Exhibit
99.1
EXECUTIVE
SUMMARY
Third Party Due Diligence Review
Overview
Consolidated
Analytics, Inc (“Consolidated Analytics”), a third-party due diligence provider, performed the review described below on newly
originated residential mortgage loans acquired by Citadel Servicing Corporation dba Acra Lending. The review included a total of 271 newly
originated residential mortgage loans, in connection with the securitization identified as ACRA 2026-NQM1 (the “Securitization”).
The Review was conducted from February 2026 through May 2026 on mortgage loans originated between January 2026 and May 2026.
Scope of Review
Credit Review
Consolidated
Analytics performed a “Credit Review” to verify compliance with guidelines in effect at the time of loan origination, or other
guidelines provided by Client prior to review, and ensure the characteristics used by the underwriter are supported by the file documentation;
and determine whether any loans outside of those guidelines contain legitimate and approved exceptions with compensating factors.
The Credit Review attempted to confirm the
following:
| a. | QM
or ATR Validation / Review of 8 Key Underwriting Factors |
| ● | Validate borrower(s) monthly gross income |
| ● | Validate funds required to close, required reserves |
| ● | Review file documentation for required level of income and asset verifications |
| ● | Review file documentation for required level of employment |
| iii. | Monthly Mortgage Payment |
| ● | Confirm program, qualifying rate, terms |
| ● | Validate all concurrent loans are included in the DTI to properly assess
the ability to repay |
| v. | Mortgage Related Obligations: PITI, HOA, PMI, etc. |
| ● | Validate subject loan monthly payment (PITI) and associated obligations |
| ● | Validate monthly recurring liabilities |
| vii. | DTI and/or Residual Income |
| ● | Validate debt-to-income ratio (DTI) based upon income and debt documentation
provided in the file |
| ● | Documentation meets Appendix Q requirements for QM Loans |
| ● | Review credit report for credit history and required credit depth including
any / all inquiries |
| ● | Determine representative credit score from credit report |
| b. | Validate
loan-to-value (LTV) and combined loan-to-value |
| c. | Review
borrower's occupancy |
| d. | Validation
through third party resource of the subject properties most recent twelve (12) month sales history |
| e. | Confirm
sufficient evidence in loan file, by reviewing the underwriter’s decision to approve the loan based upon the borrows income, debt,
and credit history, to support borrower's willingness and ability to repay the debt |
| f. | Confirm
that Final 1003 is sufficiently completed |
| g. | Provide
Audit 1008 with accurate data based on file documentation |
| h. | Confirm
Loan Approval conditions were met |
| i. | Review
condominium questionnaire to verify all information is complete, prepared by an authorized representative, and address any red flags
that may deem condominium project ineligible |
| j. | General
QM for any loans originated under the GQM Rule |
| a. | Pricing
for First Lien Loans: |
| i. |
|
2.25% for a first-lien covered transaction with a loan amount greater than or equal to the applicable dollar
amount threshold; and |
| ii. |
|
3.5% for a first-lien covered transaction with a loan amount greater than or equal to the applicable dollar
amount threshold; and |
| iii. |
|
6.5% for a first-lien covered transaction with a loan amount less than the applicable dollar amount threshold. |
| b. | Pricing
for Subordinate Lien Loans: |
| i. | |
3.5% for a subordinate-lien covered transaction with a loan amount greater than or equal to the applicable
dollar amount threshold; and |
| ii. | |
6.5% for a subordinate-lien covered transaction with a loan amount less than the applicable dollar amount
threshold. |
| c. | Pricing
for Manufactured Homes: |
| i. | |
2.25% for a first-lien covered transaction secured by a manufactured home with a loan amount equal to or
greater than the applicable dollar amount threshold; and |
| ii. | |
6.5% for a covered transaction secured by a manufactured home with a loan amount less than applicable dollar
amount threshold. |
| ii. | Consider Income and Assets: |
| o | Consumer’s current or reasonably expected income or assets (other than the value of the dwelling
that secures the loan; |
| o | The consumer’s debt obligations, alimony, child support; and |
| o | The monthly DTI or residual income. |
| iii. | Verification of Income and Assets: |
