Unique ID LoanID Seller Loan ID Servicer Loan ID Loan Exception ID Exception Type Exception Grade Exception Exception Detail Exception Information Amount of Underdisclosure Compliance Factors Subject to Predatory - Unable to Test Origination Date Statute of Limitation Date State Purpose at Origination Occupancy at Origination Disposition 3 UAL State Fitch Exception Level Grade Moody's Exception Level Grade DBRS Exception Level Grade S&P Exception Level Grade Date Reported by AMC Date Cure Provided Cured / Waived Cleared Issue with Cure Doc Unable to Clear QM Status Seller Comments AMC Additional Comments
625489216 XXX XXX XXX 3063638 compliance 3 Missing Final HUD-1: HUD-1 Not Signed or Stamped Used For Fee Testing Missing Final HUD-1: HUD-1 Not Signed or Stamped used for any applicable Yes 3/XX/2004 GA Refinance - Rate/Term Primary No D D D D 5/XX/2017 Yes 2017/XX/18: Additional HUD provide 2017/XX/18: HUD not legible
Federal, State or Local compliance testing.
625489216 XXX XXX XXX 3063639 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using Yes 3/XX/2004 GA Refinance - Rate/Term Primary No B B B B 5/XX/2017
an application date of 2/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 9/XX/2003.
625489216 XXX XXX XXX 3081198 compliance 2 Missing Document: Missing Lender's Initial 1003 Yes 3/XX/2004 GA Refinance - Rate/Term Primary No B B B B 5/XX/2017
625488655 XXX XXX XXX 3048250 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2008 MD Purchase Primary No B B B B 5/XX/2017
an application date of 7/XX/2008 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 7/XX/2008.
625488655 XXX XXX XXX 3048294 credit 3 Missing Document: FHA Mortgage Insurance Certificate not provided 7/XX/2008 MD Purchase Primary No C C C C 5/XX/2017
625488655 XXX XXX XXX 3048331 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 7/XX/2008 MD Purchase Primary No B B B B 5/XX/2017
following clauses:
625488655 XXX XXX XXX 3048347 credit 2 Loan has been identified as FHA/VA 7/XX/2008 MD Purchase Primary No B B B B 5/XX/2017
625488655 XXX XXX XXX 3066966 compliance 2 Missing Document: Missing Lender's Initial 1003 7/XX/2008 MD Purchase Primary No B B B B 5/XX/2017
625488742 XXX XXX XXX 3053309 credit 3 Missing Document: Missing Final 1003 3/XX/2006 FL Refinance - Cash-out - Other Primary No C C C C 5/XX/2017
625488742 XXX XXX XXX 3053386 credit 3 Missing Document: FHA Case Number Assignment not provided 3/XX/2006 FL Refinance - Cash-out - Other Primary No C C C C 5/XX/2017
625488742 XXX XXX XXX 3053416 credit 2 Loan has been identified as FHA/VA 3/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B 5/XX/2017
625488742 XXX XXX XXX 3053425 credit 2 Final Title Policy is missing. No evidence of title was found in file. 3/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B 5/XX/2017
625488742 XXX XXX XXX 3053459 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 3/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B 5/XX/2017
within a reasonably practicable time after using credit score.
625488742 XXX XXX XXX 3053460 compliance 2 FHA Case Number Assignment Date Missing FHA Case # Assignment Date missing. Creditor application date used as FHA case # 3/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B 5/XX/2017
assignment date for purposes of any applicable compliance testing.
625488742 XXX XXX XXX 3066672 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL Itemization did not disclose the closing fee of $XXX as a prepaid finance $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 3/XX/2006 3/XX/2009 FL Refinance - Cash-out - Other Primary No B B B B 5/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. charge. The Lender's TIL reflects MI dropping off after 218 months, however, the for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
audited TIL indicates MI should drop off after 216 months. liability.
625489096 XXX XXX XXX 3056153 credit 3 Missing Document: Missing Final 1003 8/XX/2008 FL Refinance - Cash-out - Debt Consolidation Primary No C C C C 5/XX/2017
625489096 XXX XXX XXX 3056273 credit 3 Missing Document: FHA Mortgage Insurance Certificate not provided 8/XX/2008 FL Refinance - Cash-out - Debt Consolidation Primary No C C C C 5/XX/2017
625489096 XXX XXX XXX 3056277 credit 2 Loan has been identified as FHA/VA 8/XX/2008 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 5/XX/2017
625489096 XXX XXX XXX 3056288 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2008 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 5/XX/2017
an application date of 7/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 6/XX/2008.
625489096 XXX XXX XXX 3068893 compliance 2 Missing Document: Missing Lender's Initial 1003 8/XX/2008 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 5/XX/2017
625489366 XXX XXX XXX 3061143 compliance 2 (Doc Error) Initial GFE not provided 12/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B 5/XX/2017
625489366 XXX XXX XXX 3061163 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 12/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B 5/XX/2017
an application date of 12/XX/2006 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 12/XX/2006.
625489366 XXX XXX XXX 3079697 compliance 2 Missing Document: Missing Lender's Initial 1003 12/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B 5/XX/2017
625488684 XXX XXX XXX 3043435 compliance 2 Missing Document: Missing Lender's Initial 1003 5/XX/2004 CA Refinance - Cash-out - Other Primary No B B B B 5/XX/2017
625488684 XXX XXX XXX 3043896 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2004 CA Refinance - Cash-out - Other Primary No B B B B 5/XX/2017
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488684 XXX XXX XXX 3043899 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2004 5/XX/2005 CA Refinance - Cash-out - Other Primary No B B B B 5/XX/2017
CHARM Booklet, not provided to the borrower.
625488684 XXX XXX XXX 3069419 credit 3 Missing Document: Missing Final 1003 5/XX/2004 CA Refinance - Cash-out - Other Primary No C C C C 5/XX/2017
625488684 XXX XXX XXX 3069451 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2004 CA Refinance - Cash-out - Other Primary No B B B B 5/XX/2017
an application date of 4/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 4/XX/2004.
625488684 XXX XXX XXX 3069452 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2004 CA Refinance - Cash-out - Other Primary No B B B B 5/XX/2017
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488684 XXX XXX XXX 3069453 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2004 5/XX/2005 CA Refinance - Cash-out - Other Primary No B B B B 5/XX/2017
Loan Application Date.
625489162 XXX XXX XXX 3934266 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 4/XX/2007 IN Purchase Investment Yes B B B B 8/XX/2017
625489162 XXX XXX XXX 3934267 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2007 IN Purchase Investment Yes B B B B 8/XX/2017
an application date of 03/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2006.
625489162 XXX XXX XXX 3946087 compliance 2 Missing Document: Missing Lender's Initial 1003 4/XX/2007 IN Purchase Investment Yes B B B B 8/XX/2017
625488189 XXX XXX XXX 3926064 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2005 8/XX/2006 OH Refinance - Cash-out - Debt Consolidation Primary No B B B B 8/XX/2017
borrower within three (3) days of application.
625488189 XXX XXX XXX 3926065 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2005 8/XX/2006 OH Refinance - Cash-out - Debt Consolidation Primary No B B B B 8/XX/2017
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625489699 XXX XXX XXX 3925636 compliance 3 (Missing Doc) Incomplete loan images/file Incomplete Loan File. Note, Security and Final Title in the file, unable to run UTD 12/XX/2006 CA Refinance Primary No D D D D 9/XX/2017
compliance.
625488406 XXX XXX XXX 4254368 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. Yes 7/XX/2003 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2017
Security Instrument Notary Date of 07/XX/2003 used as disbursement date for
compliance testing.
625488406 XXX XXX XXX 4254369 compliance 3 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable Yes 7/XX/2003 CA Refinance - Cash-out - Debt Consolidation Primary No D D D D 9/XX/2017 Yes 2017/XX/08: Received page 1 of HUD. 2017/XX/08: Received page 1 of HUD. Missing all fees and required information
Federal, State or Local compliance testing is unreliable. from other pages of HUD, so exception will remain.
625488406 XXX XXX XXX 4254370 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 7/XX/2003 7/XX/2004 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2017
borrower.
625488406 XXX XXX XXX 4254371 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 7/XX/2003 7/XX/2004 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2017
CHARM Booklet, not provided to the borrower.
625488406 XXX XXX XXX 4254372 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. Yes 7/XX/2003 7/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2017
625488406 XXX XXX XXX 4254373 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a Yes 7/XX/2003 7/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2017
defense to foreclosure. Assignee liability.
625488406 XXX XXX XXX 4254375 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver Yes 7/XX/2003 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2017
following clauses:
625488406 XXX XXX XXX 4254377 compliance 2 (Doc Error) Initial GFE not provided Yes 7/XX/2003 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2017
625487931 XXX XXX XXX 4254744 compliance 2 (Doc Error) Initial GFE not provided 7/XX/2003 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
625487931 XXX XXX XXX 4254784 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2003 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
an application date of 06/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2003.
625487931 XXX XXX XXX 4254785 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2003 7/XX/2004 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
borrower.
625487931 XXX XXX XXX 4254786 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2003 7/XX/2004 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
CHARM Booklet, not provided to the borrower.
625487931 XXX XXX XXX 4254787 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 7/XX/2003 7/XX/2006 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
625487931 XXX XXX XXX 4254788 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2003 7/XX/2006 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
defense to foreclosure. Assignee liability.
625487931 XXX XXX XXX 4266569 compliance 2 Missing Document: Missing Lender's Initial 1003 7/XX/2003 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
625487931 XXX XXX XXX 4266570 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2003 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
Disclosure to borrower. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488893 XXX XXX XXX 4260306 compliance 2 Missing Document: Missing Lender's Initial 1003 5/XX/2003 TX Purchase Primary No B B B B 9/XX/2017
625488893 XXX XXX XXX 4260308 credit 3 Missing Document: Missing Final 1003 5/XX/2003 TX Purchase Primary No C C C C 9/XX/2017
625488893 XXX XXX XXX 4260686 compliance 2 (Doc Error) Initial GFE not provided 5/XX/2003 TX Purchase Primary No B B B B 9/XX/2017
625488893 XXX XXX XXX 4260778 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2003 TX Purchase Primary No B B B B 9/XX/2017
an application date of 04/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2002.
