Atlas A&D Opportunity Fund III LP ABS-15G
Exhibit
99.6

ADMT
2026-NQM5
Due
Diligence Review
Narrative
Summary
June
15, 2026
Prepared
by
Mission
Global, LLC
For
A&D
Mortgage LLC
This
report summarizes the results of a due diligence review performed on a pool of eight hundred fifty-four (854) loans provided by
A&D Mortgage LLC (“A&D” collectively the "Client”). Client provided Mission Global, LLC ("Mission")
with a data tape, from which 100% of the loan sample was selected. The loan data was entered into and analyzed using the Mission
Global Grade® Underwriting and Diligence grading solution. Mission performed a detailed credit re-underwrite
and regulatory compliance review of 100% loans.
Mission
Global is a technology-forward service provider built on a culture of deep client service. Mission is a rating agency approved
Third Party Review firm delivering underwriting and compliance audits for residential and business purpose loans. Since 1994,
Mission Global and its predecessor company, Global Financial Review have provided comprehensive loan due diligence, re-underwriting,
and asset management services to clients in the financial services industry. In 2015, Global Financial Review merged with the
leading Secondary market consulting firm Mission Capital Advisors, LLC to form Mission Global, LLC. In 2020, Mission Capital Advisors,
LLC and Mission Global, LLC were acquired by the leading real estate sales, financing and advisory service firm and now a wholly-owned
subsidiary of Marcus & Millichap (NYSE:MMI).
Mission
performed a full credit re-underwrite, regulatory compliance, valuation and data integrity review to meet the criteria as published
by the Nationally Recognized Statistical Rating Organizations. This deal is to be rated in accordance with the published guidelines
of Fitch Rating, Inc. (Fitch) and Kroll Bond Rating Agency, LLC (KBRA). Mission performed the reviews
over a period of time ranging from January 1, 2024 to June 5, 2026.
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 1 |
The
pool is a mix of Qualified Mortgages (QM) and Non-Qualified Mortgage (NQM) residential and investment mortgage loans secured in
either a first or second lien position. In the pool reviewed, one hundred eighty-two (182) of the loans are considered QM qualified
residential loans. The remaining loans include two hundred four (204) loans that are considered Non-QM qualified, non-conventional
or commonly referred to as non-agency residential mortgage loans, and four hundred sixty-eight (468) are business purpose investment
loans which are ATR/QM exempt.
The
loan pool is all secured by single family residential, or one-to-four and five-to-ten multi-family condominiums, condotel, manufactured
housing, PUD, and mixed-use property as collateral. There are eight hundred eight (808) loans secured in a first lien position
and forty-six (46) loans secured in a second lien position.
| 1. | File
RE-Underwrite Credit Review |
A
full re-underwriting credit review was conducted to verify that the requisite underwriting guidelines as specified by Client were
met. Confirmation of the loan terms was conducted through recalculation and review of documentation contained in the loan files
and documents provided to Mission.
The
Credit Qualification review will consist of the following:
| 1.2 | Guidelines
and Overlays |
For
all loans underwritten to A&D Guidelines, there are two unique set of guidelines, those specific to first lien and a separate
set applicable to second liens. Mission reviewed each mortgage loan to ensure it met the requisite guideline requirements as specified
by the Client guidelines. In lieu of specific requirements, Mission also considered Regulation Z requirements including Appendix
Q or Consider and Verify rules where applicable.
In
addition to the guidelines there were seven unique overlays for each type of loan program reviewed:
|  | A&D
Prime Rate - Primary & Investment |
|  | A&D
Super Prime Rate - Primary & Investment |
|  | A&D
Prime Jumbo Full Doc Rate - Primary & Investment |
|  | DSCR
Rate - Investment Only |
|  | Foreign
National Rate - Investment Only |
|  | 2nd
Lien – Closed End A |
|  | DSCR
Rate – 2nd Lien |
These
combined guidelines and their overlays provided additional specific qualification requirements and program specific metric such
as min and max loan amounts, cash out refinance limits, ranges of values for acceptance, geographic eligibility, escrow requirements,
note, rate and term specific details, qualifying property types, residency requirements, limits on seller and third-party contributions,
valuation and title requirements The guidelines and overlays also specified borrower requirements such as credit tradeline and
credit event requirements, income and asset qualifications, and citizenship requirements.
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 2 |
The
loans were all qualified using various methods; forty-nine (49) were full document loans and one hundred forty (140) used employment
income with W2/paystub or WVOE verification of employment or 1099 verification. One hundred thirty-three (133) were qualified
using 12 or 24 month bank statements. The remainder of the loans were income qualified in a variety of ways including verified
Profit and Loss statement, retirement income, asset depletion imputed income. In the case of investment purpose loans, four hundred
forty (440) used DSCR where rental property income and debt service coverage ratio was both estimated or stated, and/or verified
through leases and rent rolls. Mission verified the file documentation for minimum required level of employment and income verifications
in accordance with Client provided underwriting guidelines.
Mission
recalculates borrower(s) monthly gross income and verified calculations of income as used by the original loan underwriter at
origination to determine compliance with the Client provided underwriting guidelines. The Underwriter used the lower of income
stated on 1003 Application or stated/verified income. In all cases, Mission verified stated/verified income in accordance with
Client provided underwriting guidelines.
Mission
confirmed the presence of adequate asset documentation to comply with the Client provided underwriting guideline requirements
for closing funds, reserves and borrower liquidity. Mission verified the file documentation for minimum required level of asset
verification in accordance with Client provided underwriting guidelines.
On
all primary or secondary residential loans, Mission recalculated and verified the debt-to-income ratio used by the loan underwriter
at origination to determine compliance with Client provided underwriting guidelines and requirements. On investment loans if full
property debt and income was available Mission calculated a property income-based DTI verification.
| 1.6 | Debt
Service Coverage Ratio |
On
all investment related loans that were qualified under the DSCR Rate program, Mission recalculated and verified the Debt Service
Coverage Ratio used by the loan underwriter at origination to determine compliance with Client provided underwriting guidelines
and requirements. Rental income used in the calculation for each loan was either verified from an in-place lease and verification
of payment or based upon projected market rents taken
from the 1007 in the subject property appraisal.
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 3 |
Mission
analyzed all appraisals and alternative value tools used to qualify the loan for integrity of comparable sales, completeness of
data, eligibility of the appraiser and reasonableness of estimated value. Mission verified the valuation waterfall in each case
to determine if based upon UCDP CU credit scores whether a Desk review or a second appraisal was required and to verify all valuation
documentation met the requirements of Client provided underwriting guidelines. Where loans are seasoned beyond 24 months since
origination an updated valuation is used to determine value is supported.
In
all cases where the collateral is residential based, the primary values were supported by secondary valuation tools including
either an AVM, BPO, 2nd Appraisal, Appraisal Desk Review or a secondary Drive-By appraisal.
Mission
recalculated and verified the loan-to-value ratio and combined loan-to-value ratio were accurate at origination and met Client
provided underwriting guideline and regulatory requirements.
Mission
reviewed the initial credit reports used at origination and captured updated gap report values to verify that the borrower(s)
demonstrate adequate credit depth to comply with the Client provided underwriting guideline requirements.
1.10
Credit Scores
Mission
captured FICO scores from credit reports used at origination and any updated gap report values to validate that borrower(s) met
minimum credit score requirements of the Client provided underwriting guidelines.
1.11
Compensating Factors
Mission
reviewed all provided guideline exceptions and verified exceptions to the Client provided underwriting guidelines were documented
and that compensating factors were reasonable.
1.12
First-time Homebuyers
A&D
guidelines do vary slightly in definition versus ASF definition. A&D considers all type of real estate owned by a borrower
in its consideration for first-time homebuyers’ designation including investment property, whereas ASF definition calls
for a borrower to be considered first-time homebuyer only when they have never owned residential property only. Mission does
not consider this a significant difference and follows A&D guidelines when reporting first-time homebuyer status.