| a. | Verification in compliance with one of the “safe harbor” guidelines will meet the QM verification
requirement. A creditor is allowed to “mix and match” provisions of the different guidelines rather than only apply one guideline
per loan. |
The specific guidelines that the CFPB is designating for the safe
harbor are: The GQM Rule provides that if the creditor verifies the consumer’s income or assets, debt obligations, alimony, child
support, and monthly DTI or residual income by meeting the standards of certain specified third-party underwriting manuals, then a creditor
is presumed to have complied with the verification requirement. These specified manuals are:
| i. | |
Chapters B3-3 through B3-6 of the Fannie Mae Single Family Selling Guide, published June 3, 2020; |
| ii. | |
Sections 5102 through 5500 of the Freddie Mac Single-Family Seller/Servicer Guide, published June 10, 2020;
|
| iii. | |
Sections II.A.1 and II.A.4-5 of the Federal Housing Administration’s Single Family Housing Policy
Handbook, issued October 24, 2019; |
| iv. | |
Chapter 4 of the U.S. Department of Veterans Affairs’ Lenders Handbook, revised February 22, 2019;
|
| v. | |
Chapter 4 of the U.S. Department of Agriculture’s Field Office Handbook for the Direct Single Family
Housing Program, revised March 15, 2019; and |
| vi. | |
Chapters 9 through 11 of the U.S. Department of Agriculture’s Handbook for the Single Family Guaranteed
Loan Program, revised March 19, 2020. |
Compliance Review
Consolidated Analytics performed a “Compliance
Review” to determine, as applicable, to the extent possible and subject to the caveats below, whether the loan complies with applicable
regulatory requirements as noted below, each as amended, restated and/or replaced from time to time. In relation to cash out refinances
of investment property loans, documentation provided in the loan file will be reviewed only to validate the use of cash out proceeds for
business purposes at the origination/consummation of the loan. In the event use of proceeds cannot be validated, or are deemed to be utilized
for consumer purposes, the loan would then be subject to a “Compliance Review” of applicable regulatory requirements as noted
below, each as amended, restated and/or replaced from time to time. The Compliance Review included the following:
| a. | Test Loan Estimate(s) for accuracy and completeness as well as timing requirements as required by TRID
Regulations |
| b. | Test Closing Disclosure(s) for accuracy and completeness as well as timing requirements as required by
TRID Regulations |
| i. | Compare Loan Estimate and Closing Disclosures |
| ii. | Identify Tolerance Violations and applicable cost to cure |
| d. | Comprehensive review of Closing Disclosure to determine transaction accuracy |
| e. | Recalculation of APR and Finance Charge |
| i. | Federal High Cost Mortgage provisions |
| ii. | Federal Higher Priced Mortgage Loans provisions |
| iii. | Local and/or State Anti-predatory and High Cost provisions |
| g. | Determine whether specified federal disclosures were provided timely based upon comparison of the application
date to the dates on such disclosures |
| ii. | Home Ownership Counselling Disclosure |
| h. | Compliance with QM as it relates to: |
| iii. | Prepayment Penalty Test |
| iv. | Product Eligibility Testing |
| i. | Notice of Right to Cancel (Rescission)
Review |
| i. | Confirm transaction date, expiration date, and disbursement date |
| ii. | Confirm document is properly executed by all required
parties to the transaction |
| iii. | Confirm the correct Right of Rescission document was executed for the transaction
type |
| j. | Confirm through NMLS the loan originator and originating
firm's license status was active and properly disclosed on appropriate loan documents |
| k. | Check the Loan participants against the exclusionary list provided by Client or by the purchaser of the
Loan(s) |
| l. | Review closing documents to ensure that the Mortgage Loan information is complete, accurate, and consistent
with other documents; Confirm collateral documents have been recorded or sent for recording |
The Compliance Review did not include any federal,
state or local laws, constitutional provisions, regulations or ordinances that are not expressly enumerated above. Furthermore, the findings
reached by Consolidated Analytics are dependent upon its receiving complete and accurate data regarding the loans from loan originators
and other third parties upon which Consolidated Analytics is relying in reaching such findings.