625488893 XXX XXX XXX 4260780 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2003 5/XX/2004 TX Purchase Primary No B B B B 9/XX/2017
borrower.
625488893 XXX XXX XXX 4260781 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2003 5/XX/2004 TX Purchase Primary No B B B B 9/XX/2017
CHARM Booklet, not provided to the borrower.
625488893 XXX XXX XXX 4260782 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2003 5/XX/2004 TX Purchase Primary No B B B B 9/XX/2017
defense to foreclosure. Assignee liability.
625488893 XXX XXX XXX 4266826 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 5/XX/2003 TX Purchase Primary No B B B B 9/XX/2017
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489367 XXX XXX XXX 4254696 credit 3 Missing Document: Missing Final 1003 5/XX/2003 CA Refinance - Cash-out - Other Primary No C C C C 9/XX/2017
625489367 XXX XXX XXX 4254766 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 5/XX/2003 CA Refinance - Cash-out - Other Primary No B B B B 9/XX/2017
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489367 XXX XXX XXX 4254777 compliance 2 (Doc Error) Initial GFE not provided 5/XX/2003 CA Refinance - Cash-out - Other Primary No B B B B 9/XX/2017
625489367 XXX XXX XXX 4254802 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2003 CA Refinance - Cash-out - Other Primary No B B B B 9/XX/2017
an application date of 04/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2002.
625489367 XXX XXX XXX 4254806 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 5/XX/2003 5/XX/2006 CA Refinance - Cash-out - Other Primary No B B B B 9/XX/2017
625489367 XXX XXX XXX 4254807 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2003 5/XX/2006 CA Refinance - Cash-out - Other Primary No B B B B 9/XX/2017
defense to foreclosure. Assignee liability.
625489367 XXX XXX XXX 4254810 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2003 5/XX/2004 CA Refinance - Cash-out - Other Primary No B B B B 9/XX/2017
CHARM Booklet, not provided to the borrower.
625489367 XXX XXX XXX 4266608 compliance 2 Missing Document: Missing Lender's Initial 1003 5/XX/2003 CA Refinance - Cash-out - Other Primary No B B B B 9/XX/2017
625488673 XXX XXX XXX 4254597 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2003 4/XX/2004 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
borrower.
625488673 XXX XXX XXX 4254598 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2003 4/XX/2004 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
CHARM Booklet, not provided to the borrower.
625487928 XXX XXX XXX 4254748 credit 3 Missing Document: Missing Final 1003 5/XX/2003 CA Refinance - Cash-out - Other Primary No C C C C 9/XX/2017
625487928 XXX XXX XXX 4254852 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2003 CA Refinance - Cash-out - Other Primary No B B B B 9/XX/2017
an application date of 04/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2002.
625487928 XXX XXX XXX 4254853 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2003 5/XX/2004 CA Refinance - Cash-out - Other Primary No B B B B 9/XX/2017
borrower.
625487928 XXX XXX XXX 4254854 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2003 5/XX/2004 CA Refinance - Cash-out - Other Primary No B B B B 9/XX/2017
CHARM Booklet, not provided to the borrower.
625487928 XXX XXX XXX 4254855 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 5/XX/2003 5/XX/2006 CA Refinance - Cash-out - Other Primary No B B B B 9/XX/2017
625487928 XXX XXX XXX 4254856 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2003 5/XX/2006 CA Refinance - Cash-out - Other Primary No B B B B 9/XX/2017
defense to foreclosure. Assignee liability.
625487928 XXX XXX XXX 4254860 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 5/XX/2003 CA Refinance - Cash-out - Other Primary No B B B B 9/XX/2017
an assumed value of a contract sales price or original loan amount, whichever
applies.
625487928 XXX XXX XXX 4254876 compliance 2 (Doc Error) Initial GFE not provided 5/XX/2003 CA Refinance - Cash-out - Other Primary No B B B B 9/XX/2017
625487928 XXX XXX XXX 4266682 compliance 2 Missing Document: Missing Lender's Initial 1003 5/XX/2003 CA Refinance - Cash-out - Other Primary No B B B B 9/XX/2017
625489687 XXX XXX XXX 4254639 credit 3 Missing Document: Missing Final 1003 5/XX/2003 CA Refinance - Rate/Term Primary No C C C C 9/XX/2017
625489687 XXX XXX XXX 4254640 compliance 2 Missing Document: Missing Lender's Initial 1003 5/XX/2003 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
625489687 XXX XXX XXX 4254646 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 5/XX/2003 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489687 XXX XXX XXX 4254650 compliance 2 (Doc Error) Initial GFE not provided 5/XX/2003 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
625489687 XXX XXX XXX 4254661 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2003 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
an application date of 04/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2002.
625489687 XXX XXX XXX 4254662 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2003 5/XX/2004 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
borrower.
625489687 XXX XXX XXX 4254663 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2003 5/XX/2004 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
CHARM Booklet, not provided to the borrower.
625489687 XXX XXX XXX 4254664 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 5/XX/2003 5/XX/2006 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
625489687 XXX XXX XXX 4254665 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2003 5/XX/2006 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
defense to foreclosure. Assignee liability.
625489495 XXX XXX XXX 4259785 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2003 5/XX/2004 OK Refinance - Rate/Term Primary No B B B B 9/XX/2017
borrower.
625489495 XXX XXX XXX 4259786 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2003 5/XX/2004 OK Refinance - Rate/Term Primary No B B B B 9/XX/2017
CHARM Booklet, not provided to the borrower.
625489495 XXX XXX XXX 4259787 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine the reason for the under disclosure due to missing the $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 5/XX/2003 5/XX/2006 OK Refinance - Rate/Term Primary No B B B B 9/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. itemization of amount financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489633 XXX XXX XXX 4258783 credit 3 Missing Document: Missing Final 1003 5/XX/2003 CA Refinance - Rate/Term Primary No C C C C 9/XX/2017
625489633 XXX XXX XXX 4259489 compliance 2 (Doc Error) Initial GFE not provided 5/XX/2003 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
625489633 XXX XXX XXX 4259499 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2003 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
an application date of 04/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2002.
625489633 XXX XXX XXX 4259501 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2003 5/XX/2004 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
borrower.
625489633 XXX XXX XXX 4259503 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2003 5/XX/2004 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
CHARM Booklet, not provided to the borrower.
625489633 XXX XXX XXX 4259505 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 5/XX/2003 5/XX/2006 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
625489633 XXX XXX XXX 4259506 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2003 5/XX/2006 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
defense to foreclosure. Assignee liability.
625489633 XXX XXX XXX 4266863 compliance 2 Missing Document: Missing Lender's Initial 1003 5/XX/2003 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
625489633 XXX XXX XXX 4266864 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 5/XX/2003 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489633 XXX XXX XXX 4266883 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2003 CA Refinance - Rate/Term Primary No B B B B 9/XX/2017
Disclosure to borrower. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489460 XXX XXX XXX 4255604 credit 3 Missing Document: Missing Final 1003 Yes 12/XX/2001 GA Refinance - Rate/Term Primary No C C C C 9/XX/2017
625489460 XXX XXX XXX 4255605 compliance 2 Missing Document: Missing Lender's Initial 1003 Yes 12/XX/2001 GA Refinance - Rate/Term Primary No B B B B 9/XX/2017
625489460 XXX XXX XXX 4255739 compliance 2 (Doc Error) Initial GFE not provided Yes 12/XX/2001 GA Refinance - Rate/Term Primary No B B B B 9/XX/2017
625489460 XXX XXX XXX 4255826 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using Yes 12/XX/2001 GA Refinance - Rate/Term Primary No B B B B 9/XX/2017
an application date of 11/XX/2001 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2001.
625489460 XXX XXX XXX 4255827 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 12/XX/2001 12/XX/2002 GA Refinance - Rate/Term Primary No B B B B 9/XX/2017
borrower.
625489460 XXX XXX XXX 4255828 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 12/XX/2001 12/XX/2002 GA Refinance - Rate/Term Primary No B B B B 9/XX/2017
CHARM Booklet, not provided to the borrower.
625489460 XXX XXX XXX 4255829 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. Yes 12/XX/2001 12/XX/2004 GA Refinance - Rate/Term Primary No B B B B 9/XX/2017
625489460 XXX XXX XXX 4255830 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a Yes 12/XX/2001 12/XX/2004 GA Refinance - Rate/Term Primary No B B B B 9/XX/2017
defense to foreclosure. Assignee liability.
625489460 XXX XXX XXX 4266859 compliance 3 Missing Final HUD-1: HUD-1 Not Signed or Stamped Used For Fee Testing Missing Final HUD-1: HUD-1 Not Signed or Stamped used for any applicable Yes 12/XX/2001 GA Refinance - Rate/Term Primary No D D D D 9/XX/2017 Yes 2017/XX/08: Received page 1 of HUD. 2017/XX/08: Received page 1 of HUD. Missing all fees and needed information so
Federal, State or Local compliance testing. exception will remain.
625488605 XXX XXX XXX 4354004 credit 3 Missing Document: Missing Final 1003 11/XX/2004 CA Purchase Primary No C C C C 9/XX/2017
625488605 XXX XXX XXX 4357168 credit 3 FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not FEMA Disaster Date: XX/XX/XXXX 11/XX/2004 CA Purchase Primary No C C C C 9/XX/2017
been inspected.
625488605 XXX XXX XXX 4357286 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2004 CA Purchase Primary No B B B B 9/XX/2017
an application date of 11/XX/2004 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2004.