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 4 |
Mission’s
review each loan file confirmed the presence of material documentation as applicable to the specifics of the loan transaction.
| 2.1 | Title
Commitment and Policy |
Mission
verified the presence of at a minimum the initial title commitment or final title policy. Mission confirmed the vested parties
and the description of the property, liens and tax assessments. Given the recent origination of many of the loans contained only
an initial title commitment. Comments on loans where the final title policy was still pending were noted in the resolution of
each loan in the grading findings.
| 2.2 | Mortgage
Note & Security Instrument |
Verify
the presence of the mortgage note or security instrument. Confirm that the document has been executed by all borrowers and that
all riders, addendums and endorsement were present and duly executed. Mission confirmed that Mortgage note was either fixed or
adjustable according to requirements of the Client provided underwriting guidelines and captured relevant Note data specific to
each loan.
| 2.3 | Mortgage
& Deed of Trust |
Mission
verified the presence of a copy Mortgage or Deed of Trust and confirmed that the documents were executed by all required parties
and that all riders, addendums and exhibits as required exist in the loan file. Mission also verified that the Mortgage was recorded
or sent for recording. Given the recent origination of many of the loans contained only an executed Mortgage not a recorded document.
Comments on loans where recorded Mortgage was still pending were noted in the resolution of each loan in the grading findings.
Mission
verified the presence of income and employment related documentation as required by the Client provided underwriting guidelines
for all borrowing parties contributing income to the debt ratio calculation.
Mission
verified the presence of asset documentation required by the Client provided underwriting guidelines in the loan file.
Mission
verified the presence of insurance policies and certificates for mortgage, hazard and flood insurance on each loan depending upon
the specifics of the loan. Mission confirmed that adequate coverage is present to meet the requirements of the Client provided
underwriting guidelines.
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 5 |
For
each primary or secondary home mortgage loan file Mission conducted a post-closing regulatory compliance review to verify that
each loan was originated in compliance with the applicable federal, state and local anti-predatory lending statutes in effect
at the time of origination of the Mortgage Loan. Mission further validated that the loans met the applicable disclosure requirements
provided under (i) the federal Truth in Lending Act (“TILA”), as implemented by Regulation Z, 12 C.F.R. Part 1026;
(ii) Section 4 of the Real Estate Settlement Procedures Act (“RESPA”), as implemented by Regulation X, 24 C.F.R. Part
3500; (iii) the National Flood Insurance Act, (iv) the disclosure requirements and prohibitions of Section 50(a)(6), Article XVI
of the Texas Constitution and associated regulations; and (v) the disclosure requirements and prohibitions of the applicable state,
county and municipal laws and ordinances enacted to combat predatory lending, as was applicable depending upon the specifics of
the loan.
| 2.1 | Federal
Truth in Lending Act/Regulation Z |
A
review of the material compliance disclosures set forth in Reg Z, as amended, including the Truth in Lending Disclosure and the
Notice of Right-to-Cancel, if applicable; and a review and comparison of the material disclosures with a report outlining any
TILA violations. This includes a re-calculation of disclosed finance charge [§1026.18(d)], proper execution by all required
parties [§1026.17(b)], principal and interest calculations [§1026.18(s)], payment stream(s), recalculation of disclosed
APR [§1026.22], and a review to ensure disclosure differences are within the allowed tolerances [§1026.18(d) and §1026.23(g)].
A review of the Notice of Right to Cancel (§1026.15 I §1026.23): Review includes a verification of the transaction
date and expiration date, ensures proper execution of the Notice of Right to Cancel by all required parties verifies the disbursement
date and determines if a full 3 day rescission period was adequately provided to the borrower(s).
| 3.2 | Business
Days as Defined by Regulation Z |
General
business day is defined as the days on which a creditor’s offices are open to the public for carrying on substantially all
of its business functions excluding Sundays and holidays specified by §1026.2(a)(6). Specific business day is defined as
all calendar days (Monday through Saturday) excluding Sundays and holidays specified by 5 U.S.C. 6103(a)
| 3.3 | Home
Ownership Equity Protection Act (HOEPA) testing, to include: |
| 3.3.1 | APR
test [HOEPA (§1026.32(a)(l))] and [HPML(§1026.35(a)(l))] |
| 3.3.2 | Points
and Fees test [HOEPA (§1026.32(a)(2))] |
Review
of HOEPA disclosure (§1026.32(c)) for accuracy (i.e. payment stream, highest payment scenario; dates disclosed, dates acknowledged)
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 6 |
| 3.3.3 | Review
and confirm documentation type (i.e. full, stated, no ratio) |
| 3.3.4 | Review
for evidence of prepayment penalty |
| 3.3.5 | Verification
of Debt-to-Income conformity, when necessary. |
HOEPA
(Section 32) loan coverage has been expanded to include purchase-money mortgages and open-end credit plans (i.e., home equity
lines of credit or HELOCS), as well as the amendment of rate and points and fees threshold testing. Mission system requirements
have been updated to address the expansion of coverage as well as amendments to threshold testing. In addition, there is a homeownership
counseling requirement that was verified for all covered loans.
Each
investment purpose loan was reviewed by Mission to ensure compliance with the most current amendments to Regulation X. The RESPA/Regulation
X review consisted of the following:
| 4.1 | Good
Faith Estimate (GFE) |
Mission
confirmed compliance with current RESPA requirements in effect at origination of the Mortgage Loan including confirming the presence
of the current GFE form in effect at the time of origination and verification the GFE was provided to the borrower(s) within three
days of “Application”.
Application
was defined by Regulation X and generally considered complete when the creditor collected information regarding the following:
| | ▪ | Borrower(s)
First and Last Name |
| ▪ | Borrower(s)
Social Security Number (to enable the loan originator to obtain a credit report) |
| ▪ | Subject
Property Address |
| ▪ | Mortgage
Loan Amount Sought |
| ▪ | Estimation
of Property Value |
| 4.3 | Broker
Fees and Yield Spread |
Mission
verified that all Broker fees, including Yield Spread Premium (“YSP”) were accurately disclosed and reflected in the
appropriate locations.
Fees
were reviewed to ensure they are reasonable and customary fees for the lender and title and escrow companies and that those fees
were accurately disclosed on the GFE and were reflected in the proper location on the document.
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 7 |
| 4.5 | Change
of Circumstance (COC) |
Mission
reviewed all available documentation to determine whether a Change of Circumstance (COC) form was required to accompany each revised
Good Faith Estimate (GFE).
| 4.6 | Change
of Circumstance Definition: |
| 4.2.1 | Acts
of God, war, disaster or other emergencies; |
| 4.2.2 | Information
in particular to borrower or transaction that was relied on in providing the GFE and
that changes or is found to be inaccurate after GFE has been provided to borrower; |
| 4.2.3 | New
information particular to the borrower or transaction that was not relied on in providing
the GFE; or |
| 4.2.4 | Other
circumstances that are particular to borrower or transaction, including boundary disputes,
need for flood insurance or environmental problems |
| 4.2.5 | In
the event any of the above occurs, the loan originator is required to provide a new revised
GFE to the borrower within three business days of receiving information sufficient to
establish “changed circumstances” and document the reason the revised GFE
was provided. |
| 4.2.6 | Rate
Locks: If the rate has not been locked by the borrower or a locked rate has expired,
the charge or credit for rate chosen, adjusted origination charges, per diem interest
and loan terms related to the rate may change. If borrower later locks the rate, a new
GFE must be provided showing the revised rate-dependent charges and terms. All other
charges and terms must remain the same as on the original GFE, except as otherwise provided
above for “changed circumstances.” |
Mission
confirmed compliance with current RESPA requirements in effect at origination of the Mortgage Loan including the presence of the
current applicable Final HUD-1 form and that the Final HUD-1 accurately lists all broker and YSP fees.
| 4.8 | Good
Faith Estimate (GFE) and Final HUD-1 Analysis |
Mission
confirmed compliance with current RESPA requirements in effect at origination of the Mortgage Loan.