Valuation Review
Consolidated Analytics performed a “Valuation
Review,” which included the following:
| a. | Review original appraisal, determination that property is in "average" condition or better,
or property requires cosmetic improvements (as defined by the appraiser) that do not affect habitability. Should an area of concern be
identified with the condition of the property, Consolidated Analytics will alert Client. |
| b. | Review appraisal, determination that property is completely constructed and appraisal is on an “as
is basis,” or property is identified as not completely constructed by originating appraiser. |
| c. | Review and determine if the appraisal report was performed on appropriate GSE forms and if the appraiser
indicated in the body of the subject appraisal that the appraisal conforms to USPAP standards. |
| d. | Review and determine the relevance of the comparable properties and ensure that a rational and reliable
value was provided and supported as of the effective date of the Origination Appraisal. |
| e. | Review adjustments (line item, net and gross adjustments) to ensure they are reasonable. |
| f. | Ensure that the appraisal conforms to the guidelines provided from the Client. |
| g. | Review appraisal to ensure all required documents were included. |
| h. | Review location map provided within the appraisal for external obsolescence. |
| i. | Ensure highest and best use and zoning complies with guidelines. |
| j. | Confirm there are no marketability issues that affect the subject property. |
| k. | Ensure subject property does not suffer any functional obsolescence. |
| l. | Where applicable, determine if the file did not contain the appraisal or other valuation method and a
review could not be performed. |
| m. | Additional valuation products were not required when the CU score provided was 2.5 or below or the appraisal
LCA risk score was eligible for Collateral Rep and Warranty relief. In the event the CU score was greater than 2.5 or the LCA score was
not eligible for R&W relief, an additional valuation product was obtained to confirm value was supported within 10% tolerance. In
some instances, based on guidance from the seller, CDA’s were ordered on loans that had an acceptable CU score or R&W eligibility. |
Consolidated Analytics applied a cascade methodology
to determine if the original appraised value was reasonably supported when compared to an independent third-party valuation product.
For
loans reviewed in a post-close valuation review scenario (271 loans in total):
Zero
(0) loans had a Secondary Appraisal, one (1) loan had an AVM, zero (0) loans had an Exterior Only Appraisal Review, and one hundred seventy-one
(171) loans had Desktop Reviews.
If
a loan with an AVM or Desktop Review fell outside of a -10% tolerance, was inconclusive, or a PIW was present, then a Field Review, a
Broker Price Opinion (BPO) along with a Reconciliation of the values or a 2nd Appraisal was completed. There were zero (0) occurrences
of this.
One
(1) loan had a Field Review or BPO, six (6) loans had a Second Desk Review, and zero (0) loans had a Full Appraisal Review, all of which
supported value.
Product totals may not sum due to multiple products for each
loan
TAPE INTEGRITY REVIEW RESULTS SUMMARY
Of the two hundred seventy-one (271) mortgage loans reviewed, one hundred seventy-four (174) unique mortgage loans (64.21% by loan count)
had a total of six hundred two (602) discrepancies across thirty-one (31) data fields. A blank or zero value on the data tape when an
actual value was captured by Consolidated Analytics was not treated as a data variance.