625488605 XXX XXX XXX 4357287 compliance 2 California Primary Residence Late Charge Percent Testing Note late charge exceeds maximum per state. Erroneous exception- California statute allows for a late charge of up to 6%; 11/XX/2004 CA Purchase Primary No B B B B 9/XX/2017
Note indicates penalty of 5% after 15 days.
625488605 XXX XXX XXX 4357289 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2004 11/XX/2005 CA Purchase Primary No B B B B 9/XX/2017
Loan Application Date.
625488605 XXX XXX XXX 4358761 credit 3 AUS/Guideline Findings: All conditions were not met File does not contain one month's asset statements for all funds used to 11/XX/2004 CA Purchase Primary No C C C C 9/XX/2017
qualify, most recent paystub with 30 days YTD history, and verbal VOE dated
within 10 days of closing as required by AUS findings.
625488605 XXX XXX XXX 4358768 credit 3 Income Docs Missing: Borrower: XXX Paystubs (2004), VVOE - Employment Only (2004) File does not contain most recent paystub with 30 days YTD history and verbal 11/XX/2004 CA Purchase Primary No C C C C 9/XX/2017
VOE dated within 10 days of closing per AUS findings.
625488605 XXX XXX XXX 4359284 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2004 11/XX/2005 CA Purchase Primary No B B B B 9/XX/2017
Loan Application Date.
625488605 XXX XXX XXX 4359285 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Variance is due to lender disclosing Escrow Fee as $XXX vs. $XXX on final HUD-1, $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 11/XX/2004 11/XX/2005 CA Purchase Primary No B B B B 9/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488683 XXX XXX XXX 4355150 credit 3 Missing Document: Missing Final 1003 4/XX/2003 CA Refinance - Cash-out - Other UTD No C C C C 9/XX/2017
625488683 XXX XXX XXX 4355153 credit 3 Missing Document: Credit Report not provided 4/XX/2003 CA Refinance - Cash-out - Other UTD No D D D D 9/XX/2017
625488683 XXX XXX XXX 4355156 credit 3 Missing Document: Flood Certificate not provided 4/XX/2003 CA Refinance - Cash-out - Other UTD No C C C C 9/XX/2017
625488683 XXX XXX XXX 4355157 credit 3 Missing Document: Hazard Insurance Policy not provided 4/XX/2003 CA Refinance - Cash-out - Other UTD No C C C C 9/XX/2017
625488683 XXX XXX XXX 4355159 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2003 CA Refinance - Cash-out - Other UTD No B B B B 9/XX/2017
an application date of 03/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2002.
625488683 XXX XXX XXX 4355161 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2003 4/XX/2004 CA Refinance - Cash-out - Other UTD No B B B B 9/XX/2017
borrower.
625488683 XXX XXX XXX 4355162 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2003 4/XX/2004 CA Refinance - Cash-out - Other UTD No B B B B 9/XX/2017
CHARM Booklet, not provided to the borrower.
625488683 XXX XXX XXX 4355163 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 4/XX/2003 4/XX/2006 CA Refinance - Cash-out - Other UTD No B B B B 9/XX/2017
625488683 XXX XXX XXX 4355164 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 4/XX/2003 4/XX/2006 CA Refinance - Cash-out - Other UTD No B B B B 9/XX/2017
defense to foreclosure. Assignee liability.
625488683 XXX XXX XXX 4355165 credit 3 Hazard Insurance Error: Subject hazard insurance premium is missing from 4/XX/2003 CA Refinance - Cash-out - Other UTD No C C C C 9/XX/2017
evidence of insurance.
625488683 XXX XXX XXX 4355166 credit 3 FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not FEMA Disaster Date: XX/XX/XXXX 4/XX/2003 CA Refinance - Cash-out - Other UTD No C C C C 9/XX/2017
been inspected.
625488683 XXX XXX XXX 4355167 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 4/XX/2003 CA Refinance - Cash-out - Other UTD No B B B B 9/XX/2017
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488683 XXX XXX XXX 4355168 credit 3 Missing Document: Approval not provided 4/XX/2003 CA Refinance - Cash-out - Other UTD No C C C C 9/XX/2017
625488683 XXX XXX XXX 4355169 credit 3 Missing Document: Mortgage Loan Payoff Statement not provided 4/XX/2003 CA Refinance - Cash-out - Other UTD No C C C C 9/XX/2017
625488683 XXX XXX XXX 4355171 compliance 2 (Doc Error) Initial GFE not provided 4/XX/2003 CA Refinance - Cash-out - Other UTD No B B B B 9/XX/2017
625488683 XXX XXX XXX 4355173 compliance 2 Unable to determine occupancy, compliance results were generated using a 4/XX/2003 CA Refinance - Cash-out - Other UTD No B B B B 9/XX/2017
defaulted value of Primary.
625488683 XXX XXX XXX 4355174 credit 3 The hazard insurance policy does not reflect the Lender as Payee. 4/XX/2003 CA Refinance - Cash-out - Other UTD No C C C C 9/XX/2017
625488683 XXX XXX XXX 4355182 compliance 2 California Primary Residence Late Charge Percent Testing Note late charge exceeds maximum per state. 4/XX/2003 CA Refinance - Cash-out - Other UTD No B B B B 9/XX/2017
625489254 XXX XXX XXX 6298024 credit 3 Missing Document: Missing Final 1003 Yes 2/XX/2007 NE Refinance - UTD Primary No C C C C 4/XX/2018
625489254 XXX XXX XXX 6298472 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. Yes 2/XX/2007 NE Refinance - UTD Primary No B B B B 4/XX/2018
Security Instrument Notary Date of 02/XX/2007 used as disbursement date for
compliance testing.
625489254 XXX XXX XXX 6298474 compliance 3 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable Yes 2/XX/2007 NE Refinance - UTD Primary No D D D D 4/XX/2018
Federal, State or Local compliance testing is unreliable.
625489254 XXX XXX XXX 6298475 compliance 2 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using Yes 2/XX/2007 NE Refinance - UTD Primary No B B B B 4/XX/2018
an application date of 01/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/2006. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625489254 XXX XXX XXX 6298476 compliance 2 (Missing Data) Missing Information to Determine Origination Channel Unable to determine the origination channel based on the loan documents provided Yes 2/XX/2007 NE Refinance - UTD Primary No B B B B 4/XX/2018
for review. The compliance review was performed with using the equivalent
evaluation that would be considered for an Origination Channel of Retail.
625489254 XXX XXX XXX 6298479 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. Yes 2/XX/2007 2/XX/2010 NE Refinance - UTD Primary No B B B B 4/XX/2018
625489254 XXX XXX XXX 6298480 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a Yes 2/XX/2007 2/XX/2010 NE Refinance - UTD Primary No B B B B 4/XX/2018
defense to foreclosure. Assignee liability.
625489254 XXX XXX XXX 6298609 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off Yes 2/XX/2007 NE Refinance - UTD Primary No B B B B 4/XX/2018
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489254 XXX XXX XXX 6298647 compliance 2 (Doc Error) Initial GFE not provided Yes 2/XX/2007 NE Refinance - UTD Primary No B B B B 4/XX/2018
625488438 XXX XXX XXX 10024098 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 2/XX/2007 MD Purchase Primary No B B B B 1/XX/2019
625488438 XXX XXX XXX 10024099 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2007 MD Purchase Primary No B B B B 1/XX/2019
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488438 XXX XXX XXX 10024100 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing Itemization of Amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 2/XX/2007 2/XX/2008 MD Purchase Primary No B B B B 1/XX/2019
calculated Finance Charge of $XXX in the amount of $XXX. Financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488438 XXX XXX XXX 10024101 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2007 MD Purchase Primary No B B B B 1/XX/2019
an application date of 01/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 12/XX/2006.
625488438 XXX XXX XXX 10024102 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2007 MD Purchase Primary No B B B B 1/XX/2019
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488597 XXX XXX XXX 10031745 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 12/XX/2006 CA Refinance - Rate/Term Primary No B B B B 1/XX/2019
an application date of 11/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2006.
625488597 XXX XXX XXX 10031746 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2006 CA Refinance - Rate/Term Primary No B B B B 1/XX/2019
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488597 XXX XXX XXX 10031747 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2006 12/XX/2007 CA Refinance - Rate/Term Primary No B B B B 1/XX/2019
Loan Application Date.
625488597 XXX XXX XXX 10031748 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2006 12/XX/2007 CA Refinance - Rate/Term Primary No B B B B 1/XX/2019
Loan Application Date.
625489053 XXX XXX XXX 10522693 credit 3 Missing Document: Missing Final 1003 12/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No C C C C 2/XX/2019
625489053 XXX XXX XXX 10524105 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 12/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 2/XX/2019
Security Instrument Notary Date of 12/XX/2007 used as disbursement date for
compliance testing.
625489053 XXX XXX XXX 10524106 compliance 1 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable 12/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No A A A A 2/XX/2019 2/XX/2019 Yes 2019/XX/23: Received Final HUD, exception cleared.
Federal, State or Local compliance testing is unreliable.
625489053 XXX XXX XXX 10524107 compliance 1 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using 12/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No A A A A 2/XX/2019 2/XX/2019 Yes 2019/XX/23: Received Final HUD, exception cleared.
an application date of 11/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2007. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625489053 XXX XXX XXX 10524108 compliance 2 Property Type Not Provided (Missing Data) Property Type. If property type is other than single family 12/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 2/XX/2019
residence, state and federal testing may be impacted.
625489053 XXX XXX XXX 10524109 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 12/XX/2007 12/XX/2010 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 2/XX/2019
625489053 XXX XXX XXX 10524110 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 12/XX/2007 12/XX/2010 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 2/XX/2019
defense to foreclosure. Assignee liability.
625489053 XXX XXX XXX 10524220 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 12/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 2/XX/2019
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489053 XXX XXX XXX 10524250 compliance 2 (Doc Error) Initial GFE not provided 12/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 2/XX/2019
625489053 XXX XXX XXX 10782401 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 12/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 2/XX/2019
an application date of 11/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2007.