This
analysis included the following:
| 4.2.7 | Analysis
of Origination fees disclosed on the Good Faith Estimate (GFE) and those charged to the
borrower(s) on the Final HUD-1 (no variance) - No variance for the following charges: |
| ▪ | Credit
or Charge for Interest Rate Chosen |
| ▪ | Adjusted
Origination Charge |
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 8 |
| 4.2.8 | Analysis
of Third-Party fees disclosed on the Good Faith Estimate (GFE) and those charged to the
borrower(s) on the Final HUD-1 (10% tolerance) - 10% tolerance between GFE and actual
charges at settlement for sum of following services: |
| ▪ | Lender-required
settlement services (lender selects third-party provider); |
| ▪ | Lender-required
services, title services and required title insurance, and owner’s title insurance,
when the borrower uses a settlement service provider identified by the loan originator;
and |
| ▪ | Government
recording charges. Analysis to confirm all fees are accurately reflected in the correct
tolerance category on the Good Faith Estimate (GFE) and Final HUD-1. |
| 4.2.9 | Analysis
to confirm lender accurately provided borrower adequate restitution in the event of tolerance
violations and timelines for restitution/document correction were adhered to. |
| 4.2.10 | Analysis
to confirm loan terms are accurately disclosed between the Good Faith Estimate(GFE) and
Final HUD-1. |
| 4.2.11 | Analysis
to confirm page 3 of the HUD-1 accurately reflects fees disclosed on the Good Faith Estimate
(GFE) and Final HUD-1. |
| 5. | QM/ATR
(Qualified Mortgage and Ability to Repay) Dodd Frank Review (Loans with Application Date
on or after 01/10/2014) |
All
one hundred eighty-two (182) of the QM loans, as well as all two hundred four (204) of the loans underwritten as Non-QM were subject
to ATR testing. The remainder of the loans reviewed in this pool were all business purpose and therefore exempt from testing.
Where ATR testing is applicable, Mission did verify that underwriter considered and verified ATR's eight verification steps for
any origination. Mission verified documentation sufficient to run ATR checks on all applicable loans to meet ATR requirements.
| ▪ | Current
employment status |
| ▪ | Monthly
qualifying mortgage payment for the proposed loan |
| ▪ | Monthly
qualifying mortgage payment for the simultaneous loan on the same property payments for
taxes, insurance and HOA, and other housing expenses |
| ▪ | Debts,
alimony and child support |
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 9 |
Mission
did confirm that the underwriting met all Regulation Z Appendix Q, or in the case of loans originated after the new rules in effect
as of July 1, 2021, all Consider and Verify requirements under the revised rule. All the verifications were made and each of the
eight topic areas were confirmed to agree with the representations made by the lender, and there were no material credit exceptions
to the lender’s guidelines that would negate the Consider and Verify rules, the loan passed the ATR test. If any of the
conditions fail or the loan lacked sufficient documentation to support the stated values in any of the areas, affected items will
not be considered verified and the loan was failed for the ATR test. In all cases the loans reviewed by Mission in this pool were
reported as ATR-Pass or ATR-Exempt.
One
hundred eighty-two (182) loans were qualified as QM: Safe Harbor or QM: Average Prime Offer Rate (APOR) Safe Harbor, QM: Rebuttable
Presumption (APOR) or QM: Safe Harbor Verified (VSH) and were subject to both Qualified Mortgage testing and ATR testing depending
upon the rules in effect at the time of origination.
The
remainder of the loans reviewed in this pool were all non-QM loans at origination or business purpose exempt and therefore not
tested as Qualified Mortgages.
For
QM qualified loans the following was verified as well:
| 5.3.1 | Mission
verified the were no Negative Amortization and no interest only payments |
| 5.3.2 | Mission
verified there were no QM loan terms that exceeded 30 years |
| 5.3.3 | Mission
verified these were non-QM loans and therefore exempt from QM Points and Fees or APOR
pricing testing. |
The
QM loans in the pool were qualified under the new QM: Average Prime Offer Rate (APOR) rules which do not consider DTI. The debt-to-income
threshold of 43.00% applies only to any QM loan subject to Regulation Z appendix Q and originated prior to the new rules. However
where applicable, Mission did re-calculate DTI and verify compliance with the Client provided underwriting guideline requirements.
Mission verified amounts included in the QM debt-to-income test, verified income and assets, loan and simultaneous loan payments,
insurance, taxes and HOA, alimony, child support and open debts. For loans qualified under the New rules in effect July 1, 2021
Mission did verify APOR pricing thresholds were not exceeded
Mission
verified any applicable HMPL requirements for the QM loans and verified these requirements met the rules for HPML loans.
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 10 |
| 5.6 | Escrow
Requirement – High Price Mortgage Loans (HPML) |
Mission
verified the required escrow accounts to be in place for the first five years of the transaction for all HPML loans in the pool.
| 6. | TILA/RESPA
Integrated Disclosures |
Mission
used following criteria was used in determining whether TRID applies:
The
Application Date is October 3, 2015, or later (the earlier of the date the broker or lender received the borrower’s application).
| 6.3 | Purpose
and Property Type |
For
those loans where the Purpose and Property Type included a closed-end mortgage secured by real estate and primary purpose was
to occupy or hold as a second home (Purchase or Refinance).
The
loan Purpose and Property Type does not include:
| ▪ | Home
Equity Lines of Credit |
| ▪ | Dwellings
that are not attached to real property |
| ▪ | Mobile
homes, where the consumer does not own the land |
Mission
applied the standard exemptions from TILA, i.e., business purposes loans, loans for agricultural purposes and loans secured by
five (5) or more units.
| 6.5 | TRID
Loan Estimate (“LE”) |
Mission
verified of compliance with timing requirements as to whether the Initial LE was delivered within three (3) business days from
the Application Date. The Initial LE shall use the delivery date to calculate the earliest closing Consummation Date (no less
than seven (7) business days from the delivery of the Initial LE). The delivery date is the date the creditor hand delivers the
disclosures or places the disclosures in the mail, 1026.19(e)(l).
Mission
verified any revision to the Initial LE and validated that the Revised LE was provided within three (3) days of COC, BRC or interest
rate lock. Mission validated as necessary for sufficient information to establish one of the six (6) valid reasons to reset tolerance
fees set forth in TRID:
| ▪ | Changed
Circumstance affecting settlement charges |
| ▪ | Change
Circumstance affecting eligibility |
| ▪ | Revisions
requested by the consumer |
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 11 |
| ▪ | Interest
rate dependent charges |
| ▪ | Expiration
of the LE and |
| ▪ | Delayed
settlement date on a construction loan |
| ▪ | Timing
Requirement for LE seven days prior to consummation |
Mission
also validated that settlement charges good through date, time and time zone were properly disclosed with minimum of ten (10)
days during which borrower is permitted to shop knowing fees are locked during that timeframe.
| 6.7 | Determination
of Final LE |
Mission
analyzed each LE in file to determine final Binding LE. If there is a change in loan terms, change in interest rate or increase
in charges subject to variances without valid reason for a Revised LE as set forth above, findings were cited. If the Revised
LE was issued without a valid reason, the previous valid LE was considered the Binding LE for the purposes of comparison with
the Closing Disclosure. Mission verified compliance with timing requirements to ensure there were no loan estimates provided to
the borrower after a Closing Disclosure had been delivered, and whether the Final LE was provided at least four (4) business days
prior to the closing Consummation Date.
| 6.8 | LE
Confirmation of Receipt |
If
the LE did not contain a signature line for the consumer’s confirmation of receipt, then Mission verified electronic delivery
of documents provided to borrower.
