others was already taken into consideration. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122932 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122932 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122932 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood certification. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122932 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122933 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122933 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122933 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122933 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122934 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122934 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX% The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122934 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122934 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122935 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122935 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122935 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122935 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122936 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122936 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122937 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122937 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Other | XXXX | The investor guidelines allowed for a Ownership and Encumbrance report. The O & E report provided was illegible. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) copy of title report. Rebuttal 2 (XX/XX/XXXX XX:XXAM) copy of title report |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation not received. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122938 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122938 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122939 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122939 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122940 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122940 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122941 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122941 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122942 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. The loan's nonrefundable prepaid finance charge exceeds: XXXX% of the note amount or line of credit for loans on or after XXXX. | Acknowledged | Rebuttal 1 (XX/XX/XXXX XX:XXPM) See XXXX and XXXX fees |
Response 1 (XX/XX/XXXX XX:XXAM) Points being bona fide does not affect the results of this state prepaid finance charge test. Additionally, the XXXX report provided also confirms an XXXX for this particular state test. However, this is an Ev2 citation and so the strength has been updated and finding acknowledged. |
2 | 2 | 2 | 2 | |||
| XXXX | 2122942 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood certification fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122942 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122943 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122943 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122944 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - Revised CD Delivery Date (No Waiting Period) | XXXX | This loan failed the revised Closing Disclosure delivery date test (no waiting period required) due to the following: Without evidence of receipt, it is assumed that the disclosure dated' XX/XX/XXXX 'was mailed, and therefore not received by the consumer prior to the consummation date,' XX/XX/XXXX. If disclosure was delivered electronically, evidence of receipt as well as the consumer's E-consent is required. Truth in XXXX (Regulation Z)12 CFR 1026.19(f)(2)(i) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) CD tracking |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122944 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122945 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122945 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122945 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122945 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122946 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122946 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122947 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122947 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122948 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122948 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122949 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122949 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122950 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122950 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122951 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - Non-Borrower with Right to Rescind | XXXX | There is no evidence of an initial CD provided to the non-borrower. Per regulation, CD(s) must be provided to all who have the right to rescind. Truth in XXXX (Regulation Z)12 CFR 1026.19(f)(1)(i), 12 CFR 1026.2(a)(11) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Please see attached that confirms all borrowers received the initial CD |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122951 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122951 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122952 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood certification. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122952 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127817 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Inaccurate | XXXX | The security instrument was not completed accurately. The PUD name is incorrect on the PUD Rider. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see revised PUD rider with the addition of XXXX as PUD Name. Thank you! Rebuttal 2 (XX/XX/XXXX XX:XXAM) DOT with PUD rider. Recording will trail |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The PUD rider is acceptable once executed and re-recorded. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2127817 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2127817 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122953 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122953 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122953 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)). The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122953 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122953 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122954 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122954 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122955 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122955 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122956 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122956 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122957 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122957 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127818 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Discount Point Calc |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2127818 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122958 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122958 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122959 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122959 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122960 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122960 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122961 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122961 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122962 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122962 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122963 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122963 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122964 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122964 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122965 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122965 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122966 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122966 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122967 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122967 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122967 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122968 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122968 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122968 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122969 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122969 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122970 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122970 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127819 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2127819 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Settlement and transfer taxes. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required of which $XXXX was reimbursed at closing, a cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached Rebuttal. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2127819 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Flood Certificate - Missing | XXXX | The flood certificate is missing. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Please see attached XXXX. |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122971 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122971 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122972 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122972 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122973 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122973 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122974 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122974 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122974 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122976 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122976 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122977 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122977 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)) The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122977 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122977 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122978 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood certification. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122978 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122979 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122979 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122979 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122979 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127820 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2127820 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Missing/Incomplete | XXXX | The title commitment/policy is missing. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) please see attached Title Report |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122980 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122980 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122981 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: XXXX, CD XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Please see attached Resolution docs. Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please see attached. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding. The LOE, PCCD, and copy of the refund check have been provided. Proof of Delivery is required. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2122981 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122982 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122982 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127821 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Name Discrepancy | XXXX | The Title Report is not legible and vesting cannot be confirmed. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Please see attached Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please see attached |
Response 1 (XX/XX/XXXX XX:XXPM) Document not provided. Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2127821 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | DTI - Exceeds Guidelines | XXXX | The application and XXXX show the borrower is paying of an XXXX loan for $XXXX however that account is not reflected on the final CD. The debt has been added to the DTI calculation bringing the total DTI to XXXX% which is over the allowed tolerance. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached DL showing XXXX payment is made by others - Also XXXX month history is in our original upload page XXXX -XXXX showing it is paid by another Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please see attached DL showing XXXX payment is made by others - Also XXXX month history is in our original upload page XXXX -XXXX showing it is paid by another |
Response 1 (XX/XX/XXXX XX:XXPM) Document not provided. Response 2 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2127821 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Missing/Incomplete | XXXX | The title commitment/policy is missing. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Please see attached Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please see attached |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation not received. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2127822 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the addition to the following fees was not accepted: Title Tax Search. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Attached change of XXXX. Rebuttal 2 (XX/XX/XXXX XX:XXPM) Attached COC. final invoice from title on XXXX/XXXX which included the title tax search fee of $XXXX and we disclosed it to the borrower on CD dated XXXX/XXXX within the XXXX days requirement. Rebuttal 3 (XX/XX/XXXX XX:XXPM) Attached PCCD LOE and XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding. The COC provided on XX/XX/XXXX does not provide a valid reason for the addition of the Title - Tax Search without more details. The COC states the reason for the addition was due to information relied on became inaccurate.. Provide information as to what information became inaccurate for the addition of the Title - Tax Search. A cost to cure in the amount of $XXXX remains. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The COC for the addition of the Title - Tax Search Fee with more details as to why it was added has been provided. However, the addition of the fee due to receiving updated fees/ final invoice from tile is not a valid reason. It does not provide a reason for the addition. A cost to cure int eh amount of $XXXX remains. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2127822 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122983 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122983 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122984 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122984 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122985 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122985 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122986 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122986 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122986 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122986 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122987 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122987 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122987 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122987 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122988 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122988 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122989 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood certification. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122989 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122990 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122990 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122991 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122991 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122992 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122992 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122993 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122993 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122994 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood Certification Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122994 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122995 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122995 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122996 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122996 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2122997 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122997 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122999 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2122999 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2123000 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2123000 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2123001 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2123001 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2123002 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2123002 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2123003 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2123003 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2123004 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2123004 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2123005 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: XXXX. The loan fails the prohibited fees test by $XXXX. (MRS § 408.052(XXXX); 408.233(XXXX)) | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2123005 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2123006 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2123006 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. (12 CFR §1026.43(b)(4), (e)(1)) The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2123006 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2123007 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Inaccurate | XXXX | The security instrument was not completed accurately. The Security instrument shows the Trust dated XX/XX/XXXX however the Trust Cert shows the trust date is XX/XX/XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) The Security Instrument is correct, however, there was a typo on the Trust Cert. Will you be able to accept a correction from us using the Correction Agreement/LPOA we have in the file or will you require borrower to re-execute one? Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please see attached |
Response 1 (XX/XX/XXXX XX:XXPM) We will be able to accept a correction form from you using the correction Agreement/POA. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2123007 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2123007 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2123008 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2123008 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2123009 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee where'compensation to' does not reflect a XXXX on the revised CD. Flood CertificateFee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2123009 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2123010 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2123010 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in Regulation Z The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2123010 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2123010 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Other | XXXX | The subject loan does not meet Program Parameters. The loan file is missing the required Flood Certification to be able to determine if the subject property is in a flood zone or not. Additional conditions may apply. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) See attached copy of XXXX. |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2123011 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2123011 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2123012 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2123012 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127831 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127831 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127832 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: Without evidence of receipt, it is assumed that the disclosure dated XX/XX/XXXX was mailed, and therefore not received by the consumer XXXX business days prior to the consummation date, XX/XX/XXXX disclosure was delivered electronically, evidence of receipt as well as the consumer's E-consent is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) please see disclosure tracking. Also the borrowers signed the One -Time econsent |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2127832 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2127833 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2127833 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127834 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127834 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127834 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127835 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127835 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127835 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2127835 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127836 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127836 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127836 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127837 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2127837 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Other | XXXX | There are additional findings regarding the title commitment. The loan file is missing the Ownership and Encumbrance report as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached Ownership & Encumbrance. |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2127838 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127838 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127839 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX% the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127839 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ).This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127839 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the threshold loan points and fees test. (XXXX. Code, XXXX. XXXX Art. V Div. XXXX Subd. I Sec. XXXX-407(a) "Threshold loan" (XXXX)) The total points and fees of the mortgage exceed XXXX% of the total loan amount in the case that the loan amount is $XXXX or greater, or $XXXX in the case that the loan amount is less than $XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2127839 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2127839 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2123013 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2123013 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127840 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | ROR- Incorrect Form/Same creditor (H9) version required (circuits 2nd, 5th, 7th, 8th, 9th, 10th, District of Columbia) | XXXX | The consumer(s) was provided the incorrect RTC version. The consumer is refinancing with the original (same) creditor (-new advance of money with the same creditor). XXXX was provided; however, because the property is located in XXXX, model H-XXXX should have been used. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2127840 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood Certification Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2127840 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127841 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2127841 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The HOA documentation provided in the loan file is illegible/distorted. It does not contain sufficient information to determine if the document is associated with subject property or if the payment indicated is the HOA or an additional special assessment and the processor certification provided in the loan file is in direct contradiction to the visible information on the HOA document. Unable to verify the HOA monthly payment for the subject property based on the documentation provided. XXXX indicates a higher HOA. Additional conditions may apply. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) hoa dues |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2127841 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Missing/Incomplete | XXXX | The title commitment/policy is incomplete/missing. The ownership and XXXX report provided is distorted/eligible. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) title |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2127842 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2127842 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127844 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127844 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127844 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2127844 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127845 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2127845 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The subject property is located in a XXXX. The loan transmittal reflects a monthly HOA payment of $XXXX; however, the loan file does not reflect any verification of monthly HOA payment. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOA |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2127846 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood Certification Fee. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2127846 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fee was not accepted: Points on XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached TRID Cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2127846 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2123014 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2123014 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127807 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - Closing Information/Disbursement Date | XXXX | The CD issued on XX/XX/XXXX does not reflect the correct Disbursement Date when compared to the ALTA Statement. Truth in XXXX (Regulation Z) 12 CFR 1026.38(a)(3)(iii) | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2127807 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2123015 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood cert. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2123015 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127808 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127808 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ).This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127808 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX, HOA Certification Fee and HOA Master Insurance Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2127808 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127809 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2127809 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Transfer Taxes. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required, of which $XXXX was cured at closing. A remaining cost to cure in the amount of $.XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) copy of refund check, CD , LOE and FED-X |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2127809 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2127810 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127810 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127811 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127811 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127811 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127812 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127812 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 1913908 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Late Fees Test | XXXX | This loan failed the late fees test. The loan has late fees that do not conform to the requirements for the lender's license type in the state where the property is located.' The state regulation of XXXX allows for a maximum XXXX% late fee, the loan has a XXXX% late fee.' The loan fails the late fees test by XXXX%. Please have Digital Risk make note that these loans are acknowledged and that they are Non-Material grade XXXX | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 1913908 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed XXXX prohibited lender fees test. This test includes the following fees: Loan Origination Fee and Processing Fee. The loan fails the prohibited fees test by $XXXX (XXXX §XXXX-XXXXA(e); XXXX XXXX-10(a), (g)) Please have Digital Risk make note that these loans are acknowledged and that they are Non-Material grade XXXX | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 1913908 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 1913908 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is not supported within a 10% variance | XXXX | The AVM did not support the value within a 10% variance. Per guidelines when a XXXX is being used as the appraisal an AVM is to be provided to support. AVM supported but confidence score was under XXXX at XXXX. CDA provided supports the appraised value. As this was the second valuation product, per the rating agencies, this is graded an EV2. (Resolved) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) CDA provided. |
Response 1 (XX/XX/XXXX XX:XXPM) CDA provided supports the appraised value. As this was the second valuation product, per the rating agencies, this is graded an EV2. (Resolved) |
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| XXXX | 1987151 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 1987151 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Credit - Other | XXXX | The loan file did not contain documentation to confirm the first mortgage principal and interest payment. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX MTG STMT |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
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| XXXX | 1987151 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is not supported within a 10% variance | XXXX | The AVM did not support the value within a 10% variance. The lower of the AVM value was used but per the rating agencies this has to be included in the guidelines to be able to do that and it is not. CDA provided and supports the appraised value within 10%. As this was the second valuation product, per the rating agencies, this is graded an EV2 (Resolved) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) CDA provided. |
Response 1 (XX/XX/XXXX XX:XXPM) CDA supports. (Resolved) |
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| XXXX | 2015549 | 1 of 8 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX/XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2015549 | 2 of 8 | XXXX | XXXX | XXXX | XXXX | Compliance | Note - Incomplete / Inaccurate | XXXX | The address in the note has a clerical error with the address. XXXX should be XXXX. Please have XXXX make note that these loans are acknowledged and that they are Non-Material grade XXXX | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2015549 | 3 of 8 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%; The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2015549 | 4 of 8 | XXXX | XXXX | XXXX | XXXX | Compliance | ROR - Other | XXXX | The address in the Right to Cancel Notice has a clerical error with the address. XXXX should be XXXX. Please have Digital Risk make note that these loans are acknowledged and that they are Non-Material grade XXXX | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2015549 | 5 of 8 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Inaccurate | XXXX | The address in the mortgage has a clerical error with the address. XXXX should be XXXX. Please have XXXX make note that these loans are acknowledged and that they are Non-Material grade XXXX | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2015549 | 6 of 8 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - Closing Information/Property Address | XXXX | The CD issued on XX/XX/XXXX does not reflect the correct property address when compared to the Note. XXXX should be XXXX Truth in XXXX (Regulation Z) 12 CFR 1026.38(a)(3)(vi) Please have Digital Risk make note that these loans are acknowledged and that they are Non-Material grade XXXX | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2015549 | 7 of 8 | XXXX | XXXX | XXXX | XXXX | Credit | HELOC - Closure Letter | XXXX | Loan file does not contain evidence to verify HELOC Closure as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HELOC RELEASE |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
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| XXXX | 2015549 | 8 of 8 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is not supported within a 10% variance | XXXX | The AVM did not support the value within a 10% variance. Per guidelines if CU score is above XXXX an AVM is required. AVM provided but did not support within -XXXX% as required. CDA provided and supports the appraised value within 10%. As this was the second valuation product, per the rating agencies, this is graded an EV2. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) CDA provided. |
Response 1 (XX/XX/XXXX XX:XXPM) CDA supports. (Resolved) |
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| XXXX | 2009880 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Late Fees Test | XXXX | This loan failed the late fees test. The loan has late fees that do not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of XXXX allows for a maximum $XXXX late fee; the loan has a $XXXX late fee. The loan fails the late fees test by $XXXX. Please have Digital Risk make note that these loans are acknowledged and that they are Non-Material grade XXXX | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2009880 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2009880 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is not supported within a 10% variance | XXXX | The AVM did not support the value within a 10% variance. Per guidelines when a XXXX is being used as the appraisal an AVM is to be provided to support. AVM did not support, and confidence score was under XXXX at XXXX. CDA provided supports the appraised value within 10%. As this was the second valuation product, per the rating agencies, this is graded an EV2. (Resolved) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) CDA provided. |
Response 1 (XX/XX/XXXX XX:XXPM) CDA supports. (Resolved) |
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| XXXX | 2023971 | 1 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2023971 | 2 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: This loan failed the qualified mortgage APR threshold test. (12 CFR §1026.43(e)(2)(vi)). A qualified mortgage is a covered transaction which, among other requirements, is not negatively amortizing and the note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2023971 | 3 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - Revised CD Delivery Date (Waiting Period, APR) | XXXX | XXXX Required: An APR outside of allowable tolerance required a corrected Closing Disclosure and the corrected Closing Disclosure was not received by the borrower at least three business days prior to the Consummation Date. The APR baseline was reset of XX/XX/XXXX with an APR of XXXX%. On XX/XX/XXXX the APR increased more than XXXX to XXXX%. A new XXXX-day waiting period was required prior to closing. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) XXXX XXXX-XXXX CD AUDIT LOG Rebuttal 2 (XX/XX/XXXX XX:XXPM) XXXX-XXXX CD |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding. The disclosure tracker has been provided reflecting a CD was issued and received on XX/XX/XXXX. The actual document, CD XX/XX/XXXX needs to be provided to verify it was complete. The actual CD is also needed for accurate XXXX, HPML, APR, and Points and Fees testing. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2023971 | 4 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that cannot increase test. Because the loan failed the revised CD delivery date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset as a result of the following increase: Loan Origination Fee. The violation may be cured if documentation is provided showing the disclosure was delivered timely. A total cost to cure in the amount of $XXXX is required, of which $XXXX was cured at closing. A cost to cure in the amount of $XXXX remains. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) XXXX-XXXX CD |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2023971 | 5 of 6 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2023971 | 6 of 6 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10%and all applicable appraisal guidelines were satisfied. Per guidelines if a CU score is over XXXX an AVM must be providedand support the appraisal. A CDA was provided instead and supports original appraised value. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2003845 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2003845 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2003845 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is not supported within a 10% variance | XXXX | Guidelines require when an appraisal is being used a UCDP with a CU score of XXXX or less be in file. The UCDP did not reflect a CU score due to property type therefore an AVM should have been ordered and was not. CDA provided and supports the appraised value. (Resolved) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) CDA provided. |
Response 1 (XX/XX/XXXX XX:XXPM) CDA supports. (Resolved) |
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| XXXX | 2023964 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Colorado Tangible Net Benefit Disclosure - Signature | XXXX | The XXXX Tangible Net Benefit Disclosure in the file was not signed bythe Lender/MLO; MLO XXXX signature is missing. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX NET TANG |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to cure the finding. (Resolved) |
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| XXXX | 2023964 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2023964 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: A qualified mortgage is a covered transaction which, among other requirements, is not negatively amortizing and: The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2023964 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2023964 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10%and all applicable appraisal guidelines were satisfied. Per guidelines if a CU score is over XXXX an AVM must be providedand support the appraisal. AVM provided and supported. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2023966 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2023966 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: This loan failed the qualified mortgage APR threshold test. (12 CFR §1026.43(e)(2)(vi)). A qualified mortgage is a covered transaction which, among other requirements, is not negatively amortizing and the note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2023966 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Recording Fee, CD XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) The XXXX% Fees are tested in the aggregate (not by line item). We disclosed $XXXX in XXXX% fees on the LE&#XXXX;s giving us a XXXX threshold of $XXXX and charged the borrower $XXXX at closing so no refund required. Rebuttal 2 (XX/XX/XXXX XX:XXPM) Pls clarify. Final CD lists Priority Title and SSPL also shows Priority???? Rebuttal 3 (XX/XX/XXXX XX:XXPM) XXXX CURE DOCS |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding. The XXXX used at closing was not on the SPL issued on XX/XX/XXXX and considered Borrower chosen tested with unlimited increase. The only fee included in XXXX% testing is the Recording fee. The Initial LE recording fee was $XXXX, the Final CD recording Fee $XXXX. A cost to cure in the amount of $XXXX remains. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The SPL issued on XX/XX/XXXX was XXXX pages and does list Priority title on the SPL. Updated testing to include the title fees in XXXX% tolerance bucket results in an increased cost to cure in the amount of $XXXX. Only fees charged at closing can be included in the baseline; the only fees disclosed on the LE and charged at closing are the Title- Abstract or Title -Search fee and the Title - Settlement fee, both fees along with the Recording fee increased on the final CD issued on XX/XX/XXXX without a valid COC. A cost to cure in the amount of $XXXX remains. Response 3 (XX/XX/XXXX XX:XXAM) Documentation provided is sufficient to cure the exception. (Resolved) |
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| XXXX | 2023966 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2023966 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | UCDP with CU score was N/A therefore an AVM is required. AVM provided and supports original appraised value. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2023965 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2023965 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2023965 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2023961 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2023961 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: A qualified mortgage is a covered transaction which, among other requirements, is not negatively amortizing and The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX% The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2023961 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2023962 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2023962 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: This loan failed the qualified mortgage APR threshold test. (12 CFR §1026.43(e)(2)(vi)) A qualified mortgage is a covered transaction which, among other requirements, is not negatively amortizing and the note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2023962 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Admin Fee and Processing Fee. The loan fails the prohibited fees test by $XXXX. The loan charges a fee not provided for in the act. A lender is prohibited from charging fees, except those provided for in this act. Please have Digital Risk make note that these loans are acknowledged and that they are Non-Material grade XXXX | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2023962 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2023958 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2023958 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: A qualified mortgage is a covered transaction which, among other requirements, is not negatively amortizing and: the note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2023958 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2023959 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Colorado Tangible Net Benefit Disclosure - Signature | XXXX | The XXXX Tangible Net Benefit Disclosure in the file was not signed by the Lender/MLO; MLO XXXX signature is missing. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NET TANG |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to cure the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2023959 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2023959 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: This loan failed the qualified mortgage APR threshold test. (12 CFR §1026.43(e)(2)(vi)) A qualified mortgage is a covered transaction which, among other requirements, is not negatively amortizing and: The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX% The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2023959 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2023959 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10%and all applicable appraisal guidelines were satisfied. Although not required per guidelines an AVM was provided datedafter the appraisal and supports the original appraised value. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2076545 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APRXXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2076545 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of XXXXCFR §XXXX(e)(XXXX)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2076545 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2037768 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2037768 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | This loan failed the qualified mortgage APR threshold test. (12 CFR §1026.43(e)(2)(vi)). A qualified mortgage is a covered transaction which, among other requirements, is not negatively amortizing and the note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2037768 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Name Discrepancy | XXXX | Title was in the name of a trust but the mortgage was taken out stating the individuals only. There is a QCD in the file dated XX/XX/XXXX with the individuals attempting to grant ownership to the trust. However, this is not relevant as title vesting was already in the name of the trust as of XXXX. The mortgage to be corrected reflecting the name of the trust reflected on title. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) QCD OUT OF TRUST Rebuttal 2 (XX/XX/XXXX XX:XXPM) QCD OUT OF TRUST |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. A certificate of trust was provided and not an appropriate QCD. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to cure the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2037768 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2037765 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Colorado Tangible Net Benefit Disclosure - Signature | XXXX | The XXXX Tangible Net Benefit Disclosure in the file was not signed by the XXXX; XXXX signature is missing. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NET TANG |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2037765 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2037765 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: This loan failed the qualified mortgage APR threshold test. (12 CFR §1026.43(e)(2)(vi)) A qualified mortgage is a covered transaction which, among other requirements, is not negatively amortizing and the note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2037765 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2047517 | 1 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | Colorado Tangible Net Benefit Disclosure - Signature | XXXX | The XXXX Tangible Net Benefit Disclosure in the file was not signed by the XXXX; XXXX signature is missing. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NET TANG |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2047517 | 2 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2047517 | 3 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1))This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2047517 | 4 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - Revised CD Delivery Date (Waiting Period, APR) | XXXX | XXXX Required: An APR outside of allowable tolerance required a corrected Closing Disclosure and the corrected Closing Disclosure was not received by the borrower at least three business days prior to the Consummation Date. The APR increased more than XXXX% on the CD issued XX/XX/XXXX. Evidence of receipt for this CD for XXXX (party with vested interest) was not provided, therefore the mailing rule was applied. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX/XXXX CD AUDIT LOG Rebuttal 2 (XX/XX/XXXX XX:XXPM) XXXX-XXXX CD AUDIT LOG WHEN XXXX ADDED |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The receipt for XXXX was provided however it is the receipt for XXXX that is missing. On a rescindable transaction, receipt date is based on when the last party received the document. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to cure the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2047517 | 5 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that cannot increase test. Because the loan failed the Revised CD delivery date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset as a result of the following increase: Loan Origination on XX/XX/XXXX. The violation may be cured if documentation is provided showing the disclosure was delivered timely. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) E-receipt. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to cure the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2047517 | 6 of 6 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - CLTV | XXXX | The maximum CLTV for a loan with FICO<XXXX is XXXX%; however the subject loan closed with CLTV of XXXX%. The Borrower Credit Score is XXXX. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX INTERNAL EXCEPTION APPROVAL |
Response 1 (XX/XX/XXXX XX:XXAM) Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Investor has approved to waive based on compensating factors. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted compensating factors: 0x30 mortgage history XXXX months reviewed, $XXXX monthly residual income, subject property owned XXXX years. |
Comp factors - 0x30 mortgage history with XXXX months reviewed, $XXXX monthly residual income and has owned subject property XXXX years. | 3 | 2 | 3 | 2 | |
| XXXX | 2047516 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Colorado Tangible Net Benefit Disclosure - Signature | XXXX | The XXXX Tangible Net Benefit Disclosure in the file was not signed by the XXXX; XXXX signature is missing. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NET TANG |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2047516 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - DTI | XXXX | The subject loan does not meet Investor Program Parameters for DTI. The Maximum DTI allowed by guidelines is XXXX%. The loan was approved at XXXX%. Audit reveals the actual DTI was XXXX%. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) MAY I GET YOUR CALCULATIONS PLEASE? THANK YOU~ Rebuttal 2 (XX/XX/XXXX XX:XXPM) XXXX INTERNAL EXCEPTION TO XXXX% |
Response 1 (XX/XX/XXXX XX:XXAM) There is only XXXX difference between Originator and Reviewer calculations. The Originator used first mortgage principal and interest of $XXXX per month. Reviewer used first mortgage principal and interest reflected on the first mortgage statement of $XXXX per month. This is the only difference between origination DTI of XXXX% and audit DTI of XXXX%. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Exception must be granted by Investor. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) Investor approved to waive based on compensating factors. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted Compensating factors: XXXXx30x48 months mortgage history, $XXXX monthly residual income |
Comp factors - 0x30xXXXX months mortgage history and $XXXX monthly residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2047516 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicableappraisal guidelines were satisfied. Per guidelines if a XXXX is used as theappraisal product an AVM is required to support. AVM was provided and supportvalue. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2067809 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2067809 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | DTI - Exceeds Guidelines | XXXX | The DTI exceeds Originator Guidelines. The maximum allowable DTI is XXXX%; however, the subject loan closed with an origination DTI of XXXX%, which exceeds the maximum allowed. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX INTERNAL EXCEPTION APPROVAL Rebuttal 2 (XX/XX/XXXX XX:XXPM) Investor approved to waive. |
Response 1 (XX/XX/XXXX XX:XXPM) Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Investor approved to waive based on compensating factors. (Waived) |
Comp factors - XXXX% CLTV, XXXX years in home and XXXX years on job. | 3 | 2 | 3 | 2 | ||
| XXXX | 2067803 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX% the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 4 | 1 | |||||
| XXXX | 2067803 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Income Documentation - Violation | XXXX | The income is not documented properly according to guides. Per program guidelines, when the borrower is using overtime and or bonus income to qualify, the borrower is required to provide to years of receipt. The loan file did not contain XXXX years history of the borrower receiving Overtime income. Provide additional documentation in the form of year end paystubs or a written VOE to document a XXXX year history of Overtime. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) there is a previous voe in file showing OT income was received at the previous job this accounts for the XXXX yrs |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
4 | 1 | 4 | 1 | |||
| XXXX | 2067801 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX was set was: XX/XX/XXXX. The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2067801 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Loan Amount | XXXX | The loan amount does not meet minimum loan amount requirements under the guidelines. The subject 2nd mortgage loan amount is $XXXX; however, the guidelines require a minimum loan amount of $XXXX. In addition, the guidelines do not reflect an exception would be permitted, and the loan file did not contain an exception. *** Additional Conditions May Apply** | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX INTERNAL EXCEPTION APPROVAL Rebuttal 2 (XX/XX/XXXX XX:XXPM) Investor approved to waive. |
Response 1 (XX/XX/XXXX XX:XXPM) Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Investor approved to waive based on compensating factors. (Waived) |
Comp factors - XXXX and no mortgage or revolving lates on credit report. | 3 | 2 | 3 | 2 | ||
| XXXX | 2067808 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The rate lock date was: XX/XX/XXXX. The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2067808 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Condo - Documentation | XXXX | Loan file did not contain required condo documentation (XXXX, Condo Budget, Project Review). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NOT REQUIRED ON 2ND MTGS |
Response 1 (XX/XX/XXXX XX:XXAM) Explanation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2067808 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | DTI - Exceeds Guidelines | XXXX | The DTI exceeds Originator Guidelines. The maximum allowable DTI is XXXX%; however, the subject loan closed with an origination DTI of XXXX%. At audit it was determined that the first lien P&I payment was higher than the origination underwriter used, per the VOM. Therefore, the audit DTI is XXXX%, which exceeds the maximum allowed. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX INTERNAL EXCEPTION APPROVAL Rebuttal 2 (XX/XX/XXXX XX:XXPM) Investor approved to waive. |
Response 1 (XX/XX/XXXX XX:XXAM) Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Investor approved to waive based on compensating factors. (Waived) |
Comp factors - XXXX, XXXX years at current residence and XXXX% CLTV. | 3 | 2 | 3 | 2 | ||
| XXXX | 2067804 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APRXXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2067804 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Tax Return Documentation Incomplete | XXXX | Tax returns for the previous two (XXXX) years (including all schedules and XXXX forms) were not obtained. The XXXX XXXX Schedule F reflected income from farming was used to qualify. Per the lender's guidelines for self-employed borrower's all pages and schedules of the most recent XXXX years personal tax returns was required. Only XXXX XXXX tax returns was obtained. Additionally, a review of the XXXX transcripts reflected a loss for XXXX | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) We documented the borrower&#XXXX;s s/e for XXXX+ years and the updated guides from June allow us to use only the most recent years&#XXXX; returns to qualify! |
Response 1 (XX/XX/XXXX XX:XXPM) Explanation and documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2064390 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2064390 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: Without evidence of receipt, it is assumed that the disclosure dated XX/XX/XXXX was mailed, and therefore not received by the consumer XXXX business days prior to the consummation date, XX/XX/XXXX. If disclosure was delivered electronically, evidence of receipt as well as the consumer's E-consent is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) XXXX-XXXX CD AUDIT LOG |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to cure the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2064390 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2064383 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2064383 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2064383 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value wassupported within 10% and all applicable appraisal guidelines were satisfied.Per guidelines if a XXXX is used as the appraisal product an AVM is required tosupport. AVM was provided and supported value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2064391 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2064391 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2076548 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX% the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2076548 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of XXXXCFR §XXXX(e)(XXXX)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. truth in XXXX Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2076548 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. XXXX $XXXX, Processing Fee $XXXX. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2076548 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VOE/Missing | XXXX | A VOE is missing from the loan file. The loan file is missing a VOE for the borrower. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) VOE |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2076548 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The CU score is XXXX. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2067802 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2067802 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - $35 Tolerance Threshold/Rescindable | XXXX | The loan failed the Rescission Finance Charge tolerance test. Per the special foreclosure rule under Regulation Z, for loans subject to the right of rescission the Finance Charge is considered inaccurate if the disclosed Finance Charge is understated by more than $XXXX. The final (last revised) CD issued on XX/XX/XXXX has a disclosed Finance Charge of $XXXX, which is less than the system calculated Finance Charge of $XXXX. The Finance Charge on the final CD is understated by $XXXX which is more than the allowable tolerance of $XXXX.The following fees were included in the Finance Charge calculation: Origination Fee $XXXX, Prepaid Interest $XXXX, Settlement /closing Fee XXXX, and Recording Service Fee $XXXX. A cost to cure in the amount of $XXXX is required. Additionally, rescission needs to be reopened. Truth in XXXX (Regulation Z) 12 CFR 1026.23(h)(2)(i) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PLEASE ADVISE WHAT CD YOU ARE LOOKING AT. I DO NOT HAVE A CD GENERATED XXXX/XXXX AND NOT SURE WHERE YOU ARE PICKING THESE FEES UP FROM. Rebuttal 2 (XX/XX/XXXX XX:XXPM) Pls see attached post cd and refund check |
Response 1 (XX/XX/XXXX XX:XXPM) The Original loan file contains a CD issued on XX/XX/XXXX to the borrowers and included in testing. A cost to cure in the amount of $XXXX is required. Additionally, rescission needs to be reopened. Truth in XXXX (Regulation Z) 12 CFR 1026.23(h)(2)(i) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2067802 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2067802 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. Guidelines require when CU score over XXXX, an AVM is required. AVM provided and supported original appraised value. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2064395 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The rate set date was: XX/XX/XXXX. The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2064395 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2076552 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX Rate Set was: XX/XX/XXXX. The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2076552 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: This loan failed the qualified mortgage APR threshold test. (12 CFR §1026.43(e)(2)(vi)). A qualified mortgage is a covered transaction which, among other requirements, is not negatively amortizing and the note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%.The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2076552 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2076552 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. CDA provided and supports the original appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2067810 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Colorado Tangible Net Benefit Disclosure - Signature | XXXX | The XXXX Tangible Net Benefit Disclosure in the file was not signed by the Mortgage Loan Originator. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NET TANG |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to cure the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2067810 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX% the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2067810 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Insufficient Documentation | XXXX | Per Lender's guides, if the borrower has not filed their XXXX tax returns; a completed XXXX tax extension (form XXXX) and XXXX/XXXX tax returns are required to be obtained for self-employed borrowers. The loan file obtains the borrower's XXXX form XXXX and XXXX tax returns; however, XXXX tax returns are missing from the loan file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Business is greater than XXXX yrs old we only need to provide most recent years taxes |
Response 1 (XX/XX/XXXX XX:XXPM) Explanation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2067810 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VOE Self-Employed/Missing | XXXX | The loan file is missing a Verification of Self-Employment for the borrower as required per Lender's guides. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) VOE |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2064393 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2064393 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2064393 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. Guidelines require when CU score is missing, an AVM is required. A CDA was provided and supported original appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2076553 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Colorado Tangible Net Benefit Disclosure - Signature | XXXX | The XXXX Tangible Net Benefit Disclosure in the file was not signed by the XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NET TANG |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2076553 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2076553 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: This loan failed the qualified mortgage APR threshold test. (12 CFR §1026.43(e)(2)(vi)) A qualified mortgage is a covered transaction which, among other requirements, is not negatively amortizing and: The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2076553 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. This loan has points and fees that exceed the points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. Fees included in the test: Loan Origination $XXXX, Processing $XXXX, Discount Points $XXXX. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2076553 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2076554 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2076554 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: This loan failed the qualified mortgage APR threshold test. (12 CFR §1026.43(e)(2)(vi)). A qualified mortgage is a covered transaction which, among other requirements, is not negatively amortizing and the note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2076554 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2068703 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Colorado Tangible Net Benefit Disclosure - Signature | XXXX | The XXXX Tangible Net Benefit Disclosure in the file was not signed by the Mortgage Loan Originator. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NET TANG |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to cure the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2068703 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2068703 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - Missing/Insufficient | XXXX | The loan was missing current hazard insurance policy on the subject property with evidence of XXXX. The hazard insurance policy in file did not contain evidence of perils coverage as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) we need to understand why you are asking this, what are you looking for specifically? Rebuttal 2 (XX/XX/XXXX XX:XXPM) XXXX-XXXX |