625489178 XXX XXX XXX 13890904 credit 3 Missing Document: Missing Final 1003 5/XX/2007 NJ Refinance - Cash-out - Other Primary Yes C C C C 9/XX/2019
625489178 XXX XXX XXX 13891182 compliance 2 (Doc Error) Initial GFE not provided 5/XX/2007 NJ Refinance - Cash-out - Other Primary Yes B B B B 9/XX/2019
625489178 XXX XXX XXX 13891184 credit 3 Final Title Policy is missing. No evidence of title in file. 5/XX/2007 NJ Refinance - Cash-out - Other Primary Yes C C C C 9/XX/2019
625489178 XXX XXX XXX 13891271 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2007 NJ Refinance - Cash-out - Other Primary Yes B B B B 9/XX/2019
an application date of 04/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625489178 XXX XXX XXX 13891272 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2007 NJ Refinance - Cash-out - Other Primary Yes B B B B 9/XX/2019
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625489178 XXX XXX XXX 13904242 compliance 2 (Missing Data) Unable to determine if loan is a same lender refi Original Lender was not able to be determined. Unable to determine if correct 5/XX/2007 5/XX/2010 NJ Refinance - Cash-out - Other Primary Yes B B B B 9/XX/2019
TILA rescission form was used.
625489178 XXX XXX XXX 13904243 compliance 2 Right of Rescission Timing - Receipt Date Missing Missing RTC Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. 5/XX/2007 5/XX/2010 NJ Refinance - Cash-out - Other Primary Yes B B B B 9/XX/2019
timing requirements.
625489178 XXX XXX XXX 13904244 compliance 2 Notice of Right To Cancel Not Provided to All Required Parties Truth in Lending Act: Notice of Right to Cancel was not signed by all parties TILA ROR - 3yrs for rescindable transactions. 5/XX/2007 5/XX/2010 NJ Refinance - Cash-out - Other Primary Yes B B B B 9/XX/2019
whose ownership interest is or will be subject to the security interest.
625488617 XXX XXX XXX 14189679 credit 3 Missing Document: Missing Final 1003 10/XX/2006 IL Refinance - Cash-out - Other Primary No C C C C 8/XX/2019
625488617 XXX XXX XXX 14189680 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 10/XX/2006 IL Refinance - Cash-out - Other Primary No B B B B 8/XX/2019
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488617 XXX XXX XXX 14189681 credit 3 Final Title Policy is missing. No evidence of title in file. File does not contain either Preliminary or Final Title. 10/XX/2006 IL Refinance - Cash-out - Other Primary No C C C C 8/XX/2019
625488617 XXX XXX XXX 14189682 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 10/XX/2006 IL Refinance - Cash-out - Other Primary No B B B B 8/XX/2019
Security Instrument Notary Date of 10/XX/2006 used as disbursement date for
compliance testing.
625488617 XXX XXX XXX 14189683 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 10/XX/2006 10/XX/2009 IL Refinance - Cash-out - Other Primary No B B B B 8/XX/2019
625488617 XXX XXX XXX 14189684 compliance 2 TILA HELOC - HELOC Brochure Not Provided Timely Unable to determine compliance with timing requirements due to missing Initial TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2006 10/XX/2009 IL Refinance - Cash-out - Other Primary No B B B B 8/XX/2019
Loan Application Date. defense to foreclosure. Assignee liability.
625488617 XXX XXX XXX 14189686 compliance 2 TILA HELOC - Important Terms Disclosure Not Provided Timely Unable to determine compliance with timing requirements due to missing Initial TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2006 10/XX/2009 IL Refinance - Cash-out - Other Primary No B B B B 8/XX/2019
Loan Application Date. defense to foreclosure. Assignee liability.
625488617 XXX XXX XXX 14189687 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2006 IL Refinance - Cash-out - Other Primary No B B B B 8/XX/2019
an application date of 09/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2006.
625488370 XXX XXX XXX 14213372 credit 3 Missing Document: Missing Final 1003 2/XX/2005 NJ Refinance - UTD Primary Yes C C C C 8/XX/2019
625488370 XXX XXX XXX 14213373 compliance 2 TILA HELOC - HELOC Brochure Missing Truth in Lending Act (HELOC): HELOC Brochure not provided to borrower. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 2/XX/2005 2/XX/2008 NJ Refinance - UTD Primary Yes B B B B 8/XX/2019
defense to foreclosure. Assignee liability.
625488370 XXX XXX XXX 14213374 compliance 2 TILA HELOC - Important Terms Disclosure Missing Truth in Lending Act (HELOC): "Important Terms" disclosure not provided to TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 2/XX/2005 2/XX/2008 NJ Refinance - UTD Primary Yes B B B B 8/XX/2019
borrower. defense to foreclosure. Assignee liability.
625488370 XXX XXX XXX 14213375 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2005 NJ Refinance - UTD Primary Yes B B B B 8/XX/2019
an application date of 01/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625488370 XXX XXX XXX 14213376 compliance 2 Property Type Not Provided (Missing Data) Property Type. If property type is other than single family 2/XX/2005 NJ Refinance - UTD Primary Yes B B B B 8/XX/2019
residence, state and federal testing may be impacted.
625488370 XXX XXX XXX 14213377 compliance 3 New Jersey Home Loan (Late Charge) Unable to determine if loan contains an impermissible late charge due to missing Assignee Liability: Assignees and purchasers of New Jersey high cost home loans 2/XX/2005 NJ Refinance - UTD Primary Yes C C C C 8/XX/2019
information. are subject to all affirmative claims and any defenses with respect to the loan
that the borrower could assert against the original creditor of the loan.
Section 6(c) of the Act also provides that a borrower acting only in an
individual capacity may assert against the creditor or any subsequent holder or
assignee: (1) Within six years of the closing of covered home loan, a violation
of the Act as an original action or as a defense, claim, or counterclaim; and
(2) At any time during the term of a high cost home loan a defense, claim or
counterclaim. The aforementioned may both be brought after an action to collect
on the home loan or foreclose on the collateral securing the home loan has been
initiated, the debt arising from the home loan has been accelerated, or the home
loan has become 60 days in default. Further, the Act contains a choice of law
provision permitting actions under either the New Jersey Consumer Fraud Act
("NJCFA"), which possibly allow for class actions, or the Act. The July 6, 2004
amendments clarify that a defense, claim, or counterclaim may only be brought in
an individual capacity and may not be asserted in a class action. Additionally,
the statute provides for punitive damages.
625488370 XXX XXX XXX 14213380 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 2/XX/2005 2/XX/2008 NJ Refinance - UTD Primary Yes B B B B 8/XX/2019
625488370 XXX XXX XXX 14213383 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 2/XX/2005 NJ Refinance - UTD Primary Yes B B B B 8/XX/2019
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488370 XXX XXX XXX 14213385 credit 3 Final Title Policy is missing. No evidence of title in file. File does not contain either Preliminary or Final Title. 2/XX/2005 NJ Refinance - UTD Primary Yes C C C C 8/XX/2019
625488114 XXX XXX XXX 15483057 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TIL in file indicated to be final, expected funding date same as disbursement TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a Yes 11/XX/2006 11/XX/2007 GA Purchase Primary No B B B B
and/or note date but is not signed or dated by borrower so cannot confirm that defense to foreclosure. Assignee liability.
borrower received.
625488114 XXX XXX XXX 15483058 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. Yes 11/XX/2006 GA Purchase Primary No B B B B
Security Instrument Notary Date of 11/XX/2006 used as disbursement date for
compliance testing.
625488114 XXX XXX XXX 15483059 compliance 3 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable Yes 11/XX/2006 GA Purchase Primary No D D D D
Federal, State or Local compliance testing is unreliable.
625488114 XXX XXX XXX 15483061 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 11/XX/2006 11/XX/2007 GA Purchase Primary No B B B B
application due to missing information.
625488114 XXX XXX XXX 15483063 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a Yes 11/XX/2006 11/XX/2007 GA Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625489330 XXX XXX XXX 16450228 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2007 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B 2/XX/2020
an application date of 09/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625488847 XXX XXX XXX 16454590 credit 3 Missing Document: Missing Final 1003 6/XX/2002 OH Refinance - Cash-out - Other Primary No C C C C 2/XX/2020
625488847 XXX XXX XXX 16454705 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2002 OH Refinance - Cash-out - Other Primary No B B B B 2/XX/2020
an application date of 05/XX/2002 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625488847 XXX XXX XXX 16454707 compliance 2 Ohio Prepayment Penalty Ohio Prepayment Penalty: Maximum calculated prepay of $XXX exceeds the state 6/XX/2002 OH Refinance - Cash-out - Other Primary No B B B B 2/XX/2020
maximum of 1% of the original balance ($XXX). Prepay language states prepay will
not exceed maximum permitted by applicable law.
625489205 XXX XXX XXX 18270822 credit 3 Missing Document: Missing Final 1003 9/XX/2004 NY Purchase Primary No C C C C 9/XX/2020
625489205 XXX XXX XXX 18271304 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2004 NY Purchase Primary No B B B B 9/XX/2020
an application date of 08/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625488770 XXX XXX XXX 18271003 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2004 MI Refinance - Cash-out - Other Primary No B B B B 9/XX/2020
an application date of 07/XX/2004 which is 0 months prior to consummation. A
lookback was performed to determine this application date.
625488770 XXX XXX XXX 18271004 compliance 2 Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Unable to determine compliance with timing requirements due to missing Initial Assignee liability is unclear. Purchasers and assignees would not appear to be 7/XX/2004 MI Refinance - Cash-out - Other Primary No B B B B 9/XX/2020
Not Provided Timely) Loan Application Date. liable for violations of the Act, except to the extent involved I violations
arising from servicing or collecting.