Mission
analyzed each Closing Disclosure in the file all sections of Closing Disclosures were completed (no blanks, ‘‘NA’s”
or incomplete sections) and the Disclosure is accurate as follows:
| 6.9.1 | Mission
verified that the correct form is used and General loan information and loan terms sections
were completed, and formatting is accurate. |
| 6.9.2 | Verified
the loan term, purpose, and product descriptions follow the prescribed format. |
| 6.9.3 | Verified
all applicants applying for credit, as disclosed on the application, are listed on the
CD |
| 6.9.4 | Verified
critical section such as “Can this amount increase after closing?” and “Does
the loan have these features” sections are completed and are accurate based on
the terms disclosed on the LE. |
| 6.9.5 | If
rate was locked, Mission verified lock expiration date, time and time zone was disclosed. |
| 6.9.6 | Validated
projected Payments and Estimated Taxes, Insurance & Assessments sections were complete
and accurate based on the loan terms and information known at the time of disclosure. |
| 6.9.7 | Verified
the Closing Costs and Cash-to-Close sections were complete and accurate based on the
information provided on page 2 of the CD. |
| 6.9.8 | Verified
fees disclosed properly (alphabetical order within Section with certain exceptions,
and all title fees start with “Title - “) were accurate in the Closing Cost
Details section. |
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 12 |
| 6.9.9 | Validated
when Interest Only Payments, Optional Payments, Step Payments, or Seasonal Payments,
is Adjustable Payment (“AP”) Table were disclosed and accurate based on early
disclosures in the file. |
| 6.9.10 | Validated
when ARM or Step Rate, that Adjustable Interest Rate (“AIR”) Table was properly
disclosed and accurate based on the early disclosures in the file. |
| 6.9.11 | Verified
the Comparison section is complete. |
| 6.9.12 | Validated
that all Rounding rules were verified as per 1026.37(o)(4). |
| 6.9.13 | Validated
the Other Considerations Section was complete |
| 6.10 | Written
List of Providers |
Mission
verified that if the lender placed fees in the Services You Can Shop For category, that the file properly contained a Written
List of Providers provided to the borrower within three (3) business days of application. The WLSP must have included at least
one available provider for each service and state the consumer may choose a different provider for that service. If a WLSP was
not provided, the fees will be treated as a 10% Tolerance fee and a finding for missing service provider list will be noted. If
a WLSP is provided outside of three (3) days of the application date, the fees will be treated as a 10% Tolerance fee and a finding
for a service provider list being provided outside of three (3) days from application will be noted.
Mission
deploys in its testing one or the other of the following Variance Categories in performing variance tests:
| 6.11.1 | Zero
Tolerance Variance- A finding will be cited if any
charges increase from the Binding LE to the Final CD without COC or BRC. |
Such
increases include:
| ▪ | Fees
paid to the lender, broker or an affiliate of either lender or broker [except fees paid
to an affiliate of the lender for services NOT required by the creditor are not subject
to tolerance/variance per CFR 1026.19(e)(3)(iii)(E)]; |
| ▪ | Fees
paid to an unaffiliated third party if the lender did not permit the borrower to shop
for servicer; and |
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 13 |
| 6.11.2 | 10%
Tolerance Variance- A finding will be cited if the
aggregate of the charges increased by more than 10% from the Binding LE to the Final
CD without COC or BRC. If a fee/service is listed on the LE but not charged/reflected
on the Final CD, the fee will be removed and not considered in calculating the 10% variance
threshold pursuant to CFR 19(e)(3)(ii)-5. |
Such
increases include:
| ▪ | Charges
for third party services not paid to creditor or affiliate AND borrower permitted to
shop for service but selects a provider on the creditor’s Written List of Service
Providers. |
| 6.11.3 | Prepaid
mortgage insurance will be treated as a 10% tolerance fee if it can be shopped for (and
not identified as an affiliate), otherwise it will be treated as a Zero Tolerance fee. |
| 6.11.4 | No
Tolerance/Unlimited - No finding will be cited if any of the charges change from the
Binding LE to the Final CD, provided that the disclosed amount on the LE is based on
information reasonably known to the creditor at the time of disclosure (disclosed in
good faith), such as: |
| ● | Property
insurance premiums; |
| ● | Charges
for services required by the creditor but the borrower is permitted to shop for and borrower
selects a third party provider not on the lender’s Written Service Provider List;
and |
| ● | Charges
for third party services not required by the creditor (even if paid to an affiliate of
the creditor). |
| 6.11.5 | Prepaid
property taxes charged by local and state governments periodically will have no tolerance
under the general ‘best information reasonably available’ standard unless
otherwise instructed by the Client. |
| 6.11.6 | As
noted above, Mission reviewed the loan file for evidence the disclosure was not made
in “Good Faith”. “Good faith” means the creditor made the estimate
based on the information reasonably available to them at the time the LE was provided.
Absent such evidence, Mission will consider the disclosures made in “good faith”.
|
| 6.11.7 | Additionally,
if a documented valid COC or BRC occurred resulting in a change to loan terms, settlement
charges or interest rate within four (4) business days of consummation, the variance
test will be performed based on the revised amounts disclosed on the initial CD (or subsequent
CD if change occurs after the initial CD has been provided) provided that the change
is related to the COC or BRC per Comment 19(e)(4)(ii)-1. |
| 6.11.8 | For
loans with no Interim LE and no COC or BRC occurring four (4) days prior to consummation,
fees and charges on the CD were tested for compliance with permitted variances against
fees disclosed on Initial LE. |
| 6.11.9 | For
loans with an Interim LE, the review of each Interim LE and fees and charges on the CD
were tested for compliance with variance thresholds against fees supported by a valid
COC or BRC related to the charge that increases. |
| 6.11.10 | In
those cases where an Interim LE was issued with several fee increases, but only
some are supported by or related to a valid COC or BRC, those fees which are not supported
by or related to a valid COC, BRC or disclosed on an LE that was not provided timely
(within three (3) business days of changed circumstance) were tested for variance using
the amounts disclosed in the Initial LE previously valid LE. |
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 14 |
| 6.12 | TRID
Review - Closing Disclosures (“CD”) |
Mission
conducted a full Closing Disclosure review and verified the following:
| 6.12.1 | That
the correct form was used and all sections of the CD were completed (no blanks or incomplete
sections). |
| 6.12.2 | Acknowledgement
of receipt, either by signature or evidence of electronic delivery by all borrowers with
a right to rescind under 1026.23 by verifying that each borrower with a right to rescind
was provided with a copy of the CD. This could include the non-borrowing spouse. Acknowledgement
is based on either signature, evidence of electronic delivery or by apply the common
mail rules. |
| 6.12.3 | If
a subsequent CD was issued with changes to (a) the loan product which affects disclosed
terms and loan information; (b) the addition of a prepayment penalty; or (c) an APR which
exceeds the previously disclosed APR by more than the permitted tolerances for accuracy,
Mission validated that the borrower was given an additional three (3)-business day waiting
period from the date of final pre-close CD with (a) the final loan product; (b) the prepayment
penalty addition; or (c) the APR, and that the final pre-close CD has been received by
borrower by consummation. |
| 6.12.4 | On
the final CD the following checks and limitations apply: |
| 6.12.5 | Verification
of the technical formatting of the CD is out of scope in the standard review. The formatting
of the document is the responsibility of the document preparation source. |
| 6.12.6 | Closing,
Transaction and Loan Information sections have been completed with accurate information. |
| 6.12.7 | Loan
terms sections are completed. |
| 6.12.8 | Mission