| Fields Reviewed |
Discrepancy Count |
Percentage |
| Loan Program |
79 |
13.12% |
| Qualifying Total Reserves Number of Months |
79 |
13.12% |
| Total Qualified Assets Available |
78 |
12.96% |
| Monthly Total Escrow Payment |
76 |
12.62% |
| Borrower Appraisal Receipt Date |
73 |
12.13% |
| Total Liquid Assets Available For Close |
59 |
9.80% |
| Qualifying Total Monthly Liabilities |
49 |
8.14% |
| Qualifying FICO |
16 |
2.66% |
| Borrower 1 Total Years Employment/Self-Employment Verified |
10 |
1.66% |
| Originator DSCR |
9 |
1.50% |
| Cash Disbursement Date |
9 |
1.50% |
| Property Address |
8 |
1.33% |
| Borrower 1 FTHB |
8 |
1.33% |
| Cash out Include Debt Paid at Close |
7 |
1.16% |
| Borrower 1 Citizen |
7 |
1.16% |
| Qualifying Monthly P&I Amount |
6 |
1.00% |
| Qualifying LTV |
4 |
0.66% |
| Qualifying CLTV |
4 |
0.66% |
| Calculated DSCR |
3 |
0.50% |
| Borrower 1 Qualifying Income |
3 |
0.50% |
| Property Type |
3 |
0.50% |
| Lock Term (Days) |
3 |
0.50% |
| Qualifying Total Housing Expense PITIA |
1 |
0.17% |
| Borrower 2 Qualifying Income |
1 |
0.17% |
| Borrower 1 First Name |
1 |
0.17% |
| Prepayment Penalty Flag |
1 |
0.17% |
| Reviewed Appraised Property Value |
1 |
0.17% |
| Prepayment Penalty Calculation |
1 |
0.17% |
| Borrower 2 Last Name |
1 |
0.17% |
| Mortgage Origination Channel |
1 |
0.17% |
| Number of Units |
1 |
0.17% |
| Grand Total |
602 |
100.00% |
Summary of Results
OVERALL RESULTS SUMMARY
Final Loan Grades
| |
Overall Loan Results: |
|
|
| |
Event
Grade |
Loan
Count |
Original
Principal Balance |
Percent
of Sample |
|
| |
Event
Grade A |
225 |
$113,864,913.00 |
83.03% |
|
| |
Event
Grade B |
46 |
$25,075,550.00 |
16.97% |
|
| |
Event
Grade C |
0 |
$0.00 |
0% |
|
| |
Event
Grade D |
0 |
$0.00 |
0% |
|
| |
Total
Sample |
271 |
$138,940,463.00 |
100.00% |
|
| |
Credit
Results: |
|
| |
Event
Grade |
Loan
Count |
Percent
of Sample |
|
| |
Event
Grade A |
230 |
84.87% |
|
| |
Event
Grade B |
41 |
15.13% |
|
| |
Event
Grade C |
0 |
0% |
|
| |
Event
Grade D |
0 |
0% |
|
| |
Total
Sample |
271 |
100.00% |
|
| |
Compliance Results: |
|
| |
Event
Grade |
Loan
Count |
Percent
of Sample |
|
| |
Event
Grade A |
268 |
98.89% |
|
| |
Event
Grade B |
3 |
1.11% |
|
| |
Event
Grade C |
0 |
0% |
|
| |
Event
Grade D |
0 |
0% |
|
| |
Total
Sample |
271 |
100.00% |
|
| |
Valuation Results: |
|
| |
Event
Grade |
Loan
Count |
Percent
of Sample |
|
| |
Event
Grade A |
266 |
98.15% |
|
| |
Event
Grade B |
5 |
1.85% |
|
| |
Event
Grade C |
0 |
0% |
|
| |
Event
Grade D |
0 |
0% |
|
| |
Total
Sample |
271 |
100.00% |
|
Exception Category Summary
The table below summarizes the individual exceptions which carried an associated
“A”, “B”, “C”, or “D” level exception grade. One loan may have carried more than one exception.