625488770 XXX XXX XXX 18271005 compliance 2 Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided Unable to determine compliance with timing requirements due to missing Initial Assignee liability is unclear. Purchasers and assignees would not appear to be 7/XX/2004 MI Refinance - Cash-out - Other Primary No B B B B 9/XX/2020
Timely Loan Application Date. liable for violations of the Act, except to the extent involved I violations
arising from servicing or collecting.
625488770 XXX XXX XXX 18271006 compliance 2 Michigan Consumer Mortgage Protection Act (Counseling Agencies List Timing) Michigan Consumer Mortgage Protection Act: List of HUD-approved credit 7/XX/2004 MI Refinance - Cash-out - Other Primary No B B B B 9/XX/2020
counseling agencies not provided to borrower at the time of application.
625487944 XXX XXX XXX 18278418 credit 3 Missing Document: Missing Final 1003 7/XX/1998 WV Refinance - Cash-out - Other Primary No C C C C 9/XX/2020
625487944 XXX XXX XXX 18278742 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/1998 WV Refinance - Cash-out - Other Primary No B B B B 9/XX/2020
an application date of 07/XX/1998 which is 0 months prior to consummation. A
lookback was performed to determine this application date.
625487944 XXX XXX XXX 18278743 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 7/XX/1998 7/XX/2001 WV Refinance - Cash-out - Other Primary No B B B B 9/XX/2020
calculated Finance Charge of $XXX in the amount of $XXX. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625487944 XXX XXX XXX 18278744 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 07/XX/1998, prior to TILA ROR - 3yrs for rescindable transactions. 7/XX/1998 7/XX/2001 WV Refinance - Cash-out - Other Primary No B B B B 9/XX/2020
Date three (3) business days from transaction date of 07/XX/1998.
625487944 XXX XXX XXX 18278752 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 7/XX/1998 WV Refinance - Cash-out - Other Primary No B B B B 9/XX/2020
an assumed value of a contract sales price or original loan amount, whichever
applies.
625487944 XXX XXX XXX 18278753 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 7/XX/1998 WV Refinance - Cash-out - Other Primary No B B B B 9/XX/2020
following clauses:
625489052 XXX XXX XXX 18364284 compliance 2 (Doc Error) Initial GFE not provided 9/XX/2001 WA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489052 XXX XXX XXX 18364285 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2001 WA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 08/XX/2001 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625489052 XXX XXX XXX 18364286 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 9/XX/2001 9/XX/2004 WA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489052 XXX XXX XXX 18364287 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2001 9/XX/2004 WA Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625489052 XXX XXX XXX 18364288 credit 3 Missing Document: Credit Report not provided 9/XX/2001 WA Refinance - Cash-out - Debt Consolidation Primary No D D D D
625488834 XXX XXX XXX 18366516 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2002 5/XX/2005 TX Refinance - Rate/Term Primary No B B B B
defense to foreclosure. Assignee liability.
625488834 XXX XXX XXX 18366517 credit 3 Missing Document: Appraisal not provided Valuation Type: Stated / Valuation Report Date: <empty> 5/XX/2002 TX Refinance - Rate/Term Primary No D D D D
625488834 XXX XXX XXX 18366518 compliance 2 Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. 5/XX/2002 5/XX/2005 TX Refinance - Rate/Term Primary No B B B B
timing requirements.
625489165 XXX XXX XXX 18368927 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from The under disclosure is payment stream related due to lender's TIL reflecting MI $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 1/XX/2003 1/XX/2004 FL Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. being in force for 126 months, however based on loan amount and appraised value for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
the MI would be in force for 138 months. liability.
625488961 XXX XXX XXX 18374488 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2004 NY Purchase Primary No B B B B
an application date of 06/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625488961 XXX XXX XXX 18374489 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2004 7/XX/2005 NY Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625489172 XXX XXX XXX 18377151 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2005 FL Purchase Second Home No B B B B
an application date of 10/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625489172 XXX XXX XXX 18377152 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2005 11/XX/2006 FL Purchase Second Home No B B B B
defense to foreclosure. Assignee liability.
625488071 XXX XXX XXX 18377828 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 02/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625488071 XXX XXX XXX 18377829 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625489363 XXX XXX XXX 18382097 credit 3 Missing Document: Missing Final 1003 5/XX/2007 AZ Purchase Primary No C C C C
625489363 XXX XXX XXX 18382098 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 5/XX/2007 AZ Purchase Primary No B B B B
625489363 XXX XXX XXX 18382099 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2007 AZ Purchase Primary No B B B B
an application date of 05/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625489363 XXX XXX XXX 18382100 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2007 6/XX/2008 AZ Purchase Primary No B B B B
application due to missing information.
625489363 XXX XXX XXX 18382101 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2007 6/XX/2008 AZ Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489363 XXX XXX XXX 18382102 credit 3 Missing Document: Credit Report not provided 5/XX/2007 AZ Purchase Primary No D D D D
625489449 XXX XXX XXX 18383754 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 9/XX/2007 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489449 XXX XXX XXX 18383755 compliance 2 (Missing Data) Last Rate Set Date Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario 9/XX/2007 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
between Creditor Application Date and Transaction Date used to determine rate
used for testing.
625489449 XXX XXX XXX 18383756 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2007 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 08/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625489449 XXX XXX XXX 18383757 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2007 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625489449 XXX XXX XXX 18383758 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2007 9/XX/2008 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625489449 XXX XXX XXX 18383759 compliance 2 CHARM Booklet Disclosure Prior to Closing Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2007 9/XX/2008 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
CHARM Booklet, not provided to the borrower at least three (3) days prior to
consummation for a loan that did not start as an ARM.
625489428 XXX XXX XXX 18384413 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 12/XX/2007 TX Purchase Primary No B B B B
625488337 XXX XXX XXX 18385497 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2008 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488337 XXX XXX XXX 18385498 credit 3 Missing Document: Appraisal not provided Valuation Type: Stated / Valuation Report Date: 04/XX/2008 5/XX/2008 IL Refinance - Cash-out - Debt Consolidation Primary No D D D D
625488805 XXX XXX XXX 18385979 compliance 2 Washington Residential Mortgage Loan (Disclosure of Material Terms Not Provided) Washington HB 2770: Mortgage loan file does not contain a disclosure summary of The Act does not appear to provide for assignee liability. 1/XX/2009 WA Refinance - Rate/Term Primary No B B B B
all material terms provided to borrower.
625488575 XXX XXX XXX 18387748 compliance 2 (Doc Error) GFE Error: There is no evidence that the interest rate was locked 11/XX/2011 FL Refinance - Rate/Term Primary No B B B B
prior to closing
625488575 XXX XXX XXX 18387749 compliance 2 (Missing Data) Last Rate Set Date Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario 11/XX/2011 FL Refinance - Rate/Term Primary No B B B B
between Creditor Application Date and Transaction Date used to determine rate
used for testing.
625488575 XXX XXX XXX 18387750 compliance 2 SAFE Act - NMLS Info Not in File Secure and Fair Enforcement for Mortgage Licensing Act: NMLSR information not Liability appears to be limited to originators/licensees. 11/XX/2011 FL Refinance - Rate/Term Primary No B B B B
present on loan application.
625488575 XXX XXX XXX 18387751 compliance 2 RESPA (2010) - Loan Amount on Final GFE Inaccurate RESPA (2010): Loan Amount on Final GFE does not match Note. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2011 FL Refinance - Rate/Term Primary No B B B B
within the statute or implementing regulation, Regulation X, for these type of
violations.
625488575 XXX XXX XXX 18387752 compliance 2 RESPA (2010) - Initial Payment on GFE Inaccurate RESPA (2010): Initial payment on GFE does not match actual payment on loan. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2011 FL Refinance - Rate/Term Primary No B B B B
within the statute or implementing regulation, Regulation X, for these type of
violations.
625488575 XXX XXX XXX 18387753 compliance 2 RESPA - Initial Escrow Account statement Inaccurate RESPA: Initial escrow account statement does not match charges on HUD-1/Final RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2011 FL Refinance - Rate/Term Primary No B B B B
Closing Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488575 XXX XXX XXX 18387754 compliance 2 RESPA Servicing Disclosure: Servicing Disclosure Statement Missing RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2011 FL Refinance - Rate/Term Primary No B B B B
Statement. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488826 XXX XXX XXX 18389018 credit 3 Missing Document: Appraisal not provided Valuation Type: Stated / Valuation Report Date: <empty> 6/XX/2012 FL Refinance - Rate/Term Investment No D D D D
625488994 XXX XXX XXX 18391066 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA Disaster area. Provide a post-disaster 6/XX/2015 TX Purchase Primary No C C C C Temporary SHQM (GSE/Agency Eligible)
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage to the subject. The inspection must
Disaster Name: XXX include exterior photos of the subject.
Disaster Declaration Date: XX/XX/XXXX
625488994 XXX XXX XXX 18391067 property 1 Loan is to go in a securitization and reflects only one valuation product when 6/XX/2015 TX Purchase Primary No C C C C Temporary SHQM (GSE/Agency Eligible) 2020/XX/24: Regraded to EV1
two are required.
625488994 XXX XXX XXX 18391068 compliance 2 RESPA Disclosure - HUD Settlement Cost Booklet Missing RESPA Disclosure Rule: Creditor did not provide HUD Settlement Cost Booklet. No evidence Borrower received disclosure RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2015 TX Purchase Primary No B B B B Temporary SHQM (GSE/Agency Eligible)
within the statute or implementing regulation, Regulation X, for these type of
violations.
625488994 XXX XXX XXX 18391069 compliance 2 2011 TIL-MDIA ARM Introductory Rate Disclosure - Discounted Interest Rate Fully Truth in Lending Act (MDIA 2011): The fully-indexed rate on the Final TIL does The fully-indexed rate on the Final TIL does not match the fully-indexed rate TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2015 6/XX/2016 TX Purchase Primary No B B B B Temporary SHQM (GSE/Agency Eligible)
Indexed Rate Inaccurate not match the fully-indexed rate for the loan. for the loan. Fully indexed rate disclosed on final TIL states XX.XX and system defense to foreclosure. Assignee liability.
states XXXX. Difference is due to rounding.