will verify loan term, purpose, and product descriptions follow the prescribed format. |
| 6.12.9 | Mission
will verify all applicants applying for credit, as disclosed on the application, are
listed on the LE |
| 6.12.10 | “Can
this mount increase after closing?” and “Does the loan have these features”
sections are completed accurately. |
| 6.12.11 | Projected
Payments and Estimated Taxes, Insurance & Assessments sections are completed accurately. |
| 6.12.12 | Fees
have been disclosed properly (alphabetically, correct buckets and all title fees start
with “Title - “) in Closing Cost Details section. |
| 6.12.13 | Any
additional fees for sections other than Section C (Services You Can Shop For). |
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 15 |
| 6.12.14 | Calculating
Cash to Close table completed accurately. |
| 6.12.15 | Summaries
of Transaction section completed accurately |
| 6.12.16 | CD
Assumption, Demand Feature, Negative Amortization, and Partial Payments sections completed
properly (at least and only one box selected). |
| 6.12.17 | Late
Payment completed properly (terms disclosed and accurate per note). |
| 6.12.18 | Escrow
Amount section was completed properly (only one box selected and amounts disclosed). |
| 6.12.19 | Escrow
Property Costs over Year 1 to be calculated per the payments scheduled to be made in
a 1 year period after consummation (1026.38)1)(7)(i) (A)( I). |
| 6.12.20 | Non-Escrowed
Property Costs over 1 Year to be calculated using either 11 or 12 months as determined
by client. (1026.38)(1)(7)(i)(B)(1) |
| 6.12.21 | If
Interest Only, Optional Payments, Step Payments, or Seasonal Payments, is |
| 6.12.22 | Adjustable
Payment (“AP”) Table disclosed accurately. |
| 6.12.23 | If
ARM or Step, is Adjustable Interest Rate (“AIR”) Table was disclosed accurately. |
| 6.12.24 | Loan
Calculations sections were complete and accurate. |
| 6.12.25 | Total
of Payments is accurate per 1026.38(o)(1). |
| 6.12.26 | Include
fees in section A, B, and C that are paid by the borrower as well as the seller or other
if those fees are customarily paid by the borrower. |
| 6.12.27 | Mission
captured amounts disclosed in Loan Calculations section and tested for TILA tolerance
violations on disclosed APR and Finance Charge. |
| 6.12.28 | Mission
confirmed the Total Interest Percentage (TIP) was accurate with proper rounding. |
| 6.12.29 | Other
Disclosures section was complete with at least one choice selected as applicable. |
| 6.12.30 | Rounding
rules were verified as per 1026.38(t)(4). Rounding on all percentages except APR is percentages
should be truncated so that a zero is not disclosed in the last decimal place (7.250
should be rounded to 7.25). |
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 16 |
| 6.13 | TRID
Method of Delivery/Receipt LE and CD |
Mission
verified the method of receipt of the revised LE and CD and performed a compliance test with timing requirements. For purposes
of the review and verification, the date the borrower is deemed to have received the disclosure(s) is based on any of the following
methods:
| 6.13.1 | In
Person: borrower signature date is used. |
| 6.13.2 | Electronic
- No Receipt Confirmation in File: three (3) business days from later of document issue
date or proof of e-delivery date is used. |
| 6.13.3 | Electronic
- With Receipt Confirmation in File, date of receipt confirmation is used. |
| 6.13.4 | Electronic
- Delivery confirmation of an email, assuming the borrower(s) have consented to electronic
delivery. |
| 6.13.5 | Mail
(USPS or other parcel delivery service) - No Receipt Confirmation in File: three (3)
business days from later of document issue date or proof of mailing date is used. Delivery
confirmation, i.e., confirmation that documents have been delivered to the borrower(s)
door. Signature receipt by anyone other than the borrower(s) to the mortgage transaction
constitutes evidence of delivery, not receipt, for the purposes of the receipt requirements. |
| 6.13.6 | Mail
(USPS or other parcel delivery service) - With Receipt Confirmation in File: date of
receipt confirmation is used. Delivery confirmation, i.e., confirmation that documents
have been delivered to the borrower(s) door. Signature receipt by anyone other than the
borrower(s) to the mortgage transaction constitutes evidence of delivery, not receipt,
for the purposes of the receipt requirements. Unknown (unable to determine delivery method
or unable to verify borrower received disclosures in any other method than by USPS Mail
method): follow the USPS Mail delivery method of three (3) business days from the document
issue date. As noted above, a signature by anyone other than the borrower(s) constitutes
evidence of delivery and the method of receipt will be considered unknown, requiring
an additional three (3) days from the date the non-borrower received the documents. |
| 6.13.7 | Electronic
Disclosures. If disclosures were sent electronically, a finding was cited if there was
no evidence in the file that the borrower consented to receive disclosures electronically.
Default to the three (3) business day mail rule for delivery without the proper documentation
of borrower consent. |
| 6.14 | Other
TRID Compliance Testing |
| 6.14.1 | Mission
verified that the Home Loan Toolkit was present. If not present, a finding was cited
if the Your Home Loan Toolkit Disclosure or evidence the disclosure was delivered or
placed in the mail is not in the file or was not provided to the borrower within three
(3) business days of application. |
| 6.14.2 | Consummation
Date: Consummation varies by applicable state law and the term is not often clearly defined.
Accordingly, Mission used the notary date of the Deed of Trust to confirm consummation.
|
| 6.14.3 | Post-Consummation
Disclosures: As noted in the findings resolutions, the creditor
used a Post-consummation Closing Disclosure to either correct clerical errors and clear
findings or to cure pre-consummation fee tolerance errors and clear findings. In all
cases, Mission confirmed the testing against the Post-consummation Closing Disclosure
before findings were resolved. |
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 17 |
| 6.15 | SUBSEQUENT
CHANGES AFTER CONSUMMATION |
There
were loans in the pool reviewed by Mission that contained findings related to issues that could only be cured by issuance of a
Post-close Closing Disclosure. The following prescribed cures as set forth in section 1026.19 (t)(2)(iii) through (v) that are
acceptable for changes and corrections to the Final CD after consummation.
| 6.15.1 | Section
1026.19(t)(2)(iii) - Changes due to events occurring after consummation. If within 30
days of consummation or as in this case, within 30 days of creditor first becoming aware
of the existence of an event, an event occurs that causes the final CD to become inaccurate
and such inaccuracy results in a change to an amount actually paid by the borrower(s)
from the amount disclosed, Mission tested for evidence that a new, corrected CD was delivered
or placed in the mail to the borrower within thirty (30) days of receiving information
that an event occurred. |
| 6.15.2 | Section
1026.19(f)(2)(iv)- Changes due to clerical errors. Non-numeric clerical errors, for the
purpose of this scope are any error not related to a disclosed dollar amount or percentage.
Where applicable, Mission tested for evidence that a new, corrected Post-Closing CD was
delivered or placed in the mail to the borrower within sixty (60) calendar days of consummation,
or within sixty (60) calendar days of the first date of which the creditor becomes aware
of such error. |
| 6.15.3 | Section
1026.19(f)(2)(v)-Refunds related to the good faith analysis. Where applicable, Mission
identified findings related to fee disclosures and brought such findings to the attention
of the creditor. As noted in the resolution of these findings, the Creditor acted in
Good Faith and cured these findings by issuing a corrected Post-Closing CD and where
a fee tolerance violation occurred the Creditor issued a refund to the borrower. In all
cases, Mission tested for evidence such as a copy of the refund check, a new corrected
CD, and evidence the creditor delivered or placed in the mail to the borrower within
the timeframe necessary as noted in the resolution to the findings. |
| 6.15.4 | A
post-consummation CD is understood to be issued with a Date Issued represented as the
date the post-consummation CD was issued. |
| 6.15.5 | Errors
on LE’s and Interim CD’s and numeric errors on final CD’s which do
not have prescribed cures as per the regulation were not be reported as having been cured.