Response 1 (XX/XX/XXXX XX:XXAM) The property must be identified on the form as HO-XXXX or indicate all perils are covered. Fire, windstorm, explosion, riot, etc. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2068703 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | HELOC - Closure Letter | XXXX | Loan file does not contain evidence to verify HELOC Closure as required. The subject loan paid off a HELOC with XXXX on the subject property. The Final Closing Disclosure reflected the HELOC being paid off; however, the loan file did not contain a signed HELOC Closure letter as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HELOC CLOSE OUT LETTER |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2076555 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX% the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2076555 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: This loan failed the qualified mortgage APR threshold test. (12 CFR §1026.43(e)(2)(vi)). A qualified mortgage is a covered transaction which, among other requirements, is not negatively amortizing and the note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2076555 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. This loan has points and fees that exceed the points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2076555 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the lender fees test due to one of the following findings: (XXXX §XXXX-XXXXA(e); XXXX XXXX-10(a), (g)). The loan is a second XXXX mortgage and is not a "construction loan" as defined in XXXX General Statutes § XXXX-XXXX (c), was made by a HUD approved lender, and the sum of all lender fees exceeds XXXX% of the principal amount (XXXX XXXX-10(a)). Please have Digital Risk make note that these loans are acknowledged and that they are Non-Material grade XXXX | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2076555 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VVOE Salaried/Missing | XXXX | A VVOE is missing from the loan file. The loan file is missing a VVOE for the borrower. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) VOES |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2064389 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Colorado Tangible Net Benefit Disclosure - Signature | XXXX | The XXXX Tangible Net Benefit Disclosure in the file was not signed by the Mortgage Loan Originator. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NET TANG |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to cure the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2064389 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX% the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2064389 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2064392 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Colorado Tangible Net Benefit Disclosure - Signature | XXXX | The XXXX Tangible Net Benefit Disclosure in the file was not signed by the Mortgage Loan Originator. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NET TANG |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to cure the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2064392 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2064392 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Credit Missing - One or More Reports Missing | XXXX | The credit report is dated XX/XX/XXXX and the loan closed on XX/XX/XXXX. Guidelines require a gap credit report/UDM/No Score Pre Close Credit to be supplied within XXXX days of closing and is missing from the file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) UPDATED GUIDELINES NO LONGER REQUIRE |
Response 1 (XX/XX/XXXX XX:XXAM) Explanation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2076559 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Colorado Tangible Net Benefit Disclosure - Signature | XXXX | The XXXX Tangible Net Benefit Disclosure in the file was not signed by the XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NET TANG |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2076559 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2076559 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2076559 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2064394 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Colorado Tangible Net Benefit Disclosure - Signature | XXXX | The XXXX Tangible Net Benefit Disclosure in the file was not signed by the XXXX | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) net tang |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to cure the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2064394 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2064394 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2076560 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Colorado Tangible Net Benefit Disclosure - Signature | XXXX | The XXXX Tangible Net Benefit Disclosure in the file was not signed by the XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NET TANG |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 3 | |||
| XXXX | 2076560 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 3 | |||||
| XXXX | 2076560 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of XXXXCFR §XXXX(e)(XXXX)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | 3 | 3 | 3 | 3 | ||||||
| XXXX | 2076560 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - Missing/Insufficient | XXXX | The XXXX must either identify the policy as HO3 or reflect All-Perils coverage. Neither was reflected. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX-XXXX |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 3 | |||
| XXXX | 2067800 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2067800 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Tax Return Documentation Incomplete | XXXX | Tax returns for the previous two (XXXX) years (including all schedules and XXXX forms) were not obtained or were not properly retained in the file. XXXX personal tax returns are required to complete the income calculation for the borrower per guidelines. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) business greater than XXXX yrs so only most recent tax returns needs to be provide |
Response 1 (XX/XX/XXXX XX:XXPM) Explanation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2067800 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Tax Transcripts Missing | XXXX | Tax Transcripts were not provided as required. XXXX years of tax transcripts are required and only XXXX was provided. Provide XXXX tax transcripts to validate the required income years per guidelines. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) business greater than XXXX yrs so only most recent tax returns needs to be provide |
Response 1 (XX/XX/XXXX XX:XXPM) Explanation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2067800 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - DTI | XXXX | The subject loan does not meet Investor Program Parameters for DTI. Maximum DTI per the matrix is XXXX% and DTI is verified at XXXX%. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PLEASE ADVISE HOW YOU ARRIVED AT DTI OF XXXX. TY Rebuttal 2 (XX/XX/XXXX XX:XXPM) The mtg ins gets paid out from the escrow account thats included the total payment Rebuttal 3 (XX/XX/XXXX XX:XXPM) Pls see uploaded XXXX internal exception. |
Response 1 (XX/XX/XXXX XX:XXPM) The originator did not include HOA fee and mortgage insurance payment. It should also be noted that the transmittal summary in file reflected a DTI of XXXX%. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) New transmittal provided in rebuttal reflects XXXX%DTI. Please provide Investor exception for the DTI. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) Waver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Investor reviewed condition and elects to waive. Noted compensating factors: XXXX. Subject property owned XXXX years. XXXX. $XXXX monthly residual income. XXXX. 0x30 mortgage history for XXXX+ months. |
XXXX. XXXX CLTV. $XXXX per month residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2068704 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Colorado Tangible Net Benefit Disclosure - Signature | XXXX | The XXXX Tangible Net Benefit Disclosure in the file was not signed by the XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Pls see attached signed document |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to cure the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2068704 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2068704 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - Missing/Insufficient | XXXX | The loan was missing current hazard insurance policy on the subject property with sufficient coverage/replacement cost. The hazard insurance policy in file did not contain evidence of perils coverage as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HAZ DEC PAGE Rebuttal 2 (XX/XX/XXXX XX:XXPM) XXXX-XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) All Perils are not reflected. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2068704 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | HELOC - Closure Letter | XXXX | Loan file does not contain evidence to verify HELOC Closure as required. The subject mortgage closed as a 2nd mortgage refinance of a primary residence with an existing HELOC secured by the subject property being paid off at closing. The Final Closing Disclosure reflected the HELOC being paid off; however, the loan file did not contain a signed HELOC Closure letter as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HELOC CLOSE OUT LETTER |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2076562 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Colorado Tangible Net Benefit Disclosure - Signature | XXXX | The XXXX Tangible Net Benefit Disclosure in the file was not signed by the XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NET TANG |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2076562 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2076562 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: This loan failed the qualified mortgage APR threshold test. (12 CFR §1026.43(e)(2)(vi)) A qualified mortgage is a covered transaction which, among other requirements, is not negatively amortizing and: The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2076562 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | DTI - Exceeds Guidelines | XXXX | The subject closed with a DTI of XXXX. Audit DTI is XXXX. According to guidelines the maximum allowable DTI is XXXX%. No lender exception was provided in the loan file. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX INTERNAL EXCEPTION APPROVAL |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) Response 2 (XX/XX/XXXX XX:XXPM) Apologies. Exception must be granted by Investor. (XXXX) Response 3 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted compensating factors: XXXX. Subject residence owned XXXX years XXXX. $XXXX in monthly residual income XXXX. 1x30 mortgage history since XXXX |
XXXX. XXXX% LTV. $XXXX per month residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2068702 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Colorado Tangible Net Benefit Disclosure - Signature | XXXX | The XXXX Tangible Net Benefit Disclosure in the file was not signed by the XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) net tang |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to cure the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2068702 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2068702 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Flood Certificate - Missing | XXXX | The flood certificate is missing from the loan file as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) FLOOD CERT |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2068702 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - Missing/Insufficient | XXXX | The loan was missing current hazard insurance policy on the subject property with sufficient coverage/replacement cost. The hazard insurance policy in file did not contain evidence of perils coverage as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) we need to understand why you are asking this, what are you looking for specifically? Rebuttal 2 (XX/XX/XXXX XX:XXPM) XXXX-XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) Please provide evidence that the policy is HO-XXXX or that all perils are covered. Fire, Smoke, Windstorm, Explosion, XXXX, etc. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2076565 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Colorado Tangible Net Benefit Disclosure - Signature | XXXX | The XXXX Tangible Net Benefit Disclosure in the file was not signed by the XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NET TANG |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 1 | 1 | |||
| XXXX | 2076565 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2076565 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: This loan failed the qualified mortgage APR threshold test. (12 CFR §1026.43(e)(2)(vi)). A qualified mortgage is a covered transaction which, among other requirements, is not negatively amortizing and: The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2076565 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Incomplete | XXXX | The following section(s) of the Security Instrument (Mortgage/Deed of Trust) is incomplete: Unable to confirm vesting on the new mortgage due to missing Title Commitment. | Void | Rebuttal 1 (XX/XX/XXXX XX:XXPM) WE ONLY REQUIRE TITLE COMMITMENT FOR LOANS GREATER THAN XXXX EQUAL TO $XXXXK. ANTHING LESS A PROPERTY REPORT IS XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) Finding voided. (Void) |
1 | 1 | 1 | 1 | |||
| XXXX | 2076565 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2082201 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX% the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2082201 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2082204 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2082204 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2082205 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2082205 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2082206 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2082206 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2082207 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2082207 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Disclosure - Colorado Tangible Net Benefit Disclosure/Signature | XXXX | The XXXX Tangible Net Benefit Disclosure is not signed by the MLO; MLO signature is missing. Required for all mortgage loans to evidence that the loan is beneficial to the borrower. XXXX Originator Licensing and Mortgage Company Registration XXXX. Rev. XXXX. XXXX. XXXX-XXXX-XXXX; XXXX XXXX. Code Regs. ' XXXX-XXXX, Rule XXXX-XXXX-XXXX, 5(XXXX) / XXXX XXXX. Code Regs. ' XXXX-XXXX, XXXX | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NET TANG |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2082207 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2082208 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2082208 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Recording Service Fee. The loan fails the prohibited fees test by $XXXX. The loan is a second lien and charges fees that are not specifically permitted under MRS § XXXX et seq. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2082208 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2082209 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Colorado Tangible Net Benefit Disclosure - Signature | XXXX | The XXXX Tangible Net Benefit Disclosure in the file was not signed by the Lender. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NET TANG |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2082209 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2082209 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2082210 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Colorado Tangible Net Benefit Disclosure - Signature | XXXX | The XXXX Tangible Net Benefit Disclosure in the file was not signed by the Lender. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NET TANG |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2082210 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2082210 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2082211 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2082211 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104618 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2104618 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)) Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2104618 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - All Perils | XXXX | XXXX, HOI policy must specifically state “All Perils” or meet one of the three options provided in overlay to Correspondent. The lender required all hazard insurance policies to reflect perils coverage, which was not reflected on the hazard insurance policy in the loan file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX FULL POLICY WITH PERILS |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2082203 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Colorado Tangible Net Benefit Disclosure - Signature | XXXX | The XXXX Tangible Net Benefit Disclosure in the file was not signed by the Lender. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NET TANG |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2082203 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2104612 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104612 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104612 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a CDA dated XX/XX/XXXX, which supports the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104620 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fees was not accepted: Title Fees on XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required of which $XXXX was cured at closing. There is a remaining cost to cure required in the amount of $XXXX. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX CURE DOCS |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2104620 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Total of Payments Rescindable | XXXX | This loan failed the TRID foreclosure rescission total of payments test. (12 CFR §1026.23(h)(2)(ii)) The total of payments is $XXXX. The disclosed total of payments charge of $XXXX is not considered accurate for purposes of rescission because it is understated by more than $XXXX. A cost to cure in the amount of $XXXX is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX CURE DOCS |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2104620 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2104624 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and XXXX requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2104624 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - CLTV | XXXX | The subject loan does not meet Program Parameters for CLTV. The subject loan was delivered as an XXXX% CLTV 2nd mortgage refinance of a primary residence condominium. Lender guidelines allow for a maximum CLTV of XXXX% for condominiums. The subject loan does not meet program parameters. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) MATRIX Rebuttal 2 (XX/XX/XXXX XX:XXPM) XXXX-XXXX-MATRIX Rebuttal 3 (XX/XX/XXXX XX:XXPM) Maybe something in the guides they&#XXXX;re seeing? Did we explain that there were typos in there and our last update was a correction, not a change? |
Response 1 (XX/XX/XXXX XX:XXAM) The subject is a condo. Line XXXX of the matrix allows a maximum CLTV of XXXX% for condo properties. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) The loan closed XX/XX/XXXX, which was prior to the updated XX/XX/XXXX matrix. (XXXX) Response 3 (XX/XX/XXXX XX:XXAM) Explanation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2104624 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Credit Score | XXXX | The subject loan was delivered as an XXXX% CLTV 2nd mortgage refinance of a property in XXXX, and the borrower had a qualifying credit XXXX. Lender guidelines require a minimum credit XXXX for XXXX loans. The subject loan does not meet program parameters. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) MTRIX Rebuttal 2 (XX/XX/XXXX XX:XXPM) Maybe something in the guides they&#XXXX;re seeing? Did we explain that there were typos in there and our last update was a correction, not a change? |
Response 1 (XX/XX/XXXX XX:XXAM) The subject is in XXXX. Line XXXX of the matrix utilized at review, allows XXXX with a minimum FICO of XXXX. If the matrix provided in rebuttal supersedes the one utilized for review, please provide the date and confirm if the written additions to the matrix still apply. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Explanation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2104619 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2104619 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | HELOC - Closure Letter | XXXX | The loan file does not contain evidence to verify HELOC Closure as required. The existing second XXXX was paid off on the closing disclosure; however, the XXXX was a HELOC. The loan file did not contain a signed closure letter. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX HELOC CLOSE OUT LETTER |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2104613 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104613 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104631 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test.A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Recording Fee, Settlement Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) PLS PROVIDE YOUR CALCS. THANKS Rebuttal 2 (XX/XX/XXXX XX:XXPM) XXXX CURE DOCS |
Response 1 (XX/XX/XXXX XX:XXPM) The fees included in XXXX% testing are the following: Abstract/Title - Search Fee $XXXX, Settlement Fee $XXXX and Recording Fee $XXXX. The Settlement Fee and Recording Fee increase on the CD issued on XX/XX/XXXX without a valid COC. A cost to cure in the amount of $XXXX remains. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2104631 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - DTI | XXXX | The subject loan was approved at XXXX% DTI. The program maximum per guidelines is XXXX%. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX INTERNAL EXCEPTION APPROVAL |
Response 1 (XX/XX/XXXX XX:XXPM) Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted compensating factors: Subject property owned XXXX years, XXXX qualifying fico, 0x30 mortgage history for XXXX months reviewed |
XXXX. XXXX% CLTV. | 3 | 2 | 3 | 2 | |
| XXXX | 2104631 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. A CDA Dated XX/XX/XXXX supported the appraised value. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2101772 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2101772 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - All Perils | XXXX | XXXX, HOI policy must specifically state “All Perils” or meet one of the three options provided in overlay to Correspondent. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX UPDATED HOI |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2101771 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2101771 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2101771 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM report dated XX/XX/XXXX which supports the original appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104623 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104623 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2101769 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2101769 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2101769 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM report dated XX/XX/XXXX which supports the original appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104610 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104610 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104610 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a AVM, dated XX/XX/XXXX, which supports the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104629 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2104629 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | DTI - Exceeds Guidelines | XXXX | The matrix states the max DTI is XXXX%. The subject loan was approved with a DTI of XXXX% and audit found a DTI of XXXX% both exceeding guidelines. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX INTERNAL EXCEPTION APPROVAL |
Response 1 (XX/XX/XXXX XX:XXPM) Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted compensating factors: Subject property owned XXXX years, Self employed XXXX years, $XXXX monthly residual income |
XXXX. XXXX% CLTV. | 3 | 2 | 3 | 2 | |
| XXXX | 2104629 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a AVM, dated XX/XX/XXXX, which supports the appraised value. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2104622 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104622 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2101773 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2101773 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2101773 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - DTI | XXXX | The subject loan was approved with a DTI of XXXX%, and the review DTI was XXXX%. The maximum allowed DTI per guidelines is XXXX%. The subject loan did not meet program parameters for DTI. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX INTERNAL EXCEPTION APPROVAL |
Response 1 (XX/XX/XXXX XX:XXPM) Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted compensating factors: Subject property owned XXXX years, XXXX years with employer, $XXXX monthly residual income |
XXXX. XXXX% CLTV. $XXXX per month residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2101773 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. AVM was provided and did not support original appraised value. A CDA was then provided and supports. As this is a second valuation product, per the rating agencies this is an EV2 grade. | Cleared | 2 | 2 | 3 | 2 | |||||
| XXXX | 2101780 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Colorado Tangible Net Benefit Disclosure - Signature | XXXX | The XXXX Tangible Net Benefit Disclosure in the file was not signed by the MLO; MLO, XXXX signature is missing. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NET TANG |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2101780 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2101780 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a AVM dated XX/XX/XXXX which supports the appraised value. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2104628 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104628 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104628 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a AVM dated XX/XX/XXXX which supports the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2101779 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2101779 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - All Perils | XXXX | XXXX, HOI policy must specifically state “All Perils” or meet one of the three options provided in overlay to Correspondent. The lender required all hazard insurance policies to reflect perils coverage, which was not reflected on the hazard insurance policy in the loan file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOI WITH PERILS |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2101779 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a AVM dated XX/XX/XXXX which supports the appraised value. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2104626 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104626 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)) Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104626 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2101782 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2101782 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2101782 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM report dated XX/XX/XXXX which supports the original appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104611 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2104611 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Credit Missing - One or More Reports Missing | XXXX | The credit report is dated XX/XX/XXXX and the loan closed XX/XX/XXXX which is XXXX days from the credit report date. Guidelines require a gap credit report/UDM/no score pre close credit within XXXX days of the closing date and not provided in the file. The UDM within the Drive Report reflects monitoring not started on the borrower. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PLS WAIVE. XXXX NO LONGER REQUIRES |
Response 1 (XX/XX/XXXX XX:XXPM) Guide available at review still required. Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted compensating factors: XXXX years with same employer, subject property owned XXXX years, credit report is not over XXXX days old from closing. |
XXXX. XXXX% CLTV. $XXXX per month residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2104611 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. File contains AVM which supports the exterior only appraisal XXXX. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2104625 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104625 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104616 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104616 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2104630 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: Without evidence of receipt, it is assumed that the disclosure dated XX/XX/XXXX was mailed, and therefore not received by the consumer XXXX business days prior to the consummation date, XX/XX/XXXX. If disclosure was delivered electronically, evidence of receipt as well as the consumer's E-consent is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX XXXX-XXXX CD AUDIT LOG |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2104630 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (Revised Disclosure Late) | XXXX | The loan failed the charges that cannot increase test.Because the change occurred on XX/XX/XXXX, and consumer was not provided the disclosure within XXXX days of the change, the increase to the following fees was not accepted as valid: XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. | Resolved | Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | ||||
| XXXX | 2104630 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - Missing/Insufficient | XXXX | The loan was missing current hazard insurance policy on the subject property with sufficient coverage/replacement cost. The subject property was an attached PUD, and a walls in policy was presented for the Borrower but the master policy for the building was not provided. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Homeowners Insurance Fixed Rate The hazard insurance policy is acceptable if all of the following requirements are met: • The policy shows the subject property address, the effective dates, the total annual premium, and existing dwelling coverage amount. Replacement cost estimators or increases in coverage are not required regardless of outstanding lien amounts Rebuttal 2 (XX/XX/XXXX XX:XXPM) XXXX MASTER |
Response 1 (XX/XX/XXXX XX:XXPM) Still missing master policy. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2104630 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - DTI | XXXX | The subject loan does not meet Investor Program Parameters for DTI. The Approval DTI was XXXX%, and the program maximum was XXXX%. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX XXXX INTERNAL EXCEPTION APPROVAL |
Response 1 (XX/XX/XXXX XX:XXPM) Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted compensating factors: Subject property owned XXXX years, XXXX years same employer, 0x30 mortgage history for XXXX months reviewed |
XXXX. XXXX% CLTV. | 3 | 2 | 3 | 2 | |
| XXXX | 2104630 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. An AVM dated XX/XX/XXXX supported the appraised value. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2101775 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2101775 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - All Perils | XXXX | XXXX, HOI policy must specifically state “All Perils” or meet one of the three options provided in overlay to Correspondent. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOI PERILS |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2101775 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. An AVM dated XX/XX/XXXX supported the appraised value. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2101770 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2101770 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2101770 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. An AVM dated XX/XX/XXXX supported the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2101777 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2101777 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The loan application indicated that the borrower owned a second home with a $XXXX XXXX payment on the property. The file does not contain documentation indicating the taxes and HOI are escrowed. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX DOCS |
Response 1 (XX/XX/XXXX XX:XXAM) The property is not escrowed. Taxes and insurance take the DTI to XXXX%. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted Compensating factors: XXXX qualifying credit score, subject property owned XXXX years, XXXX years with employer |
XXXX. XXXX% CLTV. | 3 | 2 | 3 | 2 | |
| XXXX | 2101777 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is not supported within a 10% variance | XXXX | The AVM did not support the value within a 10% variance, confidence score was below XXXX, or there was no hit. The loan file did not contain a CDA, Field Review, or 2nd Appraisal to support the origination appraised value. The loan file did not contain a CDA. | Acknowledged | Rebuttal 1 (XX/XX/XXXX XX:XXAM) The AVM in the file came in at XXXX the appraised value came in at XXXX the value is supported by the avm? |
Response 1 (XX/XX/XXXX XX:XXPM) AVM is in file and supports the original appraised value but the Confidence score is XXXX and per the rating agencies is required to be XXXX or above. Please provide another valuation product that supports. Also, if a second valuation report does support the grading will be an EV2 (non-material) per the rating agencies. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Additional secondary valuation product support. EV2 rating. (Acknowledged) |
XXXX (XX/XX/XXXX XX:XXAM) field review uploaded |
3 | 2 | 3 | 2 | ||
| XXXX | 2104614 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2104614 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This loan failed the lender prohibited fees test. (XXXX XXXXC.S.§6122(a)). This test includes the following fees: Processing Fee. The loan fails the prohibited fees test by $XXXX. The loan charges a fee not provided for in the act. A lender is prohibited from charging fees, except those provided for in this act. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2104614 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Credit Missing - One or More Reports Missing | XXXX | The credit report is dated XX/XX/XXXX and the loan closed XX/XX/XXXX which is XXXX days from the credit report date. Guidelines require a gap credit report/UDM/no score pre close credit within XXXX days of the closing date and not provided in the file. The UDM within the Drive Report reflects monitoring not started on the borrower. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXAM) PLS WAIVE. XXXX NO LONGER REQUIRES. |
Response 1 (XX/XX/XXXX XX:XXPM) Guide current at review still requires. Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted Compensating factors: Subject property owned XXXX years, XXXX years with same employer. |
XXXX. XXXX% DTI. XXXX% CLTV. | 3 | 2 | 3 | 2 | |
| XXXX | 2104621 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2104621 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - $35 Tolerance Threshold/Rescindable | XXXX | This loan failed the TILA foreclosure rescission finance charge test. (12 CFR §1026.23(h), transferred from 12 CFR §226.23(h)) The finance charge is $XXXX. The disclosed finance charge of $XXXX is not considered accurate for purposes of rescission because it is understated by more than $XXXX. A cost to cure in the amount of $XXXX is required. Additionally, rescission needs to be reopened. Truth in XXXX (Regulation Z) 12 CFR 1026.23(h)(2)(i) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2104621 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Total of Payments Rescindable | XXXX | This loan failed the TRID foreclosure rescission total of payments test. (12 CFR §1026.23(h)(2)(ii)) The total of payments is $XXXX. The disclosed total of payments charge of $XXXX is not considered accurate for purposes of rescission because it is understated by more than $XXXX. A cost to cure in the amount of XXXX is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX CURE DOCS |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2104621 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - All Perils | XXXX | XXXX, HOI policy must specifically state “All Perils” or meet one of the three options provided in overlay to Correspondent. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOI PERILS |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2104621 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. File contains CDA dated XX/XX/XXXX which supports the appraised value. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2114516 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2114516 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Other/Missing | XXXX | According to guidelines for self employed borrowers all pages and schedules of the most recent XXXX years personal and business tax returns are required. The loan file only contains XXXX personal and business return. Additional conditions may apply. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) RETURNS AND TRANSCRIPTS Rebuttal 2 (XX/XX/XXXX XX:XXPM) GUIDELINES Rebuttal 3 (XX/XX/XXXX XX:XXAM) TRANSCRIPTS Rebuttal 4 (XX/XX/XXXX XX:XXPM) BIZ RETURNS |
Response 1 (XX/XX/XXXX XX:XXAM) Still missing XXXX business returns. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Pages XXXX and XXXX of the guide support the finding. (XXXX) Response 3 (XX/XX/XXXX XX:XXAM) Still missing XXXX Business returns. (XXXX) Response 4 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2104617 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2104617 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - All Perils | XXXX | XXXX, HOI policy must specifically state “All Perils” or meet one of the three options provided in overlay to Correspondent. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOI PERILS |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2104627 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2104627 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Credit Missing - One or More Reports Missing | XXXX | Not all required credit reports are within the file. Guidelines require a Gap Credit Report/UDM/No Score Pre Close Credit to be supplied within XXXX days of closing. The credit report is dated XX/XX/XXXX and the loan closed XX/XX/XXXX. The file did not contain the additional report as required. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PLS WAIVE. XXXX NO LONGER REQUIRES. THANKS |
Response 1 (XX/XX/XXXX XX:XXPM) Guide current at review still requires. Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted Compensating factors: XXXX% DTI, Subject property owned XXXX years |
XXXX. XXXX% DTI. $XXXX per month residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2101776 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2101776 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2101776 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM dated XX/XX/XXXX, which supports. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2101781 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2101781 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - All Perils | XXXX | XXXX, HOI policy must specifically state “All Perils” or meet one of the three options provided in overlay to Correspondent. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) HOI WITH PERILS |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2101781 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM dated XX/XX/XXXX, which supports the appraised value. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2101778 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2101778 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Income - W2(s) Missing | XXXX | Per Lender's guides, the borrower is required to provide XXXX years of W2s or a year end pay stub if the W2s are not available. The borrower provided XXXX W2s. However, the loan file does not contain a XXXX W2 as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX RETURNS |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2101778 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM dated XX/XX/XXXX, which supports the appraised value. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2104615 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2104615 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)) Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in the XXXX Financial Code. The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2104615 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Credit Missing - One or More Reports Missing | XXXX | Not all required credit reports are within the file. Guidelines require a Gap Credit Report/UDM/No Score Pre Close Credit to be supplied within XXXX days of closing. The credit report is dated XX/XX/XXXX and the loan closed XX/XX/XXXX. The file did not contain the additional report as required. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXAM) PLS WAIVE. XXXX NO LONGER REQUIRES GAP CREDIT RPTS |
Response 1 (XX/XX/XXXX XX:XXPM) Guide current at review still requires. Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted compensating factors: XXXX% DTI, $XXXX monthly residual income, Subject property owned XXXX years. |
XXXX. XXXX% CLTV. XXXX% LTV. | 3 | 2 | 3 | 2 | |
| XXXX | 2129585 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX%and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2129585 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - DTI | XXXX | Per Lender's guides, the max DTI is XXXX%. The borrower's audit DTI is XXXX%, which exceeds the max DTI of XXXX%. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX XXXX INTERNAL EXCEPTION APPROVAL |
Response 1 (XX/XX/XXXX XX:XXAM) Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Investor reviewed and elects to waive. Noted Compensating factors: Subject property owned XXXX years, Job stability XXXX years, XXXX% LTV |
XXXX% CLTV. $XXXX per month residual income. XXXX. | 3 | 2 | 3 | 2 | |
| XXXX | 2109720 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX Rate Set was: XX/XX/XXXX. The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2109720 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)). Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in the XXXX Financial Code. The loan is a compliant HPML. Prepayment, and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2109720 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VOE/Missing | XXXX | A VOE is missing from the loan file. The loan file is missing a VOE for the borrower. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) VO |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2101774 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2101774 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Credit Missing - One or More Reports Missing | XXXX | Not all required credit reports are within the file. Guidelines require a Gap Credit Report/UDM/No Score Pre Close Credit to be supplied within XXXX days of closing. The credit report is dated XX/XX/XXXX and the loan closed XX/XX/XXXX. The file did not contain the additional report as required. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXAM) PLS WAIVE. XXXX NO LONGER REQUIRE GAP CREDIT RPT |
Response 1 (XX/XX/XXXX XX:XXPM) Guide current at review still requires. Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted compensating factors: Subject property owned XXXX years, XXXX% DTI |
XXXX% DTI. $XXXX per month residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2125717 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2125717 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | DTI - Exceeds Guidelines | XXXX | Guidelines allow for a maximum XXXX% DTI; however, the loan closed with a DTI of XXXX%, which exceeds the maximum. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX INTERNAL EXCEPTION APPROVAL |
Response 1 (XX/XX/XXXX XX:XXAM) Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted Compensating factors: Subject property owned XXXX years, XXXX qualifying credit score, 0x30 mortgage history for XXXX months reviewed. |
XXXX. $XXXX per month residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2109721 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX Rate Set was: XX/XX/XXXX. The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2109721 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the prohibited fees test. XXXX loans may fall into more than one loan category at the same time. A fee is allowed if authorized by one or more statutes that apply. Otherwise fees are prohibited: The loan is a Home Acquisition Loan (XXXX Code §535.8(XXXX)) the lender may collect fees as allowed by statute. (XXXX Code §535.8(XXXX), XXXX v. XXXX. XXXX N.W.d2 XXXX). Prohibited Fee included in test; XXXX payable to someone other than the XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2109721 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2109721 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM, dated XX/XX/XXXX which supports the appraised value. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2109722 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2109722 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2109723 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX Rate Set was: XX/XX/XXXX. The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2109723 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2109723 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM, dated XX/XX/XXXX which supports the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2109724 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2109724 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2109724 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a BPO, dated XX/XX/XXXX which supports the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2109725 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2109725 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2109725 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a AVM, dated XX/XX/XXXX which supports the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2114517 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX% the loan is a higher-priced mortgage loan, as defined in Regulation Z. Date Rate Set was: XX/XX/XXXX. The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2114517 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Business Tax Returns | XXXX | Copies of XXXX years signed federal business income tax returns (including all schedules) were not obtained or were not properly retained in the file. The loan file contained a copy of the XXXX returns; however, XXXX years were required and the XXXX returns were not present in the loan file. Further, the XXXX transcripts are not present in the loan file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Our guides are if we can prove he has been SE for XXXX+ years we only need the most recent year. The Business License shows he has been SE since XXXX Rebuttal 2 (XX/XX/XXXX XX:XXPM) GUIDELINES |
Response 1 (XX/XX/XXXX XX:XXAM) Please provide the guide that allows only XXXX year. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2114517 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - DTI | XXXX | The subject loan does not meet Investor Program Parameters for DTI. The maximum DTI allowed is XXXX%. The subject loan was approved with a DTI of XXXX%, which exceeds the maximum allowed. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXAM) INTERNAL EXCEPTION |
Response 1 (XX/XX/XXXX XX:XXAM) Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted compensating factors: Self-employed XXXX years, $XXXX monthly residual income, 0x30 mortgage history for XXXX months reviewed |
XXXX. XXXX% CLTV. $XXXX per month residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2129041 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129041 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2109726 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2109726 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Missing/Incomplete | XXXX | The title commitment/policy or the O&E report is missing from the loan file as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) PROP RPT |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2109726 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contained a BPO dated XX/XX/XXXX that supported the value. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2114518 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | ROR - Missing | XXXX | There is no evidence in the file that the Right to Cancel Notice was provided to the borrower and all consumers with a right to rescind. Truth in XXXX (Regulation Z) 12 CFR 1026.23(b), (a)(1) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) XXXX RTCS |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2114518 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2114518 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contained an AVM dated XX/XX/XXXX that supported the value. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2114519 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2114519 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Name Discrepancy | XXXX | The Vested Interest on the Security Instrument cannot be verified as accurate due to Title Commitment missing from the loan file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) prop rpt |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2114519 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Income - W2(s) Missing | XXXX | The investor guidelines required XXXX years of XXXX's to support income. The XXXX W2 for the co-borrower was not provided. Additionally, the XXXX W2 for the co-borrower was illegible. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) W2&#XXXX;S |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2114519 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Missing/Incomplete | XXXX | The investor guidelines required an owner and encumbrance report (property report). Required documentation was not provided. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) PROP RPT |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2109727 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2109727 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2109728 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2109728 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2109728 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. A XXXX BPO dated XX/XX/XXXX was provided and supported the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2109729 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2109729 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Name Discrepancy | XXXX | The Vested Interest on the Security Instrument cannot be verified as accurate due to Title Commitment missing from the loan file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PLEASE REVIEW PROP RPT THAT HAS ALREADY BEEN SATISFIED AND ADVISE |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2109729 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Missing/Incomplete | XXXX | The investor guidelines required an owner and encumbrance report (property report). Required documentation was not provided. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) PROP RPT |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2109730 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2109730 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2114520 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2114520 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Credit - Other | XXXX | There are additional observations that could impact the credit decision and/or quality of the loan. The subject loan is a 2nd mortgage cash out refinance that paid off an existing HELOC with the proceeds.; however, the loan file did not contain the Request for the HELOC Closure as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HELOC CLOSE OUT LETTER |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2114520 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Tax Return Documentation Incomplete | XXXX | Tax returns for the previous two (XXXX) years (including all schedules and XXXX forms) were not obtained or were not properly retained in the file as required for self employed borrowers per the guidelines. The loan file contained only XXXX year for XXXX of personal and business returns. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Our guides are if we can prove he has been SE for XXXX+ years we only need the most recent year. The Business License shows he has been SE since XXXX Rebuttal 2 (XX/XX/XXXX XX:XXPM) GUIDELINES |
Response 1 (XX/XX/XXXX XX:XXAM) Please provide the guide that allows only XXXX year. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2114520 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contained an AVM dated XX/XX/XXXX that supported the value. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122523 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122523 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129586 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2129586 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | DTI - Exceeds Guidelines | XXXX | The DTI exceeds Originator Guidelines. Origination and Audit DTI are XXXX%, which exceeds the max of XXXX%. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX XXXX INTERNAL EXCEPTION APPROVAL |
Response 1 (XX/XX/XXXX XX:XXAM) Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Investor reviewed and elects to waive. Noted Compensating factors: $XXXX monthly residual income, Subject property owned XXXX years, XXXX years job stability. |
$XXXX per month residual income. XXXX% CLTV. | 3 | 2 | 3 | 2 | |
| XXXX | 2125718 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2125718 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fee was not accepted: Title - Lender's Title Policy on the revised CD issued on XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumers, PCCD and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX CURE DOCS |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2125718 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2120088 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2120088 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2120088 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM, dated XX/XX/XXXX which supports the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2120089 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2120089 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | HELOC - Closure Letter | XXXX | Loan file does not contain evidence to verify HELOC Closure as required. The existing HELOC was paid at closing; however, a signed closure letter is missing from the loan file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HELOC CLOSE OUT LETTER |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2120089 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a AVM, dated XX/XX/XXXX which supports the appraised value. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2120090 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2120090 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - All Perils | XXXX | XXXX, HOI policy must specifically state “All Perils” or meet one of the three options provided in overlay to Correspondent. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX PERILS COVERAGE |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2120090 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM, dated XX/XX/XXXX which supports the appraised value. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122524 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122524 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Credit Missing - One or More Reports Missing | XXXX | Not all required credit reports are within the file. Guidelines require a Gap Credit Report/UDM/No Score Pre Close Credit to be supplied within XXXX days of closing. The credit report is dated XX/XX/XXXX and the loan closed XX/XX/XXXX. The file did not contain the additional report as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PLS WAIVE. XXXX NO LONGER REQUIRES |
Response 1 (XX/XX/XXXX XX:XXAM) Explanation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2120091 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and XXXX requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2120091 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2120091 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Settlement or Closing Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) COC |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2120091 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - All Perils | XXXX | XXXX, HOI policy must specifically state “All Perils” or meet one of the three options provided in overlay to Correspondent. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PERILS |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2120092 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2120092 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - All Perils | XXXX | XXXX, HOI policy must specifically state “All Perils” or meet one of the three options provided in overlay to Correspondent. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PERILS |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2125719 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2125719 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in the XXXX Financial Code. The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2125719 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - DTI | XXXX | The subject loan does not meet Investor Program Parameters for DTI. The loan was approved with a DTI of XXXX%. This DTI included a debt with XXXXCB with a payment of $XXXX from the credit report dated XX/XX/XXXX. The file contained an updated credit report dated XX/XX/XXXX which reflected the payment for this debt as $XXXX. The DTI increased from XXXX% to XXXX% and the maximum allowed is XXXX%. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) XXXX UPDATED XXXX AND UPDATED XXXX Rebuttal 2 (XX/XX/XXXX XX:XXAM) OT WAS ADDED. PLEASE RE-REVIEW. TY |
Response 1 (XX/XX/XXXX XX:XXAM) Updated XXXX and XXXX are not sufficient. Please provide detailed explanation and documentation, if applicable, of how the XXXX% DTI was achieved. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2120093 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2120093 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - All Perils | XXXX | XXXX, HOI policy must specifically state “All Perils” or meet one of the three options provided in overlay to Correspondent. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PERILS |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2120093 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | HELOC - Closure Letter | XXXX | Loan file does not contain evidence to verify HELOC Closure as required. The existing HELOC was paid at closing; however, a signed closure letter is missing from the loan file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HELOC CLOSER OUT LETTER |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122525 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122525 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the discount fee test. (XXXX. §XXXX:11C-XXXX, XXXX. §§XXXX:XXXX-XXXX). The loan charges a discount fee that exceeds XXXX% of the principal amount of the loan. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122525 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | This loan failed the initial closing disclosure delivery date test due to the following finding: Without evidence of receipt, it is assumed that the disclosure dated XX/XX/XXXX was mailed, and therefore not received by the consumer XXXX business days prior to the consummation date, XX/XX/XXXX. If disclosure was delivered electronically, evidence of receipt as well as the consumer's E-consent is required. (12 CFR §1026.19(f)(1)(ii)) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) INIITAL CD AUDIT LOG |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122525 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2120095 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2120095 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2120096 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fee was not accepted: Recording Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX UPDATED COC |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2120096 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122526 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122526 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Credit Missing - One or More Reports Missing | XXXX | Credit report dated XX/XX/XXXX. The loan closed XX/XX/XXXX. Guidelines require a Gap Credit Report/UDM/No Score Pre Close Credit within XXXX days of closing and is missing from the file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PLS WAIVE. XXXX NO LONGER REQUIRES |
Response 1 (XX/XX/XXXX XX:XXAM) Explanation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122526 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. File contains AVM which supports the appraised value. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2120097 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2120097 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2125720 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2125720 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX COMAR higher-priced mortgage loan test. (XXXX COMAR 09.03.06.02B(XXXX), COMAR XXXX)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in the Code of XXXX Regulations (COMAR). The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2125720 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fee was not accepted: Recording fee on the revised CD issued on XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer, PCCD and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX CURE DOCS |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2125720 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | DTI - Exceeds Guidelines | XXXX | Guidelines allow for a maximum XXXX% DTI; however, the loan closed with a DTI of XXXX%, which exceeds the maximum. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX INTERNAL EXCEPTION APPROVAL |
Response 1 (XX/XX/XXXX XX:XXAM) Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted compensating factors: $XXXX monthly residual income, Subject property owned XXXX years, XXXX% LTV |
XXXX% CLTV. $XXXX per month residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2125720 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. CDA in file supported original appraised value. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2120098 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2120098 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2120098 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is not supported within a 10% variance | XXXX | The AVM did not support the value within a 10% variance. AVM provided and did not support withing a -XXXX% tolerance. Another valuation product will need to be provided. | Acknowledged | Rebuttal 1 (XX/XX/XXXX XX:XXAM) XXXX AVM |
Response 1 (XX/XX/XXXX XX:XXAM) CDA received supports value. Downgraded to EV2. (Acknowledged) |
3 | 2 | 3 | 2 | |||
| XXXX | 2122527 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and XXXX requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2122527 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Processing Fee. The loan fails the prohibited fees test by $XXXX. This loan failed the lender prohibited fees test. (XXXX XXXXXXXX §6122(a)). The loan charges a fee not provided for in the act. A lender is prohibited from charging fees, except those provided for in this act. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2122527 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Credit Missing - One or More Reports Missing | XXXX | Credit report dated XX/XX/XXXX. The loan closed XX/XX/XXXX. Guidelines require a Gap Credit Report/UDM/No Score Pre Close Credit within XXXX days of closing and is missing from the file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PLS WAIVE. XXXX NO LONGER REQUIRES |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2122528 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122528 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129042 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129042 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129042 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM, which supports value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2125721 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2125721 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Credit Missing - One or More Reports Missing | XXXX | Credit report dated XX/XX/XXXX. The loan closed XX/XX/XXXX. Guidelines require a Gap Credit Report/UDM/No Score Pre Close Credit within XXXX days of closing and is missing from the file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PLS WAIVE. XXXX NO LONGER REQUIRES |
Response 1 (XX/XX/XXXX XX:XXAM) Explanation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2125721 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Loan Amount | XXXX | Loan closed with a loan amount of $XXXX. The required minimum loan amount is $XXXX. The loan amount does not meet the required guideline. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX INTERNAL EXCEPTION APPROVAL |
Response 1 (XX/XX/XXXX XX:XXAM) Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted Compensating factors: Subject property owned XXXX years, Job stability of XXXX years, XXXX qualifying credit score. |
XXXX. $XXXX per month residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2122529 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2122529 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Credit Missing - One or More Reports Missing | XXXX | Credit report dated XX/XX/XXXX. The loan closed XX/XX/XXXX. Guidelines require a Gap Credit Report/UDM/No Score Pre Close Credit within XXXX days of closing and is missing from the file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PLS WAIVE. XXXX NO LONGER REQUIRES. TY |
Response 1 (XX/XX/XXXX XX:XXAM) Explanation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122529 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | HELOC - Closure Letter | XXXX | File contains HELOC closure letter with XXXX indicating whether to paydown only or payoff/terminate/satisfy and not executed by the borrower. Loan file does not contain evidence to verify HELOC Closure as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HELOC CLOSE OUT LETTER |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2122530 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122530 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129043 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129043 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122531 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2122531 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129044 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129044 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129044 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a AVM dated XX/XX/XXXX which supports the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129045 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129045 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129046 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129046 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129047 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129047 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129047 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a AVM dated XX/XX/XXXX which supports the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129048 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129048 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129049 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129049 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129049 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a CDA, dated XX/XX/XXXX, which supports value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2138569 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2138569 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Texas High Cost & Antipredatory Lending/Total Indebtedness Test | XXXX | The loan failed the XXXX Home Equity Loan Total Indebtedness Test due to the following: The loan is of a principal amount that when added to the total of all outstanding principal balances secured by valid liens against the homestead exceeds XXXX% of the fair market value of the homestead on the date the extension of credit is made. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PLS CLARIFY. BALANCE PER MTG SMT IS SUCH THAT WE ARE UNDER XXXX%, |
