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◾	“Compliance Review”:	2,428 mortgage loans
◾	“Leases Review”	10 mortgage loans
◾	“Lease Review with Limited Compliance”	3 mortgage loans
◾	“Credit and Compliance Review”	35 mortgage loans
◾	“Valuation Review”	48 mortgage loans
◾	“Modification Review”	1,840 mortgage loans
◾	“Collection Comment Review”:	93 mortgage loans
◾	“Payment History Review”:	381 mortgage loans
◾	“Tax and Title Review”:	2,231 mortgage loans

a)

High Cost testing in Chicago Illinois and Cook County Illinois;

b)

Higher Priced testing in Minnesota;

c)

Other applicable state testing in Maryland, Minnesota, New Jersey, West Virginia, Wyoming, and Vermont, Virginia and

d)

State specific prepayment penalty and late charge testing applicable to non-owner occupied loans.

a)

Rescission (§1026.23):

i)

failure to provide the right of rescission notice;

ii)

failure to provide the right of rescission notice in a timely manner and to the correct consumer(s);

iii)

errors in the right of rescission notice;

iv)

failure to provide the correct form of right of rescission notice;

v)

failure to provide the three (3) business day rescission period; and

vi)

any material disclosure violation on a rescindable loan that gives rise to the right of rescission under TILA, which means the required disclosures of the annual percentage rate, the finance charge, the amount financed, the total of payments, the payment schedule, the HOEPA disclosures;

b)

TIL Disclosure (§§1026.17, 18 and 19) as applicable for loans with application dates prior to October 3, 2015:

i)

review and comparison of the initial and final TIL disclosures, and any re-disclosed TIL(s);

ii)

proper execution by all required parties;

iii)

principal and interest calculations, and proper completion of the interest rate and payment summary; and

iv)

timing of initial and re-disclosed TIL(s);

c)

Tolerances (§§1026.18, 22 and 23):

i)

inaccurate Annual Percentage Rate (APR) outside of applicable tolerance by comparing disclosed APR to re-calculated APR; and

ii)

inaccurate Finance Charge outside of applicable tolerance by comparing disclosed Finance Charge to re-calculated Finance Charge;

d)

High-cost Mortgage (§§1026.31, 32 and 33):

i)

points and fees threshold test;

ii)

APR threshold test;

iii)

prepayment penalty test; and

iv)

compliance with the disclosure requirements, limitation on terms and prohibited acts or practices in connection with a high-cost mortgage;

e)

Higher-priced Mortgage Loan (§1026.35):

i)

APR threshold test; and

ii)

compliance with the escrow account and appraisal requirements;

a)

Good Faith Estimate (GFE) (§1024.7) as applicable for loans with application dates prior to October 3, 2015:

i)

confirm the presence of the current GFE form in effect at the time of origination;

ii)

verify GFE was provided to the borrower(s) within three (3) business days of application;

iii)

verify all sections of the GFE were accurately completed and that information was reflected in the appropriate locations;

iv)

determine whether a valid and properly documented changed circumstance accompanies any changes to loan terms and/or fees on any revised GFEs over the applicable tolerance(s); and

v)

confirm the presence of a settlement service provider list, as applicable.

b)

Final HUD-1/A Settlement Statement (HUD) (§1024.8) as applicable for loans with application dates prior to October 3, 2015:

i)

confirm current applicable HUD form was provided;

ii)

determination that the loan file contains the final HUD;

iii)

escrow deposit on the final HUD matches the initial escrow statement amount; and

iv)

verify all sections of the final HUD were accurately completed and that information was reflected in the appropriate locations.

c)

GFE and Final HUD Comparison (§1024.7) as applicable for loans with application dates prior to October 3, 2015:

i)

review changes disclosed on the last GFE provided to the borrower(s) to determine that such changes were within the allowed tolerances;

ii)

confirm loan terms and fees disclosed on the third page of the final HUD accurately reflect how such items were disclosed on the referenced GFE, page 2 of the final HUD and loan documents; and

iii)

review any documented cure of a tolerance violation to determine that the proper reimbursement was made and a revised HUD was provided at or within 30 days of settlement.

d)

Additional RESPA/Regulation X Disclosures and Requirements (§1024.6, 15, 17, 20, and 33):

i)

confirm the presence of the Servicing Disclosure Statement form in the loan file;

ii)

verify the Servicing Disclosure Statement was provided to the borrower(s) within three (3) business days of application;

iii)

confirm the presence of the Special Information Booklet in the loan file or that the loan file contains documentary evidence that the disclosure was provided to the borrower;

iv)

confirm the Special Information Booklet was provided within three (3) business days of application;

v)

confirm the presence of the Affiliated Business Arrangement Disclosure in the loan file in the event the lender has affiliated business arrangements;

vi)

confirm the Affiliated Business Arrangement Disclosure was provided no later than three (3) business days of application;

vii)

confirm the Affiliated Business Arrangement Disclosure is executed; and

viii)

confirm the presence of the Initial Escrow Disclosure Statement in the loan file and proper timing.