The assessment of risk and decision to accept a finding that does not have a prescribed
cure is the responsibility of the purchaser of the loan. |
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 18 |
| 6.16 | Additional
Disclosures and Requirements: |
Mission
confirmed compliance with current documentation and timing requirements in effect at origination of the Mortgage Loan including:
| 6.16.1 | Confirmed
the presence of the Home Loan Tool Kit is in file for covered loans. |
| 6.16.2 | Confirmed
the presence of the Affiliated Business Disclosure in file in the event the lender has
affiliated business arrangements |
| 6.16.3 | Confirmed
the Affiliated Business Disclosure provided within three general business days of “Application”
(Mission reviews for this disclosure to be provided within three general business days,
as the lender will typically know at the time of application if borrower(s) will be referred
to affiliates for provision of third party services) |
| 6.16.4 | Confirmed
the Affiliated Business Disclosure is executed. |
| 6.16.5 | Confirmed
the presence of the Initial Escrow Disclosure Statement in file |
| 6.16.6 | Confirmed
the Initial Escrow Disclosure Statement was provided at closing or within 45 days after
settlement |
| 6.16.7 | Confirmed
that each mortgage loan adhered to flood insurance coverage requirements as outlined
under the NFIP, including identification of flood zones and subsequent policy documentation
for evidence of adequate coverage amounts. |
| 6.17 | High
Cost- State & Local Anti-Predatory Regulations: |
In
addition to federal thresholds, Mission reviewed the anti-predatory lending statutes in the following states and local municipalities,
as applicable:
| 6.17.1 | Arkansas
Home Loan Protection Act, AR. Stat. Ann.§ 23-53-101 et seq. |
| 6.17.2 | California
Anti-Predatory Lending Statute, CA. Fin. Code§ 4970 et seq. |
| 6.17.3 | 4.3
California Higher Priced Mortgage Loan Statute, CA. Fin Code § 4995 et seq. |
| 6.17.4 | 4.4
Colorado Consumer Equity Protection Act, CO. Rev. Stat. § 5-3.5-101 et seq. and
as amended by Senate Bi11216 (2007) and House Bi111322 (2007) |
| 6.17.5 | Colorado
Consumer Credit Code, CO. Rev. Stat. 5-1-101 et seq. |
| 6.17.6 | Connecticut
Abusive Home Loan Lending Practices Act, CT. Stat. Ann. § 36a-746 et seq. and the
Responsible Lending and Economic Security Act, CT. House Bill 5577 (2008). |
| 6.17.7 | Connecticut
Nonprime Home Loan Statute, CT. Gen. Stat. §§ 36a-760 et seq. (as originally
enacted and as amended by Senate Bill 949. |
| 6.17.8 | District
of Columbia Home Loan Protection Act of 2002, D.C. Official Code § 26-1151.01 et
seq., as implemented by 20 D.C. Municipal Reg. § 2000.1 et seq. and DC Mortgage
Disclosure Act of2007. |
| 6.17.9 | Florida
Fair Lending Act, FL. Stat. Ann. § 494.0078 et seq. |
| 6.17.10 | Georgia
Fair Lending Act, GA. Stat. Ann.§ 7-6A-1 et seq. (as originally enacted by House
Bill 02-1361 and as modified by Senate Bill 03-53) |
| 6.17.11 | Idaho
Residential Mortgage Practices Act, ID. Code§ 26-3101 et seq. |
| 6.17.12 | Illinois
High Risk Home Act, IL. Comp Stat. tit. 815, §§ 137/5 et seq. |
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 19 |
| 6.17.13 | Illinois
High Risk Home Loan Regulations, 38 IL. Admin. Code § 345.10 et seq. |
| 6.17.14 | Illinois
High Risk Home Loan Act, Public Act. 93-0561 (2003). |
| 6.17.15 | City
of Chicago, Illinois, Anti-Predatory Lending Ordinance, Chicago Municipal Code, §§
2-32-440; 2-32-455; 2-92-325; 4-4-155; 8-4-325. |
| 6.17.16 | Cook
County, Illinois, Anti-Predatory Lending Ordinance, Ordinance No. 240864 (2001) as amended
by Illinois SB 1167 (2007). |
| 6.17.17 | Indiana
Home Loan Practices Act, IN. Code§ 24-9-1-1 et seq. and as amended by 2005 In. P.L.
141 § 6 P2013-011. |
| 6.17.18 | Kansas
Consumer Credit Code, KS. Stat. Ann. § 16a-1-101 et seq. Sections 16a-1-301, 16a-3-
207 and 16a-3-308a. |
| 6.17.19 | Kentucky
Anti-Predatory Lending Statute, KY. Rev. Stat. § 360.100 et seq. and as amended
by KY. House Bill 552 (2008). |
| 6.17.20 | Maine,
An Act to Enhance Consumer Protections in Relation to Certain Mortgages, 9A ME. Rev.
Stat. Ann. §§ 8-101; 8-103(1); 8-206(8); 8-206A and ME. Legislative Document
1869 (2007). |
| 6.17.21 | Maryland
Commercial Law, MD. Stat. Ann. §§ 12-124.1; 12-127; 12-409.1; 12-1029 and as
amended by MD. Senate Bill 270 (2008) and Maryland Regulations under the MD. Mortgage
Lender Law (2009). |
| 6.17.22 | Maryland
Regulations for Higher Priced Mortgage Loans, as promulgated under the MD. Mortgage Lender
Law, MD. Code Ann., Fin. Instit. Code §§ 11-501 et seq.; MD. Code Regs. §§
09.03.06.01 et seq. |
| 6.17.23 | Massachusetts
High Cost Mortgage Regulations, 209 CMR § 32.32 et seq. including MA. House Bill4387
(2008) 20. MA. Predatory Home Loan Practices Act, M.G.L. Chapter 183(C). |
| 6.17.24 | Massachusetts
Regulations for Higher Priced Mortgage Loans, 209 MA. Code Regs. §§ 32.00 |
| 6.17.25 | Massachusetts
“Borrower’s Interest” Standard, M.G.L. Chapter 183, §28C. |
| 6.17.26 | Massachusetts
Mortgage Lender and Broker Regulations, 940 CMR § 8.00 (15-17). |
| 6.17.27 | Michigan
Consumer Mortgage Protection Act, MI. Stat. Ann. § 445-1631 et seq. |
| 6.17.28 | Minnesota
Mortgage Originator and Service Licensing Act, § 58.137 etal. (S.F. 2988 (2002)
and as amended by House File 1004 and SF 98 (2007) and SF 3154 and 3214 (2008). |
| 6.17.29 | Nebraska
Mortgage Bankers Registration and Licensing Act, NE. Stat.§ 45-702 et seq. |
| 6.17.30 | Nevada
Anti-Predatory Lending Law, NV. Rev. Stat. § 598D.010 et seq. and as amended by
AB 440 and492. |
| 6.17.31 | New
Jersey Home Ownership Security Act of 2002, NJ. Stat. Ann. §C:46:10 B-22 et seq.