Response 1 (XX/XX/XXXX XX:XXPM) The information provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2138569 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Title-Attorney's Fee | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2138569 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VVOE Salaried/Missing | XXXX | A VVOE is missing from the loan file. The loan file is missing a VVOE for the: borrower. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) VOE |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2138569 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is not supported within a 10% variance | XXXX | The AVM did not support the value within a 10% variance. The loan file contains a CU Score of XXXX and does not contain an AVM as required by guidelines. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) AVM |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2129050 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129050 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129050 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM, which supports value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129587 | 1 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2129587 | 2 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The loan failed the prohibited fees test. XXXX loans may fall into more than one loan category at the same time. A fee is allowed if authorized by one or more statutes that apply. Otherwise fees are prohibited: If the loan is a Consumer Loan (XXXX Code §537.1301(XXXX)) it may charge an "additional charge". (XXXX Code §XXXX and§XXXX). | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2129587 | 3 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: Without evidence of receipt, it is assumed that the disclosure dated XX/XX/XXXX was mailed, and therefore not received by the consumer XXXX business days prior to the consummation date, XX/XX/XXXX. If disclosure was delivered electronically, evidence of receipt as well as the consumer's E-consent is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) INITIAL CD AUDIT LOG |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2129587 | 4 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that cannot increase test. Because the loan failed the initial CD delivery date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset as a result of the following increases: XXXX. The violation may be cured if documentation is provided showing the disclosure was delivered timely. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Docs uploaded. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2129587 | 5 of 6 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2129587 | 6 of 6 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM, which supports value. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2129588 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2129588 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | DTI - Exceeds Guidelines | XXXX | The DTI exceeds Originator Guidelines. The Lender's guidelines state XXXX of XXXX%. The loan was submitted at origination with a DTI of XXXX%. The DTI at time of Audit was XXXX%, which still exceeds the maximum of XXXX%. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX XXXX INTERNAL EXCEPTION APPROVAL |
Response 1 (XX/XX/XXXX XX:XXAM) Waiver must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Investor reviewed and elects to waive. Noted Compensating factors: XXXX qualifying credit score, Subject property owned XXXX years, 0x30 mortgage history XXXX months. |
XXXX. XXXX% CLTV. $XXXX per month residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2129588 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. BPO provided and supports original appraised value. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2129051 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2129051 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the application fee test. (XXXX XXXXXXXX6125(b)(2)(ii)) The loan is a second XXXX mortgage and charges both an application fee and loan origination fee, or charges a single application or loanorigination fee that exceeds XXXX% of the original principal amount.The original principal of this loan, as defined by the state of XXXX, is $XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2129051 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2129052 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129052 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129053 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129053 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129053 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a BPO dated XX/XX/XXXX, which supports the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129054 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129054 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX rate spread home loan test. ( XXXX GS §XXXX-XXXXF(a)(XXXX) ) The loan is a rate spread home loan, as defined in the legislation. Using the greater of the disclosed APR % and the calculated APR %, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129054 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133301 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133301 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133301 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. XXXX was a XXXX and CDA was provided and supports original appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129055 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129055 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129055 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. A AVM dated XX/XX/XXXX was provided and supported the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133302 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133302 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133302 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. XXXX is XXXX and AVM provided and supports original appraised value per guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133303 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133303 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129056 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129056 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129056 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. A CDA dated XX/XX/XXXX was provided and supported the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129057 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129057 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2138570 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2138570 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Missing/Incomplete | XXXX | The title O & E is missing. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PROP RPT |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2133304 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133304 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)) Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133304 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129058 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129058 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129058 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a BPO dated XX/XX/XXXX, which supports value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2138571 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2138571 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The credit report reflects the 1st XXXX mortgage payment as $XXXX and the Final XXXX reflects the 1st lien P&I payment as $XXXX. The loan file is missing a recent mortgage statement or other documentation to verify the P&I payment for the 1st XXXX mortgage. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HERE IS XXXX. IT ALSO MATCHES WHAT IS LISTED ON XXXX |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2138572 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2138572 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Other/Missing | XXXX | The guidelines indicate when Social Security Income is used to qualify, it must be supported by the most recent SSI Award Letter and the most recent year XXXX. The loan file is missing the most recent year XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) WE DO NOT HAVE XXXX AND HAVE BANK STMT SHOWING RCPT. PLS CLEAR. TY |
Response 1 (XX/XX/XXXX XX:XXAM) SS XXXX in file. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2138572 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Other/Missing | XXXX | The guidelines indicate when using Trust Income to qualify, a trust agreement or trustee statement is required in addition to all pages and schedules of the most recent years XXXX fiduciary income tax return, including the XXXX. The loan file is missing the Borrower's XXXX fiduciary income tax return and XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) It&#XXXX;s not trust income, it is income coming out of the borr&#XXXX;s XXXX acct (asset stmts in the file) she just has it set up under her trust name but it is not a trust. |
Response 1 (XX/XX/XXXX XX:XXAM) Consistent monthly brokerage deposits and source provided. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2138572 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is not supported within a 10% variance | XXXX | The loan file did not contain a CDA, Field Review, or 2nd Appraisal to support the origination appraised value. The loan file did not contain a CDA. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) DESK REVIEW |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2138573 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2138573 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Appraisal - Missing required 1004 D | XXXX | The loan is HPML per the loan detail report; therefore a full appraisal is required. The loan file contains an exterior appraisal and AVM; however, is missing the required full appraisal. | Void | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PLS CLARIFY. OUR LOAN DETAINS REPORT DOES NOT INDICATE THIS TO BE HPML? |
Response 1 (XX/XX/XXXX XX:XXAM) Agree. Not a high cost mortgage. (Void) |
1 | 1 | 1 | 1 | |||
| XXXX | 2138573 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a AVM dated, XX/XX/XXXX, which supports the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133305 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fee: Title-Recording Service Fee. The loan fails the prohibited fees test by $XXXX. MRS § XXXX et seq | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2133305 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2133305 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM dated, XX/XX/XXXX, which supports the appraised value. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2138574 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2138574 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | DTI - Exceeds Guidelines | XXXX | The DTI exceeds Originator Guidelines. The full mortgage payment listed on the senior XXXX's mortgage statement was added with the P&I payment of the second XXXX giving us a total housing expense of $XXXX; which is greater than the $XXXX calculated at originations. The DTI calculated at audit is XXXX% which exceeds the XXXX allowed DTI of XXXX%. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX UPDATED XXXX AND XXXX INTERNAL EXCEPTION APPROVAL |
Response 1 (XX/XX/XXXX XX:XXAM) It appears the new calculation has used miscellaneous pay to qualify the borrower. There was no documentation provided to illustrate the continuance or description of miscellaneous pay. Even if it is sufficiently documented and allowed, an exception from the Investor is required. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted Compensating Factors: XXXX qualifying credit score, subject property owned XXXX years, job stability XXXX years |
XXXX. XXXX% LTV. $XXXX residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2138574 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan contains a AVM, dated XX/XX/XXXX, which supports the appraised value. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2133306 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133306 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2138575 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2138575 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2138575 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is not supported within a 10% variance | XXXX | The AVM did not support the value within a 10% variance. CU score of XXXX and AVM provided that did not support original appraised value. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX AVM |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2133307 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133307 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133308 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133308 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133308 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a CDA, dated XX/XX/XXXX which supports the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133309 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133309 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133310 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the nonrefundable prepaid finance charge test. (XXXX. Code § XXXX-XXXX-XXXX-201(XXXX))The loan's nonrefundable prepaid finance charge exceeds: XXXX% of the note amount or line of credit for loans on or after XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2133310 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2133310 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a AVM, dated XX/XX/XXXX which supports the appraised value. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2138576 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2138576 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Other/Missing | XXXX | The file is missing documentation for the XXXX YTD income from XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) XXXX W2 |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2138576 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a AVM, dated XX/XX/XXXX which supports the appraised value. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2133311 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133311 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133311 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. CDA provided and supports original appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2138577 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: Without evidence of receipt, it is assumed that the disclosure dated XX/XX/XXXX was mailed, and therefore not received by the consumer XXXX business days prior to the consummation date, XX/XX/XXXX. If disclosure was delivered electronically, evidence of receipt as well as the consumer's E-consent is required. (12 CFR §1026.19(f)(1)(ii)) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX INITIAL CD AUDIT LOG |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2138577 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that cannot increase test. Because the loan failed the initial CD delivery date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset as a result of the following increase: XXXX on the revised CD issued on XX/XX/XXXX. The violation may be cured if documentation is provided showing the disclosure was delivered timely. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Docs uploaded. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2138577 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2138577 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM dated, XX/XX/XXXX, which supports the appraised value. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2138578 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2138578 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The application lists significant debts that were not verified on the credit report and not independently verified. The loan file does not contain a Mortgage Statement for the Borrower's Primary residence to determine if the amount of payment reflected on the Credit report includes escrows for taxes and insurance. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX MTG STMT |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2138578 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan vile contains an AVM dated XX/XX/XXXX, which supports the original appraised value. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2133312 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2133312 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2138579 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: Without evidence of receipt, it is assumed that the disclosure dated XX/XX/XXXX was mailed, and therefore not received by the consumer XXXX business days prior to the consummation date, XX/XX/XXXX. If disclosure was delivered electronically, evidence of receipt as well as the consumer's E-consent is required. (12 CFR §1026.19(f)(1)(ii)) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) INITIAL CD AUDIT LOG |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2138579 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that cannot increase test. Because the loan failed the initial CD delivery date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset as a result of the following increase: XXXX on the revised CD issued on XX/XX/XXXX. The violation may be cured if documentation is provided showing the disclosure was delivered timely. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Docs uploaded. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2138579 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2094919 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2094919 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127814 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127814 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127823 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood Certification Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2127823 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127824 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127824 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127825 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127825 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127825 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127826 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2127826 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127827 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX% the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2127827 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2127827 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX and Property Condition Report. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2127827 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: The loan failed the Initial Closing Disclosure delivery date test due to the following: The Closing Disclosure was not received by the borrower at least three business days prior to the Consummation Date. The CD issued on XX/XX/XXXX was signed and dated at consummation, XX/XX/XXXX. If disclosure was delivered electronically evidence of receipt as well as the consumer's E-consent is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) initial CD delivered prior to close- see attached LOE- Please review and clear. if unable o clear please provide a detailed explanation to why. Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please see attached for CD XX/XX/XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) Thedocumentation provided is not sufficient to cure the finding. The disclosuretracker has been provided reflecting a CD was issued on XX/XX/XXXX. The actualdocument, CD XX/XX/XXXX. needs to be provided to verify it was complete and for accurate testing. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2127827 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2127828 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX% the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2127828 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2127828 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Credit - Other | XXXX | The Underwriting Decision Logic Guide reflects the 1st mortgage concurrently refinancing (XXXX loan #XXXX) with the subject transaction. The file is missing the terms/approval of the new 1st mortgage, loan amount, P&I payment, etc. According to the final application/XXXX, the new loan amount is $XXXX and loan escrowed with a monthly payment of $XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) 1st XXXX CD |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2127829 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2127829 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2123016 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2123016 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127830 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127830 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127848 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127848 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127848 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood Certification Fee. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2127848 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2127849 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2127849 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD: Flood Certificate Fee and HOA Master Insurance Fee. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2127849 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The application lists significant debts that were not verified on the credit report and not independently verified. The loan file reflects the subject property is a Condo; however, the loan file does not contain verification of the HOA dues as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOA DUES |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2127850 | 1 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2127850 | 2 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a compliant HPML. Prepayment requirements have been met. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2127850 | 3 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The loan is a subordinate lien and the APR exceeds the Average Prime Offer Rate (XXXX%) by XXXX% or more. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2127850 | 4 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - LE/Revised LE Delivery Date (prior to consummation) | XXXX | The loan failed the Revised Loan Estimate delivery date test due to the following: The Loan Estimate XX/XX/XXXX was not received by the borrower at least four business days prior to the Consummation Date, XX/XX/XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please clear condition as LE was sent to borrower XXXX/XXXX, Consummation Date – XXXX/XXXX, and disbursed on XX/XX/XXXX. Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please see attached CD signed by borrower on XXXX/XXXX. Rebuttal 3 (XX/XX/XXXX XX:XXPM) here is the LE with the esign log |
Response 1 (XX/XX/XXXX XX:XXPM) The information provided is not sufficient to clear the finding. Without evidence of receipt the mailing rule is applied and the receipt date is XX/XX/XXXX; this is not XXXX business days prior to closing as required. Please provide evidence of receipt for review. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2127850 | 5 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that cannot increase test. Because the loan failed the revised LE date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset as a result of the following increases: Points - Loan Discount Fee. The violation XXXX be cured if documentation is provided showing the disclosure was delivered timely. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please clear condition as LE was sent to borrower XXXX/XXXX, Consummation Date – XXXX/XXXX, and disbursed on XX/XX/XXXX. Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please see attached CD signed by borrower on XXXX/XXXX. |
Response 1 (XX/XX/XXXX XX:XXPM) The information provided is not sufficient to clear the finding. Without evidence of receipt the mailing rule is applied and the receipt date is XX/XX/XXXX; this is not XXXX business days prior to closing as required. Please provide evidence of receipt for review. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2127850 | 6 of 6 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2127851 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127851 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2127852 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee or fees where 'compensation to' does not reflect a XXXX on the revised CD. Flood Certification Fee. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2127852 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The application lists significant debts that were not verified on the credit report and not independently verified. The loan file does not contain documentation as to whether or not the borrower's following investment properties are subject to any XXXX Dues: XXXX., XXXX and XXXXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) See attached LOE from UW. |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2127853 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee where 'compensation to' does not reflect a XXXX on the revised CD. XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2127853 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2071673 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Name Discrepancy | XXXX | The vested interest on the Security Instrument cannot be verified as accurate due to Title Commitment missing from the loan file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Docs uploaded. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2071673 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Appraisal - Missing required 1004 D | XXXX | The appraisal provided was completed "subject to" a railing to be installed on the 2nd story of the subject. The required XXXXd was not provided. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Final Inspection |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2071673 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Missing/Incomplete | XXXX | The investor guidelines required an Owner's and Encumbrance Report, QuickEQ Report, or Home Equity Property Report verifying the senior l and no other liens or encumbrances exist or a full Alta title policy. File did not contain any of the required title options. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Doc provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Title report (XXXX Report) provided. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100185 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | State Rules Violation | XXXX | This loan failed the required fees test. (XXXX Constitution, Article 16, Section 50 (a)(6)(E) & (t)(4), as amended Jan. XXXX) The loan requires the borrowers to pay, in addition to interest, fees to any person that are necessary to originate, evaluate, maintain, record, insure, or service the extension of credit that exceed XXXX% of the original principal amount. Fees included in the test: Credit Report $XXXX, Flood $XXXX, MERS $XXXX, Broker $XXXX, Points $XXXX, Doc Prep $XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) TX2% response |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100185 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100124 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. This loan has points and fees that exceed the points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is less than $XXXX but at least $XXXX, and the transaction's total points and fees is $XXXX, which exceeds $XXXX. The following fees were included in the testing: XXXX, Discount Points. If discount points and fees are bona-fide and excludable, provide undiscounted rate. Truth In Lending Act (Regulation Z) 12 CFR 1026.43(e)(2)(iii), (e)(3). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) QM response |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100124 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099904 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. (12 CFR 1026.43(e)(3)) The loan amount is less than $XXXX but at least $XXXX, and the transaction's total points and fees is $XXXX, which exceeds $XXXX. The following fees were included in the testing; XXXX Fee $XXXX and Mortgage Broker Fee (Indirect) $XXXX. Truth in XXXX | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) QM |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099904 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100253 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Note - Trust Missing | XXXX | Title to the Property is held in Trust, but the Trust Document is missing. Unable to determine if signatures on Note are accurate. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Deed Rebuttal 2 (XX/XX/XXXX XX:XXPM) Trust Cert |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The Quit Claim Deed has been provided; however, the XXXX is blank and no other Trust documents have been provided to verify the name of the trust. Pease provide a completed XXXX documents for review. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2100253 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Trust Missing | XXXX | Title to the Property is held in a Trust, but the Trust Document is missing. Unable to determine if signatures on the Security Instrument are accurate. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Deed Rebuttal 2 (XX/XX/XXXX XX:XXPM) Trust Cert |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The Quit Claim Deed has been provided; however, the XXXX is blank and no other Trust documents have been provided to verify the name of the trust. Pease provide a completed XXXX documents for review. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2100253 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Loan Amount | XXXX | The loan amount of $XXXX exceeds maximum allowable under the investor guidelines of $XXXX due to an incorrect income calculation paired with incorrect taxes used for the PITI in qualifying at origination. The income at origination is $XXXX higher than audit due to the use of asset depletion for borrower XXXX. Investor guidelines state asset depletion is an ineligible source of income and was excluded at audit. The taxes used to qualify at origination were also incorrect, the proposed taxes at origination of $XXXX are based off of the last amount due which is one instalment. The total taxes on the subject property per the tax cert and appraisal is $XXXX which equals $XXXX in monthly taxes. The increase in liabilities along with the decrease in income caused the DTI to go from XXXX% to XXXX% which not only is higher than the maximum approvable DTI of XXXX% overall but also since the DTI is over XXXX% the maximum loan amount allowed is decreased from $XXXX to $XXXX. | Waived | Response 1 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Investor reviewed and elects to waive. Noted Compensating Factors: $XXXX monthly residual income, XXXX qualifying credit score, XXXX years with employer, subject residence owned XXXX years |
XXXX. XXXX CLTV. $XXXX per month residual income. | 3 | 2 | 3 | 2 | ||
| XXXX | 2100249 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. This loan has points and fees that exceed the points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) QM |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100249 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - LE/Revised LE Delivery Date (prior to consummation) | XXXX | The loan failed the Revised Loan Estimate delivery date test due to the following: Without evidence of receipt, it is assumed that the disclosure dated XX/XX/XXXX was mailed, and therefore not received by the consumer XXXX business days prior to the consummation date, XX/XX/XXXX. If disclosure was delivered electronically, evidence of receipt as well as the consumer's E-consent is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) LE |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100249 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099958 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Lender Credits that Cannot Decrease (No Valid COC) | XXXX | The loan failed the Lender Credits that Cannot Decrease Test.The lender credit decreased on the CD issued on XX/XX/XXXX without a valid change of circumstance. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund.A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i) & Official Comment 19(e)(3)(i)-XXXX, -XXXX; 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099958 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100274 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the addition to the following fees was not accepted: Title Endorsement Fee on the Initial CD issued XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) A refund check was sent via regular mail for the full $XXXX through a different department and our request for a cure of $XXXX was also placed via principal reduction |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2100274 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100401 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100401 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Missing/Incomplete | XXXX | The title commitment is missing. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Doc provided. |
Response 1 (XX/XX/XXXX XX:XXAM) Title Commitment provided. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099903 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099903 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - Missing/Insufficient | XXXX | The current hazard insurance policy on the subject property is missing XXXX as second XXXX holder as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Policy |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099903 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | HELOC - Closure Letter | XXXX | The loan file does not contain evidence to verify HELOC Closure as required for the HELOC paid off at closing with XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) New credit report shows the XXXX is closed by consumer. see page XXXX of XXXX. |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099960 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Rescission Test | XXXX | This loan failed the TILA right of rescission test. Closed-end (12 CFR §1026.23(a)(3), transferred from 12 CFR §226.23(a)(3)), Open-end (12 CFR §1026.15(a)(3), transferred from 12 CFR §226.15(a)(3)) The funding date, XX/XX/XXXX, is before the third business day following consummation, XX/XX/XXXX. The consumer may exercise the right to rescind until midnight of the third business day following consummation, delivery of the notice required by 12 CFR §XXXX or §XXXX, or delivery of all material disclosures, whichever occurs last. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NRTC Rebuttal 2 (XX/XX/XXXX XX:XXPM) NRTC response |
Response 1 (XX/XX/XXXX XX:XXPM) The referenced documentation was not received. Please provide for review. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099960 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100231 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100231 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The final application reflects an additional debt not reporting on the credit report: XXXX with a balance of $XXXX and payments $XXXX. The file is missing documentation verifying the balance and payments. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX/XXXX was identified through our internal, back-end Transunion Gap Report process. When the gap process is run, we are provided with only the account name, number, balance and payment. We do not request a statement from the broker/borrower because a) we already have the details directly from XXXX and b) the borrowers qualify with the liabilities. Rebuttal 2 (XX/XX/XXXX XX:XXPM) LOE Rebuttal 3 (XX/XX/XXXX XX:XXAM) Please see attached post close credit report which verifies the account in question. |
Response 1 (XX/XX/XXXX XX:XXAM) Please provide the referenced information. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Documentation provided does not match the application. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100276 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the addition to the following fees was not accepted: Title Endorsement. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2100276 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Lender Credits that Cannot Decrease (Disclosure Timing Fail) | XXXX | The loan failed the Lender Credits that Cannot Decrease Test. Because the loan failed the revised LE date test and initial CD delivery date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset for the decrease of Lender Credits. The violation may be cured if documentation is provided showing the disclosures were delivered timely. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i) & Official Comment 19(e)(3)(i)-XXXX, -XXXX; 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Tracking, COC |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2100276 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: Without evidence of receipt, it is assumed that the disclosure dated, XX/XX/XXXX, was mailed, and therefore not received by the consumer XXXX business days prior to the consummation date, XX/XX/XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Cure docs |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2100276 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - LE/Revised LE Delivery Date (prior to consummation) | XXXX | The loan failed the Revised Loan Estimate delivery date test due to the following: Without evidence of receipt, it is assumed that the disclosure dated, XX/XX/XXXX, was mailed, and therefore not received by the consumer XXXX business days prior to the consummation date, XX/XX/XXXX. If disclosure was delivered electronically, evidence of receipt as well as the consumer's E-consent is required. Truth in XXXX (Regulation Z) 12 CFR 1026.19(e)(4)(ii) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Tracking, COC |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2100276 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2099954 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: XXXX and Recording Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Refund Rebuttal 2 (XX/XX/XXXX XX:XXPM) Refund response |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding. The LOE, PCCD, and copy of the refund check have been provided. Proof of Delivery is required. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2099954 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100039 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100039 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Liabilities - Excluded Debts | XXXX | The loanfile contains a debt with XXXX that was omitted from the qualifying DTI due to less than ten (XXXX) payments remaining. Per guidelines, debts with less than XXXX payment remaining must be paid in full prior to or at closing to be excluded from DTI for qualification purposes. The loan file did not contain any documentation confirming the XXXX debt was paid in full at or prior to closing. The DTI inclusive of this debt was XXXX% which exceeds the program maximum. Additional conditions may apply. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) That is incorrect - Per FNMA Installment loans that are being paid off or paid down to XXXX or fewer remaining monthly payments do not need to be included in the borrower’s long-term debt. |
Response 1 (XX/XX/XXXX XX:XXPM) Stand Alone Closed End Second product guidelines require that installments be paid in full to exclude. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted Compensating factors: XXXX qualifying credit score, $XXXX monthly residual income, subject property owned XXXX years, 0x30 mortgage history for XXXX months reviewed. |
XXXX. XXXX% CLTV. Employment stability. | 3 | 2 | 3 | 2 | |
| XXXX | 2099927 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is less than $XXXX but at least $XXXX, and the transaction's total points and fees is $XXXX, which exceeds $XXXX Fees included in testing: Mortgage Broker Fee and Points. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) QM |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099927 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130180 | 1 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | FACTA Disclosure - Missing | XXXX | The FACTA Disclosure (Notice to Home Loan Applicant/Credit Information Disclosure) is missing. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2130180 | 2 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | HOC - Late | XXXX | The Homeownership Counseling Disclosure (HOC) dated XX/XX/XXXX was not disclosed within XXXX days of the application date, XX/XX/XXXX. Real Estate Settlement Procedures Act (Regulation X) 12 CFR 1024.20(a)(1) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Docs uploaded. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
2 | 1 | 3 | 2 | |||
| XXXX | 2130180 | 3 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. Because the loan failed the Initial LE date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset as a result of the following additions/increases: Title Fees, Recording Fee. The violation may be cured if documentation is provided showing the disclosure was delivered timely. A cost to cure in the amount of $XXXX is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Initial LE, COC |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2130180 | 4 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Lender Credits that Cannot Decrease (Disclosure Timing Fail) | XXXX | The loan failed the Lender Credits that Cannot Decrease Test. Because the loan failed the Initial LE date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset as a result of the following decrease in Lender Credits. The violation may be cured if documentation is provided showing the disclosure was delivered timely. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i) & Official Comment 19(e)(3)(i)-XXXX, -XXXX; 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Initial LE, COC Rebuttal 2 (XX/XX/XXXX XX:XXPM) COC |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The COC dated XX/XX/XXXX for the decrease to the Lender Credit from $XXXX to $XXXX was applied. However, a COC has not been provided for the decrease to the Lender Credit on the Final CD issued on XX/XX/XXXX from $XXXX to $XXXX. Please provide a valid COC for review. A cost to cure in the amount of $XXXX remains. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2130180 | 5 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial LE/Delivery Date (from application) | XXXX | The loan failed the Initial Loan Estimate delivery date test (from application). The Initial LE issued on XX/XX/XXXX was not disclosed within XXXX days of the application date, XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.19(e)(1)(iii)(A) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan pkg |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2130180 | 6 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that cannot increase test. Because the loan failed the Initial LE date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset as a result of the following additions/increases: XXXX, Appraisal, Credit Report, XXXX, MERS, XXXX. The violation may be cured if documentation is provided showing the disclosure was delivered timely. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) initial loan pkg |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2130180 | 7 of 7 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2129864 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fees was not accepted: Lender's Title Insurance Policy, Settlement or Closing Fee, Title Certification and Title Policy Guaranty Fee (XXXX only). If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) cured Rebuttal 2 (XX/XX/XXXX XX:XXAM) cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding. The LOE, PCCD and copy of the refund check have been provided. Proof of Delivery is required. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2129864 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130243 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130243 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130065 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130065 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | DTI - Exceeds Guidelines | XXXX | The DTI exceeds Originator Guidelines - The borrowers 1st mortgage payment increased from the initial credit report and is supported by the mortgage statement and credit supplement provided showing the higher payment. When using the higher new 1st mortgage payment the borrowers DTI increases to XXXX% which is over the guidelines for the program for this loan amount. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) I asked the underwriting team to review and update the XXXX/XXXX. We landed on a DTI of XXXX%, does this match your calculation? I understand it&#XXXX;s high for the program, but I want to make sure we&#XXXX;re on the same page before I proceed with a possible cure. Thanks! |
Response 1 (XX/XX/XXXX XX:XXPM) The review calculation is XXXX%. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Client reviewed and elects to waive. Noted Compensating Factors: Subject property owned XXXX years, job stability XXXX years, XXXX qualifying credit score |
XXXX. XXXX% CLTV. $XXXX per month residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2130000 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold (12 CFR 1026.43(e)(3)). The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. If discount points and fees are bona-fide and excludable, provide undiscounted rate. Truth In Lending Act (Regulation Z) 12 CFR 1026.43(e)(2)(iii), (e)(3). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) QM |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130000 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130112 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130112 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129998 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Lender Credits that Cannot Decrease (No Valid COC) | XXXX | The loan failed the Lender Credits that Cannot Decrease Test. The lender credit decreased on the LE issued on XX/XX/XXXX without a valid change of circumstance. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z). 12 CFR 2016.19(e)(3)(i) & Official Comment 19(e)(3)(i)-XXXX, -XXXX; 12 CFR 1026.19(e)(3)(iv). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129998 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129998 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM dated XX/XX/XXXX, which supports the appraised value. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130303 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130303 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129861 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129861 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130173 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130173 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130027 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130027 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129881 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129881 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130291 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130291 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Other | XXXX | The subject property is located in XXXX. A Property Report from XXXX was provided. The investor guidelines required a either Residential Equity Loan Policy Certificate (RELP) or a Home Equity Loan Policy Certificate (HELP) evidencing coverage under a Master Residential Equity Loan Policy (MRELP) or Master Home Equity Loan Policy. A full ALTA title policy may be obtained in lieu of either a RELP or HELP certificate or E & O certificate. Required documentation was not provided. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Please see MRELP Rebuttal 2 (XX/XX/XXXX XX:XXPM) MRELP |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation not received. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130192 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130192 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2158227 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Inaccurate | XXXX | The security instrument was not completed accurately. The name of the trust listed in the mortgage does not match the name of the trust listed in the trust document. The date of the trust on page XXXX of the mortgage and riders, XX/XX/XXXX, does not match the executed date of the trust on the certification of trust, XX/XX/XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Letter of Intent to Re-Record and corrected DOT and Riders for Trust date XX/XX/XXXX on signature lines Rebuttal 2 (XX/XX/XXXX XX:XXPM) Re-recorded, corrected DOT |
Response 1 (XX/XX/XXXX XX:XXAM) The referenced documentation was not received. Please provide for review. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2158227 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2158227 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is not supported within a 10% variance | XXXX | The loan file does not contain a second valuation to support the appraised value used. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Per our guidelines we are good with the AVM and the PCR |
Response 1 (XX/XX/XXXX XX:XXAM) Explanation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2155686 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2155686 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | DTI - Exceeds Guidelines | XXXX | The DTI exceeds Originator Guidelines. The max DTI for a borrower with a credit XXXX is XXXX%. The subject loan closed with a DTI of XXXX%, which exceeds the max of XXXX%. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2155686 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM, dated XX/XX/XXXX, which supports value. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2144633 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2144633 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Appraisal - Other | XXXX | There are additional appraisal findings. Guidelines require all AVM's be provided by XXXX or XXXX. The primary valuation AVM was provided by XXXX. Guidelines require the secondary valuation be ordered through a different vendor, in this case XXXX. The secondary valuation AVM dated XX/XX/XXXX with a value of $XXXX supports the value within 10%; however, the provider was XXXX and not XXXX as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX is a Vendor they do not supply the AVM themselves. Here are the AVM providers for XXXX: XXXX can return any of these when an AVM is requested. • XXXX Value • XXXX Value MC • XXXX • XXXX AP2000C0511A00 • XXXX Value Report • XXXX • XXXX • RVM • XXXXValue • ValueSure • XXXX |
Response 1 (XX/XX/XXXX XX:XXAM) Explanation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2144633 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. AVM provided as appraisal. Another AVM from different vendor provided as valuation product and supports first AVM. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2154869 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2154869 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Appraisal - Other | XXXX | Per Lender's guides an AVM is acceptable from XXXX or XXXX only. However, the loan file obtains an AVM from XXXX dated XX/XX/XXXX, with value of $XXXX. The loan file does not contain an AVM from XXXX or XXXX as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) The AVM was pulled thru XXXX. See attached list, we can get any of the results. Also our CLTV is XXXX% Rebuttal 2 (XX/XX/XXXX XX:XXAM) Please Escalate. The AVM was ordered thru XXXX per GLs, and they have providers for XXXX that XXXX can return any on the list provided when an AVM is requested. |
Response 1 (XX/XX/XXXX XX:XXAM) Referenced list not received. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2154869 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - CLTV | XXXX | Per Lender's guides, the max CLTV for a standalone C/O Refi of an owner occupied SFR with credit XXXX+, is XXXX%. However, the CLTV is XXXX%, which exceeds the max of XXXX%. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Please Escalate. The AVM was ordered thru XXXX per GLs, and they have providers for XXXX that XXXX can return any on the list provided when an AVM is requested. Rebuttal 2 (XX/XX/XXXX XX:XXPM) XXXX Shows CLTV at XXXX% below guidelines Rebuttal 3 (XX/XX/XXXX XX:XXAM) We are using the appraised value of $XXXX and XXXX is using $XXXX. We are allowed to use $XXXX as long as the 2nd AVM is within 10% of value and the $XXXX is within this range. Please see attached 2nd AVM and update XXXX&#XXXX;s appraised value to $XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) Value is not the issue. The CLTV of XXXX% exceeds the XXXX% maximum. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Lowest first mortgage balance in file was $XXXX. New second $XXXX. Total of $XXXX / $XXXX = XXXX% CLTV. (XXXX) Response 3 (XX/XX/XXXX XX:XXAM) Explanation and documentation received is sufficient.(Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2154869 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is not supported within a 10% variance | XXXX | The loan file does not contain a second valuation product to support the appraised value used. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) AVM Rebuttal 2 (XX/XX/XXXX XX:XXPM) XXXX of XXXX AVMs used for value Rebuttal 3 (XX/XX/XXXX XX:XXAM) AVM #XXXX used for value |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation not received. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Secondary valuation product has a confidence score of XXXX%. (XXXX) Response 3 (XX/XX/XXXX XX:XXAM) AVM #XXXX cannot be used. The confidence score is XXXX%. (XXXX) Response 4 (XX/XX/XXXX XX:XXAM) Upon further review, confidence score is acceptable. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2144634 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2144634 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2144634 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contained an AVM dated XX/XX/XXXX that supported the value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2154867 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fee was not accepted: Credit Report on the revised CD issued on XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumers, PCCD and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Tolerance Cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2154867 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2154867 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contained an AVM dated XX/XX/XXXX that did not support the value within 10%; however, Lender guidelines allow the use of the lower value. Per the rating agencies, this is graded an EV2. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Seller Certificate Rebuttal 2 (XX/XX/XXXX XX:XXPM) Seller Certificatee |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation not received. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Resolved at an EV2 rating. (Resolved) |
2 | 2 | 3 | 2 | |||
| XXXX | 2155682 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2155682 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Assets - Cash to Close | XXXX | The file did not contain evidence the borrower had the $XXXX required to close. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Attached assets needed |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2155682 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Other | XXXX | The subject loan does not meet Program Parameters. Guidelines currently permit AVMs from XXXX or XXXX. The secondary AVM provided is from XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) We did pull a mercury AVM, but per the below, Mercury can return any of the results so we should be good with our AVMs in the file Rebuttal 2 (XX/XX/XXXX XX:XXPM) AVMs attached |
Response 1 (XX/XX/XXXX XX:XXAM) Document provided is not for the subject loan. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2155682 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an additional AVM, dated XX/XX/XXXX, which supports theoriginal AVM value. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2144632 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2144632 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2144632 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is not supported within a 10% variance | XXXX | The loan file did not contain a CDA. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) SSR with a low CU score to support Value |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2154868 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2154868 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2154868 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM dated XX/XX/XXXX, which supports the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2155681 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Name Discrepancy | XXXX | The Vested Interest on the Security Instrument cannot be verified as accurate due to Title Commitment missing from the loan file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) XXXX - please refer to page XXXX;the chain of title matches our current vesting on our mortgage deed. Rebuttal 2 (XX/XX/XXXX XX:XXPM) Seller Certificate Rebuttal 3 (XX/XX/XXXX XX:XXPM) XXXX and CPL |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The Title Policy has been provided in the original loan file; however, the Title Commitment is required for review. The XXXX discloses the name of the parties that have vested interest prior to the subject loan closing. The Title Policy will show the name of the parties that have vested interest after the subject loan closes. The Title Commitment is needed to ensure the borrower has vested interest in the property and able to obtain a loan on the property. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) No new documents were received. Please re-submit. (XXXX) Response 3 (XX/XX/XXXX XX:XXAM) The documents provided are sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2155681 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2155681 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is not supported within a 10% variance | XXXX | The file does not contain a second valuation to support the appraised value used as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Secondary valuation was in file from XXXX XXXX |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2154870 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - Section B incorrect payee | XXXX | The loan contains a fee or fees where 'compensation to' reflects either 'Lender or Broker' under Section B- Services Borrower Did Not Shop For of the revised CD issued on XX/XX/XXXX; AVM Fee. However, this fee should not be retained by the lender or broker. Per regulation 1026.38(f)(2), the name of the person/company ultimately receiving payment for service should be listed. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2154870 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2154870 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM report dated XX/XX/XXXX which supports the original appraised value. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2155684 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fees was not accepted: Title - Settlement/Closing and Title - Doc Prep. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PCCD, Refund cover letter, copy of check + proof of delivery |
Response 1 (XX/XX/XXXX XX:XXAM) The documents provided are sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2155684 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2155684 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a secondary AVM dated XX/XX/XXXX, which supports the original valuation product. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2155683 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fee was not accepted: Credit Report Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Attached PCCD, Refund cover letter, copy of the check + proof of delivery |
Response 1 (XX/XX/XXXX XX:XXAM) The documents provided are sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2155683 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2155683 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a secondary AVM dated XX/XX/XXXX, which supports the XXXX valuation product. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2154871 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2154871 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2154871 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM, dated XX/XX/XXXX which supports the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2151872 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2151872 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2151872 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM dated XX/XX/XXXX6, which supports the valuation of the primary valuation product. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2154873 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2154873 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2154873 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM, dated XX/XX/XXXX which supports the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2154872 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2154872 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2154872 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM, dated XX/XX/XXXX which supports the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2151873 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2151873 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2151873 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM dated XX/XX/XXXX, which supports the original appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2151874 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2151874 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2151874 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains an AVM dated XX/XX/XXXX, which supports the original appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2158228 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2158228 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2158228 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a CDA dated XX/XX/XXXX, which supports value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2154874 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2154874 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2154874 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a AVM dated XX/XX/XXXX, which supports value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2155685 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Payee Not Listed | XXXX | The loan contains the following fee where 'compensation to' does not reflect a XXXX on the revised CD, Title - Notary Fee. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2155685 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Income - W2(s) Missing | XXXX | The loan file is missing the XXXX's most recent XXXX for their current employer. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Updated XXXX/XXXX removing Borrowers income so XXXX is no longer needed |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2155685 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a AVM dated XX/XX/XXXX, which supports value. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2151002 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2151002 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2151002 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the financed lender fees test. (XXXX. XXXX) The loan has financed lender fees that exceed XXXX% of the loan amount. This test includes the following fees: Discount Points - $XXXX, Prepaid Interest - $XXXX, Underwriting - $XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2151002 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Interest Rate | XXXX | This loan failed the Interest Rate test. The loan has an Interest Rate that does not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of (XXXX) allows for a maximum (XXXX%) Interest Rate, the loan has a (XXXX%) Interest Rate. The loan fails the Interest Rate test by (XXXX%). | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2151002 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150985 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150985 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150985 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Interest Rate | XXXX | This loan failed the Interest Rate test. The loan has an Interest Rate that does not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of (XXXX) allows for a maximum (XXXX%) Interest Rate, the loan has a (XXXX%) Interest Rate. The loan fails the Interest Rate test by XXXX %. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2150985 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150997 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150997 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows:This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX . The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150997 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Interest Rate | XXXX | This loan failed the Interest Rate test. The loan has an Interest Rate that does not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of (XXXX) allows for a maximum (XXXX%) Interest Rate, the loan has a (XXXX%) Interest Rate. The loan fails the Interest Rate test by XXXX%. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2150997 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150993 | 1 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2150993 | 2 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2150993 | 3 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | ROR- Incorrect Form/New creditor (H8) version required | XXXX | The consumer(s) was provided the incorrect RTC version. The consumer is refinancing with a new creditor; however, the version provided is for a refinance with the same creditor. Version H-XXXX was provided; Version H-XXXX was required. Rescission is required to be re-opened. Truth in XXXX (Regulation Z) 12 CFR 1026.23(b)(1)(v), (a) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) RTC Rebuttal 2 (XX/XX/XXXX XX:XXPM) RTC has expired |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding. The Updated ROR for the loan transaction was issued and the borrower has until midnight on XX/XX/XXXX to rescind. The exception can not be resolved until the recession period ends. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The re-opened rescission expired at midnight on XX/XX/XXXX clearing the exception. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2150993 | 4 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Interest Rate | XXXX | This loan failed the Interest Rate test. The loan has an Interest Rate that does not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of (XXXX) allows for a maximum XXXX% Interest Rate, the loan has a XXXX% Interest Rate. The loan fails the Interest Rate test by XXXX %. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2150993 | 5 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: HOA Certification Handling Fee and Transfer Taxes. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX was required of which $XXXX was cured on the PCCD issued XX/XX/XXXX as a principal reduction; however, the PCCD was not issued within XXXX days of consummation and the loan file did not contain an LOE, Proof of delivery, or evidence that the Principal Reduction was applied to the loan. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv). The loan reviewed contains a note dated more than XXXX months old, outside the applicable statute of limitations. | Resolved | 3 | 2 | 3 | 2 | |||||