◾

Initial application (1003);

◾

Final application (1003);

◾

Note;

◾

Appraisal;

◾

Sales contract;

◾

Title/Preliminary Title;

◾

Initial TIL;

◾

Final TIL;

◾

Final HUD-1;

◾

Initial and final GFE’s;

◾

Right of Rescission Disclosure;

◾

Mortgage/Deed of Trust;

◾

Mortgage Insurance;

◾

Tangible Net Benefit Disclosure;

◾

FACTA disclosures; and

◾

Certain other disclosures related to the enumerated tests set forth herein.

a)

With respect to brokered loans, the Prohibitions and Restrictions related to Loan Originator Compensation and Steering (§1026.36):

i)

review relevant documentation to determine if compensation to a Loan Originator was based on a term of the transaction;

ii)

review relevant document to determine if there was dual compensation; and

iii)

review the presence of the loan option disclosure and to determine if the Steering Safe Harbor provisions were satisfied.

(1)

Note: Where available, AMC reviewed the relevant documents in the loan file and, as necessary, attempted to obtain the loan originator compensation agreement and/or governing policies and procedures of the loan originator. In the absence of the loan originator compensation agreement and/or governing policies and procedures, AMC’s review was limited to formal general statements of entity compliance provided by the loan originator, if any. These statements, for example, were in the form of

a letter signed by the seller correspondent/loan originator or representations in the mortgage loan purchase agreement between the Client and seller correspondent;

b)

Homeownership counseling (§1026.36):

i)

determine if the creditor obtained proof of homeownership counseling in connection with a loan to a first time homebuyer that contains a negative amortization feature;

c)

Mandatory Arbitration Clauses (§1026.36):

i)

determine if the terms of the loan require arbitration or any other non-judicial procedure to resolve any controversy or settle any claims arising out of the transaction;

d)

Prohibition on Financing Credit Insurance (§1026.36):

i)

determine if the creditor financed, directly or indirectly, any premiums or fees for credit insurance; and

e)

Nationwide Mortgage Licensing System (NMLS) & Registry ID on Loan Documents (§1026.36):

i)

review for presence of loan originator organization and individual loan originator name and NMLSR ID, as applicable, on the credit application, note or loan contract, security instrument, Loan Estimate and Closing Disclosure; and

ii)

verify the data against the NMLSR database, as available.

a)

Additional RESPA/Regulation X Disclosures and Requirements (§1024.6, 15, 17, 20, and 33):

i)

confirm that the creditor provided the borrower a list of homeownership counseling organizations within three (3) business days of application; and

ii)

confirm that the list of homeownership counseling organizations was obtained no earlier than 30 days prior to when the list was provided to the loan applicant.

a)

The general Ability to Repay (ATR) underwriting standards (12 C.F.R. 1026.43(c));

b)

Refinancing of non-standard mortgages (12 C.F.R. 1026.43(d));

c)

Qualified Mortgages (QM) (12 C.F.R. 1026.43(e) (including qualified mortgages as separately defined by the Department of Housing and Urban Development (24 C.F.R. 201 and 203 et seq.), and the Department of Veterans Affairs (38 C.F.R. Part 36 et seq.); and

d)

Balloon-payment qualified mortgages made by certain creditors (12 C.F.R. 1026.43(f)).

a)

Providing Appraisals and Other Valuations (12 C.F.R. 1002.14):

i)

timing and content of the right to receive copy of appraisal disclosure;

ii)

charging of a fee for a copy of the appraisal or other written valuation;

iii)

timing of creditor providing a copy of each appraisal or other written valuation;

iv)

with respect to a borrower that has waived the three (3) business day disclosure requirement, confirm that the borrower has signed the waiver or other acknowledgment at least three (3) business days prior to consummation; and (2) confirm that the lender has provided copies of appraisals and other written valuations at or prior to consummation.

a)