625488994 XXX XXX XXX 18391070 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, No evidence Borrower received disclosure TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2015 6/XX/2016 TX Purchase Primary No B B B B Temporary SHQM (GSE/Agency Eligible)
CHARM Booklet, not provided to the borrower.
625488994 XXX XXX XXX 18391071 credit 2 The Investor's qualifying total debt ratio is less than the QM qualifying total Investor's qualifying DTI: 25.94132% Tax certificate (D0190) which shows taxes at an annual amount of $XXX. 6/XX/2015 TX Purchase Primary No B B B B Temporary SHQM (GSE/Agency Eligible)
debt ratio. QM qualifying DTI: 28.85902%
625489012 XXX XXX XXX 18763477 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 4/XX/2004 MI Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625489012 XXX XXX XXX 18763478 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2004 MI Purchase Primary No B B B B 10/XX/2017
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489012 XXX XXX XXX 18763479 compliance 2 ARM Disclosure Compliant TIL variable rate disclosure: ARM loan program disclosure does not match terms TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2004 4/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
of loan.
625489012 XXX XXX XXX 18763480 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2004 4/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625489012 XXX XXX XXX 18763481 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2004 4/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489012 XXX XXX XXX 18763482 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 4/XX/2004 4/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488948 XXX XXX XXX 18763695 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2006 7/XX/2007 TX Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488948 XXX XXX XXX 18763696 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 7/XX/2006 TX Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625488948 XXX XXX XXX 18763697 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2006 7/XX/2007 TX Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625488665 XXX XXX XXX 18763754 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 4/XX/2004 OH Refinance - Rate/Term Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625488665 XXX XXX XXX 18763755 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2004 4/XX/2005 OH Refinance - Rate/Term Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488547 XXX XXX XXX 18764114 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 2/XX/2004 KY Refinance - Cash-out - Other Primary Yes C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625488547 XXX XXX XXX 18764115 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Closing instructions indicate the Index used was 1.182%. The lowest Index $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 2/XX/2004 2/XX/2007 KY Refinance - Cash-out - Other Primary Yes B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. available within the Look-back period is 1.19%. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488547 XXX XXX XXX 18764116 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2004 2/XX/2005 KY Refinance - Cash-out - Other Primary Yes B B B B 10/XX/2017
borrower within three (3) days of application.
625488547 XXX XXX XXX 18764117 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2004 2/XX/2005 KY Refinance - Cash-out - Other Primary Yes B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488671 XXX XXX XXX 18764212 compliance 2 Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Michigan Consumer Mortgage Protection Act: Borrower Bill of Rights disclosure Assignee liability is unclear. Purchasers and assignees would not appear to be 1/XX/2004 MI Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
Not Provided Timely) not provided to borrower at the time of application. liable for violations of the Act, except to the extent involved I violations
arising from servicing or collecting.
625488671 XXX XXX XXX 18764213 compliance 2 Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided Michigan Consumer Mortgage Protection Act: Consumer Caution and Home Ownership Assignee liability is unclear. Purchasers and assignees would not appear to be 1/XX/2004 MI Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
Timely Counseling Notice not provided to borrower at the time of application. liable for violations of the Act, except to the extent involved I violations
arising from servicing or collecting.
625488671 XXX XXX XXX 18764214 compliance 2 Michigan Consumer Mortgage Protection Act (Counseling Agencies List) Michigan Consumer Mortgage Protection Act: List of HUD-approved credit 1/XX/2004 MI Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
counseling agencies not provided to borrower.
625488671 XXX XXX XXX 18764215 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2004 1/XX/2005 MI Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625488671 XXX XXX XXX 18764216 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2004 1/XX/2005 MI Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625488671 XXX XXX XXX 18764217 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Closing instructions indicate the Index used was 1.1%. The closest Index $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 1/XX/2004 1/XX/2007 MI Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. available in our look-back period is 1.19%. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488671 XXX XXX XXX 18764218 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 1/XX/2004 MI Refinance - Cash-out - Other Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625488671 XXX XXX XXX 18764219 compliance 2 (Doc Error) Initial GFE not provided 1/XX/2004 MI Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
625488713 XXX XXX XXX 18764239 compliance 2 (Doc Error) Initial GFE not provided 10/XX/2001 NC Purchase Second Home No B B B B 10/XX/2017
625488713 XXX XXX XXX 18764240 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 10/XX/2001 NC Purchase Second Home No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625488713 XXX XXX XXX 18764241 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2001 NC Purchase Second Home No B B B B 10/XX/2017
an application date of 9/XX/2001 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 4/XX/2001.
625488713 XXX XXX XXX 18764242 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL Itemization did not disclose the closing attorney fee of $XXX the attorney $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 10/XX/2001 10/XX/2002 NC Purchase Second Home No B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. review fee of $XXX or the assignment recording fee of $XXX as prepaid finance for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
charges. liability.
625489502 XXX XXX XXX 18764243 credit 3 Missing Document: Flood Certificate not provided 6/XX/2006 IN Purchase Primary Yes C C C C 10/XX/2017
625489502 XXX XXX XXX 18764244 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 6/XX/2006 IN Purchase Primary Yes C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625489502 XXX XXX XXX 18764245 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2006 6/XX/2007 IN Purchase Primary Yes B B B B 10/XX/2017
borrower within three (3) days of application.
625489502 XXX XXX XXX 18764246 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2006 6/XX/2007 IN Purchase Primary Yes B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625489048 XXX XXX XXX 18764416 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2004 1/XX/2005 KY Purchase Primary Yes B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489176 XXX XXX XXX 18764555 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 1/XX/2004 OH Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625489176 XXX XXX XXX 18764556 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 1/XX/2004 OH Purchase Primary No B B B B 10/XX/2017
an application date of 12/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 7/XX/2003.
625489176 XXX XXX XXX 18764557 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2004 1/XX/2005 OH Purchase Primary No B B B B 10/XX/2017
Loan Application Date.
625489176 XXX XXX XXX 18764558 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2004 1/XX/2005 OH Purchase Primary No B B B B 10/XX/2017
Loan Application Date.
625489627 XXX XXX XXX 18764637 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2006 6/XX/2007 MA Refinance - Cash-out - Other Primary Yes B B B B 10/XX/2017
borrower within three (3) days of application.
625489627 XXX XXX XXX 18764638 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2006 6/XX/2007 MA Refinance - Cash-out - Other Primary Yes B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489627 XXX XXX XXX 18764639 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization did not disclose an escrow waiver fee of $XXX as a prepaid $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 6/XX/2006 6/XX/2010 MA Refinance - Cash-out - Other Primary Yes B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. finance charge. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489627 XXX XXX XXX 18764640 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 6/XX/2006 MA Refinance - Cash-out - Other Primary Yes C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625488430 XXX XXX XXX 18764744 credit 3 Missing Document: Flood Certificate not provided 5/XX/2006 UT Purchase Primary No C C C C 10/XX/2017
625488430 XXX XXX XXX 18764745 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2006 UT Purchase Primary No B B B B 10/XX/2017
an application date of 4/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2005.
625489560 XXX XXX XXX 18764990 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 11/XX/2003 MA Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625489560 XXX XXX XXX 18764991 compliance 2 ARM Disclosure Status Unable to determine if loan file contains ARM Disclosure due to missing Date Sent or Date Signed were not provided. TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2003 11/XX/2004 MA Purchase Primary No B B B B 10/XX/2017
information.
625488895 XXX XXX XXX 18765187 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX Tested 5/XX/2006 SC Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625488895 XXX XXX XXX 18765188 credit 3 Missing Document: Missing Final 1003 Tested 5/XX/2006 SC Purchase Primary No C C C C 10/XX/2017
625488895 XXX XXX XXX 18765189 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA Tested 5/XX/2006 5/XX/2007 SC Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625488895 XXX XXX XXX 18765190 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA Tested 5/XX/2006 5/XX/2007 SC Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625488895 XXX XXX XXX 18765191 compliance 3 (Doc Error) HUD Error: Disbursement date is earlier than notary/security Disbursement date: 5/XX/2006. Notary date on the mortgage 5/XX/2006. Tested 5/XX/2006 SC Purchase Primary No C C C C 10/XX/2017
instrument date.
625488895 XXX XXX XXX 18765192 compliance 2 South Carolina Home Loan (Complaint Agency Disclosure Not Provided) South Carolina Home Loan: Borrower not provided with a document specifying the Exceptions occurring more than 6 years ago may be outside the states statute of Tested 5/XX/2006 5/XX/2012 SC Purchase Primary No B B B B 10/XX/2017
agency designated to receive complaints or inquiries about the origination and limitations. Due to the potential remedies available to a court, this exception
making of the loan. carries elevated risk to an assignee during the initial 6 years after occurrence
of the violation. After the expiration of this 6 year period, the exception
retains risk for claims raised as a defense to foreclosure, but not at the same
level as during the initial 6 years for affirmative claims.
625489182 XXX XXX XXX 18765247 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 2/XX/2004 WI Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625489182 XXX XXX XXX 18765248 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2004 2/XX/2005 WI Purchase Primary No B B B B 10/XX/2017
borrower.
625489182 XXX XXX XXX 18765249 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2004 2/XX/2005 WI Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488986 XXX XXX XXX 18765294 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2006 NH Purchase Primary No B B B B 10/XX/2017
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488986 XXX XXX XXX 18765295 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2006 NH Purchase Primary No B B B B 10/XX/2017
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488986 XXX XXX XXX 18765296 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2006 4/XX/2007 NH Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488986 XXX XXX XXX 18765297 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2006 4/XX/2007 NH Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625488986 XXX XXX XXX 18765298 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 4/XX/2006 NH Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625488561 XXX XXX XXX 18765454 compliance 3 Missing Final HUD-1: Estimated HUD-1 Used For Fee Testing Missing Final HUD-1: Estimated HUD-1 used for any applicable Federal, State or Yes 11/XX/2003 AZ Refinance - Cash-out - Debt Consolidation Primary No D D D D 10/XX/2017
Local compliance testing.