In such cases, the exception with the lowest grade would drive the loan grade for that particular area of the review. The overall loan
grade is the lowest grade for any one particular review scope (ex. a loan with a Compliance Grade of “B”, a Credit Grade of
“A”, and a Property Grade of “A” would receive an overall Loan Grade of “B”).
| Exception Type |
Exception Level Grade |
Exception Category |
Total |
| Credit |
A |
No Credit Findings |
146 |
| Flood Certificate Missing |
12 |
| Borrower 1 3rd Party VOE Prior to Close Missing |
11 |
| Verification of Rent (VOR)/Verification of Mortgage (VOM) Document is incomplete |
11 |
| Property Title Issue |
10 |
| Borrower 1 Credit Report is Missing |
9 |
| Missing verification of taxes, insurance, and/or HOA fees for non-subject property |
9 |
| Housing History Does Not Meet Guideline Requirements |
8 |
| |
|
Audited FICO is less than Guideline FICO |
7 |
| Asset Qualification Does Not Meet Guideline Requirements |
6 |
| Missing income documentation |
6 |
| Borrower residency documentation not provided or issue with documentation |
6 |
| Fraud Report Shows Uncleared Alerts |
6 |
| Loan does not conform to program guidelines |
5 |
| Approval/Underwriting Summary Partially Provided |
4 |
| All Interested Parties Not Checked with Exclusionary Lists |
4 |
| Borrower Non-US Citizen Identification Document Missing |
3 |
| Borrower 2 Credit Report is Missing |
3 |
| Missing letter of explanation |
3 |
| Borrower 2 3rd Party VOE Prior to Close Missing |
3 |
| The Final 1003 is Incomplete |
3 |
| Missing Letter of Explanation (Credit) |
2 |
| Missing evidence of self employment |
2 |
| The Deed of Trust is Incomplete |
2 |
| Audited Reserves are less than Guideline Required Reserves (Dollar Amount) |
2 |
| Asset 2 Missing |
2 |
| Audited Reserves are less than Guideline Required Reserves (Number of Months) |
2 |
| Missing VOM or VOR |
2 |
| Income and Employment Do Not Meet Guidelines |
2 |
| Asset 1 Does Not Meet Guideline Requirements |
2 |
| ATR: Current Employment Not Verified |
2 |
| Hazard Insurance Effective Date is after the Disbursement Date |
2 |
| The Total Hazard Coverage is LESS than the Required Coverage Amount |
2 |
| The Final 1003 is Missing |
1 |
| Overdraft/NSF Count Exceeds Tolerance |
1 |
| Borrower 2 Non-US Citizen Identification Document Missing |
1 |
| Asset 4 Expired |
1 |
| Satisfactory Chain of Title not Provided |
1 |
| Borrower 1 Credit Report is Incomplete |
1 |
| Audited HCLTV Exceeds Guideline HCLTV |
1 |
| Guideline Seasoning not Met |
1 |
| |
|
Audited Interested Party Contribution Exceeds Guideline Program Maximum |
1 |
| Asset 2 Does Not Meet Guideline Requirements |
1 |
| Purchase Contract is Missing |
1 |
| HO6 Master Insurance Policy is Missing |
1 |
| The Deed of Trust is Missing |
1 |
| The Note is Missing |
1 |
| Final CD: Calculating Cash to Close Closing Costs Paid, Closing Costs Financed, Down Pmt, Deposit, and/or Funds for Borrower discrepancy |
1 |
| Title Document Missing |
1 |
| Missing Letter of Explanation (Assets) |
1 |
| Borrower 1 Lease Agreements Missing |
1 |
| Asset General |
1 |
| Income 7 Months Income Verified is Missing |
1 |
| Asset 11 Expired |
1 |
| Borrower 1 Tax Returns Not Signed |
1 |
| Assets do not meet guideline requirements |
1 |
| Income/Employment General |
1 |
| Rent Loss Coverage Not Sufficient |
1 |
| Borrower 1 W2/1099 Missing |
1 |
| Cash Out Does Not Meet Guideline Requirements |
1 |
| Audited LTV Exceeds Guideline LTV |
1 |
| Delinquent Credit History Does Not Meet Guideline Requirements |
1 |
| Missing final HUD-1 from sale of non-subject property |
1 |
| The Note is Incomplete |
1 |
| Asset 9 Expired |
1 |
| Missing Lease Agreement |
1 |
| Asset 5 Expired |
1 |
| Verification of Borrower Liabilities Missing or Incomplete |
1 |