Loan Estimate (LE) (§§1026.19 and 37):

i)

confirm the presence of LE for applications on or after October 3, 2015;

ii)

confirm the initial LE date indicates it was delivered or placed in the mail within three (3) business days of application;

iii)

confirm that certain sections of each LE determined to carry assignee liability were accurately completed and that information was reflected in the appropriate locations, which, in certain instances, was based solely on the information disclosed on the LE;

iv)

confirm the initial LE was delivered or placed in the mail not later than seven (7) business days prior to consummation of the transaction, or such period was waived due to a bona fide financial emergency;

v)

confirm that any written estimate of terms or costs provided prior to receipt of a LE contained the required disclosures;

vi)

confirm that each revised LE is accompanied by valid written documentation explaining the reason for re-disclosure to allow for fee increases based on a valid change of circumstance and was timely provided within 3 business days of issuance;

vii)

confirm the presence and timely provision of a settlement service provider list (when consumer is given the opportunity to shop for services);

viii)

confirm borrower received LE not later than four (4) business days prior to consummation; and

ix)

confirm LE was not provided to the borrower on or after the date of the CD.

b)

Closing Disclosure (CD) (§§1026.19 and 38):

i)

confirm the presence of CD for applications on or after October 3, 2015;

ii)

confirm the borrower received CD at least three (3) business days prior to consummation, or that such period was waived due to a bona fide financial emergency;

iii)

confirm that certain sections of each CD determined to carry assignee liability were accurately completed and that information was reflected in the appropriate locations, which, in certain instances, was based solely on the information disclosed on the CD;

iv)

confirm that a revised CD was received in a timely manner if the initial or any revised CD became inaccurate;

v)

identify tolerance violations based on the charges disclosed on the initial and interim LE’s, initial CD, and reflected on the final CD;

vi)

with respect to tolerance violations based on the disclosed charges on the LE and CD, confirm that the creditor cured the violations no later than 60 days after consummation, or within 60 days of discovery; and

vii)

with respect to applicable exception remediation measures for numerical exceptions, confirm that a letter of explanation, as well as a refund as applicable, was delivered or placed in the mail no later than 60 days after discovery of the exception establishing the need for a revised CD or with respect to exception remediation measures for non-numerical exceptions, that a corrected CD was delivered or placed in the mail no later than 60 days after consummation. (In an attempt to establish a best practices approach to pre-securitization due diligence, as it applies to TILA RESPA Integrated Disclosure testing, the Structured Finance Industry Group (“SFIG”) has a working group that consists of industry participants including third party review providers and law firms who agreed to a standardized approach to remediation considerations. This approach is intended to be based on a reasoned legal analysis that expressly assumes that courts will interpret TRID in accordance with the principals of liability set forth in the letter to the MBA from Richard Cordray, the Director of the CFPB. No assurances can be provided that the courts in question will interpret TRID in accordance with the SFIG Compliance Review Scope.)

c)

Your Home Loan Toolkit (§1026.19):

i)

confirm the presence of Your Home Loan Toolkit in the mortgage loan file or that the mortgage loan file contains documentary evidence that the disclosure was provided to the borrower; and

ii)

confirm Your Home Loan Toolkit was delivered or placed in the mail not later than three (3) business days after receipt of application.

◾

Loan Estimates;

◾

Closing Disclosures; and

◾

Certain other disclosures related to the enumerated tests set forth herein.

Moody NRSRO Grade	Loan Count	% of Loans
A	166	6.84%
B	1,750	72.08%
C	62	2.55%
D	285	11.74%
N/A	165	6.80%
Total	2,428	100.00%

Moody NRSRO Grade	Loan Count	% of Loans
A	163	6.80%
B	1,723	71.91%
C	62	2.59%
D	283	11.81%
N/A	165	6.89%
Total	2,396	100.00%

Moody NRSRO Grade	Loan Count	% of Loans
A	3	9.38%
B	27	84.38%
C	0	0.00%
D	2	6.25%
Grand Total	32	100.00%

Credit: Moody NRSRO Grade	Loan Count	% of Loans
A	21	43.75%

B	2	4.17%
C	16	33.33%
D	2	4.17%
N/A	7	14.58%
Total	48	100.00%

Property: Moody NRSRO Grade	Loan Count	% of Loans
A	30	62.50%
B	0	0.00%
C	2	4.17%
D	9	18.75%
N/A	7	14.58%
Total	48	100.00%

Compliance: Moody NRSRO Grade	Loan Count	% of Loans
A	10	20.83%
B	10	20.83%
C	11	22.92%
D	0	0.00%
N/A	17	35.42%
Total	48	100.00%