and as amended by PL. 2004, Ch. 84 § 1. |
| 6.17.32 | New
Mexico Home Loan Protection Act, NM. Stat. Ann. § 58-21A-1 et seq. and as amended
by Senate Bill 342 (2009 High Cost Home Loan Act, NY. Bank. L. Ch. 626., as implemented
by 3 NYCCR Part 41 (2003) and as amended by Senate Bill 8143-A (2008). Banking Law Article
6-1 (2003) and 6-m (2008). |
| 6.17.33 | New
York High Cost Home Loan Regulations, 3 NYCCR Part 41 (2001). |
| 6.17.34 | New
York High Cost Home Loan Act, NY. Bank. L. Ch. 626., as implemented by 3 NYCCR Part 41
(2003) and as amended by Senate Bill 8143-A (2008). Banking Law Article 6-1 (2003) and
6-m (2008). |
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 20 |
| 6.17.35 | North
Carolina Anti-Predatory Lending Law, NC. Gen. Stat. §§ 24-l.1 to 24-10.2 and
North Carolina Amendments to Anti-Predatory Lending Law, NC. Gen. Stat. §§
24-9; 24-l.l(E)(a); 24-10.2(a) and as amended by House Bill1817 (2007). |
| 6.17.36 | Ohio
Anti-Predatory Lending Statute, OH. Rev. Code Ann. §§ 1349.25 to 1349.37and
§ 1.63 and as amended by S.B. 185. |
| 6.17.37 | City
of Cleveland Heights, Ohio, Anti-Predatory Lending Ordinance, Ordinance No. 72-2003. |
| 6.17.38 | Oklahoma
Anti-Predatory Lending Law, House Bill No. 1574 (2003). |
| 6.17.39 | Oklahoma
Higher -Priced Mortgage Loans Law, OK. Admin. Code§§ 160:45-9-1 et seq. |
| 6.17.40 | Pennsylvania
Consumer Equity Protection Act, 63 PA. Cons. Stat. Ann. § 456.501 et seq. 4.41 City
of Providence, Rhode Island Predatory Lending Ordinance, Ordinance No. 245, Chapter 2006-33
as amended. |
| 6.17.41 | Rhode
Island Home Loan Protection Act, Chapter 25.2 of Title 34 of RI. Gen. Laws. §§
34-25.2-1 et seq., including the Emergency and Final Regulations. |
| 6.17.42 | South
Carolina High-Cost and Consumer Home Loans Act, SC. Code§ 37-23-10 et seq. |
| 6.17.43 | South
Carolina Consumer Protection Code, SC. Code 37-1-101 et seq. |
| 6.17.44 | Tennessee
Home Loan Protection Act, TN. Code Annotated §§ 45-20-101 et seq., Title 47
et seq. |
| 6.17.45 | Texas
High-Cost Home Loan Statute, TX. Fin. Code Ann.§ 343.201 et seq. |
| 6.17.46 | Texas
Constitution, Section 50(a)(6), Article XVI |
| 6.17.47 | Utah
Residential Mortgage Practices Amendments, UT. Code Ann.§ 61- 2c-102 et seq. |
| 6.17.48 | Utah
High Cost Home Loan Act, UT. Code § 61-2d-101 et seq. |
| 6.17.49 | Vermont
Interest Act, 9 V.S.A. § 104, implemented by Regulation B-98-2. |
| 6.17.50 | Virginia
Mortgage Lender and Broker Act (for loans originated prior to July 1, 2003), VA. Code
Ann.§§ 6.1-413; 6.1-422, 6.1-428. |
| 6.17.51 | Virginia
Mortgage Lender and Broker Act (for loans originated after July 1, 2003), VA. Code Ann.§§
6.1-411; 6.1-422.1, 6.1-425.1; 6.1-425.2. |
| 6.17.52 | Washington
House Bill 2770, Mortgage Lending and Homeownership, Chapter 108, Laws of 2008. |
| 6.17.53 | Wisconsin
Responsible High Cost Mortgage Lending Act, WI. Stat. § 428.202. |
| 6.17.54 | West
Virginia Residential Mortgage Lender, Broker and Servicer Act, WV. Code § 31-17-1
et seq. |
| 6.17.55 | Wyoming
Credit Code, WY. Stat. Ann.§§ 40-14-101 et seq. |
| 6.18 | Regulatory
Compliance Disclaimer |
Please
be advised that Mission did not make a determination as to whether loans complied with federal, state or local laws, constitutional
provisions, regulations or ordinances that are not expressly enumerated herein. There can be no assurance that the review uncovered
all issues relating to the origination of the mortgage loans, their compliance with applicable law and regulation and the original
appraisals relating of the mortgaged properties or uncovered all relevant factors that could affect the future performance of
the mortgage loans. Furthermore, the findings reached by Mission are dependent upon its receiving complete and accurate data regarding
the mortgage loans from loans originators and other third parties upon
which Mission is relying in reaching such findings.
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 21 |
Please
be further advised that Mission does not employ personnel who are licensed to practice law in various jurisdictions, and the findings
set forth in the reports prepared by Mission do not constitute legal advice or opinions. They are recommendations or conclusions
based on information provided to Mission. All final decisions as to whether to purchase or enter into a transaction related to
any individual mortgage loan or the mortgage loans in the aggregate, any investment strategy and any legal conclusions, including
potential liability related to the purchase or other transaction involving any such loans, shall be made solely by the Client,
or other agreed upon party, that has engaged Mission to prepare its reports pursuant to its instructions and guidelines. Client,
or other agreed upon party, acknowledges and agrees that the scoring models applied by Mission are designed to identify potential
risk and the Client, or other agreed upon party, assumes sole responsibility for determining the suitability of the information
for its particular use.
| 6.19 | Misrepresentation
and Third-Party Report Review |
Mission
verified that fraud reports were present on all loans and independent third-party property valuations reports are in the file.
| 6.19.1 | Misrepresentation
Review |
Mission
validated the presence of a Fraud Guard report on each loan to identify potential misrepresentations of income, employment, identity,
occupancy, transaction and appraisal misrepresentation or other areas of potential misrepresentation.
Mission
validated credit report alerts for accuracy and potential issues.
| 6.19.3 | Social
Security Numbers |
Mission
verified SSN(s) across all file documents.
Mission
validated to the extent possible for apparent alterations to loan documents.
Mission
validated the documents contained in the loan file for consistency of data.
| 6.19.6 | Third
Party Fraud Tools |
To
the extent a third-party Fraud Guard was present in the loan file, Mission reviewed high level or critical warnings were reviewed
and addressed.
Mission
was provided with a Client bid tape to conduct a Data Integrity Review. The Client provided a data tape with the following data
fields and Mission compared the field to the applicable source document and reported all variances.
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 22 |
The
following fields were provided and compared:
| ● | All
Borrower Total Income |
| ● | Initial
Monthly PI or IO Payment |
| ● | Mortgage
Origination Channel |
| ● | Primary
Appraised Property Value |
| 8. | Loan
and Exception Level Grading Methodology |
Pursuant
to the applicable NRSRO criteria, Mission graded each loan exception with an event level 1 for exceptions findings that are informational
in nature, event level 2 for exceptions findings that are considered non-material, event level 3 for exceptions findings that
are considered material. In accordance applicable NRSRO criteria exceptions and overall initial loan grades and final loan Grades
were assigned with an A, B, C or D. The methodology for the application of RMBS grading is defined by each NRSRO in their current
industry publications as updated from time to time.
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 23 |
Pursuant
to the applicable NRSRO criteria, Mission graded certain compliance exceptions as nonmaterial based on seasoning of the mortgage
loan. Where applicable, mortgage loans that are seasoned beyond the applicable period under TILA in which affirmative claims could
be brought by a consumer. The period is not limited for claims, other than recission, which are raised as a defense to foreclosure.
Information contained in any Mission reports related to the applicable statute of limitations for certain claims may not be accurate
or reflect the most recent controlling case law. Further, a particular court in a particular jurisdiction may extend, not enforce
or otherwise allow claims beyond the statute of limitations identified in the report based on certain factors, including the facts
and circumstances of an individual loan.