| Income 3 Months Income Verified is Missing |
1 |
| Audited CLTV Exceeds Guideline CLTV |
1 |
| Income 5 Months Income Verified is Missing |
1 |
| Total Credit Grade (A) Exceptions: |
337 |
| B |
Delinquent Credit History Does Not Meet Guideline Requirements |
5 |
| Audited Reserves are less than Guideline Required Reserves (Dollar Amount) |
4 |
| |
|
Loan does not conform to program guidelines |
4 |
| Audited CLTV Exceeds Guideline CLTV |
4 |
| Audited Reserves are less than Guideline Required Reserves (Number of Months) |
4 |
| Audited HCLTV Exceeds Guideline HCLTV |
4 |
| Audited LTV Exceeds Guideline LTV |
4 |
| Borrower 1 3rd Party VOE Prior to Close Missing |
4 |
| Audited FICO is less than Guideline FICO |
3 |
| Purchase Contract is Incomplete |
2 |
| Missing evidence of self employment |
2 |
| ATR: Reasonable Income or Assets Not Considered |
2 |
| Purchase is not considered to be an Arm's Length Transaction |
2 |
| Guideline Seasoning not Met |
2 |
| Audited DTI Exceeds Guideline DTI |
2 |
| Missing income documentation |
1 |
| Borrower 2 3rd Party VOE Prior to Close Missing |
1 |
| Approval/Underwriting Summary Not Provided |
1 |
| Title Document is Partially Present |
1 |
| Asset 1 Does Not Meet Guideline Requirements |
1 |
| Verification of Rent (VOR)/Verification of Mortgage (VOM) Document is incomplete |
1 |
| Missing VVOE dated within 10 days consummation |
1 |
| Asset Qualification Does Not Meet Guideline Requirements |
1 |
| Borrower 1 Paystubs Missing |
1 |
| Housing History Does Not Meet Guideline Requirements |
1 |
| Audited Loan Amount is greater than Guideline Maximum Loan Amount |
1 |
| Asset General |
1 |
| DSCR is less than guideline minimum |
1 |
| Total Credit Grade (B) Exceptions: |
61 |
| Compliance |
A |
No Compliance Findings |
152 |
| Higher-Priced Mortgage Loan Test |
37 |
| CA AB 260 Higher-Priced Mortgage Loan Test |
5 |
| Initial Closing Disclosure Delivery Date Test |
4 |
| NC Rate Spread Home Loan Test |
3 |
| MD COMAR Higher-Priced Mortgage Loan Test |
3 |
| Missing Required Affiliated Business Disclosure |
2 |
| Charges That Cannot Increase Test |
2 |
| |
|
Revised Loan Estimate Delivery Date Test (prior to consummation) |
2 |
| Lender Credits That Cannot Decrease Test |
2 |
| Revised Closing Disclosure Delivery Date and Changed Circumstances Date Test |
1 |
| TRID: Missing Closing Disclosure |
1 |
| eSigned Documents Consent is Missing |
1 |
| Incorrect rescission model used - RTC form model H-9 used for refinance not with Original Lender or Lender Affiliate |
1 |
| CT Nonprime Home Loan Test |
1 |
| Or. Rev. Stat. Ann. § 746.201 Collateral Protection Notice was not provided (Disclosure Page v2) |
1 |
| Total Compliance Grade (A) Exceptions: |
218 |
| B |
Charges That Cannot Increase Test |
1 |
| TILA Post-Consummation Revised Closing Disclosure Finance Charge Test |
1 |
| Lender Credits That Cannot Decrease Test |
1 |
| Total Compliance Grade (B) Exceptions: |
3 |
| Property |
A |
No Property Findings |
244 |
| FEMA Post Disaster Inspection Report not Provided |
9 |
| Property/Appraisal General |
8 |
| FEMA Declared Disaster Dated Prior to the Note Date, After Appraisal Date |
7 |
| Appraisal incomplete (missing map, layout, pages, etc.) |
3 |
| The appraiser was not licensed (Primary Value) |
2 |
| Third Party Valuation Product Not Provided within 10% Tolerance |
2 |
| Incorrect Appraisal Form For Property Type |
1 |
| Ineligible Property |
1 |
| Total Property Grade (A) Exceptions: |
277 |
| B |
Property/Appraisal General |
2 |
| HOA Questionnaire is Incomplete |
1 |
| Appraisal is Expired |
1 |
| HOA Does Not Meet Guidelines |
1 |
| Total Property Grade (B) Exceptions: |
5 |
Event Grade Definitions
| Final
Loan Grade |
| A |
Loan
meets Credit, Compliance, and Valuation Guidelines |
| B |
The
loan substantially meets published Client/Seller