Exception Type	Moodys Final Exception Rating	Exception Category	Total
Compliance	D	Missing, Incorrect, or Incomplete HUD-1	294
		Incomplete File	20
		Missing, Incorrect, or Incomplete Note	3
		Compliance	1
		Total Compliance Grade (D) Exceptions:	318
	C	ATR/QM Defect	132
		State Defect	67
		State HPML	22
		FHA MIP	10
		Missing Required Data (other than HUD-1 or Note)	7
		Missing, Incorrect, or Incomplete HUD-1	3
		Compliance	1
		Total Compliance Grade (C) Exceptions:	242
	B	Missing Application Date	1,346
		TILA	1,289
		Missing Non-Required Data	1,152
		TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form	805
		RESPA	775
		Missing, Incorrect, or Incomplete GFE	436
		LTV Test	353
		FACTA	352
		Missing Required Data	291
		Missing, Incorrect, or Incomplete Final TIL	278
		State Defect	275
		TRID Defect	194
		Misc. State Level	166
		Loan Package Documentation	149
		Missing Required Data (other than HUD-1 or Note)	82
		State Late Charge	68
		Final TIL Estimated	44
		Compliance	37
		Federal HPML	29
		FHA	29
		ATR/QM Defect	21
		ECOA	18
		GSE	14
		Missing, Incorrect, or Incomplete Final or Initial 1003	14
		TIL-MDIA	13
		Missing, Incorrect, or Incomplete Initial TIL	12
		Missing, Incorrect, or Incomplete Note	7
		Safe Act	7

		State HPML	6
		Cross Collateralized	4
		TRID	4
		Missing Document	2
		1003	1
		Legal / Regulatory / Compliance	1
		Missing Disclosure	1
		Other TILA Violations	1
		TIL	1
		Total Compliance Grade (B) Exceptions:	8,277
Total Compliance Exceptions:			8,837
Grand Total:			8,837

Exception Type	Moody Final Exception Rating	Exception Category	Total
Compliance	D	Missing, Incorrect, or Incomplete HUD-1	2
		Total Compliance Grade (D) Exceptions:	2
	B	Misc. State Level	65
		Missing, Incorrect, or Incomplete Initial TIL	14
		RESPA	10
		Missing Disclosure	10
		Missing, Incorrect, or Incomplete GFE	8
		FACTA	5
		Missing, Incorrect, or Incomplete Final TIL	1
		Total Compliance Grade (B) Exceptions:	113
Total Compliance Exceptions:			115
Grand Total:			115

Exception Type	Moodys Final Exception Rating	Exception Category	Total
Compliance	D	Incomplete File	3
		Total Compliance Grade (D) Exceptions:	3
	C	ATR/QM Defect	52
		Total Compliance Grade (C) Exceptions:	52
	B	TRID Defect	21
		ECOA	10
		ATR/QM Defect	5
		FACTA	2
		RESPA	2
		TILA	1

		Federal HPML	1
		Missing, Incorrect, or Incomplete Final or Initial 1003	1
		Total Compliance Grade (B) Exceptions:	43
Total Compliance Exceptions:			98
Credit	D	Loan Package Documentation	1
		Incomplete File	1
		Total Credit Grade (D) Exceptions:	2
	C	Loan Package Documentation	15
		Disclosure	6
		Missing Document	6
		Income / Employment	5
		Guideline	4
		Hazard Insurance	3
		Document Error	3
		Borrower and Mortgage Eligibility	3
		Asset	3
		Flood	1
		Total Credit Grade (C) Exceptions:	49
	B	Loan Package Documentation	4
		Guideline	2
		Document Error	1
		Total Credit Grade (B) Exceptions:	7
Total Credit Exceptions:			58
Property	D	Property - Appraisal	9
		Total Property Grade (D) Exceptions:	9
	C	Property - Appraisal	3
		Total Property Grade (C) Exceptions:	3
Total Property Exceptions:			12
Grand Total:			168

Servicing Review Grade	Loan Count	% of Loans
1	50	53.76%
2	25	26.88%
3	18	19.35%
Total	93	100.00%

Category	# of Mortgage Loans	% of Mortgage Loans
No Delinquency, No Missing Data	59	15.49%
Delinquency, No Missing Data	313	82.15%
No Delinquency, At Least One Month Missing	0	0.00%
Delinquency, At Least One Month Missing	9	2.36%
Total	381	100.00%
Lookback	Loan Count	% of Loans
Twenty-Four (24) Months	381	100.00%
Total	381	100.00%

•

Except with respect to 12 mortgage loan files, there are no potential issues concerning origination deed vesting.  With respect to the 12 mortgage loan files, all 12 mortgage loan files contain a Title Policy on which there are no stated exceptions which explicitly preclude coverage.

•

Except with respect to 1 mortgage loan file, there are no potential issues concerning the recordation of the subject mortgage.  With respect to the 1 mortgage loan file, evidence of the release/satisfaction of the security instrument is present in the mortgage loan file.