| XXXX | 2150993 | 6 of 6 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2150984 | 1 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150984 | 2 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150984 | 3 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the financed lender fees test. (XXXX. XXXX) The loan has financed lender fees that exceed XXXX% of the loan amount. This test includes the following fees: Loan discount points $XXXX; XXXX interest $XXXX, settlement fee to affiliate $XXXX and underwriting fee $XXXX. The loan fails the prohibited fees test by $XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2150984 | 4 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Interest Rate | XXXX | This loan failed the Interest Rate test. The loan has an Interest Rate that does not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of (XXXX) allows for a maximum (XXXX%) Interest Rate, the loan has a (XXXX%) Interest Rate. The loan fails the Interest Rate test by XXXX %. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2150984 | 5 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: Without evidence of receipt for the Non Borrowing Spouse, it is assumed that the disclosure dated' XX/XX/XXXX was mailed, and therefore not received by the consumer XXXX business days prior to the consummation date, XX/XX/XXXX. | Acknowledged | 3 | 2 | 2 | 2 | |||||
| XXXX | 2150984 | 6 of 6 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150999 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150999 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows:This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150999 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Interest Rate | XXXX | This loan failed the Interest Rate test. The loan has an Interest Rate that does not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of (XXXX) allows for a maximum (XXXX%) Interest Rate, the loan has a (XXXX%) Interest Rate. The loan fails the Interest Rate test by XXXX %. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2150999 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2151003 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2151003 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows:This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX . The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2151003 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Interest Rate | XXXX | This loan failed the Interest Rate test. The loan has an Interest Rate that does not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of (XXXX) allows for a maximum (XXXX%) Interest Rate, the loan has a (XXXX%) Interest Rate. The loan fails the Interest Rate test by XXXX %. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2151003 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - Missing/Insufficient | XXXX | The loan was missing current hazard insurance policy/premium on the subject property. First mortgage servicing data reflects XXXX policy with a $XXXX premium payment, which is not found in the loan file. The file contains only an incomplete declaration page with XXXX missing insurance agency address, mortgagee address, premium due date and continued coverage. Adequate insurance coverage with monthly payment of $XXXX required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOI |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2151003 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Liabilities - Missing Debts/ DTI Exceeds Tolerance | XXXX | The DTI did not reflect all of the borrower's debts resulting in a DTI that exceeds allowable tolerances. The file contains Dissolution of Marriage (XX/XX/XXXX) that reflects XXXX was required to pay $XXXX Child Support and $XXXX Alimony per month, which is not included in the Borrowers monthly debt. The application does not reflect required payments and there is no documentation in the file to address the omitted obligations. Including $XXXX Child Support/Alimony, DTI increased from XXXX% to XXXX%, which exceeds the maximum of XXXX%. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) From our underwriter: Loan was updated with alimony ($XXXX) and child support ($XXXX) per decree. Unable to determine where $XXXX amount came from. The DTI is outside guidelines, but I&#XXXX;d like to make sure our system is accurate. Where did you identify $XXXX? Thanks! |
Response 1 (XX/XX/XXXX XX:XXAM) Page XXXX of the Dissolution reflects child support is $XXXX twice a month. Page XXXX of the Dissolution reflects $XXXX per month in XXXX maintenance. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Client reviewed and elects to waive. Noted compensating factors: XXXX qualifying credit score, subject property owned XXXX years, job stability XXXX years, 0x30x30 mortgage history |
XXXX. XXXX% CLYV. $XXXX per month residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2150986 | 1 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150986 | 2 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is10.XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150986 | 3 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the financed lender fees test. (XXXX. XXXX) The loan has financed lender fees that exceed XXXX% of the loan amount. This test includes the following fees: Discount Points, Prepaid Interest, Title Settlement Fee, Underwriting Fee. The loan fails the prohibited fees test by $XXXX. (XXXX. XXXX) | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2150986 | 4 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Interest Rate | XXXX | This loan failed the Interest Rate test. The loan has an Interest Rate that does not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of XXXX allows for a maximum XXXX% Interest Rate, the loan has a XXXX% Interest Rate. The loan fails the Interest Rate test by XXXX %. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2150986 | 5 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv). The loan reviewed contains a note dated more than XXXX months old, outside the applicable statute of limitations. | Resolved | 3 | 2 | 2 | 2 | |||||
| XXXX | 2150986 | 6 of 6 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2151000 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment ad requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2151000 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2151000 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the financed lender fees test. (XXXX. XXXX) The loan has financed lender fees that exceed XXXX% of the loan amount. This test includes the following fees: Discount Points, Prepaid Interest, and XXXX. The loan fails the prohibited fees test by $XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2151000 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Interest Rate | XXXX | This loan failed the Interest Rate test. The loan has an Interest Rate that does not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of XXXX allows for a maximum XXXX% Interest Rate, the loan has a XXXX% Interest Rate. The loan fails the Interest Rate test by XXXX%. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2151000 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150995 | 1 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150995 | 2 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150995 | 3 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the financed lender fees test. (XXXX. XXXX) The loan has financed lender fees that exceed XXXX% of the loan amount. This test includes the following fees: Discount Points, Prepaid Interest, and XXXX. The loan fails the prohibited fees test by $XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2150995 | 4 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Interest Rate | XXXX | This loan failed the Interest Rate test. The loan has an Interest Rate that does not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of XXXX allows for a maximum XXXX% Interest Rate, the loan has a XXXX% Interest Rate. The loan fails the Interest Rate test by XXXX%. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2150995 | 5 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Discount Points, Prepaid Interest, and XXXX. The loan fails the prohibited fees test by $XXXX. (XXXX. XXXX) | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2150995 | 6 of 6 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150994 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150994 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150994 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Interest Rate | XXXX | This loan failed the Interest Rate test. The loan has an Interest Rate that does not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of (XXXX) allows for a maximum (XXXX) Interest Rate, the loan has a (XXXX) Interest Rate. The loan fails the Interest Rate test by (XXXX) %. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2150994 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150992 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150992 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is10.XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150992 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Interest Rate | XXXX | This loan failed the Interest Rate test. The loan has an Interest Rate that does not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of (XXXX) allows for a maximum (XXXX%) Interest Rate, the loan has a (XXXX%) Interest Rate. The loan fails the Interest Rate test by XXXX%. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2150992 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150990 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150990 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150990 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Interest Rate | XXXX | This loan failed the Interest Rate test. The loan has an Interest Rate that does not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of XXXX allows for a maximum XXXX% Interest Rate, the loan has a XXXX% Interest Rate. The loan fails the Interest Rate test by XXXX%. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2150990 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150983 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150983 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150983 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the financed lender fees test. (XXXX. XXXX) The loan has financed lender fees that exceed XXXX% of the loan amount. This test includes the following fees: Discount Points, Prepaid Interest, and XXXX. The loan fails the prohibited fees test by $XXXX. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2150983 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Interest Rate | XXXX | This loan failed the Interest Rate test. The loan has an Interest Rate that does not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of (XXXX) allows for a maximum (XXXX%) Interest Rate, the loan has a (XXXX%) Interest Rate. The loan fails the Interest Rate test by XXXX%. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2150983 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2151001 | 1 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2151001 | 2 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows:The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%.The date used for rate set is XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2151001 | 3 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan is a rate restricted loan. (XXXX. §58.137.2(c)), The loan is secured by a subordinate lien on a dwelling, the term means a loan for which the APR (XXXX%) is greater than fivepercentage points above the yield on XXXX securities having comparable periods of maturity, as of the 15thday of the preceding month if the rate is set between the first and the XXXXth day of the month and as of the XXXXth day of the currentmonth if the rate is set on or after the XXXXth day (XXXX%). | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2151001 | 4 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Interest Rate | XXXX | This loan failed the Interest Rate test. The loan has an Interest Rate that does not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of XXXX allows for a maximum XXXX% Interest Rate, the loan has a XXXX% Interest Rate. The loan fails the Interest Rate test by XXXX%. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2151001 | 5 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: The Closing Disclosure was not received by the borrower at least three business days prior to the Consummation Date. The CD issued on XX/XX/XXXX was signed and dated at consummation, XX/XX/XXXX. The loan reviewed contains a note dated more than XXXX months old, outside the applicable statute of limitations. | Resolved | 3 | 2 | 3 | 2 | |||||
| XXXX | 2151001 | 6 of 6 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2150991 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150991 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150991 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the financed lender fees test. (XXXX. XXXX) The loan has financed lender fees that exceed XXXX% of the loan amount. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2150991 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Interest Rate | XXXX | This loan failed the Interest Rate test. The loan has an Interest Rate that does not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of XXXX allows for a maximum XXXX% Interest Rate, the loan has a XXXX% Interest Rate. The loan fails the Interest Rate test by XXXX%. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2150991 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150987 | 1 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2150987 | 2 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | HOC - Missing | XXXX | The Homeownership Counseling Disclosure (HOC) is missing. Real Estate Settlement Procedures Act (Regulation X) 12 CFR 1024.20(a) | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2150987 | 3 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2150987 | 4 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Interest Rate | XXXX | This loan failed the Interest Rate test. The loan has an Interest Rate that does not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of XXXX allows for a maximum XXXX% Interest Rate, the loan has a XXXX% Interest Rate. The loan fails the Interest Rate test by XXXX%. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2150987 | 5 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fee was not accepted: Recording Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) The loan reviewed contains a note dated more than XXXX months old, outside the applicable statute of limitations. | Resolved | 3 | 2 | 3 | 2 | |||||
| XXXX | 2150987 | 6 of 7 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Transfer Taxes. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv)The loan reviewed contains a note dated more than XXXX months old, outside the applicable statute of limitations. | Resolved | 3 | 2 | 3 | 2 | |||||
| XXXX | 2150987 | 7 of 7 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2150996 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX Rate Set was: XX/XX/XXXX. The loan is a compliant HPML. Prepayment requirement have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2150996 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii). | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2150996 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the financed lender fees test. The loan has financed lender fees that exceed XXXX% of the loan amount. This test includes the following fees: Lender's Title Insurance, Points-Loan Discount Fee, Settlement or Closing Fee, and XXXX. The loan failed the prohibited fees test by $XXXX. (XXXX. XXXX). | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2150996 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Interest Rate | XXXX | This loan failed the Interest Rate test. The loan has an Interest Rate that does not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of XXXX allows for a maximum XXXX% Interest Rate, the loan has a XXXX% Interest Rate. The loan fails the Interest Rate test by XXXX%. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2150996 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The application lists significant debts that were not verified on the credit report and not independently verified. The borrower owns a second home located at XXXX., XXXX, the loan file does not contain required documentation to verify whether or not the property is owned free and clear, amount of property taxes and if there are any homeowner association dues. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Per google maps, the lot is very rural...HOA dues are unlikely |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2150998 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX Rate Set was: XX/XX/XXXX. The loan is a compliant HPML. Prepayment requirement have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150998 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii). | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150998 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the financed lender fees test. The loan has financed lender fees that exceed XXXX% of the loan amount. This test includes the following fees: Points-Loan Discount Fee, Prepaid Interest, and XXXX. The loan failed the prohibited fees test by $XXXX. (XXXX. XXXX). | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2150998 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Interest Rate | XXXX | This loan failed the Interest Rate test. The loan has an Interest Rate that does not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of XXXX allows for a maximum XXXX% Interest Rate, the loan has a XXXX% Interest Rate. The loan fails the Interest Rate test by XXXX%. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2150998 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150988 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX Rate Set was: XX/XX/XXXX. The loan is a compliant HPML. Prepayment requirement have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2150988 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii). | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2150988 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the financed lender fees test. The loan has financed lender fees that exceed XXXX% of the loan amount. This test includes the following fees: Points-Loan Discount Fee, Prepaid Interest, Settlement or Closing Fee, and XXXX. The loan failed the prohibited fees test by $XXXX. (XXXX Stat. XXXX) | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2150988 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Interest Rate | XXXX | This loan failed the Interest Rate test. The loan has an Interest Rate that does not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of XXXX allows for a maximum XXXX% Interest Rate, the loan has a XXXX% Interest Rate. The loan fails the Interest Rate test by XXXX%. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2150988 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VVOE Salaried/Missing | XXXX | A VVOE is missing from the loan file. The loan file is missing a VVOE for the borrower. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) VOE |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2150989 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX Rate Set was: XX/XX/XXXX. The loan is a compliant HPML. Prepayment requirement have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150989 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii). | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2150989 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Interest Rate | XXXX | This loan failed the Interest Rate test. The loan has an Interest Rate that does not conform to the requirements for the lender's license type in the state where the property is located. The state regulation of XXXX allows for a maximum XXXX% Interest Rate, the loan has a XXXX% Interest Rate. The loan fails the Interest Rate test by XXXX%. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2150989 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2115836 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2115836 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2115836 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test.A valid change of circumstance was not provided in the loan file. Therefore, the addition to the following fees was not accepted: Lender's Title Insurance Policy. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund.A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) The loan reviewed contains a note dated more than XXXX months old, outside the applicable statute of limitations. | Resolved | 3 | 2 | 2 | 2 | |||||
| XXXX | 2115836 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2115838 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2115838 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Credit Score | XXXX | The subject Note date was XX/XX/XXXX. The subject's DTI was XXXX%. The initial credit report was obtained XX/XX/XXXX with a mid XXXX. An updated credit report was obtained on XX/XX/XXXX, prior to closing, and reflected a mid XXXX. The investor guidelines required a minimum credit XXXX for a DTI of XXXX % - XXXX%. | Waived | Response 1 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Investor reviewed and elects to waive. Noted Compensating Factors: $XXXX monthly residual income, XXXX years with employer, subject residence owned XXXX years. |
XXXX CLTV. $XXXX per month residual income. $XXXX in subject equity. | 3 | 2 | 3 | 2 | ||
| XXXX | 2119744 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2119744 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The origination credit reflected two student loan debts with XXXX with a balance of $XXXX with a payment amount on the final XXXX of $XXXX and XXXX with a balance of $XXXX with a payment on the final XXXX of $XXXX. Both student loans reflected payment deferred and no monthly payment was reflected on the origination credit. The lender's noted indicated that payments needed to be update to XXXX% of the outstanding balance. Using XXXX% of the balances increased the total outstanding liabilities and resulted in a DTI of XXXX%, exceeding the maximum of XXXX%. | Waived | Response 1 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Investor reviewed and elects to waive. Noted Compensating factors: Subject property owned XXXX years, XXXX years job stability, 0x30 mortgage history for XXXX months reviewed |
XXXX. XXXX% CLTV. | 3 | 2 | 3 | 2 | ||
| XXXX | 2071683 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2071683 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The application lists significant debts that were not verified on the credit report and not independently verified. The documentation to evidence the $XXXX debt for the additional REO located at XXXX, is missing from the loan file and would result in a DTI of XXXX%. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Lender approved to waive. |
Response 1 (XX/XX/XXXX XX:XXPM) Lender approved to waive based on compensating factors. (Waived) |
Comp factors - XXXX and XXXX years at current residence. | 3 | 2 | 3 | 2 | ||
| XXXX | 2115837 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2115837 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor isXXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2115837 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees were not accepted: Transfer Taxes and XXXX fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX of which $XXXX was cured at closing. There is a remaining cost to cure of $XXXX. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2115837 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2115840 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2115840 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2115841 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. Because the loan failed the Initial LE date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. The violation may be cured if documentation is provided showing the disclosure was delivered timely. A cost to cure in the amount of $XXXX is required. (12 CFR §1026.19(e)(3)(ii)) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XX/XX/XXXX LE |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2115841 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial LE/Delivery Date (from application) | XXXX | The loan failed the Initial Loan Estimate delivery date test (from application). The Initial LE issued on XX/XX/XXXX was not disclosed within XXXX days of the application date, XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.19(e)(1)(iii)(A) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX LE |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2115841 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that cannot increase test. Because the loan failed the Initial LE date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. The violation may be cured if documentation is provided showing the disclosure was delivered timely. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX LE |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2115841 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2071686 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | FACTA Disclosure - Missing | XXXX | The FACTA Disclosure (Notice to Home Loan Applicant/Credit Information Disclosure) is missing. Please have Digital Risk make note that these loans are acknowledged and that they are Non-Material grade XXXX | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2071686 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2071686 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Loan Discount Fee (Points). If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2071686 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2119746 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2119746 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2119746 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - DTI | XXXX | The subject loan does not meet Investor Program Parameters for DTI. The lender debt calculation omits a payment in the amount of $XXXX per month for an auto loan. The loan file contains no documentation as to why this debt was omitted, and the XXXX's bank statements in file show this debt being paid from the XXXX's account as recently as the month prior to closing. A recalculation of the XXXX's DTI including this debt results in a XXXX DTI, which exceeds the maximum guideline DTI of XXXX%. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) No open Auto loans present on credit report - where are you getting that information? |
Response 1 (XX/XX/XXXX XX:XXPM) There are XXXX borrowers. The XXXX is located as the 2nd item on Borrower 1 and XXXX's credit report. It is also reflected as being paid on their XXXX bank statement. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Investor reviewed and elects to waive. Noted Compensating factors: XXXX years job stability, subject property owned XXXX years, 0x30 mortgage history for XXXX months reviewed |
XXXX% CLTV. XXXX. $XXXX per month residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2119745 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fees was not accepted: XXXX Completion and Transfer Taxes. A cost to cure in the amount of $XXXX is required, of which $XXXX was cured at closing. There is a remaining cost to cure of $XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2119745 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - CLTV | XXXX | Per Lender's guides, properties on greater than XX acres and less than or equal to XXXX acres are required to reduce max CLTV by XXXX%. The max CLTV is XXXX% for borrowers with credit score over XXXX and max XXXX% DTI. The subject property is located on a XXXX acre land; therefore, the CLTV is required to be XXXX%. However, the CLTV is XXXX%. , which exceeds the max CLTV. | Waived | Response 1 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Investor reviewed and elects to waive. Noted compensating factors: XXXX qualifying credit score, 0x30 mortgage history for XXXX months reviewed, $XXXX monthly residual income. |
XXXX. $XXXX per month residual income. | 3 | 2 | 3 | 2 | ||
| XXXX | 2119745 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - DTI | XXXX | The Lender used P&I payment of $XXXX and did not include the XXXX payment of $XXXX, when calculating the borrower's qualifying PITI. However, the P&I payment is $XXXX, per original note and mortgage statement printout obtained in the loan file. No other documentation contained in the loan file reflects the P&I used. By using the accurate P&I payment of $XXXX and XXXX of $XXXX, the recalculation of the borrower's PITI is $XXXX. By using the updated PITI, the DTI increased from XXXX% to XXXX%; which is over the max of XXXX% for LTV/CLTV over XXXX%. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) The borrower refinanced his first mortgage at the same time he took out this closed end second. The total payment on the first lien is $XXXX + the second lien $XXXX = $XXXX. The loan qualified with PITI of $XXXX so we are still within guidelines. Rebuttal 2 (XX/XX/XXXX XX:XXPM) The original subject XXXX was $XXXX and the DTI was XXXX%. Now, I&#XXXX;ve verified that the subject PITI is $XXXX...how can the DTI be XXXX%. The DTI should be XXXX%. |
Response 1 (XX/XX/XXXX XX:XXPM) DTI with new first mortgage payment is XXXX%. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The original DTI calculated at review was XXXX%. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Investor reviewed and elects to waive. Noted compensating factors: XXXX qualifying credit score, 0x30 mortgage history for XXXX months reviewed, $XXXX monthly residual income. |
XXXX. $XXXX per month residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2129905 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129905 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2115842 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2115842 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2115842 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099870 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099870 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - Missing/Insufficient | XXXX | The hazard insurance policy provided indicates Coverage A dwelling amount of $XXXX, the loan file also includes a replacement cost estimator of $XXXX. Investor guidelines indicate in all cases Coverage A must meet or exceeds the replacement cost indicated. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) The dwelling coverage is $XXXX + XXXX% extended coverage as listed on the policy (page XXXX) $XXXX + XXXX% = $XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099820 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099820 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100323 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100323 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - Missing/Insufficient | XXXX | The loan file contains a hazard insurance policy with Dwelling Coverage A in the amount of $XXXX and a Replacement cost estimate with an amount of $XXXX. Investor guidelines states in all cases, Coverage A must meet or exceed the replacement cost indicated. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOI |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100240 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100240 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099879 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099879 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099828 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099828 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100398 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100398 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100317 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Transfer Taxes $XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2100317 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The file is missing verification of the taxes on the borrower vacant land located at XXXX XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Taxes |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2100166 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100166 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100234 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file; therefore, the increase to the following fee was not accepted: HOA Certification Handling on the revised CD issued on XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumers, PCCD and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC Rebuttal 2 (XX/XX/XXXX XX:XXPM) response |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is not sufficient to clear the finding. This fee is a XXXX% tolerance item in which the lender is required to know the cost without variance. Fee higher than expected is not a valid reason for the fee increase. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100234 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099999 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2099999 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2099999 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Lender Credits that Cannot Decrease (No Valid COC) | XXXX | The loan failed the Lender Credits that Cannot Decrease Test. The lender credit decreased on the CD issued on XX/XX/XXXX without a valid change of circumstance. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund.A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i) & Official Comment 19(e)(3)(i)-XXXX, -XXXX; 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Lender credit Rebuttal 2 (XX/XX/XXXX XX:XXPM) cure |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is not sufficient to clear the finding. Change in credit is not a valid reason for credit to decrease. There must be a valid reason that the credit decreased. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2099999 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2099981 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fee was not accepted: Transfer Tax. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099981 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099939 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099939 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099939 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fee was not accepted: XXXX (XX/XX/XXXX). If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z). 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC Rebuttal 2 (XX/XX/XXXX XX:XXPM) Fee response |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The COC dated XX/XX/XXXX does not provide any details as to why the Title - Closing Fee is increasing; please provide a detailed COC to determine if the increase is valid. It should be noted the COC dated XX/XX/XXXX discloses the fee increase will be int eh amount of $XXXX; however, the Title - Closing fee on the Final CD XX/XX/XXXX is $XXXX. A cost to cure in the amount of $XXXX remains. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099939 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100263 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fees was not accepted: Transfer Taxes. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) cure |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2100263 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2099973 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. The loan charges a discount fee that exceeds XXXX% of the principle amount of the loan. Please have Digital Risk make note that these loans are acknowledged and that they are Non-Material grade XXXX | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2099973 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2100048 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100048 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100400 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100400 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Other | XXXX | The guidelines indicate a Residential Equity Loan Policy Certificate (RELP) evidencing coverage under a Master Residential Equity Loan Policy (MRELP) is required, if the subject property is located in XXXX. The subject property is located in XXXX and the loan file is missing a copy of the Residential Equity Loan Policy Certificate. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Doc provided. |
Response 1 (XX/XX/XXXX XX:XXAM) Title Commitment provided. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100036 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100036 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100190 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100190 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100190 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the high-cost home loan points and fees threshold test. (XXXX AB XXXX, § XXXX.), (XXXX SB XXXX, § XXXX.)The total points and fees of this loan, which are $XXXX, exceed the following thresholds based on the total loan amount, which is $XXXX: The total points and fees exceed XXXX% of the total loan amount if the total loan amount is $XXXX or more | Void | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Fee response |
Response 1 (XX/XX/XXXX XX:XXAM) Finding voided |
1 | 1 | 1 | 1 | |||
| XXXX | 2100190 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099882 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Incomplete | XXXX | The following section of the Security Instrument (Mortgage/Deed of Trust) is incomplete: the notary acknowledgment is missing the notary stamp/seal. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) SI |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099882 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100174 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100174 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100030 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100030 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099814 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099814 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100279 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100279 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100392 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirement has been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100392 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100392 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Recording Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) COC |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100392 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100272 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100272 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100033 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Underwriting Fee. The loan fails the prohibited fees test by $XXXX. The loan failed the prohibited fees test due to one of the following findings: The loan is a second lien and charges fees that are not specifically permitted under MRS § XXXX et seq. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2100033 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VVOE Salaried/Missing | XXXX | A VVOE is missing from the loan file. The loan file is missing a VVOE for the: co-borrower. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) VOE Rebuttal 2 (XX/XX/XXXX XX:XXPM) L&E previously provided and is a VOE |
Response 1 (XX/XX/XXXX XX:XXAM) Still missing VVOE for the co-borrower XXXX. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2100369 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fees was not accepted: Recording Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PCCD Rebuttal 2 (XX/XX/XXXX XX:XXPM) PCCD |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding. The LOE, PCCD, and copy of the refund check have been provided. Proof of Delivery is required. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2100369 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2099850 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Settlement/Closing Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Initial cd |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099850 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: Without evidence of receipt, it is assumed that the disclosure dated XX/XX/XXXX was mailed, and therefore not received by the consumer XXXX business days prior to the consummation date, XX/XX/XXXX. If disclosure was delivered electronically, evidence of receipt as well as the consumer's E-consent is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099850 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that cannot increase test. Because the loan failed the initial CD delivery date test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset as a result of the following increases: Points. The violation may be cured if documentation is provided showing the disclosure was delivered timely. In addition, because a COC was not provided, auditor is unable to determine if the revised CD issued on XX/XX/XXXX was disclosed within XXXX business days of the change. Therefore, the increase to the following fees was not accepted: Transfer Taxes. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) TRID |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099850 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100291 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100291 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The application lists significant debts that were not verified on the credit report and not independently verified. The loan application reflects a mortgage for other real estate owned in the amount of $XXXX with a monthly payment of $XXXX. The loan file contains the sales agreement for the purchase of the property, dated XX/XX/XXXX, along with the homeowners insurance. The loan file is missing documentation verifying the mortgage payment and verification if the $XXXX payment is escrowed. Additional conditions may apply. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Statement |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100076 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100076 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100286 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100286 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100286 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | ROR - Timing | XXXX | This loan failed the TILA right of rescission test. Closed-end (12 CFR §1026.23(a)(3), transferred from 12 CFR §226.23(a) XXXX)), Open-end (12 CFR §1026.15(a)(3), transferred from 12 CFR §226.15(a)(3)) The funding date, XX/XX/XXXX, is before the third business day following consummation, XX/XX/XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NRTC response |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100286 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100029 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Inaccurate | XXXX | The security instrument was not completed accurately. The name of the Trust listed in the mortgage does not match the name of the Trust listed in the Trust documents. The date of the XXXX was not reflected on the mortgage and rider. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please disregard the upload for Underwriting conditions. This is regarding the Compliance for the SI Rebuttal 2 (XX/XX/XXXX XX:XXPM) corrected Note, SI |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. Revocable Trusts must list the date of the Trust in the mortgage. The borrower is a Revocable trust. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2100029 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Other | XXXX | The subject loan does not meet Program Parameters. The subject loan was delivered as an XXXX% CLTV cash out refinance with the existing 2nd & 3rd mortgages with XXXX being paid off at closing. Review of the credit report and the Title Commitment reflected the 3rd mortgage was opened on XX/XX/XXXX which was less than XXXX months prior to the subject note date of XX/XX/XXXX. Lender guidelines state the borrower must not have a prior cash out on the subject property in the last XXXX months to include fixed rate seconds. The loan file did not contain any documentation confirming the subject 3rd mortgage was not a cash out transaction. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) SI inquiry Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please review the email from the title company and advise if this is acceptable or specify exactly how you would like the SI to read. Thank you |
Response 1 (XX/XX/XXXX XX:XXPM) Incorrect document uploaded. Acknowledged by XXXX. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Document provided does not indicate if the mortgage in question was cash-out. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted compensating factors: Subject property owned XXXX years, 0x30 mortgage history for XXXX months reviewed; XXXX qualifying credit score; $XXXX monthly residual income. |
XXXX. $XXXX per month residual income. Guaranteed income Borrower. Employment stability Co-Borrower. | 3 | 2 | 3 | 2 | |
| XXXX | 2100321 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Incomplete | XXXX | The following section of the Security Instrument (Mortgage/Deed of Trust) is incomplete: The borrower's signature line on the Security Instrument was not dated by the borrower. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Re-recorded SI |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100321 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100210 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100210 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100382 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100382 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)).This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100382 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099866 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099866 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100248 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100248 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100248 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100187 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100187 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100094 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (Revised Disclosure Late) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. Because the change occurred on XX/XX/XXXX , and consumer was not provided the disclosure within XXXX days of the change, the increase to the following fees was not accepted as valid: Title Search Fee and Recording Fee on the revised LE issued XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, proof of delivery and copy of the refund.A cost to cure in the amount of $XXXX is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Response Rebuttal 2 (XX/XX/XXXX XX:XXPM) XXXX% response Rebuttal 3 (XX/XX/XXXX XX:XXPM) cure |
Response 1 (XX/XX/XXXX XX:XXPM) The grant deed that was required was executed on XX/XX/XXXX indicating the lender knew of the need for additional title and recording charges as far back as this date. This is not within XXXX business days of re-disclosure of fee increases on XX/XX/XXXX CD. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) We agree the cost to cure to cure the XXXX% tolerance violation is $XXXX. (XXXX) Response 3 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2100094 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (Revised Disclosure Late) | XXXX | The loan failed the charges that cannot increase test. Because the change occurred on XX/XX/XXXX, and consumer was not provided the disclosure within XXXX days of the change, the increase to the following fees was not accepted as valid: Transfer Taxes on the revised LE issued on XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, proof of delivery and copy of the refund. A cost to cure in the amount of $XXXX is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Response Rebuttal 2 (XX/XX/XXXX XX:XXPM) cure |
Response 1 (XX/XX/XXXX XX:XXPM) The grant deed that was required was executed on XX/XX/XXXX indicating the lender knew of the need for additional title and recording charges as far back as this date. This is not within XXXX business days of re-disclosure of fee increases on XX/XX/XXXX CD. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2100094 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100167 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100167 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100016 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100016 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099865 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099865 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100143 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100143 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099917 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Inaccurate | XXXX | The security instrument was not completed accurately. The subdivision name on the PUD Rider states "XXXX", on the legal description states "XXXX" | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) SI |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099917 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100120 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100120 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)). Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in the XXXX Financial Code. The Loan is a compliant HPML. Prepayment and XXXX requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100120 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099977 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099977 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099977 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Settlement /Closing Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) TRID |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099977 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100075 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - Revised CD Delivery Date (Waiting Period, APR) | XXXX | XXXX Required: An APR outside of allowable tolerance required a corrected Closing Disclosure and the corrected Closing Disclosure was not received by the borrower at least three business days prior to the Consummation Date. The CD issued on XX/XX/XXXX triggered a new XXXX-day waiting period. The baseline APR for comparison purposes was set on XX/XX/XXXX with an APR of XXXX%. The APR decreased more than XXXX. A decrease in APR alone does not cause the APR to become inaccurate. However, if in addition to the APR decrease the Actual Finance Charge is understated when compared to the previous Disclosed Finance Charge, the APR is then considered inaccurate. On XX/XX/XXXX in addition to the APR decrease of XXXX% the Finance Charge was understated by $XXXX. This was due to an increase in the loan amount. Therefore, a new waiting period was triggered on this CD. | Upheld | Rebuttal 1 (XX/XX/XXXX XX:XXPM) CD response |
Response 1 (XX/XX/XXXX XX:XXPM) An APR is considered inaccurate if it causes the Finance Charge to increase above previously disclosed thresholds. The decrease in APR is causing the borrower to pay an additional $XXXX in finance charge compared to the previous disclosure. According to the regulation this requires a new XXXX-day waiting period since the APR was Overstated but the Finance Charge was Understated compared to the previous disclosure. See 1026.22(XXXX) and (XXXX). Since no evidence of receipt was provided for the XX/XX/XXXX CD, the mailing rule was applied. If there is earlier evidence of receipt for this disclosure showing it met the timing rule, please provide (for both parties). (XXXX) |
XXXX | 3 | 3 | 3 | 3 | ||
| XXXX | 2100075 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 3 | |||||
| XXXX | 2099813 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Note - Missing Signature | XXXX | The Note was not fully executed by the borrower. Additionally, all copies were illegible. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Note |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099813 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Incomplete | XXXX | The following section of the Security Instrument (Mortgage/Deed of Trust) is incomplete: The name of the XXXX is missing in the before XXXX section. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) SI |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099813 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100159 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100159 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099908 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099908 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100014 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100014 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100319 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Signature Discrepancy | XXXX | The borrower signed the mortgage on XX/XX/XXXX but the notary stated the borrower appeared before them XX/XX/XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Recorded SI Rebuttal 2 (XX/XX/XXXX XX:XXPM) SI correction was initialed though it is quite small, it is there and County recorded |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The notary is to initial changes made to the notary section. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100319 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099898 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099898 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - Missing/Insufficient | XXXX | The loan file contains a hazard insurance policy with a coverage A amount of $XXXX and a replacement cost estimate stated as $XXXX. Investor guidelines state "In all cases, coverage A must meet or exceed the replacement cost indicated". While the email provided indicates coverage A amount is equal to the replacement cost the policy provided does not. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOI |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100002 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100002 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | DTI - Exceeds Guidelines | XXXX | Per guidelines the max LTV for a primary residence with a DTI over XXXX% is XXXX% LTV. The loan closed with a DTI of XXXX while the DTI calculated at audit is XXXX%. The variance is due to the lender inputting the current P&I incorrectly for the first mortgage. The XXXX provided shows the lender used a P&I payment of $XXXX while the mortgage statement in file verifies that the current P&I is actually $XXXX. | Waived | Response 1 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Investor reviewed and elects to waive. Noted Compensating factors: XXXX qualifying credit score, XXXX property owned XXXX years, 0x30 mortgage history for XXXX months reviewed |
XXXX. $XXXX per month residual income. XXXX% CLTV. | 3 | 2 | 3 | 2 | ||
| XXXX | 2099864 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099864 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Other | XXXX | According to guidelines a Residential Equity Loan Policy Certificate (RELP) evidencing coverage under a Master Residential Equity Loan Policy is required if the subject property is located in XXXX. The loan file is missing the RELP/MRELP as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Doc provided. |
Response 1 (XX/XX/XXXX XX:XXAM) Title Commitment provided. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100311 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100311 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100099 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fee was not accepted: Title Closing Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) TRID |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100099 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Credit Report - Alerts | XXXX | The credit report contains a fraud victim alert with a contact phone number and effective for XXXX year beginning XX/XX/XXXX. The file did not contain evidence alert had been cleared. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Fraud Review |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099861 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirement has been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2099861 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2099861 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test.A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund.A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC Rebuttal 2 (XX/XX/XXXX XX:XXPM) Cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. There's an invoice dated XX/XX/XXXX showing the full appraisal amount this indicates the lender know of the charge prior to XX/XX/XXXX. Response 2 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2099861 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100235 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100235 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100277 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100277 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100037 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | Federal - HPML APR/Compliant. This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100037 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | QM - Rebuttable Presumption. The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)).This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100037 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Recording fee $XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100037 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100177 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: Without evidence of receipt, it is assumed that the disclosure dated XX/XX/XXXX (XXXX) was mailed, and therefore not received by the consumer XXXX business days prior to the consummation date, XX/XX/XXXX. If disclosure was delivered electronically, evidence of receipt as well as the consumer's E-consent is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) CD response Rebuttal 2 (XX/XX/XXXX XX:XXPM) This was uploaded to you on XXXX/XXXX. Re-uploading now |
Response 1 (XX/XX/XXXX XX:XXPM) Please provide a copy of the referenced CD issued on XX/XX/XXXX for review. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100177 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099965 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099965 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099965 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Insufficient Documentation | XXXX | The loan file contained XXXX paystubs and a XXXX W2 documenting borrower XXXX's income; however, the paystubs in file did not reflect year-to-date XXXX earnings, and the loan file did not contain any additional documentation documenting year-to-date earnings as required. In addition, borrower XXXX is a Teacher and the loan file did not contain any documentation confirming the borrower was paid for XXXX or XXXX months as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) WVOE |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100247 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100247 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100247 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100093 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100093 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)).This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX . The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100093 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test.A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fee was not accepted:recording fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund.A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2100093 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100354 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HOEPA (High Cost)/Points & Fees | XXXX | The loan failed the high-cost mortgage (HOEPA) points and fees threshold test due to the following: his loan failed the high-cost mortgage points and fees threshold test due to one of the following findings: (12 CFR §1026.32(a)(1)(ii)(A), (B)).The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. The following points and fees were included in the calculation: Title- closing fee $ $XXXX; Title Lenders title insurance $XXXX, XXXX search $XXXX, Loan discount point $XXXX and origination fee $XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Response |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100354 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100169 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. his loan has points and fees that exceed the points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is less than $XXXX but at least $XXXX, and the transaction's total points and fees is $XXXX, which exceeds $XXXX. The following fees were included in the test : Title search fee $XXXX; Application Fee $XXXX, Lenders Title insurance $XXXX, Title -closing fee $XXXX, Loan discount points $XXXX and underwriting fee $XXXX. | Void | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan designation |
Response 1 (XX/XX/XXXX XX:XXPM) Finding voided. |
1 | 1 | 1 | 1 | |||
| XXXX | 2100169 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100327 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file; therefore, the increase to the following fee was not accepted: Appraisal on the revised LE issued on XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumers, PCCD and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2100327 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100303 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test.A valid change of circumstance was not provided in the loan file. Therefore, the addition to the following fees was not accepted: application fee and underwriting fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e).(XXXX)(iv). A tolerance cure of $XXXX was applied toward violations. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC Rebuttal 2 (XX/XX/XXXX XX:XXPM) COC |
Response 1 (XX/XX/XXXX XX:XXAM) The documents not received, please resubmit. Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100303 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099978 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099978 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100387 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100387 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099801 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fee: Loan Discount Points $XXXX. The loan fails the prohibited fees test by $XXXX. (XXXX XXXXXXXX §6122(a)) Please have Digital Risk make note that these loans are acknowledged and that they are Non-Material grade XXXX | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2099801 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2100376 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Appraisal fee increased on revised LE XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX was required in which $XXXX was reimbursed at closing. There is a remaining cost to cure in the amount of $XXXX required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100376 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100081 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100081 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100407 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100407 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Mortgage History - Missing/Incomplete | XXXX | The first mortgage on the subject property was with XXXX/XXXX. The investor guidelines required the most recent mortgage statement for the first lien mortgage. Additionally, the investor guidelines required the entire mortgage history for XXXX/XXXX or at a minimum activity for the previous XXXX months or longer. Guidelines reflect that months reporting history that is blank or has a dash (-) is not considered "activity" and does not evidence XX/XX/XXXX. Mortgage history on the origination credit does not contain XXXX months of history and has blanks and dashes. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) I asked the underwriting team to review and here is their response: A complete XXXX months of Mortgage History has been verified. XXXX is as follows: The Credit Report reflects XXXX/XXXX the borrower&#XXXX;s Mortgage loan was transferred from XXXX. ...#XXXX14 to its current loan servicer, XXXX/XXXX. See tradeline #XXXX on the XXXX. XXXX. account has Date Opened XXXX/XXXX & High Credit $XXXX that matches the XXXX XXXX mtg. See the "remarks" comments for AXXXX # ...#XXXX. It says ACCT TRANSERRED. Closed Date XXXX/XXXX. The Mortgage Payment History is thru XXXX/XXXX with XXXX. That said, if you count the mtg history info time frame to-date XXXX on the XXXX XXXX account, it starts from XXXX XXXX thru XXXX/XXXX, which is the reported dated on the XXXX XXXX tradeline. Combining these XXXX tradelines, they cover a complete XXXX months. (this would explain why theXXXX XXXX has the dashes.). It is because of the Transfer of Servicing in which they took over the account after it was closed with XXXX XXXX/XXXX). This is a complete XXXX months history. - due to Transfer of Servicing. I have uploaded the Credit Report into the Post Closing Misc placeholder. This satisfies XXXX4 to clear this item. |