guidelines and/or eligibility in the validation of income, assets, or credit, is in material
compliance
with all
applicable laws
and regulations,
and the value and valuation methodology is supported and substantially meets published guidelines. |
| C |
The
loan does not meet the
published guidelines and/or violates one material law or regulation, and/or the value
and valuation methodology is not supported or did not meet published guidelines. |
| D |
Loan
is missing documentation to perform a sufficient review. |
| Credit
Event Grades |
| A |
The
loan meets the
published guidelines without any exceptions. The employment,
income, assets and occupancy are supported
and justifiable. The borrower’s
willingness and ability to repay the loan is documented and reasonable. |
| B |
The
loan substantially meets the
published guidelines but reasonable compensating
factors were considered and documented
for exceeding published guidelines. The employment,
income, assets and occupancy are supported and justifiable. The borrower’s
willingness and ability to repay the loan
is documented and reasonable. |
| C |
The
loan does not substantially meet the
published guidelines. There
are not sufficient compensating factors that
justify exceeding the published guidelines. The
employment, income,
assets or occupancy are not supported and justifiable. The borrower’s
willingness and ability to repay the loan
were not documented or are unreasonable. |
| D |
There
was not sufficient documentation to perform a review or the
credit file was not furnished. |
| Compliance Event Grades |
| A |
The loan is in compliance with all applicable laws and regulations. The legal documents accurately reflect the agreed upon loan terms and are executed by all applicable parties. |
| B |
The loan is in material compliance with all applicable laws and regulations. The legal documents accurately reflect the agreed upon loan terms and are executed by all applicable parties. Client review required. |
| C |
The loan violates one material law or regulation. The material disclosures are absent or the legal documents do not accurately reflect the agreed upon loan terms or all required applicants did not execute the documents. |
| D |
There was not sufficient documentation to perform a review or the required legal documents were not furnished. |
| Valuation Event Grades |
| A |
The value is supported within 10% of the original appraisal by the AVM or there are other supporting documents in the originators loan file package (CDA, Field Review or Second Appraisal). The appraisal was performed on an "as-is" basis and the property is complete and habitable at origination. The appraiser was appropriately licensed and used GSE approved forms. |
| B |
The value is not supported within 10% of the original appraisal by the AVM and there are no other valuation support documents in the loan file provided by the Seller. The valuation methodology substantially meets the published guidelines but reasonable compensating factors were considered and documented for exceeding guidelines. The appraisal was performed on an "as-is" basis and the property is complete and habitable. The appraiser was appropriately licensed and used GSE approved forms. |
| C |
The value is not supported within 10% of the original appraisal. The valuation methodology did not meet the published guidelines and there were not sufficient compensating factors for exceeding published guidelines. The property is in below “average” condition or the property is not complete or requires significant repairs. The appraisal was not performed on an “as is” basis. The appraiser was not appropriately licensed or did not use GSE approved forms. |
| D |
The file was missing the appraisal or there was not sufficient valuation documentation to perform a review. |