•

Except with respect to 109 Association Liens across 52 mortgage loan files, no unresolved Super Position HOA Liens recorded after the subject mortgage which were entitled to limited or full lien priority over the subject mortgage were identified.  74 of these Association Liens were determined to be past the statutory timeline for enforcement.

•

Except with respect to 509 Municipal Liens across 164 mortgage loan files, no unresolved Municipal Liens which had limited or full lien priority over the subject mortgage were located.

•

Except with respect to 35 Property Tax Lien across 21 mortgage loan files, no unresolved Property Tax Liens which had limited or full lien priority over the subject mortgage were located.

•

Except with respect to 95 Prior Liens across 47 mortgage loan files which were recorded prior to the subject mortgage, all Prior Liens identified in our review have been resolved. With respect to the 95 Prior Liens across 47 mortgage loan files, 92 Prior Liens were determined to be mitigated as the mortgage loan files contain a Title Policy on which there are no stated exceptions which explicitly preclude coverage, 1 Prior Lien was determined to be mitigated as the statutory timeline for enforceability has passed, and 2 Prior Liens could not be mitigated as the mortgage file contained insufficient title evidence to mitigate the issues.

•

Except with respect to 133 Prior Mortgages across 116 mortgage loan files which were recorded prior to the subject mortgage, all Prior Mortgages identified in our review have been resolved. With respect to the 133 Prior Mortgages across 116 mortgage loan files, 110 Prior Mortgages were determined to be mitigated as the mortgage loan files contain a Title Policy on which there are no stated exceptions which explicitly preclude coverage, 6 Prior Mortgages were determined to be mitigated as the statutory timeline for enforceability has passed, and 17 Prior Mortgages could not be mitigated as the mortgage file contained insufficient title evidence to mitigate the issues.

•

As to any Miscellaneous Items of substance, the items in this category typically defy standard categorization or summarization and are individually detailed.

Amortization Type	Loan Count	% of Loans
Fixed	1,787	73.12%
Adjustable	639	26.15%
Unknown	18	0.74%
Total	2,444	100.00%

Lien Position	Loan Count	% of Loans
1	2,253	92.18%
2	172	7.04%
Unknown	19	0.78%
Total	2,444	100.00%
Loan Purpose	Loan Count	% of Loans
Cash Out: Debt Consolidation	667	27.29%
Cash Out: Home Improvement/Renovation	5	0.20%
Cash Out: Other/Multi-purpose/Unknown Purpose	475	19.44%
Limited Cash-Out	18	0.74%
First Time Home Purchase	414	16.94%
Other-than-first-time Home Purchase	368	15.06%
Rate/Term Refinance - Lender Initiated	1	0.04%
Rate/Term Refinance - Borrower Initiated	295	12.07%
Construction to Permanent	12	0.49%
Unavailable	189	7.73%
Total	2,444	100.00%
Original Term	Loan Count	% of Loans
0-120 Months	13	0.53%
121-180 Months	113	4.62%
181-240 Months	162	6.63%
241-360 Months	2,071	84.74%
361+ Months	66	2.70%
Unknown	19	0.78%
Total	2,444	100.00%
Property Type	Loan Count	% of Loans
Single Family Detached	1,528	62.52%
Co-op	2	0.08%
Condo, Low Rise	70	2.86%
Condo, High Rise	10	0.41%
PUD	195	7.98%
Townhouse	6	0.25%
Single-wide Manufactured Housing	79	3.23%
1 Family Attached	46	1.88%
2 Family	49	2.00%
3 Family	11	0.45%
4 Family	5	0.20%
Land	2	0.08%
Other	3	0.12%
Unavailable	438	17.92%
Total	2,444	100.00%
Occupancy	Loan Count	% of Loans
Primary	2,123	86.87%

Investment	73	2.99%
Second Home	29	1.19%
Unknown	219	8.96%
Total	2,444	100.00%

Amortization Type	Loan Count	% of Loans
Fixed	7	21.88%
Adjustable	25	78.13%
Total	32	100.00%
Lien Position	Loan Count	% of Loans
1	32	100.00%
Total	32	100.00%
Loan Purpose	Loan Count	% of Loans
Cash Out: Other/Multi-purpose/Unknown Purpose	21	65.63%
Other-than-first-time Home Purchase	10	31.25%
Rate/Term Refinance - Borrower Initiated	1	3.13%
Total	32	100.00%
Original Term	Loan Count	% of Loans
Unknown	32	100.00%
Total	32	100.00%
Property Type	Loan Count	% of Loans
Unavailable	32	100.00%
Total	32	100.00%
Occupancy	Loan Count	% of Loans
Primary	32	100.00%
Total	32	100.00%