Response 1 (XX/XX/XXXX XX:XXAM) Explanation and documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100407 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Other | XXXX | The subject property is located in XXXX. A Property Report from XXXX, LP was provided. For properties located in the State of XXXX, the investor guidelines required a Residential Equity Loan Policy Certificate (RELP) evidencing coverage under a Master Residential Equity Loan Policy (MRELP), A full ALTA title policy may be obtained in lieu of either a RELP certificate or E & O certificate. Required documentation was not provided. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) MRELP |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100338 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100338 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100211 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | ROR - Timing | XXXX | This loan failed the TILA right of rescission test. Closed-end ( 12 CFR §1026.23(a)(3) , transferred from 12 CFR §226.23(a)(3) ), Open-end ( 12 CFR §1026.15(a)(3) , transferred from 12 CFR §226.15(a)(3) ). The funding date, XX/XX/XXXX, is before the third business day following consummation, XX/XX/XXXX. The consumer may exercise the right to rescind until midnight of the third business day following consummation, delivery of the notice required by 12 CFR §XXXX or §XXXX, or delivery of all material disclosures, whichever occurs last. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) NRTC Rebuttal 2 (XX/XX/XXXX XX:XXPM) today is XX/XX/XXXX, rescission has now expired |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding. The Updated ROR for the loan transaction on was issued and the borrower has until midnight on XX/XX/XXXX to rescind. The exception can not be resolved until the recession period ends. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) The re-opened rescission expired at midnight on XX/XX/XXXX clearing the exception. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2100211 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100316 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: The Closing Disclosure was not received by the borrower at least three business days prior to the Consummation Date. The CD issued on XX/XX/XXXX was signed and dated at consummation, XX/XX/XXXX. If disclosure was delivered electronically evidence of receipt as well as the consumer's E-consent is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) ICD |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100316 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099914 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099914 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The application lists significant debts that were not verified on the credit report and not independently verified. The application lists an additional REO located at XXXX with a mortgage with a monthly payment of $XXXX and account number ending *XXXX. The loan file contained a mortgage statement for this account; however, the statement reflected a property address of XXXX. The property XXXX is not listed on the application. Further, the monthly PITIA payment information for XXXX is not documented or properly disclosed in the loan file. Documented evidence of this debt is required to ensure the DTI is properly calculated. Additional conditions may apply. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Regarding XXXX. Per XXXX, owned by XXXX XXXX Mortgage XXXX opened XX/XX/XXXX Item #XXXX on credit report Shows balance "N/A", a release is not recorded We spoke to XXXX and she indicated that the XXXX mortgage transferred to XXXX but she couldn&#XXXX;t document it. Assignment of mortgage is attached. |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100294 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Points loan discount fee and lender paid discount fee. The loan fails the prohibited fees test by $XXXX.This loan failed the discount fee test. ( N.J.S.A. §XXXX:11C-XXXX, N.J.A.C. §§XXXX:XXXX-XXXX ). The loan charges a discount fee that exceeds XXXX% of the principal amount of the loan. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2100294 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2099886 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The date used for rate set is XX/XX/XXXX. The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099886 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100136 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100136 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099868 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099868 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100364 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Incomplete | XXXX | The following section(s) of the Security Instrument (Mortgage/Deed of Trust) is incomplete: The name of the non-borrower spouse is missing from page one of the Security Instrument. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Custodian review Rebuttal 2 (XX/XX/XXXX XX:XXAM) the Deed from XXXX the only vested owner in the property is Borrower XXXX, married. See attached Deed from XXXX - not sure why XXXX mortgage has it both husband and wife. Typically, the lender requires spouse to sign as a dowry rights, I do think that is what happened on XXXX mortgage. And the current mortgage has the borrower&#XXXX;s name that aligns to the Deed attached. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. Although the title property report states present recorded owner only in XXXX's name dated XXXX, the same title property report shows a new mortgage more recently on XX/XX/XXXX that shows it was taken in the name of both XXXX and XXXX. Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100364 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100022 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirement has been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100022 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100022 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Inaccurate | XXXX | The security instrument was not completed accurately. The last name of the non-borrower spouse is misspelled on page one. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Our document custodian and XXXX accepted. Recorded SI attached. Page XXXX does not require any initials. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100022 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100408 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100408 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Other | XXXX | The loan file is missing proof of P&I payment for the current first lien. Per the XXXX the lender used a P&I payment of $XXXX, however that is the PI payment for the second XXXX being paid off. If the P&I payment for the first lien exceeds $XXXX/XXXX the loan is not eligible as the DTI will exceed XXXX% which is the DTI limit for the subject transaction when the borrower has a FICO less than XXXX. | Waived | Response 1 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted Compensating Factors: Subject residence owned XXXX years; XXXX LTV, 0x30 mortgage history for XXXX months |
Guaranteed income. XXXX years at same residence. | 3 | 2 | 3 | 2 | ||
| XXXX | 2100179 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: The appraisal Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2100179 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2099856 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099856 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099856 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Incomplete | XXXX | The following section of the Security Instrument (Mortgage/Deed of Trust) is incomplete: Page XXXX of the security instrument contained a manual edit which was not initialed. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Could you please advise if you would accept a reprint page XXXX with the correct information and provide a LOI to re-record as a correction method? Thank you. |
Response 1 (XX/XX/XXXX XX:XXPM) After a re-review with counsel, due to pg. XXXX changes being done electronically and the initials on the signature page being initialed by the borrower are sufficient to clear the exception. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099856 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100040 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100040 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100215 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100215 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100215 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Appraisal - Other | XXXX | The property condition report indicates that there is an addition isn't completed. No documentation was provided to confirm the addition has been completed. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PCI |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099833 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099833 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100092 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100092 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100363 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100363 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100363 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)) Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in the XXXX Financial Code. This loan is a compliance HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100363 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test.A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: HOA Certification Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required of which $XXXX was reimbursed at closing. There is a remaining cost to cure in the amount of $XXXX required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100363 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100335 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100335 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100335 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Appraisal fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Initial LE estimated with a $XXXX AVM however a full appraisal was required = $XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100335 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100084 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100084 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100084 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100125 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fee was not accepted: Underwriting, XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required of which $XXXX was cured at closing. There is a remaining cost to cure of $XXXX required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Response Rebuttal 2 (XX/XX/XXXX XX:XXPM) XXXX pccd |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The LOE provided indicates there was a Lender Credit in the amount of $XXXX for an increase in Closing Costs; however, the Final CD issued on XX/XX/XXXX discloses a Lender Credit in the amount of $XXXX. A cost to cure in the amount of $XXXX remains. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2100125 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100270 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Underwriting Fee $XXXX. The loan fails the prohibited fees test by $XXXX. (MRS § 408.052(XXXX); 408.233(XXXX)) | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2100270 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Credit - Other | XXXX | According to guidelines if property taxes are due within XXXX days of disbursement lender must obtain a new bill and use the updated amount in calculation. The property taxes are due XX/XX/XXXX and the subject loan disbursed XX/XX/XXXX. The only tax bill provided in the loan file is from XXXX. Additional conditions may apply. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Per the attached CES guidelines, when the first XXXX is a portfolio loan taxes and insurance are calculated from the Escrow Screen > Proposed Payment |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2100273 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2100273 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2100273 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The file failed one or more of the state threshold tests. This loan failed the prohibited fees test. (MRS § 408.052(XXXX); 408.233(XXXX)). The loan failed the prohibited fees test due to one of the following findings: The loan is a second lien and charges fees that are not specifically permitted under MRS § XXXX et seq. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2100273 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2099823 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC Rebuttal 2 (XX/XX/XXXX XX:XXPM) cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. This is a XXXX % tolerance item lender is expected to know the amount to charge for this type of product. A valid reason for the increase is required. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2099823 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100197 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Recording Fee . If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX, ALTA |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100197 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100056 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100056 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100012 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100012 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100012 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Closing Fee on the final CD issued XX/XX/XXXX. The COC provided in the loan file reflects the fee swapped with the Coordination Fee, this is not a valid reason for an increase in the Closing Fee from $XXXX to $XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) TRID response |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100012 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099896 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2099896 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2099896 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | State Testing. The file failed one or more of the state threshold tests. This loan failed the prohibited fees test. (MRS § 408.052(XXXX); 408.233(XXXX)). The loan failed the prohibited fees test due to one of the following findings: The loan is a second lien and charges fees that are not specifically permitted under MRS § XXXX et seq. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2099896 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2099834 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099834 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099834 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: Without evidence of receipt, it is assumed that the disclosure dated' XX/XX/XXXX 'was mailed, and therefore not received by the consumer XXXX business days prior to the consummation date,' XX/XX/XXXX. If disclosure was delivered electronically, evidence of receipt as well as the consumer's E-consent is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) CD response Rebuttal 2 (XX/XX/XXXX XX:XXPM) ICD |
Response 1 (XX/XX/XXXX XX:XXPM) The information provided was not sufficient to clear the finding. Although evidence was provided that the XX/XX/XXXX CD was not issued to the borrower, the documents show there is an earlier CD issued on XX/XX/XXXX. We are not in possession of that CD. Please provide CD issued on XX/XX/XXXX as well as any evidence of receipt. Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099834 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100236 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX% the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100236 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100236 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No COC - Date Indeterminable) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. Although the increase may be valid, because a COC was not provided, auditor is unable to determine if the revised CD issued on XX/XX/XXXX was disclosed within XXXX business days of the change. Therefore, the increase to the following fees was not accepted: Closing Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX% response |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100236 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099852 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099852 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099852 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Insufficient Documentation | XXXX | Per the lender's guidelines XXXX disability can be documented via the Certificate of Eligibility (COE) and the COE must be dated within XXXX days of the note date. The loan file contained a decision letter dated XX/XX/XXXX. The subject note date is XX/XX/XXXX. The required documentation was not found in the loan file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) I asked the underwriting team to take a look, this is their response: The award letter in the file is the most recent document that we would be able to get as an award letter. Regardless of the date of the document the income itself wouldn&#XXXX;t change. Rebuttal 2 (XX/XX/XXXX XX:XXAM) COE |
Response 1 (XX/XX/XXXX XX:XXPM) Document does not meet guidelines. Investor exception required. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100051 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test.A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fee was not accepted: XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC Rebuttal 2 (XX/XX/XXXX XX:XXPM) cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The Change of Circumstance provided pertains to a different borrower and loan. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2100051 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100275 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100275 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)) Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in the XXXX Financial Code. This loan is a compliance HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100275 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100221 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100221 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100221 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file; therefore, the addition of the following fee was not accepted: Application on the revised CD issued on XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumers, PCCD and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) coc Rebuttal 2 (XX/XX/XXXX XX:XXPM) cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The LE expiration is not a valid reason since the borrower executed the intent to proceed on XX/XX/XXXX. Correction to the original finding. It is the underwriting fee that increased from $XXXX to $XXXX on the LE issued on XX/XX/XXXX. A cost to cure in the amount of $XXXX is still required. Response 2 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2100221 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100402 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX was required of which $XXXX was cured on the CD. A cost to cure in the amount of $XXXX is still required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100402 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099937 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test.A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Title Closing Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund.A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX% response |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099937 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099968 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099968 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The application lists significant debts that were not verified on the credit report and not independently verified. The credit report shows evidence of child support payments via collection account listed but the loan file is missing documentation to support satisfied obligation. Provide documentation to support no monthly debt obligation is required of the borrower. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100134 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100134 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100134 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)). Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in the XXXX Financial Code. The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100134 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fee was not accepted: Appraisal fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A partial reimbursement was provider for $XXXX, however the remaining cost to cure is $XXXX. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2100134 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2099827 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099827 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099839 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099839 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a))Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in the XXXX Financial Code. The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099839 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099982 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX Rate Set was: XX/XX/XXXX. The loan is a compliant HPML. Prepayment requirement have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2099982 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii). | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2099982 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX HOEPA higher-priced mortgage loan test. The loan has an APR of XXXX%. The XXXX APR threshold is XXXX%. The loan is a compliant HPML. The Date Rate Set was: XX/XX/XXXX. Prepayment requirement have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2099982 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fee was not accepted: State Transfer Taxes. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Refund provided directly from XXXX before cited exception therefore we do not have tracking nor would we require title to send via XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2099982 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100334 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100334 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100334 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100250 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100250 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100061 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100061 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100298 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file; therefore, the addition of the following fees was not accepted: Title - Lender's Insurance on the CD issued on XX/XX/XXXX and Title - State Premium Tax on the revised CD issued on XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumers, PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2100298 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2099885 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099885 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099816 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - Revised CD Delivery Date (Waiting Period, APR) | XXXX | XXXX Required: An APR outside of allowable tolerance required a corrected Closing Disclosure and the corrected Closing Disclosure was not received by the borrower at least three business days prior to the Consummation Date. The CD issued on XX/XX/XXXX (received on XX/XX/XXXX) triggered a new XXXX-day waiting period. The baseline APR for comparison purposes was set on XX/XX/XXXX with an APR of XXXX%. The APR decreased more than XXXX. A decrease in APR alone does not cause the APR to become inaccurate. However, if in addition to the APR decrease the Actual Finance Charge is understated when compared to the previous Disclosed Finance Charge, the APR is then considered inaccurate. On XX/XX/XXXX in addition to the APR decrease of XXXX% the Finance Charge was understated by $XXXX. This was due to an increase in Loan Amount. Therefore, a new waiting period was triggered on this CD. | Upheld | Rebuttal 1 (XX/XX/XXXX XX:XXPM) CD response Rebuttal 2 (XX/XX/XXXX XX:XXPM) XXXX/XXXX CD delivery |
Response 1 (XX/XX/XXXX XX:XXPM) An APR is considered inaccurate if it causes the Finance Charge to increase above previously disclosed thresholds. Finance Charge overage is compared to the CD immediately prior to the APR change/trigger and not to a future disclosed finance charge that occurs later at closing. The decrease in APR is causing the borrower to pay an additional $XXXX in finance charge compared to the previous disclosure. According to the regulation this requires a new XXXX-day waiting period since the APR was Overstated but the Finance Charge was Understated compared to the previous disclosure. See 1026.22(XXXX) and (XXXX). (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Although the documents show that all parties viewed the disclosure on the same date it was issued (XX/XX/XXXX), this is not at least XXXX business days prior to closing, XX/XX/XXXX. (XXXX) |
XXXX | 3 | 3 | 3 | 3 | ||
| XXXX | 2099816 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 3 | |||||
| XXXX | 2099902 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099902 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX COMAR higher-priced mortgage loan test. (XXXX COMAR 09.03.06.02B(XXXX), COMAR XXXX)) Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in the Code of XXXX Regulations (COMAR). The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099902 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100144 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100144 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX% The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100144 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2100144 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100082 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100082 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099900 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099900 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - CLTV | XXXX | The subject loan does not meet Program Parameters for CLTV. The maximum CLTV is XXXX% for borrowers with a credit score between XXXX-XXXX. The borrower had a XXXX credit score and the audit CLTV was XXXX%. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) 1st XXXX balance $XXXX 2nd XXXX balance $XXXX Value $XXXX CLTV XXXX% |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100046 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100046 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100046 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the addition to the following fees was not accepted: Transfer taxes were added on revised LE XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Cure docs |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2100046 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100224 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100224 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX COMAR higher-priced mortgage loan test. (XXXX COMAR 09.03.06.02B(XXXX), COMAR XXXX)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in the Code of XXXX Regulations (COMAR). The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100224 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100344 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100344 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100344 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100004 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100004 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099911 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2099911 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2099911 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Underwriting Fee $XXXX, Closing Fee $XXXX, Points $XXXX, MERS Registration Fee $XXXX, and Flood Certification $XXXX. The loan fails the prohibited fees test by $XXXX. This loan failed the fees, compensation, and points test due to one of the following findings: (WVC § XXXX-XXXX-8 (m)(4)) If no yield spread premium is charged, the aggregate of fees, compensation, and points exceed XXXX% of the loan amount financed. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2099911 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: Without evidence of receipt, it is assumed that the disclosure dated XX/XX/XXXX was mailed, and therefore not received by the consumer XXXX business days prior to the consummation date, XX/XX/XXXX. If disclosure was delivered electronically, evidence of receipt as well as the consumer's E-consent is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) CD response Rebuttal 2 (XX/XX/XXXX XX:XXPM) Second response Rebuttal 3 (XX/XX/XXXX XX:XXPM) ICD |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The tracker indicates that the Disclosure was sent to the borrower just not received by the borrower. Additionally, the Closing Disclosure issued on XX/XX/XXXX and signed prior to consummation was not included in the loan file. Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. With the XXXX/XXXX CD not having been issued, then the only CD located in the loan file is the CD issued on XX/XX/XXXX. Rebuttal comments mentioned this is a revised CD. If there are additional CDs issued prior to the XX/XX/XXXX CD, please provide along with evidence of receipt. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2099911 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100381 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test.A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund.A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2100381 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2099835 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Recording Fees. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PCCD, ALTA |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2099835 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100242 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2100242 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2100242 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the fees, compensation, and points test due to one of the following findings: (WVC § XXXX-XXXX-8 (m)(4)) If yield spread premium is charged, combined fees, compensation, and points of any kind to the lender and broker or their affiliates, to arrange, originate, evaluate, maintain or service the loan exceed XXXX% of the loan amount financed; or If no yield spread premium is charged, the aggregate of fees, compensation, and points exceed XXXX% of the loan amount financed. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2100242 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2099922 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099922 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099963 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2099963 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2099963 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test.A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Recording Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund.A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Cure |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2099963 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100271 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - Revised CD Delivery Date (Waiting Period, APR) | XXXX | XXXX Required: An APR outside of allowable tolerance required a corrected Closing Disclosure and the corrected Closing Disclosure was not received by the borrower at least three business days prior to the Consummation Date. The CD issued on XX/XX/XXXX triggered a new XXXX-day waiting period. The baseline APR for comparison purposes was set on XX/XX/XXXX with an APR of XXXX%. The APR decreased more than XXXX. A decrease in APR alone does not cause the APR to become inaccurate. However, if in addition to the APR decrease the Actual Finance Charge is understated when compared to the previous Disclosed Finance Charge, the APR is then considered inaccurate. On XX/XX/XXXX in addition to the APR decrease of XXXX% the Finance Charge was understated by $XXXX. This was due to an increase in loan amount. Therefore, a new waiting period was triggered on this CD. Evidence of receipt for CD issued on XX/XX/XXXX was not provided, therefore the mailing rule was applied. | Upheld | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Response, COC |
Response 1 (XX/XX/XXXX XX:XXPM) An APR is considered inaccurate if it causes the Finance Charge to increase above previously disclosed thresholds. The decrease in APR is causing the borrower to pay an additional $XXXX in finance charge compared to the previous disclosure. According to the regulation this requires a new XXXX-day waiting period since the APR was Overstated but the Finance Charge was Understated compared to the previous disclosure. See 1026.22(XXXX) and (XXXX). Since no evidence of receipt was provided for the XX/XX/XXXX CD, the mailing rule was applied. If there is earlier evidence of receipt for this disclosure showing it met the timing rule, please provide (for both parties). (XXXX) |
XXXX | 3 | 3 | 3 | 3 | ||
| XXXX | 2100271 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Lender Credits that Cannot Decrease (Disclosure Timing Fail) | XXXX | The loan failed the Lender Credits that Cannot Decrease Test. Because the loan failed the XXXX CD Waiting Period test, any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset as a result of the following lender credit decrease on XX/XX/XXXX was not accepted. The violation may be cured if documentation is provided showing the disclosure was delivered timely. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i) & Official Comment 19(e)(3)(i)-XXXX, -XXXX; 12 CFR 1026.19(e)(3)(iv) | Upheld | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Response, COC |
Response 1 (XX/XX/XXXX XX:XXPM) An APR is considered inaccurate if it causes the Finance Charge to increase above previously disclosed thresholds. The decrease in APR is causing the borrower to pay an additional $XXXX in finance charge compared to the previous disclosure. According to the regulation this requires a new XXXX-day waiting period since the APR was Overstated but the Finance Charge was Understated compared to the previous disclosure. See 1026.22(XXXX) and (XXXX). Since no evidence of receipt was provided for the XX/XX/XXXX CD, the mailing rule was applied. If there is earlier evidence of receipt for this disclosure showing it met the timing rule, please provide (for both parties). (Upheld |
XXXX | 3 | 3 | 3 | 3 | ||
| XXXX | 2100271 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The application lists significant debts that were not verified on the credit report and not independently verified. The loan application reflects an additional REO located at XXXX XXXX, with a mortgage payment of $XXXX and other housing debt of $XXXX. The loan file contained evidence of hazard insurance reflecting a monthly payment of $XXXX and the mortgage payment is verified via the credit report; however, the remaining $XXXX monthly property debt is not documented in the loan file. Verification of this debt is required. Additional conditions may apply. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see property tax bill attached. Expenses slightly higher, adjusted DTI XXXX% which is within tolerance. |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 3 | |||
| XXXX | 2100121 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100121 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099990 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099990 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100054 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100054 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100054 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Rescission Test | XXXX | This loan failed the TILA right of rescission test. Closed-end ( 12 CFR §1026.23(a)(3) , transferred from 12 CFR §226.23(a)(3) ), Open-end ( 12 CFR §1026.15(a)(3) , transferred from 12 CFR §226.15(a)(3) ) The funding date is before the third business day following consummation. The loan closed on XX/XX/XXXX, the rescission end date was XX/XX/XXXX and the loan funded on XX/XX/XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Disbursement ledger |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100054 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX COMAR higher-priced mortgage loan test. ( XXXX COMAR 09.03.06.02B(XXXX) , COMAR XXXX) ). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in the Code of XXXX Regulations (COMAR). Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100054 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099925 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099925 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099925 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100068 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100068 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100170 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX and the calculated APR XXXX, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100170 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100170 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099916 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099916 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100205 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100205 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100205 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100199 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX and the calculated APR XXXX, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100199 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Rescission Test | XXXX | This loan failed the TILA right of rescission test. Closed-end ( 12 CFR §1026.23(a)(3) , transferred from 12 CFR §226.23(a)(3) ), Open-end ( 12 CFR §1026.15(a)(3) , transferred from 12 CFR §226.15(a)(3) ) The loan closed on XX/XX/XXXX, the rescission end date was XX/XX/XXXX and the loan funded on XX/XX/XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Disbursement ledger |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2100199 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX XXXX CMR XXXX higher-priced mortgage loan test. (XXXX XXXX CMR XXXX) Using the greater of the disclosed APR XXXX % and the calculated APR XXXX %, the loan is a higher-priced mortgage loan, as defined in the Code of XXXX Regulations. The loan is a compliant HPML.Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2100199 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - Closing Information/Disbursement Date | XXXX | The CD issued on XX/XX/XXXX5 does not reflect the correct Disbursement Date. Truth in XXXX (Regulation Z)12 CFR 1026.38(a)(3)(iii) | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2100199 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2099956 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099956 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX . The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable resumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099956 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100142 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100142 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan hasan APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100142 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: The Closing Disclosure was not received by the borrower at least three business days prior to the Consummation Date. The CD issued on XX/XX/XXXX was signed and dated at consummation, XX/XX/XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) ICD |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100142 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100132 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100132 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100228 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100228 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099959 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099959 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100015 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100015 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100127 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. This loan has points and fees that exceed the points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. The following fees were included in the testing: Application Fee $XXXX, Points $XXXX, Settlement Fee $XXXX, and Underwriting Fee $XXXX. If discount points and fees are bona-fide and excludable, provide undiscounted rate. Truth In Lending Act (Regulation Z) 12 CFR 1026.43(e)(2)(iii), (e)(3). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) QM response |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100127 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100006 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100006 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129820 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129820 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%.The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129820 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100264 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100264 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100264 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test.A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Title Closing Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund.A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX% response |
Response 1 (XX/XX/XXXX XX:XXPM) he documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100264 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2099819 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099819 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100219 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100219 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100219 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)). Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in the XXXX Financial Code. The date used for rate set is XX/XX/XXXX. The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100219 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100243 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100243 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100243 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099953 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099953 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan hasan APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. Using the greater of the disclosed APR and the calculatedAPR, the loan is a higher-priced mortgage loan, as defined in XXXX The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099953 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130197 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130197 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130197 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Appraisal - Missing required 1004 D | XXXX | The appraisal was completed "subject to inspection" for a water leak. The appraiser indicated the leak was what appeared to be from condensation/water damage caused by the air conditioning ducts per the borrower. An HVAC inspection and invoice for work completed was provided; however, the file did not contain the XXXXd as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) The documentation noted in the finding is sufficient to clear the requirement. A XXXXD stating the same thing as the inspection and photo evidence, is not required. |
Response 1 (XX/XX/XXXX XX:XXPM) Explanation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100312 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX lender fees test. This test includes the following fees: Title -Closing Fee $XXXX, Title - Lender's Title Insurance $XXXX, Title - TitleSearch $XXXX and Underwriting Fee $XXXX. The loan fails the prohibited feestest by $XXXX. (408.233(XXXX)) | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2100312 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fees was not accepted: Loan Discount Point Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC, pricing |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2100312 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2099899 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099899 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100071 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100071 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100071 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100301 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100301 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100301 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fee was not accepted: Recording Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2100301 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100218 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100218 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2100218 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129981 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129981 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%.The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129981 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129888 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129888 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129819 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129819 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129819 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130350 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the addition of the following fee was not accepted: Title - Attorney on the revised CD issued on XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer, PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) coc |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2130350 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Other | XXXX | The subject's mid score was XXXX. The maximum DTI allowed with a XXXX was XXXX%. The audit DTI of XXXX% was higher than the origination DTI of XXXX%. The audit DTI increase was due to the inclusion of documented HOA dues in the amount of $XXXX per month. The subject property is located in a PUD. A homeowners association billing statement was provided with HOA dues in the amount of $XXXX. The file contained an appraisal from the original purchase transaction in XXXX and indicated required HOA dues. At origination, the HOA dues were not included in the DTI. Documentation to support the omission of the HOA dues was not provided. With this included, the loan is ineligible due to loans with greater than XXXX% DTI require a XXXX. | Waived | Response 1 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Client reviewed and elects to waive. Noted compensating factors: $XXXX monthly residual income, Subject property owned XXXX years, 0x30xXXXX months mortgage history |
XXXX CLTV. $XXXX per month residual income. | 3 | 2 | 3 | 2 | ||
| XXXX | 2130350 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Other | XXXX | A QuickEQ Report wasprovided from XXXX. The Investor guidelinesrequired an Errors and Omissions certificate evidencing the loan is covered undera Service Agreement for which there is an Errors and Omissions LiabilityCertificate or E & O certificate. Full Alta title policy may be obtained in lie of E & O certificate. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Not all states require a full title policy on a CES product |
Response 1 (XX/XX/XXXX XX:XXPM) Transactional Certificate does not appear to meet guidelines. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Waiver not required. XXXX and XXXX is sufficient. (Resolved) |
XXXX (XX/XX/XXXX XX:XXPM) Client reviewed and elects to waive. Noted compensating factors: $XXXX monthly residual income, Subject property owned XXXX years, 0x30xXXXX months mortgage history |
3 | 1 | 3 | 2 | ||
| XXXX | 2130277 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. This loan has points and fees that exceed the points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount .The following fees were included in the testing: Application Fee $XXXX, Points $XXXX and Underwriting Fee $XXXX. If discount points and fees are bona-fide and excludable, provide undiscounted rate. Truth In Lending Act (Regulation Z) 12 CFR 1026.43(e)(2)(iii), (e)(3). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Non-QM (General ATR) full appraisal obtained Rebuttal 2 (XX/XX/XXXX XX:XXPM) QM response Rebuttal 3 (XX/XX/XXXX XX:XXAM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) The information provided is not sufficient to clear the finding. The full XXXX does not change the QM status of the loan. The QM Point and fees of the exceed the threshold. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding. The loan tape reflects this loan’s QM status at origination was Qualified Mortgage not Non-QM, indicating the loan is subject to QM guidelines. (XXXX) Response 3 (XX/XX/XXXX XX:XXAM) The new data tape provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2130277 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Incomplete | XXXX | The following section of the Security Instrument (Mortgage/Deed of Trust) is incomplete: Page XXXX of XXXX indicates the notary is following; however, the notary page was not found with the security instrument in the loan file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) SI |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2130277 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Miscalculated/DTI Exceeds Tolerance | XXXX | The borrowers' rental income was miscalculated at origination. They were given a positive $XXXX as rental income. However, after recalculating the borrowers' rental income, it resulted in receiving a positive monthly income of $XXXX, which matches the rental income calculation worksheet obtained in the loan file. By using the accurate calculation, the audit DTI went from XXXX% to XXXX%, which exceeds the max DTI of XXXX%, for borrowers with less than XXXX credit score. The qualifying credit score is XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Regarding XXXX: My rental income is $-XXXX but yours is $XXXX. I hope I&#XXXX;m wrong! Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please see attached. Rental income recalculated giving credit for one time expense. |
Response 1 (XX/XX/XXXX XX:XXAM) Recalculated positive net rental is still $XXXX. DTI stands at XXXX%. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
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| XXXX | 2130145 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No COC - Date Indeterminable) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. Although the increase may be valid, because a COC was not provided, auditor is unable to determine if the revised CD issued on XX/XX/XXXX was disclosed within XXXX business days of the change. Therefore, the increase to the following fees was not accepted: Closing Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A total cost to cure in the amount of $XXXX is required, ofwhich $XXXX was cured at closing. A cost to cure in the amount of $XXXX remains. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) fee response |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2130145 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - Missing/Insufficient | XXXX | The subject property is located in a PUD community and is an attached Townhome. The file contained an H06 policy in the borrower's name with total coverage of $XXXX. The Master HOA policy supporting the total coverages and limits for the PUD community was not provided as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOI |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
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| XXXX | 2130276 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130276 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130276 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the addition to the following fees was not accepted: Title - Dual Signing. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2130276 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130085 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - Closing Information/Closing Date | XXXX | The CD issued on XX/XX/XXXX does not reflect the correct Closing Date when compared to the notary signature date on the Security Instrument. Truth in XXXX (Regulation Z) 12 CFR 1026.38(a)(3)(ii). | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2130085 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130327 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130327 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129806 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129806 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130026 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130026 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130134 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130134 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129847 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129847 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129874 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129874 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130071 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan designation is General ATR Rebuttal 2 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 3 (XX/XX/XXXX XX:XXPM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Statement of General ATR does not address whether the loan was originated as a Qualified Mortgage. If the loan is a Qualified Mortgage please provide undiscounted rate evidencing any potential excludable points. If the loan is Exempt/Non-QM, please provide an updated Data Tape re-designating the loan as Exempt/Non-QM and/or documentation reflecting the re-designation as Exempt/Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The new data tape provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2130071 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129970 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129970 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130166 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | ROR - Timing | XXXX | his loan failed the TILA right of rescission test. Closed-end (12 CFR §1026.23(a)(3), transferred from 12 CFR §226.23(a)(3)), Open-end (12 CFR §1026.15(a)(3), transferred from 12 CFR §226.15(a)(3)). The funding date, XX/XX/XXXX is before the third business day following consummation, XX/XX/XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) PCCD, ALTA |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2130166 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129945 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129945 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130349 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130349 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129948 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129948 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130199 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130199 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129877 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. The loan amount is less than $XXXX but at least $XXXX, and the transaction's total points and fees is $XXXX, which exceeds $XXXX. The following fees were included in the testing: Application Fee $XXXX, Lender's Title Insurance Policy $XXXX, Points - Loan Discount Fee $XXXX1.XXXX, Settlement or Closing Fee $XXXX and Underwriting Fee $XXXX. If discount points and fees are bona-fide and excludable, provide undiscounted rate. Truth In Lending Act (Regulation Z) 12 CFR 1026.43(e)(2)(iii), (e)(3). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan delivery is Non-QM with full appraisal obtained Rebuttal 2 (XX/XX/XXXX XX:XXPM) The loan delivery designation is Non-QM as stated previously which is why a full appraisal was obtained. NON-QM Rebuttal 3 (XX/XX/XXXX XX:XXPM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) The information provided is not sufficient to clear the finding. The full XXXX does not change the QM status of the loan. The QM Point and fees of the loan exceed the threshold. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding. The loan tape reflects this loan’s QM status at origination was Qualified Mortgage not Non-QM, indicating the loan is subject to QM guidelines. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The new data tape provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2129877 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - Missing/Insufficient | XXXX | The XXXX provided in the loan file expired XX/XX/XXXX, prior to the XX/XX/XXXX Note Date. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOI |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130028 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130028 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows:The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130028 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130235 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130235 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)) The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130235 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)) Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130235 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130305 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130305 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130305 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VOE/Missing | XXXX | A VOE is missing from the loan file. The loan file is missing a VOE for the Borrower. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Per FNMA Guidelines (SEL-XXXX-XXXX) A borrower&#XXXX;s Leave & Earnings Statement is an acceptable VOE and must be XXXX days to XXXX calendar days. FHLMC Guidelines XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130223 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130223 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130096 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130096 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)) The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130096 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Flood Certificate - Missing | XXXX | The flood certificate is missing. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) FC |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129973 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129973 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130136 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 4 | 1 | |||||
| XXXX | 2130136 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Right to Rescind Missing | XXXX | The file contains no evidence of the Right to Cancel Notice. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) NRTCs are not required on second homes or investment properties. This loan is for a second home. |
Response 1 (XX/XX/XXXX XX:XXPM) The information provided is sufficient to clear the finding. (Resolved) |
4 | 1 | 4 | 1 | |||
| XXXX | 2130136 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 4 | 1 | |||||
| XXXX | 2129947 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129947 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129803 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129803 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129920 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129920 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129822 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129822 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129822 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VVOE Salaried/Missing | XXXX | A VVOE is missing from the loan file. The loan file is missing a VVOE for the borrower. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) VOE was provided |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130126 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130126 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129964 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129964 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129964 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129805 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - Revised CD Delivery Date (No Waiting Period) | XXXX | This loan failed the revised Closing Disclosure delivery date test (no waiting period required) due to the following: Without evidence of receipt, it is assumed that the disclosure dated XX/XX/XXXX was mailed, and therefore not received by the consumer prior to the consummation date, XX/XX/XXXX. If disclosure was delivered electronically, evidence of receipt as well as the consumer's E-consent is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Tracking |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129805 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129944 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129944 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129950 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2129950 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Property Type | XXXX | The subject loan does not meet Program Parameters for Property Type. The origination appraisal in file and the subject hazard insurance policy reflected the subject property was a log home. Per lender guidelines, log homes are ineligible properties. The subject loan does not meet program parameters. | Waived | Response 1 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Client reviewed and elects to waive. Per appraisal, no impact on marketability, Noted Compensating factors: XXXX qualifying credit score, Subject residence owned XXXX years, 0x30x52 mortgage history |
XXXX. XXXX% LTV. | 3 | 2 | 3 | 2 | ||
| XXXX | 2130095 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepaymentrequirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130095 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130095 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130218 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130218 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130117 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The date used for rate set is XX/XX/XXXX. The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130117 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualifyfor a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130117 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130043 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. This loan has points and fees that exceed the points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. The following fees were included in the testing: Lender's Title Insurance $XXXX, Loan Discount Points $XXXX and Underwriting Fees $XXXX. Truth In Lending Act (Regulation Z) 12 CFR 1026.43(e)(2)(iii), (e)(3). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) The new data tape provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2130043 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Tax Return Documentation Incomplete | XXXX | Tax returns for the previous two (XXXX) years (including all schedules and XXXX forms) were not obtained or were not properly retained in the file. Using guarantee payments and only have XXXX returns. To be able to use that income we need a complete XXXX years of personal and business returns to determine the eligible income. XXXX XXXX's also have other income listed on line XXXX of the returns need to determine with XXXX returns that this is recuring income to be able to use it to qualify. Currently if not using it we are about allowable DTI for this product. DTI increases to XXXX%. Provide XXXX returns to accurately determine allowable income | Waived | Response 1 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Client reviewed and elects to waive. Noted Compensating factors: Self-employed XXXX years, XXXX% CLTV, $XXXX residual income |
XXXX% CLTV. $XXXX per month residual income. | 3 | 2 | 3 | 2 | ||