625488561 XXX XXX XXX 18765455 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from The itemization of amount financed did not include the wire fee of $XXX the $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years Yes 11/XX/2003 11/XX/2006 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. courier fee of $XXX the application fee of $XXX as prepaid finance charges. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488561 XXX XXX XXX 18765456 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using Yes 11/XX/2003 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B 10/XX/2017
an application date of 11/XX/2003 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2003.
625488561 XXX XXX XXX 18765457 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 11/XX/2003 11/XX/2004 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B 10/XX/2017
Loan Application Date.
625488561 XXX XXX XXX 18765458 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 11/XX/2003 11/XX/2004 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B 10/XX/2017
Loan Application Date.
625489291 XXX XXX XXX 18765627 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure No 3/XX/2008 CA Purchase Primary No B B B B 10/XX/2017
within a reasonably practicable time after using credit score.
625489291 XXX XXX XXX 18765628 compliance 3 Missing Final HUD-1: HUD-1 Not Signed or Stamped Used For Fee Testing Missing Final HUD-1: HUD-1 Not Signed or Stamped used for any applicable No 3/XX/2008 CA Purchase Primary No D D D D 10/XX/2017
Federal, State or Local compliance testing.
625489291 XXX XXX XXX 18765629 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions No 3/XX/2008 CA Purchase Primary No B B B B 10/XX/2017
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489291 XXX XXX XXX 18765630 credit 3 Missing Document: Missing Final 1003 No 3/XX/2008 CA Purchase Primary No C C C C 10/XX/2017
625489291 XXX XXX XXX 18765631 compliance 2 (Doc Error) Initial GFE not provided No 3/XX/2008 CA Purchase Primary No B B B B 10/XX/2017
625489291 XXX XXX XXX 18765632 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using No 3/XX/2008 CA Purchase Primary No B B B B 10/XX/2017
an application date of 2/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 2/XX/2008.
625489291 XXX XXX XXX 18765633 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions No 3/XX/2008 CA Purchase Primary No B B B B 10/XX/2017
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489291 XXX XXX XXX 18765634 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA No 3/XX/2008 3/XX/2009 CA Purchase Primary No B B B B 10/XX/2017
Loan Application Date.
625489291 XXX XXX XXX 18765635 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA No 3/XX/2008 3/XX/2009 CA Purchase Primary No B B B B 10/XX/2017
Loan Application Date.
625489466 XXX XXX XXX 18765886 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2006 4/XX/2007 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489466 XXX XXX XXX 18765887 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 4/XX/2006 NJ Refinance - Cash-out - Debt Consolidation Primary Yes C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625488106 XXX XXX XXX 18765890 compliance 2 ARM Disclosure Status Unable to determine if loan file contains ARM Disclosure due to missing TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2003 8/XX/2004 KY Purchase Primary No B B B B 10/XX/2017
information.
625488106 XXX XXX XXX 18765891 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2003 8/XX/2004 KY Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489562 XXX XXX XXX 18765928 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 9/XX/2003 MI Refinance - Cash-out - Other Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625489562 XXX XXX XXX 18765929 compliance 2 Michigan Consumer Mortgage Protection Act (Counseling Agencies List) Michigan Consumer Mortgage Protection Act: List of HUD-approved credit 9/XX/2003 MI Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
counseling agencies not provided to borrower.
625489562 XXX XXX XXX 18765930 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2003 9/XX/2004 MI Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625488224 XXX XXX XXX 18765987 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2006 3/XX/2007 MN Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625488224 XXX XXX XXX 18765988 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2006 3/XX/2007 MN Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625489451 XXX XXX XXX 18765992 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 8/XX/2003 GA Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625489451 XXX XXX XXX 18765993 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2003 8/XX/2004 GA Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489451 XXX XXX XXX 18765994 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 8/XX/2003 8/XX/2004 GA Purchase Primary No B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488309 XXX XXX XXX 18766024 credit 2 Final Title Policy is missing. No evidence of title was found in file. 2/XX/2008 AZ Purchase Investment No B B B B 10/XX/2017
625489446 XXX XXX XXX 18766078 credit 3 Missing Document: Flood Certificate not provided 2/XX/2006 MA Purchase Primary Yes C C C C 10/XX/2017
625489446 XXX XXX XXX 18766079 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 2/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
625489446 XXX XXX XXX 18766080 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
an application date of 2/XX/2006 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 2/XX/2006.
625489446 XXX XXX XXX 18766081 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2006 2/XX/2007 MA Purchase Primary Yes B B B B 10/XX/2017
Loan Application Date.
625489446 XXX XXX XXX 18766082 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2006 2/XX/2007 MA Purchase Primary Yes B B B B 10/XX/2017
Loan Application Date.
625489446 XXX XXX XXX 18766083 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 2/XX/2006 MA Purchase Primary Yes C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625489446 XXX XXX XXX 18766084 credit 2 Final Title Policy is missing. No evidence of title was found in file. 2/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
625488570 XXX XXX XXX 18766109 credit 3 Missing Document: Flood Certificate not provided 2/XX/2006 AZ Purchase Primary No C C C C 10/XX/2017
625488570 XXX XXX XXX 18766110 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 2/XX/2006 AZ Purchase Primary No B B B B 10/XX/2017
625488570 XXX XXX XXX 18766111 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2006 2/XX/2007 AZ Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625488570 XXX XXX XXX 18766112 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2006 2/XX/2007 AZ Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625488216 XXX XXX XXX 18766338 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2008 MD Refinance - Cash-out - Other Investment No B B B B 10/XX/2017
an application date of 2/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 1/XX/2008.
625488216 XXX XXX XXX 18766339 credit 3 Missing Document: Missing Final 1003 3/XX/2008 MD Refinance - Cash-out - Other Investment No C C C C 10/XX/2017
625489282 XXX XXX XXX 18766500 credit 3 Missing Document: Flood Certificate not provided 1/XX/2006 MD Refinance - Cash-out - Other Primary No C C C C 10/XX/2017
625489282 XXX XXX XXX 18766501 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2006 1/XX/2007 MD Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489396 XXX XXX XXX 18766684 credit 3 Missing Document: Flood Certificate not provided 10/XX/2000 IL Purchase Primary No C C C C 10/XX/2017
625489396 XXX XXX XXX 18766685 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2000 10/XX/2001 IL Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625489396 XXX XXX XXX 18766686 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 10/XX/2000 IL Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625489396 XXX XXX XXX 18766687 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2000 10/XX/2001 IL Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625489573 XXX XXX XXX 18766733 credit 3 Missing Document: Flood Certificate not provided 1/XX/2006 CT Purchase Primary No C C C C 10/XX/2017
625489573 XXX XXX XXX 18766734 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 1/XX/2006 CT Purchase Primary No B B B B 10/XX/2017
625489573 XXX XXX XXX 18766735 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 1/XX/2006 CT Purchase Primary No B B B B 10/XX/2017
an application date of 12/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 7/XX/2005.
625489573 XXX XXX XXX 18766736 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 1/XX/2006 CT Purchase Primary No B B B B 10/XX/2017
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489573 XXX XXX XXX 18766737 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2006 1/XX/2007 CT Purchase Primary No B B B B 10/XX/2017
Loan Application Date.
625489573 XXX XXX XXX 18766738 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2006 1/XX/2007 CT Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489573 XXX XXX XXX 18766739 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 1/XX/2006 CT Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625489573 XXX XXX XXX 18766740 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 1/XX/2006 CT Purchase Primary No C C C C 10/XX/2017
625488035 XXX XXX XXX 18766779 credit 3 Missing Document: Missing Final 1003 Final loan application not found in package 5/XX/2002 OH Refinance - Rate/Term Primary No C C C C 10/XX/2017
625488035 XXX XXX XXX 18766780 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX Loan package from 2002- no inspection from 2006 available 5/XX/2002 OH Refinance - Rate/Term Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625488035 XXX XXX XXX 18766781 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2002 5/XX/2003 OH Refinance - Rate/Term Primary No B B B B 10/XX/2017
borrower.
625488035 XXX XXX XXX 18766782 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2002 5/XX/2003 OH Refinance - Rate/Term Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488035 XXX XXX XXX 18766783 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine as the file did not contain an itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 5/XX/2002 5/XX/2005 OH Refinance - Rate/Term Primary No B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488035 XXX XXX XXX 18766785 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 5/XX/2002, prior to TILA ROR - 3yrs for rescindable transactions. 5/XX/2002 5/XX/2005 OH Refinance - Rate/Term Primary No B B B B 10/XX/2017
Date three (3) business days from transaction date of 5/XX/2002.
625489160 XXX XXX XXX 18766870 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 1/XX/2006 OH Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625489160 XXX XXX XXX 18766871 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 1/XX/2006 OH Purchase Primary No B B B B 10/XX/2017
625489160 XXX XXX XXX 18766872 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2006 1/XX/2007 OH Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488629 XXX XXX XXX 18767094 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 8/XX/2000 TX Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625488629 XXX XXX XXX 18767095 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2000 8/XX/2001 TX Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625489128 XXX XXX XXX 18767382 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 11/XX/2005 MA Refinance - Cash-out - Other Primary Yes C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625489128 XXX XXX XXX 18767383 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2005 MA Refinance - Cash-out - Other Primary Yes B B B B 10/XX/2017
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489128 XXX XXX XXX 18767385 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2005 11/XX/2006 MA Refinance - Cash-out - Other Primary Yes B B B B 10/XX/2017
borrower within three (3) days of application.