NRSRO
GRADING METHODOLOGY
| Fitch
Ratings Grade |
#
of Loans |
%
of Loans (by count) in MISSION Population |
| A |
704 |
82.4% |
| B |
150 |
17.6% |
| C |
0 |
0% |
| D |
0 |
0% |
NRSRO
GRADING METHODOLOGY
| KBRA
Ratings Grade |
#
of Loans |
%
of Loans (by count) in MISSION Population |
| A |
704 |
82.4% |
| B |
150 |
17.6% |
| C |
0 |
0% |
| D |
0 |
0% |
| NRSRO
GRADE SUMMARY |
|
|
|
|
| NRSRO
GRADE |
|
#
of Loans |
|
%
of Loans (by count) in MISSION Population |
| CREDIT |
|
|
|
|
| A |
|
757 |
|
88.6% |
| B |
|
97 |
|
11.4% |
| C
|
|
0 |
|
0% |
| D |
|
0 |
|
0% |
| |
|
|
|
|
| COMPLIANCE |
|
|
|
|
| A |
|
851 |
|
99.6% |
| B |
|
3 |
|
0.4% |
| C
|
|
0 |
|
0% |
| D |
|
0 |
|
0% |
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 24 |
| |
|
|
|
|
| PROPERTY/VALUE |
|
|
|
|
| A |
|
794 |
|
93.0% |
| B |
|
60 |
|
7.0% |
| C
|
|
0 |
|
0% |
| D |
|
0 |
|
0% |
| |
|
|
|
|
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 25 |
DATA
INTEGRITY REVIEW
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 26 |
| Data Compare
Summary |
| 2026_ADMT-NQM5_FINAL |
|
|
|
|
| Run Date - 6/16/2026 10:00:00
AM |
|
|
|
|
| |
|
|
|
|
| Field Label |
Loans
With Discrepancy |
Total
Times Compared |
%
Variance |
Comments |
| AllBorrowerTotalIncome |
9 |
854 |
1.05% |
All
Income was verified for each borrower |
| ApplicationDate |
86 |
852 |
10.09% |
All
variances were verified by Mission using either the 1003 date or the credit report date |
| B1Citizen |
1 |
854 |
0.12% |
All
variances were verified by Citizenship documents |
| B1FirstName |
20 |
854 |
2.34% |
All
variances were spelling differences in the tape vs on the note. |
| B1LastName |
30 |
854 |
3.51% |
All
variances were spelling differences in the tape vs on the note. |
| B1OriginationFICO |
1 |
13 |
7.69% |
All
FICO scores were verified from provided credit reports. |
| B2FirstName |
1 |
182 |
0.55% |
All
variances were spelling differences in the tape vs on the note. |
| B2LastName |
4 |
182 |
2.20% |
All
variances were spelling differences in the tape vs on the note. |
| ClosingSettlementDate |
406 |
622 |
65.27% |
In
all cases Mission verified closing dates from the relevant closing documents. |
| DSCR |
40 |
854 |
4.68% |
In
all cases Mission recalculated DSCR from relevant income and credit documents. |
| FirstPaymentDate |
53 |
854 |
6.21% |
In
all cases Mission verified first payment date from the promissory note. |
| InitialMonthlyPIOrIOPayment |
44 |
854 |
5.15% |
In
all cases Mission verified the monthly PI Payment from the promissory note. |
| InterestRate |
1 |
854 |
0.12% |
In
all cases Mission verified the interest rate from the promissory note. |
| LenderName |
6 |
854 |
0.70% |
|
| LoanAmount |
0 |
854 |
0.00% |
In
all cases Mission verified the Loan Amount from the promissory note. |
| LoanID |
0 |
854 |
0.00% |
|
| LoanProgram |
48 |
854 |
5.62% |
In
each case, these appear to be changes in Loan program during underwriting. In all cases Mission verified programs from the Loan approval
and final loan docs. |
| LoanPurpose |
0 |
854 |
0.00% |
|
| MINNo |
9 |
806 |
1.12% |
In
all cases Mission verified the MIN number present on the Deed of Trust. |
| MortgageOriginationChannel |
2 |
854 |
0.23% |
Mission
verifies origination channel from docuemntation provided with the 1008. |
| NoteDate |
3 |
799 |
0.38% |
All
date variances were verified from the Promissory Note. |
| NumberofUnits |
3 |
854 |
0.35% |
In
all cases Mission verified property units from the appraisal and other property related documents. |
| Occupancy |
0 |
854 |
0.00% |
|
| PrimaryAppraisedPropertyValue |
4 |
854 |
0.47% |
Mission
verified values used from the appraisal. |
| PropertyAddress |
98 |
854 |
11.48% |
All
variances were various slight spelling differences in the tape vs on the deed of trust. |
| PropertyCity |
0 |
854 |
0.00% |
|
| PropertyCounty |
55 |
854 |
6.44% |
All
variances were various slight spelling differences in the tape vs on the deed of trust. |
| PropertyState |
0 |
854 |
0.00% |
|
| PropertyType |
73 |
854 |
8.55% |
All
differences are enumerations are related to ASF enumerations. In each case mission verified the Property type from the appraisal. |
| PropertyZipCode |
0 |
854 |
0.00% |
|
| QualifyingCLTV |
39 |
854 |
4.57% |
In
all cases Mission verified values from appraisal documents and 2nd lien values from 2nd lien documents or credit reports. |
| RefinanceType |
44 |
313 |
14.06% |
All
variations were verified from the 1003 documentation. |
| SalesPrice |
1 |
540 |
0.19% |
All
variations were verified from the sales contract documentation. |
| SellerLoanID |
0 |
13 |
0.00% |
|
| TotalDebtIncomeRatio |
1 |
854 |
0.12% |
In
all cases Mission verified borrower income and all debts from the credit reports and recalculated DTI. |
| UnderwritingGuidelineLenderName |
0 |
854 |
0.00% |
|
| UnderwritingGuidelineName |
0 |
854 |
0.00% |
Misison
verifies guidelines used at time of origination date. |
| UnderwritingGuidelineVersionDate |
78 |
854 |
9.13% |
Misison
verifies guidelines used at time of origination date. |
| VerifiedDocType |
257 |
854 |
30.09% |
Mission
uses ASF defined doc types used for income qualification and the lender tape differs from these enumerations. |
| |
1,417 |
|
|
|
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 27 |
POOL
DETAILS
| |
|
|
|
|
|
|
| AMORTIZATION
TYPE |
Count |
%
of Pool |
|
BORROWER
CITIZENSHIP |
Count |
%
of Pool |
| Fixed |
851 |
99.65% |
|
Foreign
National |
1 |
0.12% |
| Adjustable
Rate Mortgage |
3 |
0.35% |
|
Non-Permanent
Resident Alien |
57 |
6.67% |
| Grand
Total |
854 |
100.00% |
|
Permanent
Resident Alien |
93 |
10.89% |
| |
|
|
|
US
Citizen |
703 |
82.32% |
| LOAN
TYPE |
Count |
%
of Pool |
|
Grand
Total |
854 |
100.00% |
| Purchase |
540 |
63.23% |
|
OCCUPANCY |
Count |
%
of Pool |
| Refinance
- Cash Out |
257 |
30.09% |
|
Investment |
468 |
54.80% |
| Refinance
- Limited Cash Out |
23 |
2.69% |
|
Primary
Residence |
356 |
41.69% |
| Refinance
- Rate and Term |
34 |
3.98% |
|
Secondary
Residence |
30 |
3.51% |
| Grand
Total |
854 |
100.00% |
|
Grand
Total |
854 |
100.00% |
| |
|
|
|
|
|
|
| ORIGINAL
INTEREST RATE |
Count |
%
of Pool |
|
PROPERTY
TYPE |
Count |
%
of Pool |
| 5.500
- 5.999% |
18 |
2.11% |
|
1
Family Attached |
39 |
4.57% |
| 6.000
- 6.499% |
258 |
30.21% |
|
2
Family |
56 |
6.56% |
| 6.500
- 6.999% |
297 |
34.78% |
|
3
Family |
18 |
2.11% |
| 7.000
- 7.499% |
130 |
15.22% |
|
4
Family |
11 |
1.29% |
| 7.500
- 7.999% |
82 |
9.60% |
|
5-10
Unit Multi-Family |
35 |
4.10% |
| >=
8.000% |
69 |
8.08% |
|
Condo,
High Rise |
11 |
1.29% |
| Grand
Total |
854 |
100.00% |
|
Condo,
Low Rise |
167 |
19.56% |
| |
|
|
|
Condotel |
9 |
1.05% |
| QUALIFYING
FICO |
Count |
%
of Pool |
|
Double-wide
Manufactured Housing |
1 |
0.12% |
| 601
- 700 |
116 |
13.58% |
|
Mixed
Use |
7 |
0.82% |
| 701
- 800 |
617 |
72.25% |
|
PUD |
146 |
17.10% |
| 801
- 900 |
118 |
13.82% |
|
Single
Family Detached |
354 |
41.45% |
| No
FICO |
3 |
0.35% |
|
Grand
Total |
854 |
100.00% |
| Grand
Total |
854 |
100.00% |
|
|
|
|
| |
|
|
|
VERIFIED
DSCR |
Count |
%
of Pool |
| VERIFIED
DTI |
Count |
%
of Pool |
|
<
1.00 |
50 |
5.85% |
| <
10 or Null |
454 |
53.16% |
|
1.00
- 1.99 |
379 |
44.38% |
| 10
- 19 |
27 |
3.16% |
|
2.00
- 2.99 |
10 |
1.17% |
| 20
- 29 |
58 |
6.79% |
|
3.00
- 3.99 |
1 |
0.12% |
| 30
- 39 |
122 |
14.29% |
|
N/A |
414 |
48.48% |
| 40
- 49 |
177 |
20.73% |
|
Grand
Total |
854 |
100.00% |
| >
= 50 |
16 |
1.87% |
|
|
|
|
| Grand
Total |
854 |
100.00% |
|
|
|
|
| Confidential and Privileged. Use is restricted without the written consent of the Author. | P a g e | 28 |