| XXXX | 2130228 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130228 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130228 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130245 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130245 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129955 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129955 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129955 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129974 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129974 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130106 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130106 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130106 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: HOA certification handling. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130106 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Appraisal - Appraisal Missing | XXXX | Missing required appraisal from file. The loan file did not contain an AVM as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) AVM |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130106 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Insufficient Documentation | XXXX | The XXXX's conclusions on the adequacy and the stability of the applicant's income was not supported by documentation in the file. The loan file did not contain the borrower's most recent paystub as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130233 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130233 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130233 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129837 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129837 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129837 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130111 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130111 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130111 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130268 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130268 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130348 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan designation is General ATR Rebuttal 2 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 3 (XX/XX/XXXX XX:XXPM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Statement of General ATR does not address whether the loan was originated as a Qualified Mortgage. If the loan is a Qualified Mortgage please provide undiscounted rate evidencing any potential excludable points. If the loan is Exempt/Non-QM, please provide an updated Data Tape re-designating the loan as Exempt/Non-QM and/or documentation reflecting the re-designation as Exempt/Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The new data tape provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130348 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130086 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | This loan failed the prohibited fees test. (MRS § 408.052(XXXX); 408.233(XXXX)) The loan failed the prohibited fees test due to the following finding: The loan is a second lien and charges fees that are not specifically permitted under MRS § XXXX et seq. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2130086 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130181 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130181 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130181 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130007 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX% the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130007 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: This loan failed the qualified mortgage APR threshold test. (12 CFR §1026.43(e)(2)(vi)) The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan delivery is Non QM (ATR Exempt) with full appraisal Rebuttal 2 (XX/XX/XXXX XX:XXPM) The loan delivery designation is Non-QM as stated previously which is why a full appraisal was obtained. NON-QM Rebuttal 3 (XX/XX/XXXX XX:XXPM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) The information provided is not sufficient to clear the finding. The full XXXX does not change the QM status of the loan. The QM Points and fees of the loan exceed the threshold. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding. The loan tape reflects this loan’s QM status at origination was Qualified Mortgage not Non-QM, indicating the loan is subject to QM guidelines. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The new data tape provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130007 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129827 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129827 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130284 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130284 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | HOC - Missing | XXXX | The Homeownership Counseling Disclosure (HOC) is missing. Real Estate Settlement Procedures Act (Regulation X). 12 CFR 1024.20(a) | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2130284 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z). 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130284 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130284 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130032 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130032 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129852 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129852 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129852 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130185 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130185 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130185 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130261 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130261 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130261 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Settlement/Closing fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Fee response |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130261 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129858 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129858 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130110 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130110 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130084 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130084 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130319 | 1 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130319 | 2 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows:The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12FR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan designation is General ATR Rebuttal 2 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 3 (XX/XX/XXXX XX:XXPM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Statement of General ATR does not address whether the loan was originated as a Qualified Mortgage. If the loan is a Qualified Mortgage the finding is valid. If the loan is Exempt/Non-QM, please provide an updated XXXX re-designating the loan as Exempt/Non-QM and/or documentation reflecting the re-designation as Exempt/Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The new data tape provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130319 | 3 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. The loan amount is less than $XXXX but at least $XXXX, and the transaction's total points and fees is $XXXX, whichexceeds $XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan designation is General ATR Rebuttal 2 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 3 (XX/XX/XXXX XX:XXPM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Statement of General ATR does not address whether the loan was originated as a Qualified Mortgage. If the loan is a Qualified Mortgage please provide undiscounted rate evidencing any potential excludable points. If the loan is Exempt/Non-QM, please provide an updated Data Tape re-designating the loan as Exempt/Non-QM and/or documentation reflecting the re-designation as Exempt/Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The new data tape provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130319 | 4 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Trust Not Executed | XXXX | Title to the Property is held in a Trust, but the Trust Document is not properly executed. Unable to determine if signatures on the Security Instrument are accurate. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Trust |
Response 1 (XX/XX/XXXX XX:XXPM) The documents provided are sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130319 | 5 of 6 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fees was not accepted: Title - Coordination Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX% response |
Response 1 (XX/XX/XXXX XX:XXPM) The documents provided are sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130319 | 6 of 6 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129902 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2129902 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2129902 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The file failed one or more of the state threshold tests. This loan failed the prohibited fees test. (MRS § 408.052(XXXX); 408.233(XXXX)). The loan failed the prohibited fees test due to one of the following findings: The loan is a second lien and charges fees that are not specifically permitted under MRS § XXXX et seq. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2129902 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130198 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130198 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%.The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130198 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fee was not accepted: Title - Closing Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Response |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2130198 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Occupancy | XXXX | The Final XXXX indicates the borrower is currently occupying the subject property. Investor guidelines require the subject property to either be a primary residence or a second home. The loan file contains a business purpose and occupancy affidavit signed by the borrower at closing indicating the property will not be owner occupied. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Response Rebuttal 2 (XX/XX/XXXX XX:XXPM) Hello, we are confident this loan is a primary residence. We researched why the Business Purpose & Occupancy Affidavit was printed when it does not apply and we discovered this was a system glitch. What will you accept to confirm this XXXX) was a system glitch XXXX) the borrower intends to remain in the home as a Primary/Second Home. Thank you! |
Response 1 (XX/XX/XXXX XX:XXAM) Response provided does not address the subject defect. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Please provide a borrower attestation. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waiver) |
XXXX (XX/XX/XXXX XX:XXPM) Client reviewed and elects to waive. File contains a Cash-out purpose and occupancy affidavit of primary residence dated XX/XX/XXXX. Income documentation provided matches borrowers address. Lender attested to system error. Noted compensating factors: Subject property owned XXXX years, job stability XXXX years, XXXX qualifying credit score. |
XXXX. XXXX% CLTV. | 3 | 2 | 3 | 2 | |
| XXXX | 2130198 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VVOE Salaried/Aged | XXXX | A VVOE is required within XXXX Business Days of the Note Date. The VVOE in file is dated XX/XX/XXXX which is expired as of the Note date XX/XX/XXXX. | Void | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Invalid - you do not include Sat and Sundays - it is exactly XXXX business days |
Response 1 (XX/XX/XXXX XX:XXPM) Agreed. Finding is invalid. (Void) |
1 | 1 | 3 | 2 | |||
| XXXX | 2130196 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130196 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130196 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the required fees test. (XXXX Constitution, Article 16, Section 50 (a)(6)(E) & (t)(4), as amended Jan. XXXX)The loan requires the borrower(s) to pay, in addition to interest, fees to any person that are necessary to originate, evaluate, maintain,record, insure, or service the extension of credit that exceed XXXX% of the original principal amount, excluding fees for: An appraisal performed by a third party appraiser;A state base premium for a mortgagee policy of title insurance with endorsements established in accordance with state law, or a title examination report if its cost is less than the state base premium for a mortgagee policy of title insurance without endorsements established in accordance with state law. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) State testing |
Response 1 (XX/XX/XXXX XX:XXPM) The information provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130196 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129811 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129811 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130317 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130317 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130107 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130107 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130107 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX HOEPA higher-priced mortgage loan test. The loan is a higher-priced mortgage loan, as defined in the legislation. The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130107 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129833 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | State Disclosure - Texas Home Equity Loan Consumer Disclosure (12-Day Letter)/Missing | XXXX | The XXXX Consumer Disclosure (XXXX-Day Letter) is Missing. Required to be provided in connection with a XXXX. XXXX Constitution - Home Equity Loan Provisions. XXXX. Const. art. XVI, '''50(a)(6)(M)(i), 50(g); XXXX XXXX. Admin. Code '' XXXX, XXXX | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Signed more than XXXX days from closing. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129833 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129810 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129810 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129812 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Title Closing Fee If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Title Fees |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129812 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130281 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Appraisal fee increased on revised LE XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2130281 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130022 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130022 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130138 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130138 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129949 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129949 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130023 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130023 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130023 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Credit - Other | XXXX | There are additional observations that could impact the credit decision and/or quality of the loan. XXXX debt is listed on the final XXXX with a minimum payment of $XXXX and a balance of $XXXX however it is not being included in the DTI. There are no supporting documents to why this debt is being excluded from the DTI. If included the DTI increases to over allowable to XXXX% back end. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130023 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Pay Stubs Missing | XXXX | The required pay stubs were not obtained from the applicant(s) or were not properly retained in the file. File contains a paycheck and XXXX from XXXX there is no proof of current income amount being received. Base and OT income is being used to qualify we need to have current and prior YTD income to determine correct income to use. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see attached XXXX. I hope this is acceptable...I&#XXXX;d like to avoid disturbing the borrowers if at all possible. |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130257 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the addition to the following fee was not accepted: Title - Lender's Title Insurance. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130257 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129816 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX Rate Set was: XX/XX/XXXX. The loan is a compliant HPML. Prepayment requirement have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129816 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii). | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129816 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130070 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130070 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan designation is General ATR Rebuttal 2 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 3 (XX/XX/XXXX XX:XXPM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Statement of General ATR does not address whether the loan was originated as a Qualified Mortgage. If the loan is a Qualified Mortgage the finding is valid. If the loan is Exempt/Non-QM, please provide an updated XXXX re-designating the loan as Exempt/Non-QM and/or documentation reflecting the re-designation as Exempt/Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The new data tape provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130070 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129899 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129899 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130091 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130091 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129867 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129867 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129867 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130054 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130054 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The application lists significant debts that were not verified on the credit report and not independently verified. The loan file does not contain adequate documentation to verify the cost of XXXX on the borrowers rental property located at XXXX, XXXX, XXXX XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) From the underwriting team: Per notes in the loan this isn&#XXXX;t a separate property. XXXX should have been updated but we have two properties with similar addresses:XXXX XXXX. Per borrower they are the same, which aligns with every google search and the addresses being essentially the same. RQ does have them as two different APNs but the tax amounts for both were accounted for, so there is no liability difference. |
Response 1 (XX/XX/XXXX XX:XXAM) Explanation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130087 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130087 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130047 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130047 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130101 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130101 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130101 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130219 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130219 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: A qualified mortgage is a covered transaction which, among other requirements, is not negatively amortizing and: The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan designation is ATR Exempt |
Response 1 (XX/XX/XXXX XX:XXPM) Lender originated as Non-QM. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130219 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129824 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129824 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129824 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130053 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130053 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130155 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. This loan has points and fees that exceed the points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is less than $XXXX but at least $XXXX, and the transaction's total points and fees is $XXXX, which exceeds $XXXX. If discount points and fees are bona-fide and excludable, provide undiscounted rate. Truth In Lending Act (Regulation Z) 12 CFR 1026.43(e)(2)(iii), (e)(3). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NON QM Full appraisals is required if the loan fails both HPML and any part of QM. It is the HPML rule that triggers the appraisal requirement not QM, but loans compliant with QM are exempt from the appraisal rule under HPML. While this loan is failing QM it is not failing HPML so no appraisal is required. Rebuttal 2 (XX/XX/XXXX XX:XXPM) QM response Rebuttal 3 (XX/XX/XXXX XX:XXPM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) The information provided is not sufficient to clear the finding. We agree the loan is not a Federal High-Cost loan (HPML). The full XXXX does not change the QM status of the loan. The QM Point and fees of the loan exceed the threshold. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding. The loan tape reflects this loan’s QM status at origination was Qualified Mortgage not Non-QM, indicating the loan is subject to QM guidelines. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The new data tape provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130155 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130154 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No COC - Date Indeterminable) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. Although the increase may be valid, because a COC was not provided, auditor is unable to determine if the revised CD issued on XX/XX/XXXX was disclosed within XXXX business days of the change. Therefore, the increase to the following fees was not accepted: Closing Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Fee response |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130154 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129813 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129813 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129813 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Incomplete | XXXX | The following section(s) of the Security Instrument (Mortgage/Deed of Trust) is incomplete: The Notary Acknowledgement on page XXXX of XXXX was incomplete, the XXXX did not disclose the date that the document was executed before them by the Co-Borrower. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Recorded complete DOT |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129813 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130184 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130184 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130184 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129985 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129985 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129985 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130334 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130334 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129869 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129869 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129869 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)) Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in the XXXX Financial Code. The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129869 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129869 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contained a CDA dated XX/XX/XXXX that supported the value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130098 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130098 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130098 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130225 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Name Discrepancy | XXXX | The Vested Interest on the Security Instrument is inconsistent with the XXXX. The Security Instrument removed the Borrower's ex-spouse; however, the loan file did not contain a deed for the change in Vested Interest. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Divorce Decree |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130225 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130167 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130167 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130109 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130109 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130100 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130100 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130100 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130244 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130244 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129976 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129976 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129976 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Condo - Documentation | XXXX | Loan file did not contain required condo documentation. The Condo Questionnaire was missing from the loan file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Questionnaire |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129976 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Condo - Other | XXXX | Per XXXX Statute S.B. 4D for all XXXX condo projects XXXX stories or more, XXXX years or older or XXXX years and older if within XXXX miles of coast a Structural Inspection is required. Structural inspection missing from file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Condo docs |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130108 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130108 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Credit - Other | XXXX | There are additional observations that could impact the credit decision and/or quality of the loan. The first XXXX note is missing from the loan file as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Note Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please see attached Rebuttal 3 (XX/XX/XXXX XX:XXPM) 1st XXXX |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation not received. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) The second mortgage note that was refinanced was provided. Still missing first mortgage note. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129929 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129929 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130248 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130248 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129901 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2129901 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Liabilities - Missing Debts/ DTI Exceeds Tolerance | XXXX | The DTI did not reflect all of the borrower's debts resulting in a DTI that exceeds allowable tolerances. Based on the final DTI as reflected by the Lender of XXXX%, the Lender qualified the Borrower based on total debt of $XXXX which represents the total consumer debt of $XXXX, primary housing payment of $XXXX and subject PITIA of $XXXX which appears to have been calculated based on the previous second XXXX payment being paid off in the subject transaction of $XXXX, rather than the new subject payment of $XXXX. The correct calculation results in a DTI of XXXX% which exceeds the guideline maximum of XXXX%. | Waived | Response 1 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Client reviewed and elects to waive. Noted Compensating factors: Subject residence owned XXXX years, Job stability XXXX years, $XXXX monthly residual income, 0x30xXXXX month mortgage history |
XXXX. XXXX% CLTV. $XXXX per month residual income. | 3 | 2 | 3 | 2 | ||
| XXXX | 2130182 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130182 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130150 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130150 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130150 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contained a CDA dated XX/XX/XXXX that supported the value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130102 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130102 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130102 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e)(1) ) This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130102 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129826 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX% the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129826 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129894 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. The following fees were included in the testing: Application $XXXX, Title Insurance $XXXX, Points $XXXX, Settlement $XXXX, Underwriting $XXXX. If discount points and fees are bona-fide and excludable, provide undiscounted rate. Truth In Lending Act (Regulation Z) 12 CFR 1026.43(e)(2)(iii), (e)(3). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) ATR Exempt |
Response 1 (XX/XX/XXXX XX:XXPM) Lender originated as Non-QM. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2129894 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Miscalculated/DTI Exceeds Tolerance | XXXX | The income is miscalculated on one or more borrowers, however the recalculated DTI is not within allowable tolerances. B2 Social Security income was grossed up XXXX% at Origination, with no documentation provided to verify income is non-taxable, to $XXXX. However per guideline, only XXXX% of income can be grossed up without documentation. Per Benefit letter, monthly pay is $XXXX. XXXX% of income is $XXXX, and XXXX% of that is $XXXX, totaling $XXXX. With this income, DTI ratio increased to XXXX% exceeding the guideline maximum of XXXX% for a Borrower with a a qualifying FICO of XXXX. | Waived | Response 1 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Client reviewed and elects to waive. Noted compensating factors: XXXX years with current employer, XXXXx30x15 month mortgage history, |
XXXX% LTV. $XXXX per month residual income. | 3 | 2 | 3 | 2 | ||
| XXXX | 2129821 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129821 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129821 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fee was not accepted: Title - Closing Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Title fees |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129821 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Final Application - Inaccurate | XXXX | The Final Application reflects a mortgage with XXXX with monthly payment of $XXXX and balance of $XXXX under the liabilities section and not under the property you own section. Mortgage is reflected on the credit report. It cannot be determined what property the mortgage is securing based upon the loan documentation provided and if the mortgage with XXXX is escrowed. Additional conditions may apply. Based upon a monthly payment of $XXXX the DTI increases to XXXX% which is within max XXXX% DTI. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX #XXXX $XXXX $XXXX Per MERS secured against XXXX, XXXX, XXXX. Co-signed with XXXX. Taxes $XXXX / XXXX = $XXXX |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130227 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130227 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130139 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130139 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129958 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129958 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)) This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129958 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129959 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129959 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129959 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX XXXX CMR XXXX higher-priced mortgage loan test. (XXXX XXXX CMR XXXX). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in the Code of XXXX Regulations. The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129959 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130229 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130229 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130229 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Abstract/Title Search Fee $XXXX, Lender's Title Insurance $XXXX, Settlement Fee $XXXX and Underwriting Fee $XXXX. The loan is a second lien and charges fees that are not specifically permitted under MRS § XXXX et seq | Cleared | 2 | 2 | 2 | 2 | |||||
| XXXX | 2130229 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130149 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX% the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130149 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)) The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130149 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129860 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129860 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130306 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130306 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130130 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130130 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130130 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130130 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129889 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129889 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129889 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130266 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130266 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130266 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX COMAR higher-priced mortgage loan test. (XXXX COMAR 09.03.06.02B(XXXX), COMAR XXXX)) Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in the Code of XXXX Regulations (COMAR). The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130266 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130252 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130252 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130252 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX COMAR higher-priced mortgage loan est. (XXXX COMAR 09.03.06.02B(XXXX), COMAR XXXX)) Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in the Code of XXXX Regulations (COMAR). The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130252 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130093 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130093 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130152 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | HOC - Missing | XXXX | The Homeownership Counseling Disclosure (HOC) is missing. Real Estate Settlement Procedures Act (Regulation X) 12 CFR 1024.20(a). | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2130152 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130239 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130239 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129978 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129978 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129978 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contained a CDA dated XX/XX/XXXX that supported the value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129802 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129802 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130191 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130191 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130042 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130042 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129965 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129965 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129965 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contained a CDA dated XX/XX/XXXX that supported the value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129809 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129809 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130115 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130115 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130115 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130041 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130041 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130251 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130251 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130230 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130230 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129996 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129996 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129972 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129972 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows:The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129972 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130309 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. The loan amount is less than $XXXX but at least $XXXX, and the transaction's total points and fees is $XXXX, which exceeds $XXXX. The following fees were included in the testing: Title Search, Application Fee, Lenders Title Insurance, Discount Points, Title Settlement, Underwriting Fee. Truth In Lending Act (Regulation Z) 12 CFR 1026.43(e)(2)(iii), (e)(3). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) The new data tape provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130309 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129957 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129957 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129957 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129830 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | HOC - Missing | XXXX | The Homeownership Counseling Disclosure (HOC) is missing. Real Estate Settlement Procedures Act (Regulation X) 12 CFR 1024.20(a) | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2129830 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130345 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130345 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130094 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130094 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130094 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130161 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130161 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129865 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129865 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129938 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129938 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129938 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130103 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130103 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130103 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130344 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130344 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129946 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129946 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129969 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129969 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z). 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129969 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in the XXXX Financial Code. The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129969 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129892 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Points. The loan fails the prohibited fees test by $XXXX. (XXXX RCW §31.04.105) | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2129892 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Total of Payments Rescindable | XXXX | The loan failed the Rescission Total of Payments tolerance test. Per the special foreclosure rule under Regulation Z, for loans subject to the right of rescission the Total of Payments is considered inaccurate if the disclosed Total of Payments is understated by more than $XXXX. The final CD issued on XX/XX/XXXX has a disclosed Total of Payments of $XXXX, which is less than the system calculated Total of Payments of $XXXX5.XXXX. The Total of Payments on the final CD is understated by $XXXX which is more than the allowable tolerance of $XXXX. A cost to cure in the amount of $XXXX is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) TOP Response Rebuttal 2 (XX/XX/XXXX XX:XXPM) All fees are included in the TOP calculations and reflect no variance from the CD |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. If a Fee is a PFC or a Non- PFC does not determine if a fee is included in TOP. The Total of Payments includes all amounts the borrower will pay over the life of the loan. This fee is included because it is required to obtain the loan. Including it ensures the Total of Payments accurately reflects the full cost of the loan. A cost to cure in the amount of $XXXX remains. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2129892 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130355 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130355 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130287 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130287 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130259 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130259 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130259 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the addition to the following fees was not accepted: Dual Signing Fee (Notary). If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund.A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC Rebuttal 2 (XX/XX/XXXX XX:XXPM) COC |
Response 1 (XX/XX/XXXX XX:XXPM) Documents not received. Please resubmit. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130259 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130143 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130143 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130352 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130352 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129849 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Points. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund.A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) COC only states change in settlement fee XXXX/XXXX LE XXXX XXXX XXXX PTS XXXX XXXX/XXXX LE - lock PTS XXXX XXXX/XXXX LE XXXX XXXX XXXX ** PTS XXXX XXXX/XXXX CD PTS XXXX XXXX/XXXX CD PTS XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129849 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130242 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130242 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z). 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130242 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130246 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130246 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129943 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Recording Fees (XX/XX/XXXX). If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z). 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) ALTA, PCCD |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129943 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130077 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130077 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129909 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129909 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130158 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130158 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VVOE Salaried/Aged | XXXX | Guidelines require the verbal verification of employment be within XXXX business days of the Note. Upon reviewing the loan file, the Note is dated XX/XX/XXXX and the verbal verification of employment is dated XX/XX/XXXX which is within XXXX business days of the Note. | Void | Rebuttal 1 (XX/XX/XXXX XX:XXPM) The borrower is in the military. Per FNMA B3-XXXX-XXXX, in lieu of a verbal or written VOE, the lender can obtain a military Leave and Earnings Statement dated within XXXX calendar days prior to the note date. The file contains an LES dated XX/XX/XXXX. |
Response 1 (XX/XX/XXXX XX:XXPM) Explanation received is sufficient. (Void) |
1 | 1 | 1 | 1 | |||
| XXXX | 2130224 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130224 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130337 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130337 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z). 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130337 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130083 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130083 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129879 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129879 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | DTI - Exceeds Guidelines | XXXX | The DTI exceeds Originator Guidelines. The lender calculated the total monthly other debts as $XXXX and total monthly income as $XXXX with a DTI of XXXX%; however, based on the documentation in the loan file, the actual total other debts were $XXXX and total income was $XXXX, resulting in an audit DTI XXXX%. | Void | Rebuttal 1 (XX/XX/XXXX XX:XXPM) I acknowledge the reviewer&#XXXX;s comments, however, this is non-material. The CLTV is < XXXX% and the credit score is > XXXX so maximum DTI allowed is XXXX%. |
Response 1 (XX/XX/XXXX XX:XXPM) Explanation received is sufficient. (Void) |
1 | 1 | 1 | 1 | |||
| XXXX | 2130234 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130234 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130234 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130292 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Closing Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Fees response |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130292 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130250 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130250 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129872 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129872 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129872 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129941 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129941 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z). 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129941 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129834 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2129834 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Other | XXXX | The subject loan does not meet Program Parameters. The subject loan is a primary 2nd mortgage with a loan amount of $XXXX, a LTV of XXXX%, a credit XXXX, and a Note date of XX/XX/XXXX. The subject loan proceeds were used to payoff an existing 2nd mortgage that was originated/opened on XX/XX/XXXX, along with the Title Search reflecting both mortgages on the subject property. The program guidelines reflect the borrower is not permitted to have obtained cash out on the subject property within the past XXXX months. The loan file did not contain an exception; therefore, the subject loan is an ineligible transaction. ***additional conditions may apply *** | Waived | Response 1 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Client reviewed and elects to waive: XXXX qualifying credit score, XXXX property owned XXXX years, $XXXX monthly residual income, job stability of XXXX years, 0x30 mortgage history for XXXX months reviewed |
XXXX. XXXX% CLTV. XXXX% DTI | 3 | 2 | 3 | 2 | ||
| XXXX | 2130081 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. If discount points and fees are bona-fide and excludable, provide undiscounted rate. Truth In Lending Act (Regulation Z). 12 CFR 1026.43(e)(2)(iii), (e)(3) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan designation is General ATR Rebuttal 2 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 3 (XX/XX/XXXX XX:XXPM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Statement of General ATR does not address whether the loan was originated as a Qualified Mortgage. If the loan is a Qualified Mortgage please provide undiscounted rate evidencing any potential excludable points. If the loan is Exempt/Non-QM, please provide an updated Data Tape re-designating the loan as Exempt/Non-QM and/or documentation reflecting the re-designation as Exempt/Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The new data tape provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130081 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Appraisal - Other | XXXX | The original appraisal indicates the subject property is reported to have a XXXX located within the garage, which is supported by photo showing multiple XXXX and growing systems. The appraisal was made subject to removal of the health and safety concerns in the garage. The XXXXD indicates health and safety concerns had been removed, with photos attached showing wiring removal from ceiling and empty bed growing beds (plants removed). Four empty growing beds remain. Internet Search of XXXX indicated growing XXXX at home is legal in XXXX, but strict limits of six living plants per residence. There is no documentation in the file that confirms future use of the XXXX or if it is within XXXX law. Photos with original appraisal show excess of XXXX plants. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) At the time of closing there were no plants or wiring system to support them. The property meets Agency guidelines. |
Response 1 (XX/XX/XXXX XX:XXPM) XXXXD clears the property from health and safety concerns. Electrical and plants removed. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130330 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. The loan amount is less than $XXXX but at least $XXXX, and the transaction's total points and fees is $XXXX, which exceeds $XXXX. The following fees were included in the testing: Application Fee $XXXX, Points $XXXX and Underwriting Fee $XXXX. If discount points and fees are bona-fide and excludable, provide undiscounted rate. Truth In Lending Act (Regulation Z). 12 CFR 1026.43(e)(2)(iii), (e)(3) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan designation is General ATR Rebuttal 2 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 3 (XX/XX/XXXX XX:XXPM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Statement of General ATR does not address whether the loan was originated as a Qualified Mortgage. If the loan is a Qualified Mortgage please provide undiscounted rate evidencing any potential excludable points. If the loan is Exempt/Non-QM, please provide an updated Data Tape re-designating the loan as Exempt/Non-QM and/or documentation reflecting the re-designation as Exempt/Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The new data tape provided is sufficient to clear thefinding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130330 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129900 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129900 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) The new data tape provided is sufficient to clear thefinding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129900 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129887 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129887 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130092 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130092 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130068 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130068 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130069 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130069 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130069 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Occupancy | XXXX | The final XXXX indicate the subject property is a primary residence and investor guidelines require the subject property to be either a primary residence of a second home. The loan file contains a completed and signed business purpose and occupancy affidavit stating the property is not and will not be occupied by the borrower. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Hello, we are confident this loan is a primary residence. We researched why the Business Purpose & Occupancy Affidavit was printed when it does not apply and we discovered this was a system glitch. What will you accept to confirm this XXXX) was a system glitch XXXX) the borrower intends to remain in the home as a Primary/Second Home. Thank you! |
Response 1 (XX/XX/XXXX XX:XXAM) Please provide a borrower attestation. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Client reviewed and elects to waive. File contains an Affidavit of occupancy of primary residence dated XX/XX/XXXX. Income documentation provided matches borrowers address. Lender attested to system error. Noted compensating factors: Subject property owned XXXX years, job stability XXXX years, XXXX% DTI, 0x30x63 mortgage history |
XXXX. XXXX% DTI, XXXX% CLTV. | 3 | 2 | 3 | 2 | |
| XXXX | 2130008 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130008 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130008 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130304 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. The following fees were included in the testing: Lender's Title Insurance, Application Fee, Discount Points, Title Settlement, Underwriting Fee. Truth In Lending Act (Regulation Z) 12 CFR 1026.43(e)(2)(iii), (e)(3). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) The new data tape provided is sufficient to clear thefinding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130304 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130176 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130176 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Missing | XXXX | The loan file is missing income documents, there is no way to determine if the borrower meet the DTI requirements. XXXX benefits listed of $XXXX on XXXX has no supporting documents provided. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX Income |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130080 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is less than $XXXX but at least $XXXX, and the transaction's total points and fees is $XXXX, which exceeds $XXXX. If discount points and fees are bona-fide and excludable, provide undiscounted rate. Truth In Lending Act (Regulation Z). 12 CFR 1026.43(e)(2)(iii), (e)(3) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan designation is General ATR Rebuttal 2 (XX/XX/XXXX XX:XXPM) This is Non QM Rebuttal 3 (XX/XX/XXXX XX:XXPM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Statement of General ATR does not address whether the loan was originated as a Qualified Mortgage. If the loan is a Qualified Mortgage please provide undiscounted rate evidencing any potential excludable points. If the loan is Exempt/Non-QM, please provide an updated Data Tape re-designating the loan as Exempt/Non-QM and/or documentation reflecting the re-designation as Exempt/Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The new data tape provided is sufficient toclear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2130080 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Assets - Cash to Close | XXXX | The file did not contain evidence the borrower had the proper amount of funds required to close. The subject loan requires $XXXX in verified assets ($XXXX cash to close plus $XXXX POC). the loan file does not include any asset documentation. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Per FNMA B3-XXXX-XXXX, Asset Verification Documentation, "DU will not require documentation of assets for refinance transactions when the total funds to be verified are $XXXX or less." |
Response 1 (XX/XX/XXXX XX:XXPM) Explanation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2130080 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Occupancy | XXXX | The subject loan does not meet Program Parameters for Occupancy. The final XXXX indicates the subject is the borrowers primary residence. Investor guidelines allow for the subject property to be either a primary residence or a second home. The loan file contains a business purpose & occupancy affidavit signed by the borrower stating the property will not be occupied by the borrower. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 2 (XX/XX/XXXX XX:XXPM) Hello, we are confident this loan is a primary residence. We researched why the Business Purpose & Occupancy Affidavit was printed when it does not apply and we discovered this was a system glitch. What will you accept to confirm this XXXX) was a system glitch XXXX) the borrower intends to remain in the home as a Primary/Second Home. Thank you! |
Response 1 (XX/XX/XXXX XX:XXAM) Unable to clear based upon response. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Please provide a borrower attestation. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Client reviewed and elects to waive. File contains an Affidavit of occupancy of primary residence dated XX/XX/XXXX. Income documentation provided matches borrowers address. Lender attested to system error. Noted compensating factors: Subject property owned XXXX years, job stability XXXX years, XXXX qualifying credit score, 0x30x84 mortgage history |
XXXX. XXXX% DTI. XXXX% CLTV. | 3 | 2 | 3 | 2 | |
| XXXX | 2130247 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130247 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130141 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Rules Violation | XXXX | This loan failed the required fees test. The loan requires the borrower(s) to pay, in addition to interest, fees to any person that are necessary to originate, evaluate, maintain, record, insure, or service the extension of credit that exceed XXXX% of the original principal amount. Fees included in test: Abstract/Title Fees $XXXX, Application Fee $XXXX, Credit Report Fee $XXXX, MERS Registration Fee $XXXX, Recording Fee $XXXX, Settlement and Closing Fee $XXXX, XXXX Document Preparation Fee $XXXX and Underwriting Fee $XXXX. (XXXX Constitution, Article 16, Section 50 (a)(6)(E) & (t)(4), as amended Jan. XXXX) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) cure Rebuttal 2 (XX/XX/XXXX XX:XXPM) additional cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. Testing with the updated Recording fees and reimbursement has been completed and the loan remains over the threshold. A cost to cure in the amount of $XXXX remains. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2130141 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130141 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contained a CDA dated XX/XX/XXXX that supported the value. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130131 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130131 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130088 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130088 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130125 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130125 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130347 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX% the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130347 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130347 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130282 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130282 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130269 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130269 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129896 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129896 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in XXXX The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129896 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)) Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in the XXXX Financial Code. The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129896 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Recording fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) coc |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129896 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130188 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130188 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130146 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130146 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130146 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129898 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | State Disclosure - Texas Home Equity Loan Consumer Disclosure (12-Day Letter)/Missing | XXXX | The XXXX Consumer Disclosure (XXXX-Day Letter) is Missing. Required to be provided in connection with a XXXX. XXXX Constitution - Home Equity Loan ProvisionsTex. Const. art. XVI, '''50(a)(6)(M)(i), 50(g); XXXX XXXX. Admin. Code '' XXXX, XXXX | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129898 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129962 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 3 | |||||
| XXXX | 2129962 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 3 | 3 | |||||
| XXXX | 2129962 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - Revised CD Delivery Date (Waiting Period, APR) | XXXX | XXXX Required: An APR outside of allowable tolerance required a corrected Closing Disclosure and the corrected Closing Disclosure was not received by the borrower at least three business days prior to the Consummation Date. The CD issued on XX/XX/XXXX triggered a new XXXX-day waiting period. The baseline APR for comparison purposes was set on XX/XX/XXXX with an APR of XXXX%. The APR decreased more than XXXX. A decrease in APR alone does not cause the APR to become inaccurate. However, if in addition to the APR decrease the Actual Finance Charge is understated when compared to the previous Disclosed Finance Charge, the APR is then considered inaccurate. On XX/XX/XXXX in addition to the APR decrease of XXXX%. The Finance Charge was understated by $XXXX. This was due to an increase in Loan Amount. Therefore, a new waiting period was triggered on this CD. | XXXX | 3 | 3 | 3 | 3 | |||||
| XXXX | 2129962 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 3 | |||||
| XXXX | 2130151 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130151 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130151 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129839 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Abstract/Title Search, Lender's Title Insurance, Settlement/Closing and Underwriting fees. The loan fails the prohibited fees test by $XXXX. (MRS § 408.052(XXXX); 408.233(XXXX)) | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2129839 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130217 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130217 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130241 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: underwriting fee $ XXXX; abstract/ search fee $ XXXX, title insurance $XXXX, settlement /closing fee $ XXXX. The loan failed the prohibited fees test due to one of the following findings: The loan is a second lien and charges fees that are not specifically permitted under MRS § XXXX et seq. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2130241 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2129922 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129922 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129922 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130236 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130236 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130236 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: underwriting fee $ XXXX. The loan failed the prohibited fees test due to one of the following findings:The loan is a second lien and charges fees that are not specifically permitted under MRS § XXXX et seq. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2130236 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130216 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130216 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Miscalculated/DTI Exceeds Tolerance | XXXX | The income is miscalculated. The loan application reflects the borrower was employed as a patient access assistant earning $XXXX monthly. A review of the income calculation from origination reflects this income was based on the borrower’s hourly wage of $XXXX x XXXX hours a week. A review of the paystub period ending XX/XX/XXXX reflects YTD earnings of only $XXXX. The loan file does not contain an explanation for the low YTD wages. Based on the borrower’s YTD wages the monthly income was reduced to $XXXX which results in the DTI increasing from XXXX% to XXXX% exceeding the guideline maximum of XXXX%. | Waived | Response 1 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Client reviewed and elects to waive. Noted compensating factors: Subject property owned XXXX years, XXXX years job stability, 0x30x84 mortgage history |
XXXX. XXXX% CLTV. | 3 | 2 | 3 | 2 | ||
| XXXX | 2130231 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130231 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130231 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130240 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130240 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129856 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129856 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)) The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129856 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130172 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130172 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130312 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130312 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z). 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130312 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX nonprime home loan test. The loan is a nonprime home loan, as defined in the legislation. Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130312 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129831 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129831 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129831 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130346 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130346 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129857 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129857 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130003 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130003 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129951 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129951 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129842 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2129842 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%.The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2129842 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the discount fee test. ( XXXX. §XXXX:11C-XXXX, XXXX. §§XXXX:XXXX-XXXX ) The loan charges a discount fee that exceeds XXXX% of the principle amount of the loan. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2129842 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130162 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130162 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129829 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 4 | 1 | |||||
| XXXX | 2129829 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 4 | 1 | |||||
| XXXX | 2129829 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Other | XXXX | The loan file is missing documentation verifying the borrower has at least a 2yr history of earning OT. Acceptable documentation includes a fully executed WVOE, year end paystubs from XXXX and 2024 (to coincide with XXXX in file) or even an LOE from the employers HR department. Using an LOE would allow XXXX’s to be averaged with year end XXXX paystub after backing out regular hourly pay. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) WVOE to support history of overtime |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
4 | 1 | 4 | 1 | |||
| XXXX | 2129829 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a CDA, dated XX/XX/XXXX which supports the appraised value. | Cleared | 1 | 1 | 4 | 1 | |||||
| XXXX | 2130336 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. The loan amount is less than $XXXX but at least $XXXX, and the transaction's total points and fees is $XXXX, which exceeds $XXXX. If discount points and fees are bona-fide and excludable, provide undiscounted rate. Truth In Lending Act (Regulation Z). 12 CFR 1026.43(e)(2)(iii), (e)(3) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 2 (XX/XX/XXXX XX:XXPM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The new data tape provided is sufficient toclear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130336 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130020 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130020 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129835 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129835 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130339 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is less than $XXXX but at least $XXXX, and the transaction's total points and fees is $XXXX, which exceeds $XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan designation is General ATR Rebuttal 2 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 3 (XX/XX/XXXX XX:XXPM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Statement of General ATR does not address whether the loan was originated as a Qualified Mortgage. If the loan is a Qualified Mortgage please provide undiscounted rate evidencing any potential excludable points. If the loan is Exempt/Non-QM, please provide an updated Data Tape re-designating the loan as Exempt/Non-QM and/or documentation reflecting the re-designation as Exempt/Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The new data tape provided is sufficient toclear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130339 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130237 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130237 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)).This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130237 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129931 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. If discount points and fees are bona-fide and excludable, provide undiscounted rate. Truth In Lending Act (Regulation Z). 12 CFR 1026.43(e)(2)(iii), (e)(3) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan Designation is General ATR Rebuttal 2 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 3 (XX/XX/XXXX XX:XXPM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Statement of General ATR does not address whether the loan was originated as a Qualified Mortgage. If the loan is a Qualified Mortgage please provide undiscounted rate evidencing any potential excludable points. If the loan is Exempt/Non-QM, please provide an updated Data Tape re-designating the loan as Exempt/Non-QM and/or documentation reflecting the re-designation as Exempt/Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The new data tape provided is sufficient toclear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129931 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130301 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130301 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z). 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130301 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130264 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130264 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130264 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129987 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129987 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130035 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130035 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130034 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130034 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130326 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130326 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Liabilities - Excluded Debts | XXXX | The borrower owns other REO. The lender excluded the mortgage payment; however, no explanation or documentation was provided to confirm reason for omission. DTI inclusive of payment would increase from XXXX to XXXX. Additional conditions may apply. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Agree documentation was not provided to validate who makes the payments for the REO. DTI is re-calculated at XXXX%. Please see attached XXXX. LTV/CLTV: XXXX / 25.XXXX XXXX |
Response 1 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Client reviewed and elects to waive. Noted compensating factors: Subject property owned XXXX years, XXXX qualifying credit score, 0x30xXXXX months mortgage history |
XXXX. XXXX% CLTV. XXXX% DTI. | 3 | 2 | 3 | 2 | |
| XXXX | 2130012 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130012 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129880 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Points. The loan fails the prohibited fees test by $XXXX. The loan charges a fee not provided for in the act. A lender is prohibited from charging fees, except those provided for in this act. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2129880 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2129932 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. This loan has points and fees that exceed the points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is less than $XXXX but at least $XXXX, and the transaction's total points and fees is $XXXX, which exceeds $XXXX. Fees used for testing: Loan Discount Points $XXXX and Loan Origination $XXXX. If discount points and fees are bona-fide and excludable, provide undiscounted rate. Truth In Lending Act (Regulation Z). 12 CFR 1026.43(e)(2)(iii), (e)(3) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan designation is General ATR Rebuttal 2 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 3 (XX/XX/XXXX XX:XXPM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Statement of General ATR does not address whether the loan was originated as a Qualified Mortgage. If the loan is a Qualified Mortgage please provide undiscounted rate evidencing any potential excludable points. If the loan is Exempt/Non-QM, please provide an updated Data Tape re-designating the loan as Exempt/Non-QM and/or documentation reflecting the re-designation as Exempt/Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The new data tape provided is sufficient toclear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129932 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129832 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129832 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129832 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. CDA provided and supports original appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130295 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Appraisal. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund.A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130295 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130002 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. This loan has points and fees that exceed the points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. The Following fee were included in the test: Title search fee $XXXX; application fee $XXXX, Lender title insurance $XXXX, loan discount point $XXXX, Title settlement closing fee $XXXX and underwriting fee $XXXX | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2130002 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Insufficient Documentation | XXXX | The XXXX's conclusions on the adequacy and the stability of the applicant's income was not supported by documentation in the file. The borrower's 2nd job income (XXXX and/or XXXX) was not properly verified due to the income documentation in the file were illegible. The guidelines required secondary employment income must be validated with most recent paystub covering at least XXXX days YTD income and most recent XXXX year W-XXXX. Due to these missing items, this income could not be utilized and resulted in an audit DTI of XXXX%, which exceeds the guideline maximum. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Income |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2129851 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Inaccurate | XXXX | The security instrument was not completed accurately. The PUD Rider does not reflect the correct development name compared to the Legal Description. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) SI |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129851 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129953 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129953 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129844 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129844 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129844 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a CDA, dated XX/XX/XXXX which supports the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130014 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130014 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129843 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX) and the calculated APR (XXXX), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129843 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129843 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130262 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130262 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%.The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130262 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130129 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130129 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129934 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129934 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129886 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129886 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Other | XXXX | A QuickEQ Report was provided from XXXX. The Investor guidelines required a Residential Equity Loan Policy Certificate (RELP). A junior ALTA policy may be obtained in lieu of a RELP certificate or E & O Certificate evidencing the loan is covered under a Service Agreement or which there is an Errors and Omissions Liability Policy. Required documentation was not provided. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) TC Rebuttal 2 (XX/XX/XXXX XX:XXPM) TC |
Response 1 (XX/XX/XXXX XX:XXPM) Transactional Certificate does not appear to satisfy requirement. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Waiver not required. TC with XXXX is sufficient. (Resolved) |
XXXX (XX/XX/XXXX XX:XXPM) Client reviewed and elects to waive. Noted compensating factors: XXXX% DTI, Subject property owned XXXX years, XXXX years job stability, XXXXx30x55 month mortgage history |
3 | 1 | 3 | 1 | ||
| XXXX | 2130183 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130183 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129928 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129928 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130343 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130343 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130343 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129866 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129866 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX higher-priced mortgage loan test. (Title 9-A §8A-506(1)(I) as enacted by XXXX, Chapter 427 ). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in the MaineConsumer Credit Code Truth-in-Lending Provisions. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129866 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129911 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129911 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129995 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129995 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129995 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Other | XXXX | he subject property is located in XXXX. A Property Report from XXXX was provided. The investor guidelines required a either Residential Equity Loan Policy Certificate (RELP) or a Home Equity Loan Policy Certificate (HELP) evidencing coverage under a Master Residential Equity Loan Policy (MRELP) or Master Home Equity Loan Policy. A full ALTA title policy may be obtained in lieu of either a RELP or HELP certificate or E & O certificate. Required documentation was not provided. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) The Warranty Transaction Certificate is acceptable in lieu of an MRELP for this state. |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129854 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Abstract/Title Search, Lenders Title, Settlement/Closing and Underwriting fees. The loan fails the prohibited fees test by $XXXX. (MRS § 408.052(XXXX); 408.233(XXXX)) | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2129854 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2129854 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contained a CDA dated XX/XX/XXXX that supported the value. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130195 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | This loan has points and fees that exceed the points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. The following fees were included in the testing: Title Search $XXXX, Application Fee $XXXX, Lender's Title Insurance $XXXX and Points $XXXX. If discount points and fees are bona-fide and excludable, provide undiscounted rate. Truth In Lending Act (Regulation Z). 12 CFR 1026.43(e)(2)(iii), (e)(3) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan designation is General ATR Rebuttal 2 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 3 (XX/XX/XXXX XX:XXPM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Statement of General ATR does not address whether the loan was originated as a Qualified Mortgage. If the loan is a Qualified Mortgage please provide undiscounted rate evidencing any potential excludable points. If the loan is Exempt/Non-QM, please provide an updated Data Tape re-designating the loan as Exempt/Non-QM and/or documentation reflecting the re-designation as Exempt/Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The new data tape provided is sufficient toclear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130195 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130045 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130045 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130342 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130342 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130342 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129878 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129878 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Verification - Employment History | XXXX | The Employment and/or Income Verifications do not substantially match the loan application and/or credit report information. The guidelines require XXXX year of income/employment documentation. However, the loan file contained less than XXXX year verification. The start date of the current employer was XX/XX/XXXX, yet, there was no previous employment history verification or prior year W-XXXX in file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Employment LOE Rebuttal 2 (XX/XX/XXXX XX:XXPM) Please see attached. We now have XXXX year of employment verified. Rebuttal 3 (XX/XX/XXXX XX:XXPM) Income Docs Rebuttal 4 (XX/XX/XXXX XX:XXPM) The guidelines require XXXX year of income/employment. We have documented employment with XXXX from XX/XX/XXXX to XX/XX/XXXX and XXXX from XX/XX/XXXX to current (XX/XX/XXXX). This is more than XXXX year. |
Response 1 (XX/XX/XXXX XX:XXAM) Please provide XXXX W2's and WVOE's from other jobs in XXXX. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Income documentation for XXXX in XXXX and XXXX in XXXX was not received. (XXXX) Response 3 (XX/XX/XXXX XX:XXAM) XXXX XXXX income documentation is still missing. (XXXX) Response 4 (XX/XX/XXXX XX:XXAM) Explanation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130302 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | HOC - Missing | XXXX | The Homeownership Counseling Disclosure (HOC) is missing. Real Estate Settlement Procedures Act (Regulation X) 12 CFR 1024.20(a). | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2130302 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. This loan has points and fees that exceed the points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan designation is General ATR Rebuttal 2 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 3 (XX/XX/XXXX XX:XXPM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Statement of General ATR does not address whether the loan was originated as a Qualified Mortgage. If the loan is a Qualified Mortgage please provide undiscounted rate evidencing any potential excludable points. If the loan is Exempt/Non-QM, please provide an updated Data Tape re-designating the loan as Exempt/Non-QM and/or documentation reflecting the re-designation as Exempt/Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The new data tape provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2130302 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130174 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130174 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Other | XXXX | A Property Report was provided from XXXX. The Investor guidelines required a Residential Equity Loan Policy Certificate (RELP). A junior ALTA policy may be obtained in lieu of a RELP certificate or E & O Certificate evidencing the loan is covered under a Service Agreement or which there is an Errors and Omissions Liability Policy. Required documentation was not provided. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) TC |
Response 1 (XX/XX/XXXX XX:XXAM) Waiver not required. Property Report and XXXX is sufficient. (Resolved) |
XXXX (XX/XX/XXXX XX:XXPM) Client reviewed and elects to waive. Noted compensating factors: XXXX qualifying credit score, XXXX% DTI, Subject property owned XXXX years, XXXX years job stability |
3 | 1 | 3 | 1 | ||
| XXXX | 2129882 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129882 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of XXXXCFR §XXXX(e)(XXXX)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129882 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130333 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130333 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130290 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX% the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130290 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130290 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129897 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Abstract / Title Search Fee, Lender's Title Insurance, Settlement fee, Underwriting fee. The loan fails the prohibited fees test by $XXXX.The loan is a second lien and charges fees that are not specifically permitted under MRS § XXXX et seq | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2129897 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130341 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130341 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130341 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130016 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130016 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130061 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130061 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130273 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130273 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130278 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130278 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130260 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130260 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%.The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130260 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129912 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129912 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130272 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The date used for rate set is XX/XX/XXXX. The loan is a compliant HPML. Prepayment and XXXX been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130272 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130340 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130340 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130073 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130073 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129868 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129868 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130265 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130265 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130265 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The loan file is missing documentation to support the $XXXX child support arrears payable at $XXXX per month has been satisfied. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) I acknowledge the reviewer&#XXXX;s request, however, I question whether this is material. The repayment was expected to being in December XXXX and last for XXXX months. That was XXXX years ago. It&#XXXX;s reasonable to believe that if the arrearages still existed they would appear as a collection or judgment on the borrower&#XXXX;s credit report and/or title work. |
Response 1 (XX/XX/XXXX XX:XXAM) Agree with XXXX's commentary. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130075 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130075 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Mortgage History - Missing/Incomplete | XXXX | Guidelines require a copy of the most recent mortgage statement for the first lien mortgage and a copy of the note for the first lien mortgage. The loan file contained a copy of the first XXXX note; however, a copy of the mortgage statement or XXXX data sheet was not present in the loan file as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) 1st Lien Rebuttal 2 (XX/XX/XXXX XX:XXPM) 1st lien |
Response 1 (XX/XX/XXXX XX:XXPM) Document provided is for the second lien that was paid off. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129885 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Appraisal and Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129885 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: The loan amount is less than $XXXX but at least $XXXX, and the transaction's total points and fees is $XXXX, which does not exceed $XXXX. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan designation is General ATR Rebuttal 2 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 3 (XX/XX/XXXX XX:XXAM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Statement of General ATR does not address whether the loan was originated as a Qualified Mortgage. If the loan is a Qualified Mortgage the finding is valid. If the loan is Exempt/Non-QM, please provide an updated XXXX re-designating the loan as Exempt/Non-QM and/or documentation reflecting the re-designation as Exempt/Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 3 (XX/XX/XXXX XX:XXAM) The new data tape provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129885 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130175 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130175 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: The loan amount is less than $XXXX but at least $XXXX, and the transaction's total points and fees is $XXXX, which does not exceed $XXXX. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan designation is General ATR Rebuttal 2 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 3 (XX/XX/XXXX XX:XXAM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Statement of General ATR does not address whether the loan was originated as a Qualified Mortgage. If the loan is a Qualified Mortgage the finding is valid. If the loan is Exempt/Non-QM, please provide an updated XXXX re-designating the loan as Exempt/Non-QM and/or documentation reflecting the re-designation as Exempt/Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 3 (XX/XX/XXXX XX:XXAM) The new data tape provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2130175 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Abstract / Title Search Fee, Lender's Title Insurance, Settlement fee, Underwriting fee. The loan fails the prohibited fees test by $XXXX. The loan is a second lien and charges fees that are not specifically permitted under MRS § XXXX et seq | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2130175 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2129870 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129870 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)), This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129870 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130178 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Abstract / Title Search Fee, Lender's Title Insurance, Settlement fee, Underwriting fee. The loan fails the prohibited fees test by $XXXX. The loan is a second lien and charges fees that are not specifically permitted under MRS § XXXX et seq | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2130178 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130177 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130177 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130177 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | ROR- Incorrect Form/New creditor (H8) version required | XXXX | The consumers were provided the incorrect RTC version. The consumers are refinancing with a new creditor; however, the version provided is for a refinance with the same creditor. Version H-XXXX was provided; Version H-XXXX was required. Rescission is required to be re-opened. Truth in XXXX (Regulation Z) 12 CFR 1026.23(b)(1)(v), (a) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) RTC response |
Response 1 (XX/XX/XXXX XX:XXPM) The information provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130177 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129904 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129904 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129904 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130202 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130202 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The loan file is missing proof of PITIA for XXXX and XXXX XXXX | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX XXXX & XXXX XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
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| XXXX | 2130202 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VVOE Salaried/Missing | XXXX | A VVOE is missing from the loan file. The loan file is missing a VVOE, dated within XXXX days of note, for the co-borrower. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) XXXX dated XXXX/XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
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| XXXX | 2130193 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. (12 CFR 1026.43(e)(3))The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan designation is General ATR Rebuttal 2 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 3 (XX/XX/XXXX XX:XXAM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Statement of General ATR does not address whether the loan was originated as a Qualified Mortgage. If the loan is a Qualified Mortgage please provide undiscounted rate evidencing any potential excludable points. If the loan is Exempt/Non-QM, please provide an updated Data Tape re-designating the loan as Exempt/Non-QM and/or documentation reflecting the re-designation as Exempt/Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 3 (XX/XX/XXXX XX:XXAM) The new data tape provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2130193 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129910 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129910 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129910 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Credit - Other | XXXX | Per the guidelines on title requirements, in addition to the Property Report provided in the loan file, guidelines also require a Residential Equity Loan Policy Certificate and is missing from the file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) TC |
Response 1 (XX/XX/XXXX XX:XXAM) Waiver not required. Property Report and XXXX is sufficient. (Resolved) |
XXXX (XX/XX/XXXX XX:XXPM) Client reviewed and elects to waive. Noted compensating factors: Subject property owned XXXX years, job stability XXXX years, $XXXX monthly residual income |
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| XXXX | 2130056 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130056 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Other | XXXX | The subject property is located in XXXX. A QuickEQ Report from XXXX was provided. The investor guidelines required a either Residential Equity Loan Policy Certificate (RELP) or a Home Equity Loan Policy Certificate (HELP) evidencing coverage under a Master Residential Equity Loan Policy (MRELP) or Master Home Equity Loan Policy. A full ALTA title policy may be obtained in lieu of either a RELP or HELP certificate or E & O certificate. Required documentation was not provided. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) TC Rebuttal 2 (XX/XX/XXXX XX:XXPM) TC |
Response 1 (XX/XX/XXXX XX:XXPM) Transactional Certificate does not appear to meet the requirement. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Waiver not required. Property Report and XXXX is sufficient. (Resolved) |
XXXX (XX/XX/XXXX XX:XXPM) Client reviewed and elects to waive. Noted compensating factors: Subject property owned XXXX years, 0x30x54 mortgage history, $XXXX monthly residual income |
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| XXXX | 2129937 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129937 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129936 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129936 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130267 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130267 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The Final XXXX reflects a XXXX liability with a $XXXX Balance and $XXXX monthly payment that was not reflected on the credit report. The credit report does reflect an inquiry dated XX/XX/XXXX. The loan file is missing an account statement or other documentation to verify the new account balance/monthly payment. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) This liability was identified through our pre-funding Transunion Gap Report process. If an undisclosed liability is identified it is added to the XXXX and included in the DTI. This process runs in the background so we don&#XXXX;t get any output...it just populates in the system. Rebuttal 2 (XX/XX/XXXX XX:XXPM) LOE |
Response 1 (XX/XX/XXXX XX:XXPM) Could we get a screenshot of this documentation please. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
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| XXXX | 2130293 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130293 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Other | XXXX | The subject property is located in XXXX. A Quick O & E Report from XXXX was provided. The investor guidelines required a either Residential Equity Loan Policy Certificate (RELP) or a Home Equity Loan Policy Certificate (HELP) evidencing coverage under a Master Residential Equity Loan Policy (MRELP) or Master Home Equity Loan Policy. A full ALTA title policy may be obtained in lieu of either a RELP or HELP certificate or E & O certificate. Required documentation was not provided. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) Please see TC along with Quick O&E is sufficient Title validation Rebuttal 2 (XX/XX/XXXX XX:XXAM) Documentation uploaded. Rebuttal 3 (XX/XX/XXXX XX:XXAM) Documentation uploaded. |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation not received. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
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| XXXX | 2130030 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan designation is General ATR Rebuttal 2 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 3 (XX/XX/XXXX XX:XXAM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Statement of General ATR does not address whether the loan was originated as a Qualified Mortgage. If the loan is a Qualified Mortgage please provide undiscounted rate evidencing any potential excludable points. If the loan is Exempt/Non-QM, please provide an updated Data Tape re-designating the loan as Exempt/Non-QM and/or documentation reflecting the re-designation as Exempt/Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 3 (XX/XX/XXXX XX:XXAM) The new data tape provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2130030 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129919 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129919 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129919 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130040 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: Without evidence of receipt, it is assumed that the disclosure dated' XX/XX/XXXX was mailed, and therefore not received by the consumer XXXX business days prior to the consummation date, XX/XX/XXXX. If disclosure was delivered electronically, evidence of receipt as well as the consumer's E-consent is required. | XXXX | 3 | 3 | 3 | 3 | |||||
| XXXX | 2130040 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 3 | |||||
| XXXX | 2130210 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130210 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130210 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129914 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129914 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130209 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130209 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) XXXX The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130209 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130316 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130316 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130316 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130144 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Points. The loan fails the prohibited fees test by $XXXX. This loan failed the lender prohibited fees test. (XXXX XXXXXXXX §6122(a)) The loan charges a fee not provided for in the act. A lender is prohibited from charging fees, except those provided for in this act. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2130144 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130320 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | This loan has points and fees that exceed the points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. The following fees were included in the testing: Application Fee $XXXX, Lender's Title Insurance $XXXX, Points $XXXX and Underwriting Fee $XXXX. If discount points and fees are bona-fide and excludable, provide undiscounted rate. Truth In Lending Act (Regulation Z) 12 CFR 1026.43(e)(2)(iii), (e)(3). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan designation is General ATR Rebuttal 2 (XX/XX/XXXX XX:XXAM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Statement of General ATR does not address whether the loan was originated as a Qualified Mortgage. If the loan is a Qualified Mortgage please provide undiscounted rate evidencing any potential excludable points. If the loan is Exempt/Non-QM, please provide an updated Data Tape re-designating the loan as Exempt/Non-QM and/or documentation reflecting the re-designation as Exempt/Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) The new data tape provided is sufficient to clear the finding. (Resolved) |
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| XXXX | 2130320 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130208 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130208 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129913 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129913 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129913 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130323 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130323 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129984 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129984 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130203 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130203 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130009 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130009 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)).This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130009 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in the XXXX Financial Code. The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130009 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130072 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130072 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130153 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130153 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130153 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130297 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130297 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130351 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130351 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130351 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130062 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130062 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130315 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130315 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130214 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. The loan amount is less than $XXXX but at least $XXXX, and the transaction's total points and fees is $XXXX, which exceeds $XXXX | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan designation is General ATR Rebuttal 2 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 3 (XX/XX/XXXX XX:XXAM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Statement of General ATR does not address whether the loan was originated as a Qualified Mortgage. If the loan is a Qualified Mortgage please provide undiscounted rate evidencing any potential excludable points. If the loan is Exempt/Non-QM, please provide an updated Data Tape re-designating the loan as Exempt/Non-QM and/or documentation reflecting the re-designation as Exempt/Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 3 (XX/XX/XXXX XX:XXAM) The new data tape provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130214 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130215 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130215 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2099946 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Non-Compliant | XXXX | The loan failed the Federal HPML APR test. Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in XXXX Rate Set was: XX/XX/XXXX. The loan is a non-compliant HPML due to the following: appraisal was missing. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) AVM |
Response 1 (XX/XX/XXXX XX:XXPM) XXXX is a compliant Federal HPML, XXXX requirements have been met.(Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2099946 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | HOC - Missing | XXXX | The Homeownership Counseling Disclosure (HOC) is missing. Real Estate Settlement Procedures Act (Regulation X)12 CFR 1024.20(a) | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2099946 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Incomplete | XXXX | The following section of the Security Instrument (Mortgage/Deed of Trust) is incomplete: The borrower's address is missing from page XXXX of XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Invalid - address is on page XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2099946 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Income - W2(s) Missing | XXXX | XXXX's missing from the loan file. The guidelines require the most recent XXXX year W-XXXX; however, the loan file did not contain XXXX for the borrower. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2100026 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: The Closing Disclosure was not received by the borrower at least three business days prior to the Consummation Date. The CD issued on XX/XX/XXXX was signed and dated at consummation, XX/XX/XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) CD Rebuttal 2 (XX/XX/XXXX XX:XXAM) Intial |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The Closing Disclosure was not received by theborrower at least three business days prior to the Consummation Date. The CDissued on XX/XX/XXXX was signed and dated on XX/XX/XXXX; XX/XX/XXXX is a Federal Holiday and not included in the XXXX business days required for the borrower to have received the CD prior to closing. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100026 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No COC - Date Undeterminable) | XXXX | The loan failed the charges that cannot increase test. Although the addition may be valid, because a COC was not provided, auditor is unable to determine if the CD issued on XX/XX/XXXX was disclosed within XXXX business days of the change. Therefore, the addition to the following fee was not accepted: XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) CD |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100026 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The application lists significant debts that were not verified on the credit report and not independently verified. The XXXX reflects HOA dues in the amount of $XXXX per month for the subject PITIA. The Property Condition Inspection verifies the subject property is in a PUD. The loan file does not contain any documentation verifying the HOA dues. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOA |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2100027 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2100027 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The application lists significant debts that were not verified on the credit report and not independently verified. The XXXX reflects HOA dues in the amount of $XXXX per month for the subject PITIA. The XXXX verifies the subject property is in a PUD. The loan file does not contain any documentation verifying the HOA dues. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOA |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130275 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130275 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Missing/Incomplete | XXXX | The title commitment/policy is missing. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) MRELP |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130116 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130116 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The loan file is missing proof of HOA dues for the subject property | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOA |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130116 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | DTI - Exceeds Guidelines | XXXX | The DIT at audit (XXXX%) exceeds DTI at close (XXXX%)and program maximum of XXXX%. The DTI variance is due to the lender using an income calc for B2 not supported but loan docs | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Please see our income summary attached. Can you provide specifics as to why you arrived at a different income? Thank you! |
Response 1 (XX/XX/XXXX XX:XXAM) DTI calculation has been resolved. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130116 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Missing | XXXX | The loan file is missing a paystub and the last XXXXyrs W2’sfor borrower XXXX | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX is self-employed so would not have paystubs and W2&#XXXX;s. See income docs for XXXX. Rebuttal 2 (XX/XX/XXXX XX:XXPM) Business tax returns Rebuttal 3 (XX/XX/XXXX XX:XXAM) XXXX business returns |
Response 1 (XX/XX/XXXX XX:XXAM) Please provide complete self-employment income documentation for XXXX. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Only XXXX's XXXX business return was provided. (XXXX) Response 3 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130116 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VOE/Missing | XXXX | A VOE is missing from the loan file. The loan file is missing a VOE for the borrower. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) VOE&#XXXX;s Rebuttal 2 (XX/XX/XXXX XX:XXPM) I pulled a new business verification. It is post-closing, but the XXXX do allow this. Rebuttal 3 (XX/XX/XXXX XX:XXAM) Please see attached |
Response 1 (XX/XX/XXXX XX:XXAM) XXXX's business record provided does not have a print date. Status update cannot be used, as it is over XXXX days old. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Referenced document not received. (XXXX) Response 3 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129862 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. §537.1301(XXXX). XXXX Code §535.8(XXXX). This test includes the following fees: Appraisal management fee $XXXX. The loan fails the prohibited fees test by $XXXX. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2129862 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Lender Credits that Cannot Decrease (No Valid COC) | XXXX | The loan failed the Lender Credits that Cannot Decrease Test. The lender credit decreased on the CD issued on XX/XX/XXXX without a valid change of circumstance. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i) & Official Comment 19(e)(3)(i)-XXXX, -XXXX; 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Final Lender credits = $XXXX + $XXXX in lender paid fees = $XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2129862 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the addition to the following fees was not accepted: XXXX fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Appraisal fee response Rebuttal 2 (XX/XX/XXXX XX:XXPM) The total appraisal fee is $XXXX as the invoice confirms. XXXX breaks out the amount that is retained by the AMC since this part of the appraisal fee is an APR fee. This is done to accurately disclose the finance charges. Nothing further is required Rebuttal 3 (XX/XX/XXXX XX:XXPM) The documents provided are sufficient to cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The LOE provided does give a breakdown of the Appraisal and XXXX; however, the LOE does not provide a valid reason for the increase/addition to the fee. A cost to cure in the amount of $XXXX remains. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The information provided is not sufficient to clear the finding. The Total Appraisal fee disclosed to the borrower on the LE issued on XX/XX/XXXX was $XXXX. The total XXXX fee increased on the LE issued on XX/XX/XXXX to $XXXX without a valid COC. The breakdown of the total fee does not negate the need for a valid COC for the increase to the fee on the LE XX/XX/XXXX. A to cure in the amount of $XXXX remains. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2129862 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130105 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: underwriting fee $ XXXX; abstract/ search fee $ XXXX, warranty $XXXX, settlement /closing fee $ XXXX. The loan failed the prohibited fees test due to one of the following findings: The loan is a second lien and charges fees that are not specifically permitted under MRS § XXXX et seq. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2130105 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: The Closing Disclosure was not received by the borrower at least three business days prior to the Consummation Date. The CD issued on XX/XX/XXXX was XXXX signed and dated XX/XX/XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Initial CD |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2130105 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130207 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX Rate Set was: XX/XX/XXXX. The loan is a compliant HPML. Prepayment requirement have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130207 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii). | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130207 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The borrower owns other REO. The loan application indicates HOA dues; however, no documentation was provided to confirm. Additional conditions may apply. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOA |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130207 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Rental Property Income | XXXX | The documentation supporting income from other real estate owned is not documented. The loan application reflects $XXXX per month income for other REO. No documentation was provided to confirm. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130207 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VVOE Salaried/Missing | XXXX | The loan file is missing a VVOE for the borrower within XXXX business days as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) VOE |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130171 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130171 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fees was not accepted: Credit Report and XXXX fee. A cost to cure in the amount of $XXXX is required, of which $XXXX was cured at closing. There is a remaining cost to cure in the amount of $XXXX required. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund.Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Appraisal fee response |
Response 1 (XX/XX/XXXX XX:XXAM) The information provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130171 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130097 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130097 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129906 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Lender Credits that Cannot Decrease (No Valid COC) | XXXX | The loan failed the Lender Credits that Cannot Decrease Test.The lender credit decreased on the CD issued on XX/XX/XXXX without a valid change of circumstance. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i) & Official Comment 19(e)(3)(i)-XXXX, -XXXX; 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129906 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: The Closing Disclosure was not received by the borrower at least three business days prior to the Consummation Date. The CD issued on XX/XX/XXXX was signed on XX/XX/XXXX . The date of consummation was XX/XX/XXXX. If disclosure was delivered electronically evidence of receipt as well as the consumer's E-consent is required. Per regulation, creditors using electronic delivery methods, such as email, must also comply with ' 1026.38(t)(3)(iii) (consumer consent and other applicable provisions of the Electronic Signatures in Global and National Commerce Act). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) ICD |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129906 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VVOE Salaried/Missing | XXXX | A VVOE, dated within XXXX days of note, is missing from the loan file for both borrowers and all XXXX employers. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) VOE |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129855 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2129855 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Credit Report - Other | XXXX | There are additional credit findings. The Credit Report reflected a collection in the amount of $XXXX with a description that did not indicate a medical collection account; therefore, as per the guidelines, the collection account was required to be paid on or before closing. The loan file did not contain documentation evidencing the collection account was paid in full as required. | Waived | Response 1 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Client reviewed and elects to waive. Noted Compensating factors: Subject property owned XXXX years, job stability XXXX years, 0x30x72 mortgage history |
XXXX. XXXX% CLTV. XXXX% DTI. | 3 | 2 | 3 | 2 | ||
| XXXX | 2129855 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VVOE Salaried/Missing | XXXX | A VVOE is missing from the loan file. The loan file is missing a VVOE for the borrower. The subject loan closed on XX/XX/XXXX, and the loan file only contained a Written Verification of Employment for the borrower dated XX/XX/XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) VOE |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2130066 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Security Instrument - Missing Signature | XXXX | The Security Instrument was not fully executed by all required parties. The co-borrower signature was missing for XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) It appears that XXXX is a co-signer as described in XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130066 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VOE Self-Employed/Missing | XXXX | A VOE is missing from the loan file. The loan file is missing a Verification of Self-Employment for the co-borrower as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) SE VOE |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130226 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130226 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130122 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130122 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Abstract XXXX $XXXX, Settlement Fee $XXXX, and XXXX fee $XXXX. The loan fails the prohibited fees test by $XXXX. (MRS § 408.052(XXXX); 408.233(XXXX)). | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2130122 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The application lists significant debts that were not verified on the credit report and not independently verified. The subject property is located in a PUD community; however, the loan file does not contain documentation verifying the HOA fees associated with the community and the payment frequency of those fees as required to evidence the full PITIA for qualifying purposes. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOA |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2130200 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - Closing Information/Closing Date | XXXX | The PCCD issued on XX/XX/XXXX does not reflect the correct Closing Date when compared to the notary signature date XX/XX/XXXX on the Security Instrument. Truth in XXXX (Regulation Z)12 CFR 1026.38(a)(3)(ii). | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2130200 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD/Lender Credits that Cannot Decrease (Disclosure Timing Fail) | XXXX | The loan failed the Lender Credits that Cannot Decrease Test.Because the loan failed the initial CD delivery date test , any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset the following: lender credits. The violation may be cured if documentation is provided showing the disclosure was delivered timely.A cost to cure in the amount of $XXXX is required. A cost to cure of $XXXX was applied to a tolerance cure. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i) & Official Comment 19(e)(3)(i)-XXXX, -XXXX; 12 CFR 1026.19(e)(3)(iv). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Initial CD, tracking Rebuttal 2 (XX/XX/XXXX XX:XXAM) coc |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is not sufficient to clear the finding. The Initial CD has been provided and still results in Lender Credits that cannot decrease. The CD issued on XX/XX/XXXX disclosed a decrease in Lender Credits without a valid COC. Please provide a detailed COC for the increase in fees for review. A cost to cure in the amount of $XXXX, XXXX remains. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2130200 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: The Closing Disclosure was not received by the borrower at least three business days prior to the Consummation Date. The CD issued on XX/XX/XXXX was signed and dated at consummation, XX/XX/XXXX. If disclosure was delivered electronically evidence of receipt as well as the consumer's E-consent is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Initial cd, tracking |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2130200 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (Disclosure Timing Fail) | XXXX | The loan failed the charges that cannot increase test. Because the loan failed the initial CD delivery date test , any values that would change under a valid changed circumstance if the disclosure had been delivered timely, will not be considered valid for tolerance purposes. Therefore, baseline did not reset as a result of the following addition: loan discount point. The violation may be cured if documentation is provided showing the disclosure was delivered timely. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Initial CD, tracking Rebuttal 2 (XX/XX/XXXX XX:XXAM) coc Rebuttal 3 (XX/XX/XXXX XX:XXPM) LE |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is not sufficient to clear the finding. The Initial CD has been provided and still results in a XXXX% tolerance violation. The CD issued on XX/XX/XXXX disclosed an increase in Points - Loan Discount fee in the amount of $XXXX, XXXX without a valid COC. The CD issued on XX/XX/XXXX disclosed an increase in XXXX in the amount of $XXXX without a valid COC. Please provide a detailed COC for the increase in fees for review. A cost to cure in the amount of $XXXX, XXXX remains. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The COC for the increase has been applied and accepted. A COC for the increase to the Transfer Taxes on CD XX/XX/XXXX has not been provided. A cost to cure in the amount of $XXXX remains. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2130200 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130163 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130163 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130163 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fees was not accepted: Loan Discount points, XXXX fee, XXXX Re-inspection fee and XXXX fee. A cost to cure in the amount of $XXXX is required, of which $XXXX was cured at closing. There is a remaining cost to cure in the amount of $XXXX required. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund.Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) response |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130163 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130064 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX Rate Set was: XX/XX/XXXX. The loan is a compliant HPML. Prepayment requirement have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130064 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fees was not accepted: Transfer Taxes. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) cure |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2130064 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Income - W2(s) Missing | XXXX | XXXX's missing from the loan file. The loan file contained a XXXX and XXXX W2; however, the income and all data fields on the W2s were blank. Therefore, the loan file had insufficient income documentation per the guidelines. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) W2&#XXXX;s |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2129968 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2129968 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - CD - Closing Information/Closing Date | XXXX | The CD issued on XX/XX/XXXX does not reflect the correct Closing Date when compared to the notary signature date on the Security Instrument. Truth in XXXX (Regulation Z) 12 CFR 1026.38(a)(3)(ii). | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2129968 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Appraisal - Other | XXXX | The subject property is an attached PUD with monthly HOA dues, guidelines require verification of the monthly HOA dues via an appraisal or a statement; The valuation within the loan file does not disclose the amount, and a statement could not be located within the loan file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOA |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2129968 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VVOE Salaried/Missing | XXXX | Guidelines require a verbal verification of employment within XXXX days of the Note for all borrowers, but the VVOE for the B2; XXXX could not be located within the loan file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) VOE |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2129963 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129963 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129963 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129961 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Non-Compliant | XXXX | The loan failed the Federal HPML APR test. Using the greater of the disclosed APR and the calculated APR, the loan is a higher-priced mortgage loan, as defined in XXXX Rate Set was: XX/XX/XXXX. The loan is a non-compliant HPML due to the following: appraisal notice not provided within XXXX days of consummation. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX delivery |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129961 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Discount Points on the XXXX issued XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129961 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130221 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130221 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129825 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2129825 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2129825 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Points. The loan fails the prohibited fees test by $XXXX. This loan failed the lender prohibited fees test. (XXXX XXXXXXXX §6122(a)) The loan charges a fee not provided for in the act. A lender is prohibited from charging fees, except those provided for in this act. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2129825 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2129818 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129818 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130004 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Points. The loan fails the prohibited fees test by $XXXX. This loan failed the lender prohibited fees test. (XXXX XXXXXXXX §6122(a)) The loan charges a fee not provided for in the act. A lender is prohibited from charging fees, except those provided for in this act. | Acknowledged | 2 | 2 | 3 | 2 | |||||
| XXXX | 2130004 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The application lists significant debts that were not verified on the credit report and not independently verified. The loan application in file reflected the borrower had an installment loan with XXXX, with a balance of $XXXX and a monthly payment of $XXXX. The loan file did not contain any documentation confirming this debt as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) We believe this liability was communicated by the borrower to the LO, then added to the XXXX. We did not obtain verification of the account prior to close, but I pulled a credit report which reflects it now. |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2130004 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Final Application - Missing | XXXX | The Final application is missing as required by guides. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Final XXXX |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2130206 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130206 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130238 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130238 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130238 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - LTV | XXXX | The subject's LTV/CLTV reflected at origination was XXXX/XXXX%. The investor guidelines allowed for a maximum CLTV of XXXX%. Additionally, the subject was located in a declining market which required an additional XXXX% reduction in CLTV which resulted in a maximum CLTV of XXXX%. Based on the appraised value of $XXXX and using the most current first mortgage balance, the actual LTV/CLTV at audit was XXXX/XXXX%. The subjects CLTV of XXXX% exceeds the maximum CLTV allowable. | Waived | Response 1 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Client reviewed and elects to waive. Noted compensating factors: XXXX% DTI, Subject property owned XXXX years, Job stability XXXX years, 0x30xXXXX months mortgage history |
XXXX. XXXX% DTI. $XXXX per month residual income. | 3 | 2 | 3 | 2 | ||
| XXXX | 2130148 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130148 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130148 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No COC - Date Undeterminable) | XXXX | The loan failed the charges that cannot increase test.Although the addition may be valid, because a COC was not provided, auditor is unable to determine if the revised CD issued on XX/XX/XXXX was disclosed within XXXX business days of the change. Therefore, the addition to the following fee was not accepted: appraisal management fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Appraisal fee response Rebuttal 2 (XX/XX/XXXX XX:XXPM) Discount points were not mentioned in the original exception, only the Appraisal/Appraisal Mgmt Fee Rebuttal 3 (XX/XX/XXXX XX:XXAM) Correct docucment provided |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The LOE for the Appraisal Management fee has been provided and is acceptable. The Points - Loan Discount Fee increased on XX/XX/XXXX without a valid COC; a reimbursement was issued in the amount of $XXXX; however a total reimbursement of $XXXX was required. A cost to cure in the amount of $XXXX remains. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The COC and CD provided are not for the borrower. Please provide a valid COC for the increase to the Points- Loan Discount Fee. A cost to cure in the amount of $XXXX remains. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130148 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129954 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129954 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - Missing/Insufficient | XXXX | The Home Owners insurance that was provided in the file had dwelling coverage in the amount of $XXXX. The total outstanding first mortgage plus the subject's 2nd mortgage amount totaled $XXXX. The insurance coverage provided was not sufficient to support the subject transaction. It should be noted that the subject property is located in a PUD with units being attached townhomes. The XXXX report indicated there was a master HOA insurance policy with walls in coverage. Additional HOA policy was not provided and existing borrower's H06 coverage was insufficient. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOI Rebuttal 2 (XX/XX/XXXX XX:XXPM) Master HOA policy |
Response 1 (XX/XX/XXXX XX:XXAM) The Master Policy is still required. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129926 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX Rate Set was: XX/XX/XXXX. The loan is a compliant HPML. Prepayment requirement have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129926 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii). | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129926 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Other/Missing | XXXX | Other Income documentation required by XXXX was missing from loan file. The loan application and Transmittal approval reflected the borrower receives a XXXX Disability benefit; however, the loan file did not contain the COE documentation as required per the guidelines. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129917 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129917 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130104 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130104 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129817 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129817 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Credit - Other | XXXX | The subject is a second mortgage. The investor guidelines required a copy of the existing 1st mortgage Note to support the terms of the first. Required documentation was not provided. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) 1st XXXX |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129884 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129884 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130283 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130283 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130283 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VVOE Salaried/Missing | XXXX | A VVOE is missing from the loan file. The loan file is missing a VVOE for both the borrower and co-borrower, dated within XXXX business days of the note date as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) VOE&#XXXX;s |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130322 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130322 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The loan file contains a PUD rider for the subject property. Additionally, the Property Condition Report reflects the subject property is in a guard gated community. At origination the PITI did not include a HOA fee. Per the lender’s guidelines the existing property PITIA (principal, interest, taxes, insurance, and HOA dues) payment must be counted as part of the borrower’s recurring monthly debt obligations. The loan file did not contain a HOA statement or other documentation to determine the amount due. Additional conditions may apply. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOA |
Response 1 (XX/XX/XXXX XX:XXAM) Adding the $XXXX per month HOA fee will result in a XXXX% DTI, which exceeds the XXXX% maximum for a XXXX credit score. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Client reviewed and elects to waive. Noted compensating factors: $$XXXX monthly residual income, subject property owned XXXX years, job stability XXXX years |
XXXX% CLTV. XXXX. $XXXX per month residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2130013 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130013 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. ( 12 CFR §1026.43(b)(4), (e) (XXXX) ). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z 12 CFR 1026.43(e)(1)(ii) Informational Only. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130013 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fees was not accepted: XXXX fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Appraisal fee response |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130013 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130121 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No COC - Date Indeterminable) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. Although the increase may be valid, because a COC was not provided, auditor is unable to determine if the revised CD issued on XX/XX/XXXX was disclosed within XXXX business days of the change. Therefore, the increase to the following fees was not accepted: Closing Fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX% fees response |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130121 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129875 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2129875 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 2 | 2 | |||||
| XXXX | 2129875 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The file failed one or more of the state threshold tests. This loan failed the prohibited fees test. (MRS § 408.052(XXXX); 408.233(XXXX)). The loan failed the prohibited fees test due to one of the following findings: The loan is a second lien and charges fees that are not specifically permitted under MRS § XXXX et seq. | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2129875 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2130186 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: The Closing Disclosure was not received by the borrower at least three business days prior to the Consummation Date. The CD issued on XX/XX/XXXX was signed and dated at consummation, XX/XX/XXXX . If disclosure was delivered electronically, evidence of receipt as well as the consumer's E-consent is required. Per regulation, creditors using electronic delivery methods, such as email, must also comply with ' 1026.38(t)(3)(iii) (consumer consent and other applicable provisions of the Electronic Signatures in Global and National Commerce Act). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) ICD |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130186 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130114 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130114 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129986 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129986 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130169 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130169 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130169 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130025 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fees: Abstract / Title Search Fee, Settlement fee, Underwriting fee. The loan fails the prohibited fees test by $XXXX. The loan is a second lien and charges fees that are not specifically permitted under MRS § XXXX et seq | Acknowledged | 2 | 2 | 2 | 2 | |||||
| XXXX | 2130025 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 2 | 2 | |||||
| XXXX | 2129975 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129975 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fees was not accepted: Loan Discount Points. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required, of which $XXXX was cured. There is a remaining cost to cure in the amount of $XXXX required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129975 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129804 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129804 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Other | XXXX | Per guidelines for self-employment, the most recent XXXX-year complete (all pages/schedules) business and personal tax return are required. The loan file is missing the most recent XXXX individual return and the XXXX business return for XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Tax Returns Rebuttal 2 (XX/XX/XXXX XX:XXPM) My apologies...this one should open! Rebuttal 3 (XX/XX/XXXX XX:XXPM) XXXX XXXX |
Response 1 (XX/XX/XXXX XX:XXAM) The XXXX personal return file received was corrupt. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) The XXXX Personal XXXX is still required. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129807 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129807 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130187 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130187 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130050 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130050 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130005 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130005 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130299 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130299 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | Per Lender's guides, HOA is to be verified by appraisal or an HOA statement. However, the loan file does not obtain documentation or an appraisal to verify the borrower's HOA of $XXXX per month as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOA |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130321 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130321 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130296 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No COC - Date Indeterminable) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. Although the increase may be valid, because a COC was not provided, auditor is unable to determine if the revised CD issued on XX/XX/XXXX was disclosed within XXXX business days of the change. Therefore, the increase to the following fee was not accepted: Recording fee. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX% response Rebuttal 2 (XX/XX/XXXX XX:XXPM) Second rebuttal |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding. The baseline from the Initial LE included the following fees that were not included on the Final CD: Title - Deed Prep. If a disclosed fee listed on the LE that was originally in the XXXX% bucket is not charged on the Final CD, then it has to be removed from the total amount in the XXXX% bucket for good faith comparison purposes. To include a fee that is not charged would be considered padding. A cost to cure in the amount of $XXXX remains. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130296 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130332 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | This loan has points and fees that exceed the points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is less than $XXXX but at least $XXXX, and the transaction's total points and fees is $XXXX, which exceeds $XXXX. The following fees were included in the testing: Abstract/Title Search $XXXX, XXXX Title Insurance $XXXX, Points $XXXX, Settlement Fee $XXXX and Underwriting Fee $XXXX. If discount points and fees are bona-fide and excludable, provide undiscounted rate. Truth In Lending Act (Regulation Z) 12 CFR 1026.43(e)(2)(iii), (e)(3). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 2 (XX/XX/XXXX XX:XXAM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) The new data tape provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130332 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: The Closing Disclosure was not received by the borrower at least three business days prior to the Consummation Date. The CD issued on XX/XX/XXXX was signed and dated XX/XX/XXXX, date of consummation XX/XX/XXXX. If disclosure was delivered electronically evidence of receipt as well as the consumer's E-consent is required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) initial cd |
Response 1 (XX/XX/XXXX XX:XXAM) The documents provided are sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130332 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130063 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130063 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The loan application reflects $XXXX per month for HOA dues; however, no documentation was provided to confirm. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOA |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130031 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130031 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130164 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130164 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130164 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130271 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Non-Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The date used for rate set is XX/XX/XXXX. The loan is a non-compliant HPML. Appraisal requirements have not been met. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX response |
Response 1 (XX/XX/XXXX XX:XXPM) The information provided is sufficient to clear the finding. Loan is a compliant Federal HPML. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130271 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130021 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130021 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The application lists significant debts that were not verified on the credit report and not independently verified. The loan file contains a XXXX to the mortgage indicating the subject property is located in a PUD community; however, the loan file did not contain verification of the HOA Maintenance fees and payment period as required to document the full PITIA for qualifying. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOA |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation not received. (XXXX) Response XXXX (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130021 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VVOE Salaried/Missing | XXXX | A VVOE is missing from the loan file. The loan file is missing a VVOE for the co-borrower. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) VOE |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation not received. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130029 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Initial CD/Delivery Date (prior to consummation)- Rescindable | XXXX | Rescindable Transaction. The loan failed the Initial Closing Disclosure delivery date test due to the following: The Closing Disclosure was not received by the borrower at least three business days prior to the Consummation Date. The CD issued on XX/XX/XXXX was signed and dated on XX/XX/XXXX and consummation date was XX/XX/XXXX. | XXXX | 3 | 3 | 3 | 3 | |||||
| XXXX | 2130029 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 3 | |||||
| XXXX | 2129991 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129991 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The loan file is missing proof of HOA dues for the subject property. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOA |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130159 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130159 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130159 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130019 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130019 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Credit - Other | XXXX | There are additional observations that could impact the credit decision and/or quality of the loan. The subject loan is a cash out 2nd Mortgage, and the loan file did not contain a copy of the 1st Mortgage Note as required per the guidelines. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) 1st XXXX note |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130024 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | This loan has points and fees that exceed the points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. The following fees were included in the testing: Loan Discount Points $XXXX, Origination $XXXX, Title - Search $XXXX and Title - Closing $XXXX (title fees payable to affiliate of lender). If discount points and fees are bona-fide and excludable, please provide undiscounted rate. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 2 (XX/XX/XXXX XX:XXPM) COC - Non QM Rebuttal 3 (XX/XX/XXXX XX:XXAM) New data tape provided |
Response 1 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) The new data tape provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 3 | |||
| XXXX | 2130024 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | ROR- Incorrect Form/New creditor (H8) version required | XXXX | The consumer was provided the incorrect RTC version. The consumer is refinancing with a new creditor; however, the version provided is for a refinance with the same creditor. Version H-XXXX was provided; Version H-XXXX was required. Rescission is required to be re-opened. Truth in XXXX (Regulation Z) 12 CFR 1026.23(b)(1)(v), (a) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NRTC Rebuttal 2 (XX/XX/XXXX XX:XXAM) Rescission period has ended, please clear |
Response 1 (XX/XX/XXXX XX:XXAM) The new Rescission is opened as required. The finding can be resolved once the new rescission period has expired. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The re-opened rescission expired at midnight on XX/XX/XXXX clearing the exception.(Resolved) |
3 | 2 | 3 | 3 | |||
| XXXX | 2130024 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing - Prohibited Fees | XXXX | The loan failed the XXXX prohibited lender fees test. This test includes the following fee: Loan Discount Points $XXXX. The loan fails the prohibited fees test by $XXXX. (XXXX XXXXXXXX §6122(a)) | Acknowledged | 2 | 2 | 3 | 3 | |||||
| XXXX | 2130024 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - Zero Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that cannot increase test. A valid change of circumstance was not provided in the loan file. Therefore, the increase to the following fee was not accepted: Loan Discount Points on the revised CD issued on XX/XX/XXXX. If curing the violation with a refund, the following documents are required: LOE to consumer, PCCD and copy of the refund. A cost to cure in the amount of $XXXX is required. Truth in XXXX (Regulation Z) 12 CFR 2016.19(e)(3)(i); 12 CFR 1026.19(e)(3)(iv) | Upheld | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX/XXXX initial LE disclosed loan points of XXXX Rebuttal 2 (XX/XX/XXXX XX:XXPM) How are you requesting a cure of $XXXX when the Loan Discount Points on the initial LE are $XXXX and increased to $XXXX after the rate was locked? XXXX- XXXX = $XXXX Rebuttal 3 (XX/XX/XXXX XX:XXPM) NonQM |
Response 1 (XX/XX/XXXX XX:XXAM) Although a COC was provided stating the reason for the Points increase was Rate Lock, the Rate Lock sheet indicates the rate was locked on XX/XX/XXXX. This is not within XXXX days of when Points were re-disclosed. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) An updated Cost to cure in the amount of $XXXX remains. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) A Non-QM loan is still a TRID loan and therefore TRID requirements still apply. The LE XX/XX/XXXX provided was not issued within XXXX days of the rate lock on XX/XX/XXXX. (XXXX) |
XXXX | 3 | 3 | 3 | 3 | ||
| XXXX | 2130024 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 3 | |||||
| XXXX | 2130294 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. This loan has points and fees that exceed the points and fees threshold. (12 CFR 1026.43(e)(3)). The loan amount is $XXXX or more, and the transaction's total points and fees is $XXXX, which exceeds XXXX percent of the total loan amount of $XXXX. The following fees were included in the test: Loan discount points $XXXX and underwriting fee $XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) QM |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130294 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | ROR - Missing | XXXX | There is no evidence in the file that the Right to Cancel Notice was provided to the co-borrower and/or all consumers with a right to rescind. Truth in XXXX (Regulation Z).12 CFR 1026.23(b), (a)(1). Missing for XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NRTC |
Response 1 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130294 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130288 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130288 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The application lists significant debts that were not verified on the credit report and not independently verified. The loan file contained a PUD Rider indicating the subject property was located in a PUD community, and the XXXX reflected a monthly HOA fee; however, the loan file did not contain documentation verifying the monthly HOA fee to be considered in the total PITIA qualifying. ***additional conditions may apply *** | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOA |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129848 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | ROR- Incorrect Form/New creditor (H8) version required | XXXX | The consumer was provided the incorrect RTC version. The consumer is refinancing with a new creditor; however, the version provided is for a refinance with the same creditor. Version H-XXXX was provided; Version H-XXXX was required. Rescission is required to be re-opened. Truth in XXXX (Regulation Z). 12 CFR 1026.23(b)(1)(v), (a). | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NRTC Rebuttal 2 (XX/XX/XXXX XX:XXAM) Expired rescission period. Rebuttal 3 (XX/XX/XXXX XX:XXAM) Expired rescission period. |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding.The Updated ROR for the loan transaction was issued and the borrower has untilmidnight on XX/XX/XXXX to rescind. The exception can not be resolved until therecession period ends. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to cure the finding.The Updated ROR for the loan transaction was issued and the borrower has untilmidnight on XX/XX/XXXX to rescind. The exception can not be resolved until therecession period ends. (XXXX) Response 3 (XX/XX/XXXX XX:XXAM) The re-opened rescission expired at midnight on XX/XX/XXXX clearing the exception. (Resolved) |
3 | 2 | 3 | 2 | |||
| XXXX | 2129848 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130324 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130324 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130324 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130168 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130168 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The application lists significant debts that were not verified on the credit report and not independently verified. The loan file does not contain the necessary documentation to confirm the amount of HOA dues on the subject property. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOA |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130168 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VVOE Salaried/Missing | XXXX | A VVOE is missing from the loan file. The loan file is missing a VVOE dated within XXXX days of the Note for the Borrower. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) VOE |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130006 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130006 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130006 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | TRID - LE/Revised Delivery Date and Rate Lock | XXXX | The Initial Closing Disclosure issued on XX/XX/XXXX was provided to the consumer more than three business days after the rate lock, XX/XX/XXXX. Per regulation, when there is a rate lock, the creditor must provide a revised LE within XXXX business days. The loan file did not contain a revised LE. Truth in XXXX (Regulation Z) 12 CFR 1026.19(e)(3)(iv)(D) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) COC |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130006 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130044 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX Rate Set was: XX/XX/XXXX. The loan is a compliant HPML. Prepayment requirement have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130044 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii). | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130044 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX COMAR higher-priced mortgage loan test. (XXXX COMAR 09.03.06.02B(XXXX), COMAR XXXX)). Using the greater of the disclosed XXXX% APR and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in the Code ofMaryland Regulations (COMAR). The Date Rate Set was: XX/XX/XXXX. The loan is a compliant HPML. Prepayment requirement have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130044 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130048 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130048 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2130051 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130051 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130051 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Condo - HOA Dues | XXXX | The file does not contain documentation supporting the XXXX dues of $XXXX per month. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOA |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130051 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Condo - Other | XXXX | Subject property a condominium. Guidelines require to be reviewed by XXXX (CPM) and must not receive an "unavailable", "guide ineligible", or "incomplete certification" status designation, and is missing from the file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) CPM |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130051 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Credit - Other | XXXX | Per the guidelines on title requirements, in addition to the XXXX Report provided in the loan file, guidelines also require a Residential Equity Loan Policy Certificate and is missing from the file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Final title |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130038 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130038 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2130038 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The XXXX and the property condition report reflect the subject in located in a PUD. At origination $XXXX monthly HOA dues were included in the total housing payment. Documentation to support the HOA dues was not provided as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) HOA |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2130038 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Final Application - Missing | XXXX | The Borrower's Final application is missing as required by guides. The most current signature date on the application was XX/XX/XXXX. The Note date was XX/XX/XXXX. | Cleared | 2 | 2 | 3 | 2 | |||||
| XXXX | 2130038 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Other | XXXX | A Property Report was provided from XXXX. The Investor guidelines required a Residential Equity Loan Policy Certificate (RELP). A junior ALTA policy may be obtained in lieu of a RELP certificate or E & O Certificate evidencing the loan is covered under a Service Agreement or which there is an Errors and Omissions Liability Policy. Required documentation was not provided. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Final Title |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2130328 | 1 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment requirement has been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130328 | 2 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130328 | 3 of 5 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | The file failed one or more of the state threshold tests. This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)) Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in the XXXX Financial Code. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130328 | 4 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VVOE Salaried/Aged | XXXX | The VVOE dated XX/XX/XXXX for the co-borrower expired as not within XXXX business days of the Note Date XX/XX/XXXX as required per the guidelines. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130328 | 5 of 5 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VVOE Salaried/Missing | XXXX | A VVOE is missing for the borrower dated within XXXX business days of the note date XX/XX/XXXX as required by the guidelines. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130078 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130078 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Loan designation General ATR Rebuttal 2 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 3 (XX/XX/XXXX XX:XXAM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Statement of General ATR does not address whether the loan was originated as a Qualified Mortgage. If the loan is a Qualified Mortgage the finding is valid. If the loan is Exempt/Non-QM, please provide an updated XXXX re-designating the loan as Exempt/Non-QM and/or documentation reflecting the re-designation as Exempt/Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 3 (XX/XX/XXXX XX:XXAM) The new data tape provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130078 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130079 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2130079 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VVOE Salaried/Aged | XXXX | A VVOE is required within XXXX Business Days of the Note Date. The VVOE in file is dated XX/XX/XXXX which is expired as of the Note date XX/XX/XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) VOE |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2129927 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129927 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Verification Documentation - VVOE Salaried/Missing | XXXX | A VVOE is missing from the loan file. The loan file is missing the VVOE for the borrower for the second employer, XXXXXXXX, within XXXX days of closing. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) VOE |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130067 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Points and Fees | XXXX | The loan's points and fees exceed the Qualified Mortgage points and fees threshold. (12 CFR 1026.43(e)(3))The loan amount is less than $XXXX but at least $XXXX, and the transaction's total points and fees is $XXXX, which exceeds $XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) NON QM Rebuttal 2 (XX/XX/XXXX XX:XXAM) New data tape provided. |
Response 1 (XX/XX/XXXX XX:XXAM) According to the Data Tape provided, the loan is a Qualified Mortgage. If the loan is Non-QM, please provide an updated XXXX re-designating the loan as Non-QM and/or documentation reflecting the loan was originated as Non-QM. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) The new data tape provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2130067 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129930 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129930 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2008365 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2008365 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2007508 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The date used for rate set is XX/XX/XXXX. The loan is a compliant HPML. Prepayment requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2007508 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii). Informational Only. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2007508 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Title Commitment - Missing/Incomplete | XXXX | The title report is missing from the loan file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) uploaded O&E |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2038996 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2038996 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Occupancy | XXXX | The subject loan does not meet Program Parameters for Occupancy. The subject loan closed as an investment property; however, investment properties are not allowed by guidelines. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) please see attached credit committee exception Rebuttal 2 (XX/XX/XXXX XX:XXPM) loan committee approved an exception and the exception was uploaded. This was indicated on the loan tape presented to XXXX for purchase. Rebuttal 3 (XX/XX/XXXX XX:XXPM) Investor approved lender exception. |
Response 1 (XX/XX/XXXX XX:XXAM) Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Origination exception received. Investor exception still required. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) Investor approved to waive based on compensating factors. (Waived) |
Comp factors - XXXX, DTI XXXX and reserves of $XXXX. | 3 | 2 | 3 | 2 | ||
| XXXX | 2038993 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2038993 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | DTI - Exceeds Guidelines | XXXX | The DTI exceeds Originator Guidelines. The subject loan was approved with a DTI of XXXX%. The lender's guidelines maximum allowable DTI is XXXX%. Approvals up to XXXX% DTI by Consumer Loan Underwriter on a case by case basis if scenario meets investor’s guidelines. The loan file did not contain an exception. However, the actual DTI is XXXX% due to incorrectly social security income. At origination the SSI was calculated at $XXXX x XXXX% = $XXXX. The correct calculation is $XXXX x XXXX% = $XXXX x XXXX% = $XXXX + $XXXX = $XXXX. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Disagree. The acceptable DTI threshold for the loan is XXXX% due to application date. At the time of application XXXX guidelines allowed for XXXX% DTI, the change in the max DTI to XXXX% took place in XXXX, XXXX loan application is dated XX/XX/XXXX, updated guidelines were put in effect as of XX/XX/XXXX The SSI for XXXX can be grossed up by XXXX%. XXXX does not file her taxes jointly with XXXX as XXXX (borrower) is her daughter. XXXX requires documentation showing SSI is non taxable in order to gross up amount by XXXX%, the documentation in file shows that there are no taxes withheld and the only deduction is for insurance. Rebuttal 2 (XX/XX/XXXX XX:XXPM) underwriter documented that XXXX% of SSI was non-taxable so is following FNMA income calculations grossing up the entire amount XXXX%. XXXX statement shows tax withheld $XXXX. This meets FNMA requirement to document non-taxable and allows gross up of XXXX%. This is in your package page XXXX of XXXX. Also application date was XXXX/XXXX and guidelines at that time were XXXX%. Rebuttal 3 (XX/XX/XXXX XX:XXPM) Investor approved to waive. |
Response 1 (XX/XX/XXXX XX:XXAM) XXXX was locked XX/XX/XXXX, which is prior to new guidelines allowing the higher DTI. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Investor approved to waive based on compensating factors. (Waived) |
Comp factors - XXXX. Below XXXX% LTV and no consumer or mortgage lates reported. | 3 | 2 | 3 | 2 | ||
| XXXX | 2038993 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Occupancy | XXXX | The subject loan does not meet Program Parameters for Occupancy Type. The subject property is an investment property. The lender's guidelines allow only primary and second home residences. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) exception regarding the property is attachedd. |
Response 1 (XX/XX/XXXX XX:XXPM) Investor approved to waive finding based on compensating factors. (Waived) |
Comp factors - XXXX XXXX & CLTV XXXX%. | 3 | 2 | 3 | 2 | ||
| XXXX | 2064399 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2064399 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX% The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2064399 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2064399 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. CU score is XXXX. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2070770 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2070770 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX% The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2070770 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - CLTV | XXXX | Per Lender's guides, the max CLTV for a primary residence with a credit score between XXXX-XXXX, is XXXX%. However, the CLTV for the subject loan is XXXX%, which exceeds the max of XXXX%. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) please see exceptions approval attached Rebuttal 2 (XX/XX/XXXX XX:XXAM) Investor approved to waive. |
Response 1 (XX/XX/XXXX XX:XXPM) Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Investor approved to waive based on compensating factors. (Waived) |
Comp factors - XXXX, residual income $XXXX and XXXX years at current residence. | 3 | 2 | 3 | 2 | ||
| XXXX | 2064400 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 2 | |||||
| XXXX | 2064400 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Occupancy | XXXX | The subject loan does not meet Program Parameters for Occupancy. The subject loan is indicated to be an investment property. The matrix allows for XXXX and Second Homes. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) ATTACHED THE CREDIT COMMITTEE EXCEPTION FOR INVESTMENT SUBJECT Rebuttal 2 (XX/XX/XXXX XX:XXPM) Investor approved lender exception. |
Response 1 (XX/XX/XXXX XX:XXPM) Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Investor approved to waive based on compensating factors. (Waived) |
Comp factors - XXXX & Reserves $XXXX. | 3 | 2 | 3 | 2 | ||
| XXXX | 2070771 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2070771 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - APR Lending Policy | XXXX | The loan exceeds the APR lending policy threshold as follows: The note amount for a second XXXX is greater than or equal to ($XXXX), and its APR calculated per the requirements of 12 CFR §1026.43(e)(2)(vi) is less than the APOR on the date the rate was set plus XXXX%. The date used for rate set is XX/XX/XXXX. Truth in XXXX (Regulation Z) 12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 3 | 1 | |||||
| XXXX | 2070771 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - CLTV | XXXX | The subject loan CLTV of XXXX% does not meet Program Parameters for CLTV of XXXX%. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) disagree - for max CLTV XXXX % Rebuttal 2 (XX/XX/XXXX XX:XXPM) Doc provided. |
Response 1 (XX/XX/XXXX XX:XXPM) Matrix sent was incorrect matrix. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Updated Mortgage Statement on first lien provided and CLTV under XXXX% at XXXX% (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2089869 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | This loan failed the higher-priced mortgage loan test. (12 CFR 1026.35(a)(1)). Using the greater of the disclosed APR (XXXX%) and the calculated APR (XXXX%), the loan is a higher-priced mortgage loan, as defined in XXXX The date used for rate set is XX/XX/XXXX. The loan is a compliant HPML. Prepayment and appraisal requirements have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2089869 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor level of compliance with the qualified mortgage rule. (12 CFR §1026.43(b)(4), (e)(1)). This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2089869 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2089869 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. CU dated XX/XX/XXXX with a score of XXXX was provided and supported the appraised value. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2089868 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2089868 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2123078 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2123078 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2089873 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2089873 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2089870 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 4 | 1 | |||||
| XXXX | 2089870 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Other | XXXX | The loan file is missing documentation to support the use of unemployment income of $XXXX per month. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) please see attached XXXX&#XXXX;s - unemployment Rebuttal 2 (XX/XX/XXXX XX:XXPM) please see attached - re uploaded second time |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation not received. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
4 | 1 | 4 | 1 | |||
| XXXX | 2089870 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The CU score is XXXX. | Cleared | 1 | 1 | 4 | 1 | |||||
| XXXX | 2123077 | 1 of 2 | XXXX | XXXX | XXXX | Compliance | TRID - 10% Tolerance Violation (No Valid COC) | XXXX | The loan failed the charges that in total cannot increase more than XXXX% test. A valid change of circumstance was not provided in the loan file. Therefore, the increase/addition to the following fees was not accepted: Endorsements, Settlement, Tax Certificate, and XXXX Guarantee Fees. If curing the violation with a refund, the following documents are required: LOE to consumer(s), PCCD, and copy of the refund. A cost to cure in the amount of $XXXX was required of which $XXXX was cured on the CD and $XXXX was applied towards a zero tolerance violation for the Attorney XXXX. A cost to cure in the amount of $XXXX is still required. Truth in XXXX (Regulation Z)12 CFR 2016.19(e)(3)(ii); 12 CFR 1026.19(e)(3)(iv) | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) please see attached Letter of explanation, PCCD, and copy of the check |
Response 1 (XX/XX/XXXX XX:XXPM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 2 | 3 | 2 | ||||
| XXXX | 2123077 | 2 of 2 | XXXX | XXXX | XXXX | Credit | HELOC - Closure Letter | XXXX | The loan file does not contain evidence to verify HELOC Closure as required. The existing second XXXX was paid off on the closing disclosure; however, the XXXX was a HELOC. The loan file did not contain a signed closure letter. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Borrower is not signing closure document however I found the recorded release instead please see attached. should suffice. |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 2 | ||||
| XXXX | 2119381 | 1 of 3 | XXXX | XXXX | XXXX | Compliance | Security Instrument - Name Discrepancy | XXXX | The Vested Interest on the Security Instrument cannot be verified as accurate due to Title Commitment missing from the loan file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Junior loan policy located on page XXXX/XXXX of the loan file. Rebuttal 2 (XX/XX/XXXX XX:XXPM) please see attached, page XXXX of XXXX property report, also was able to pull recoded documentation of the 1st mortgage, shows XXXX is the only person. also out clear to close from our title company, all should suffice, our XXXX jr and mortgage from the 2nd mortgage shows XXXX. as well. Rebuttal 3 (XX/XX/XXXX XX:XXAM) Junior XXXX. |
Response 1 (XX/XX/XXXX XX:XXPM) Policy with proposed insured is not evidence of what title was currently vested in, in order to confirm the parties to the new mortgage were authorized to take out the new loan. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) The documentation provided is not sufficient to clear the finding. The Title Commitment is required to confirm vested Interest. (XXXX) Response 3 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | ||||
| XXXX | 2119381 | 2 of 3 | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | ||||||
| XXXX | 2119381 | 3 of 3 | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is not supported within a 10% variance | XXXX | Value is not supported within a 10% variance. The appraised value was not supported within a 10% variance. CU score is XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) please see CDA |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | ||||
| XXXX | 2089871 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2089871 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2089872 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2089872 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2111946 | 1 of 2 | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | ||||||
| XXXX | 2111946 | 2 of 2 | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | ||||||
| XXXX | 2089874 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2089874 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2119382 | 1 of 2 | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | ||||||
| XXXX | 2119382 | 2 of 2 | XXXX | XXXX | XXXX | Credit | Hazard Insurance - All Perils | XXXX | XXXX, HOI policy must specifically state “All Perils” or meet one of the three options provided in overlay to Correspondent. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) please see full HOI policy for XXXX Rebuttal 2 (XX/XX/XXXX XX:XXPM) please see attached - agent email, stating policy if considered on all peril policy, , the previous HOI was already provided. re provided again |
Response 1 (XX/XX/XXXX XX:XXAM) All Perils not reflected. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | ||||
| XXXX | 2123083 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2123083 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - CLTV | XXXX | XXXX in the loan file as the subject loan does not meet Program Parameters for CLTV. The subject loan is a cash out refinance fixed 2nd mortgage of a XXXX unit investment property with a CLTV of XXXX% and a credit XXXX. The lender guidelines do not permit investment properties, or multi unit properties over XXXX units. Therefore, the subject loan is an ineligible transaction. Client to approve downgrading of finding based on compensating factors. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) pleas rebutt, we do allow investment properties and XXXX-XXXX unit, attached is the policy and also we have exception for CTLV over XXXX% |
Response 1 (XX/XX/XXXX XX:XXAM) Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted Compensating factors: Subject property owned since XXXX, XXXX qualifying credit score, XXXX% DTI, 0x30 mortgage history for XXXX months. |
Comp Factors: DTI XXXX%, Residual of $XXXX per month | 3 | 2 | 3 | 2 | |
| XXXX | 2123083 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Occupancy | XXXX | The subject loan does not meet Program Parameters for Occupancy. The subject loan is a cash out refinance fixed 2nd mortgage of a XXXX unit investment property with a CLTV of XXXX% and a credit XXXX. The lender guidelines do not permit investment properties, or multi unit properties over XXXX units. Therefore, the subject loan is an ineligible transaction. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) pleas rebutt, we do allow investment properties and XXXX-XXXX unit, attached is the policy |
Response 1 (XX/XX/XXXX XX:XXAM) HeLoan guides allow XXXX-XXXX units only if XXXX unit is primary. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted Compensating factors: Subject property owned since XXXX, XXXX qualifying credit score, XXXX% DTI, 0x30 mortgage history for XXXX months. |
Comp Factors: DTI XXXX%, Residual of $XXXX per month | 3 | 2 | 3 | 2 | |
| XXXX | 2123083 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - Property Type | XXXX | The subject loan does not meet Program Parameters for Property Type. The subject loan is a cash out refinance fixed 2nd mortgage of a XXXX unit investment property with a CLTV of XXXX% and a credit XXXX. The lender guidelines do not permit investment properties, or multi unit properties over XXXX units. Therefore, the subject loan is an ineligible transaction. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) pleas rebutt, we do allow investment properties and XXXX-XXXX unit, attached is the policy |
Response 1 (XX/XX/XXXX XX:XXAM) HeLoan guides only allow Investment SFR, PUD, or Condo. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed and elects to waive. Noted Compensating factors: Subject property owned since XXXX, XXXX qualifying credit score, XXXX% DTI, 0x30 mortgage history for XXXX months. |
Comp Factors: DTI XXXX%, Residual of $XXXX per month | 3 | 2 | 3 | 2 | |
| XXXX | 2119380 | 1 of 3 | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | ||||||
| XXXX | 2119380 | 2 of 3 | XXXX | XXXX | XXXX | Credit | Hazard Insurance - All Perils | XXXX | XXXX, HOI policy must specifically state “All Perils” or meet one of the three options provided in overlay to Correspondent. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXAM) please see full HOI |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | ||||
| XXXX | 2119380 | 3 of 3 | XXXX | XXXX | XXXX | Credit | Income - Missing | XXXX | The loan file is missing income documents; there is no way to determine if the borrower meets the DTI requirements. The guidelines required the most recent business and personal tax returns for self-employed borrowers. The loan file contained business tax returns for the borrower; however, it did not contain personal tax returns including schedule C to verify the co-borrower’s income. In addition, the borrowers were qualified with gross rental income of $XXXX for the property located at XXXXXX; however, the loan file did not contain documentation verifying this rental income. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) please see attached management approval. Rebuttal 2 (XX/XX/XXXX XX:XXPM) PLEASE SEE ATTACHED INCOME - HAS SCHEDULE C AND XXXX |
Response 1 (XX/XX/XXXX XX:XXPM) Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | ||||
| XXXX | 2129617 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129617 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129617 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a CU Score of XXXX | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129614 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2129614 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The application lists significant debts that were not verified on the credit report and not independently verified. The loan file does not contain sufficient documentation to determine whether or not the following retained properties of the borrower have XXXX Dues: XXXX., XXXX. and XXXX. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) please rebutt, Provided property search confrims there is no HOA&#XXXX;S , also for XXXX this is land meaning ther is no HOA neither. |
Response 1 (XX/XX/XXXX XX:XXAM) Still missing confirmation of no HOA dues for XXXX. and XXXX. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Investor reviewed, XXXX provided for XXXX. does not show HOA and XXXX is vacant land. Noted compensating factors: $XXXX residual income, XXXX years job stability, 0x30 mortgage history for XXXX months reviewed. |
XXXX. $XXXX per month residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2129614 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is not supported within a 10% variance | XXXX | Value is not supported within 10% of original appraisal amount. The loan file contains a CU Score of XXXX | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) please see attached CDA |
Response 1 (XX/XX/XXXX XX:XXPM) CDA provided and supports original appraised value. (Resolved) |
3 | 1 | 3 | 2 | |||
| XXXX | 2111948 | 1 of 2 | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | ||||||
| XXXX | 2111948 | 2 of 2 | XXXX | XXXX | XXXX | Credit | Program Parameters - DTI | XXXX | XXXX in file as the subject loan does not meet Program Parameters for DTI. The loan approval and audit review revealed the borrowers’ DTI was over XXXX%. Lender guides indicate the maximum DTI was XXXX%. Client to approve downgrading finding based on compensating factors. | Waived | Response 1 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXAM) Client reviewed and elects to waive. Noted Compensating factors: XXXX years with same employer, XXXX property owned XXXX years, $XXXX monthly residual income |
Compensating Factors: Low CLTV XXXX%, clean credit with only XXXX% utilization of credit, XXXX, Stable employment over XXXX years | 3 | 2 | 3 | 2 | |||
| XXXX | 2123081 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2123081 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Hazard Insurance - All Perils | XXXX | XXXX, HOI policy must specifically state “All Perils” or meet one of the three options provided in overlay to Correspondent. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) please seee attached full HOI |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2123082 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2123082 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2111947 | 1 of 2 | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | ||||||
| XXXX | 2111947 | 2 of 2 | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | ||||||
| XXXX | 2119383 | 1 of 3 | XXXX | XXXX | XXXX | Compliance | Security Instrument - Name Discrepancy | XXXX | The Vested Interest on the Security Instrument cannot be verified as accurate due to Title Commitment missing from the loan file. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) Junior loan policy page XXXX/XXXX Rebuttal 2 (XX/XX/XXXX XX:XXAM) Junior XXXX. |
Response 1 (XX/XX/XXXX XX:XXPM) Policy with proposed insured is not evidence of what title was currently vested in, in order to confirm the parties to the new mortgage were authorized to take out the new loan. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) The documentation provided is sufficient to clear the finding. (Resolved) |
3 | 1 | 3 | 1 | ||||
| XXXX | 2119383 | 2 of 3 | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 3 | 1 | ||||||
| XXXX | 2119383 | 3 of 3 | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is not supported within a 10% variance | XXXX | Value is not supported within a 10% variance. The appraised value was not supported within 10% variance. CU Score is XXXX. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) please see attached CDA |
Response 1 (XX/XX/XXXX XX:XXPM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | ||||
| XXXX | 2129615 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2129615 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Debts - Not Verified | XXXX | The application lists significant debts that were not verified on the credit report and not independently verified. The loan file does not contain proper documentation to determine if there are any Home Owner Associations Dues on the Borrower's primary residence located at XXXX, XXXX | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) please see attached, based on search the are no HOA applicable. |
Response 1 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2123079 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2123079 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2123080 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2123080 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Miscalculated/DTI Exceeds Tolerance | XXXX | The income is miscalculated on one or more borrowers, however the recalculated DTI is not within allowable tolerances (XXXX%) or DTI MAX. The origination underwriter calculated the qualifying monthly income as $XXXX. However, the loan file documents the borrower started a new full time salary 2nd job in XXXX/XXXX with an LOE stating the declining income was due to the new job, but the income from the current employer would continue. The XXXX earnings reflect a declining income of XXXX% and the position with the current employer is primraily commission based in loan originations/sales. The Audit Review used the XXXX YTD declining income calculations for the base and bonus income along with a XXXX year average for the commission earnings to arrive at a qualifying monthly income with the borrowers current employer only of $XXXX. The new salaried 2nd job income was not included in qualifying either at origination or at audit review. As a result the DTI increased from XXXX% to XXXX% exceeding maximum guidelines of XXXX%. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) please rebutt, yes borrower is comission, majority is comission tranding XXXX YTD comssions income is increasing. Borrower has been with XXXX for XXXX-XXXX-XXXX and has now establised his cliantee, and income seen to be stable. attached is XXXX incomer worksheet and XXXX revised Rebuttal 2 (XX/XX/XXXX XX:XXPM) Rental income: 5904.42 ( XXXX XXXX ) 5237.83 ( XXXX ), XXXX: XXXX, Bonus: XXXX , commission: XXXX , - please rebut, yes borrower is commission, majority is commission is trending XXXX YTD commission income is increasing. Borrower has been with XXXX since XXXX-XXXX-XXXX and has now established his clients, and income seems to be stable. Liabilities: Amex was excluded since borrower has sufficient funds to cover. Excluded duplicate: XXXX x XXXX. Citi card is excluded since borrower is just a authorized user and does not belong to the borrower, Attached is XXXX income worksheet and XXXX revised. DTI: XXXX |
Response 1 (XX/XX/XXXX XX:XXAM) Income calculated differently at review as follows: Base wages $XXXX per month + Annualized Bonus, as opposed to averaged, $XXXX per month + XXXX month commission average, as opposed to XXXX month average, $XXXX per month + $XXXX per month positive rental = $XXXX per month. DTI XXXX%. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Explanation acknowledged; however, calculation at review is conservative and accurate. (XXXX) Response 3 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Investor reviewed and elects to waive. Noted Compensating factors: XXXX qualifying credit score, $XXXX monthly residual income, Job stability XXXX years, 0x30 mortgage history for XXXX months reviewed, Experienced investor. |
XXXX. XXXX% LTV. $XXXX per month residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2129616 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129616 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129619 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129619 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2139820 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2139820 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2139820 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is supported within 10% of original appraisal amount | XXXX | The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. CU score XXXX. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129618 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129618 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129620 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2129620 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2147764 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2147764 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2139819 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2139819 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - DTI | XXXX | The subject loan does not meet Investor Program Parameters for DTI. The subject loan is a cash out refinance with the borrower obtaining a new 2nd mortgage. The origination UW calculated the borrowers income as $XXXX per month. After further review of the Final Loan Application social security income, the origination UW grossed up the income twice. The audit review income with the social security grossed up once is $XXXX. The new 2nd mortgage paid off all of the borrowers monthly debts, leaving only the PITIA of $XXXX including the new 2nd mortgage payment, with the audit review matching the debts of XXXX. The loan was approved with a DTI of XXXX%, which exceeded the guideline maximum of XXXX%. The audit review DTI is XXXX%. The loan program DTI guidelines reflect a maximum DTI of XXXX%. The loan file did not contain an exception; therefore, the subject loan is an ineligible transaction. ***additional conditions may apply***. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) please waive , by UW exception XXXX% if meets all other investor guidelines |
Response 1 (XX/XX/XXXX XX:XXPM) Originator exception missing. Investor exception also required. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Investor reviewed and elects to waive. Noted compensating factors: XXXX qualifying credit score, subject property owned XXXX years, 0x30 mortgage history, 0x30 mortgage history XXXX months reviewed |
XXXX. $XXXX per month residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2153146 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2153146 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - DTI | XXXX | Per Lender's guides, the max CLTV for credit scores XXXX-XXXX and primary residence is XXXX%. The qualifying score is XXXX, with a CLTV XXXX%, which exceeds the max of XXXX%. The loan file does not contain an exception for the CLTV. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) rebiutt, please see attached CTLV exceptions approval. |
Response 1 (XX/XX/XXXX XX:XXPM) Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Investor reviewed and elects to waive. Noted Compensating factors: Subject property owned XXXX years, Job stability XXXX years, 0x30x87 mortgage history |
XXXX. XXXX% DTI. $XXXXper month residual income. | 3 | 2 | 3 | 2 | |
| XXXX | 2139821 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2139821 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2139822 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2139822 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2147763 | 1 of 2 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2147763 | 2 of 2 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 | |||||
| XXXX | 2153147 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 1 | |||||
| XXXX | 2153147 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Tax Return Documentation Incomplete | XXXX | Per Lender's guides, XXXX years of prior earnings are required. However, the loan file obtains XXXX tax returns. The XXXX tax returns were not provided as required. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) rebutt, business has been in business for XXXX plus years, XXXX years of tax returns not required.. Rebuttal 2 (XX/XX/XXXX XX:XXAM) Escalated. |
Response 1 (XX/XX/XXXX XX:XXPM) We agree XXXX and XXXX first lien reviews allow XXXX year in most cases with XXXX years of self-employment. This is a second lien with no DU or LP and lender overlays specifically requiring XXXX years of tax returns and transcripts. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2153147 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Income - Tax Transcripts Missing | XXXX | Per Lender's guides, XXXX years of tax transcripts are required to be provided when income is reported on XXXXs. The co-borrower is self-employed and schedule C was used to calculate the qualifying income; therefore, XXXX/XXXX tax transcripts were required to be provided. However, the loan file contains XXXX tax transcripts which does not reflect any information. No other documentation was provided. | Resolved | Rebuttal 1 (XX/XX/XXXX XX:XXPM) rebutted, business has been in business for XXXX plus years, XXXX years of tax not required, Rebuttal 2 (XX/XX/XXXX XX:XXAM) Escalated. |
Response 1 (XX/XX/XXXX XX:XXPM) We agree XXXX and XXXX first lien reviews allow XXXX year in most cases with XXXX years of self-employment. This is a second lien with no DU or LP and lender overlays specifically requiring XXXX years of tax returns and transcripts. (XXXX) Response 2 (XX/XX/XXXX XX:XXAM) Documentation received is sufficient. (Resolved) |
3 | 1 | 3 | 1 | |||
| XXXX | 2153148 | 1 of 3 | XXXX | XXXX | XXXX | XXXX | Compliance | No Compliance Findings | XXXX | The loan is in compliance with all applicable laws and regulations. | Cleared | 1 | 1 | 3 | 2 | |||||
| XXXX | 2153148 | 2 of 3 | XXXX | XXXX | XXXX | XXXX | Credit | Program Parameters - CLTV | XXXX | Lender's Exception - Lender allowed the CLTV to exceed XXXX% for credit scores between XXXX-XXXX and investment property. CLTV is XXXX%. Client to approve downgrading finding based on compensating factors. | Waived | Rebuttal 1 (XX/XX/XXXX XX:XXPM) please see email approval |
Response 1 (XX/XX/XXXX XX:XXPM) Exception must be granted by Investor. (XXXX) Response 2 (XX/XX/XXXX XX:XXPM) Waiver granted by Investor. (Waived) |
XXXX (XX/XX/XXXX XX:XXPM) Investor reviewed and elects to waive. Noted compensating factors: XXXX years job stability, 0x30x99 mortgage history, XXXX% DTI |
Compensating factors - $XXXX residual income per month, No derogatory tradelines, stable line of work. | 3 | 2 | 3 | 2 | |
| XXXX | 2153148 | 3 of 3 | XXXX | XXXX | XXXX | XXXX | Valuation | Appraisal - Value is not supported within a 10% variance | XXXX | The Loan file did not contain an AVM, CDA, Field Review, 2nd appraisal or CU score at XXXX or under to support the origination appraised value. The CU score was XXXX. The loan file did not contain any other valuation product to support the appraised value. ?? | Void | Rebuttal 1 (XX/XX/XXXX XX:XXPM) please see appraisal. we either use a AVM/ PCi or a Appraisal. If the XXXX is not sufficient, We will provide a CDA. Please let us know if that will be required. our policy does not state we will have a CDA on each file. |
Response 1 (XX/XX/XXXX XX:XXPM) Explanation received is sufficient. (Void) |
1 | 1 | 3 | 2 | |||
| XXXX | 2158669 | 1 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | Federal - HPML APR/Compliant | XXXX | The loan failed the Federal HPML APR test. Using the greater of the disclosed APR XXXX% and the calculated APR XXXX%, the loan is a higher-priced mortgage loan, as defined in XXXX Rate Set was: XX/XX/XXXX. The loan is a compliant HPML. Prepayment requirement have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2158669 | 2 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | QM - Rebuttable Presumption | XXXX | The loan qualifies for QM-Rebuttable Presumption. The loan exceeds XXXX threshold as follows: This loan does not qualify for a safe harbor. The loan has an APR of XXXX%. The APR threshold to qualify for a safe harbor is XXXX%. The date used for rate set is XX/XX/XXXX. The loan is a Higher-Priced Covered Transaction subject to QM-Rebuttable Presumption. Truth in XXXX (Regulation Z)12 CFR 1026.43(e)(1)(ii) Informational Only | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2158669 | 3 of 4 | XXXX | XXXX | XXXX | XXXX | Compliance | State Testing | XXXX | This loan failed the XXXX XXXX higher-priced mortgage loan test. (XXXX XXXX, XXXX Financial Code Division XXXX 4995(a)). The loan exceeded the XXXX higher-priced mortgage loan test. The loan has an APR of XXXX%. The XXXX APR threshold is XXXX%. The loan is a compliant HPML. Prepayment requirement have been met. | Acknowledged | 1 | 1 | 1 | 1 | |||||
| XXXX | 2158669 | 4 of 4 | XXXX | XXXX | XXXX | XXXX | Credit | No Credit Findings | XXXX | The loan meets all applicable credit guidelines. | Cleared | 1 | 1 | 1 | 1 |