625489128 XXX XXX XXX 18767386 compliance 3 Massachusetts Borrower's Interest Tangible Net Benefit Test Massachusetts Home Loan: Unable to determine if mortgage loan was refinanced The regulations do not clarify the enforcement provisions of Mass. Gen. L. c. 11/XX/2005 MA Refinance - Cash-out - Other Primary Yes C C C C 10/XX/2017
within 60 months without providing a tangible net benefit to the borrower due to 183. Accordingly, the consequences of a compliance failure remain unclear. In
missing prior loan information. particular, it is probable that a violation of the "borrower's interest"
standard can be raised as a defense to, or otherwise impede, foreclosure. Also,
it is possible that a violation of the "borrower's interest" standard would
constitute a violation of the Massachusetts unfair and deceptive acts and
practices statute.
625489128 XXX XXX XXX 18767387 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2005 11/XX/2006 MA Refinance - Cash-out - Other Primary Yes B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625488285 XXX XXX XXX 18768242 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 12/XX/2007 MA Refinance - Cash-out - Other Primary Yes C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625488285 XXX XXX XXX 18768243 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 12/XX/2007 MA Refinance - Cash-out - Other Primary Yes B B B B 10/XX/2017
an application date of 11/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2007.
625488285 XXX XXX XXX 18768244 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2007 12/XX/2008 MA Refinance - Cash-out - Other Primary Yes B B B B 10/XX/2017
Loan Application Date.
625488285 XXX XXX XXX 18768245 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2007 12/XX/2008 MA Refinance - Cash-out - Other Primary Yes B B B B 10/XX/2017
Loan Application Date.
625489437 XXX XXX XXX 18768276 credit 3 Missing Document: Missing Final 1003 12/XX/1999 IN Refinance - Cash-out - Other Primary No C C C C 10/XX/2017
625489437 XXX XXX XXX 18768277 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/1999 12/XX/2000 IN Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489437 XXX XXX XXX 18768278 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 12/XX/1999 IN Refinance - Cash-out - Other Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625489462 XXX XXX XXX 18768303 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX FEMA disaster was after the original loan closing date 10/XX/2005 MA Refinance - Cash-out - Debt Consolidation Primary Yes C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625489462 XXX XXX XXX 18768304 compliance 2 FACTA Disclosure Missing Unable to determine FACTA Credit Score Disclosure was provided due to missing There is no Assignee Liability. 10/XX/2005 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 10/XX/2017
information.
625489462 XXX XXX XXX 18768305 compliance 2 ARM Disclosure Compliant TIL variable rate disclosure: ARM loan program disclosure does not match terms TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2005 10/XX/2006 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 10/XX/2017
of loan.
625489462 XXX XXX XXX 18768306 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2005 10/XX/2006 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 10/XX/2017
borrower within three (3) days of application.
625489462 XXX XXX XXX 18768307 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2005 10/XX/2006 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625489597 XXX XXX XXX 18768506 credit 3 Missing Document: Missing Final 1003 9/XX/2005 FL Purchase Second Home No C C C C 10/XX/2017
625489597 XXX XXX XXX 18768507 credit 3 Missing Document: Flood Certificate not provided 9/XX/2005 FL Purchase Second Home No C C C C 10/XX/2017
625489597 XXX XXX XXX 18768508 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 9/XX/2005 FL Purchase Second Home No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625488908 XXX XXX XXX 18768602 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 10/XX/1999 SC Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625488908 XXX XXX XXX 18768603 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/1999 10/XX/2000 SC Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625488908 XXX XXX XXX 18768604 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/1999 10/XX/2000 SC Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488511 XXX XXX XXX 18768743 credit 3 Missing Document: Flood Certificate not provided 9/XX/2005 MN Purchase Primary No C C C C 10/XX/2017
625488511 XXX XXX XXX 18768744 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 9/XX/2005 MN Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625488511 XXX XXX XXX 18768745 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL Itemization did not disclose the recording service fee of $XXX closing fee $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 9/XX/2005 9/XX/2006 MN Purchase Primary No B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. of $XXX or the title courier fee of $XXX as prepaid finance charges. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488511 XXX XXX XXX 18768746 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 9/XX/2005 MN Purchase Primary No B B B B 10/XX/2017
625488511 XXX XXX XXX 18768747 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2005 9/XX/2006 MN Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625489004 XXX XXX XXX 18769063 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 1/XX/2005 WI Refinance - Rate/Term Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625489004 XXX XXX XXX 18769064 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2005 1/XX/2006 WI Refinance - Rate/Term Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489004 XXX XXX XXX 18769065 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 1/XX/2005 1/XX/2008 WI Refinance - Rate/Term Primary No B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488392 XXX XXX XXX 18769222 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 9/XX/2005 NY Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625488392 XXX XXX XXX 18769223 credit 3 Missing Document: Flood Certificate not provided 9/XX/2005 NY Purchase Primary No C C C C 10/XX/2017
625488392 XXX XXX XXX 18769224 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2005 NY Purchase Primary No B B B B 10/XX/2017
an application date of 8/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 8/XX/2005.
625488392 XXX XXX XXX 18769225 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2005 9/XX/2006 NY Purchase Primary No B B B B 10/XX/2017
Loan Application Date.
625488392 XXX XXX XXX 18769226 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2005 9/XX/2006 NY Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489038 XXX XXX XXX 18769326 compliance 2 Notice of Special Flood Hazard Disclosure Not Provided Timely FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Liability for violations cannot be transferred to a subsequent purchaser of a 8/XX/2005 FL Purchase Second Home No B B B B 10/XX/2017
Hazard Disclosure within a reasonable time prior to closing. loan.
625489038 XXX XXX XXX 18769327 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2005 FL Purchase Second Home No B B B B 10/XX/2017
an application date of 7/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 2/XX/2005.
625488889 XXX XXX XXX 18769436 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 4/XX/1999 IN Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625488889 XXX XXX XXX 18769437 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/1999 4/XX/2000 IN Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625488889 XXX XXX XXX 18769438 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/1999 4/XX/2000 IN Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489694 XXX XXX XXX 18769483 credit 3 Missing Document: Flood Certificate not provided 8/XX/2005 IL Refinance - Rate/Term Primary No C C C C 10/XX/2017
625489694 XXX XXX XXX 18769484 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 8/XX/2005 IL Refinance - Rate/Term Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625489694 XXX XXX XXX 18769485 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization did not disclose a courier fee of $XXX and a tax pick up fee of $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 8/XX/2005 8/XX/2008 IL Refinance - Rate/Term Primary No B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. $XXX as prepaid finance charge for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489694 XXX XXX XXX 18769486 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2005 IL Refinance - Rate/Term Primary No B B B B 10/XX/2017
an application date of 7/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 7/XX/2005.
625489694 XXX XXX XXX 18769487 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2005 IL Refinance - Rate/Term Primary No B B B B 10/XX/2017
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489694 XXX XXX XXX 18769488 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2005 8/XX/2006 IL Refinance - Rate/Term Primary No B B B B 10/XX/2017
Loan Application Date.
625489694 XXX XXX XXX 18769489 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2005 8/XX/2006 IL Refinance - Rate/Term Primary No B B B B 10/XX/2017
Loan Application Date.
625489364 XXX XXX XXX 18769763 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 9/XX/2005 MA Purchase Primary Yes C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625489364 XXX XXX XXX 18769764 credit 3 Missing Document: Flood Certificate not provided 9/XX/2005 MA Purchase Primary Yes C C C C 10/XX/2017
625489364 XXX XXX XXX 18769765 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 9/XX/2005 MA Purchase Primary Yes B B B B 10/XX/2017
625489364 XXX XXX XXX 18769766 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2005 9/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
borrower within three (3) days of application.
625489364 XXX XXX XXX 18769767 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2005 9/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625489364 XXX XXX XXX 18769768 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Under-disclosure appears to be due to lender selecting an index value not $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 9/XX/2005 9/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. available in lookback period specified by Note. Variance indicated of $XXX/mo for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
over 84 months after first adjustment and $XXX/mo over final 240 of loan term, liability.
625488178 XXX XXX XXX 18770212 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 8/XX/2007 SC Purchase Primary No B B B B 10/XX/2017
625488178 XXX XXX XXX 18770213 compliance 2 South Carolina Home Loan (Complaint Agency Disclosure Not Provided) South Carolina Home Loan: Borrower not provided with a document specifying the Exceptions occurring more than 6 years ago may be outside the states statute of 8/XX/2007 8/XX/2013 SC Purchase Primary No B B B B 10/XX/2017
agency designated to receive complaints or inquiries about the origination and limitations. Due to the potential remedies available to a court, this exception
making of the loan. carries elevated risk to an assignee during the initial 6 years after occurrence
of the violation. After the expiration of this 6 year period, the exception
retains risk for claims raised as a defense to foreclosure, but not at the same
level as during the initial 6 years for affirmative claims.
625488178 XXX XXX XXX 18770214 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2007 8/XX/2008 SC Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625488178 XXX XXX XXX 18770215 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2007 8/XX/2008 SC Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488919 XXX XXX XXX 18770721 credit 3 Missing Document: Flood Certificate not provided 7/XX/2005 FL Purchase Primary No C C C C 10/XX/2017
625488919 XXX XXX XXX 18770722 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 7/XX/2005 FL Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625488919 XXX XXX XXX 18770723 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 7/XX/2005 FL Purchase Primary No B B B B 10/XX/2017
625488919 XXX XXX XXX 18770724 compliance 2 Notice of Special Flood Hazard Disclosure Not Provided Timely FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Liability for violations cannot be transferred to a subsequent purchaser of a 7/XX/2005 FL Purchase Primary No B B B B 10/XX/2017
Hazard Disclosure within a reasonable time prior to closing. loan.
625488919 XXX XXX XXX 18770725 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2005 FL Purchase Primary No B B B B 10/XX/2017
an application date of 6/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 6/XX/2005.
625488919 XXX XXX XXX 18770726 compliance 2 ARM Disclosure Status Unable to determine if loan file contains ARM Disclosure due to missing TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2005 7/XX/2006 FL Purchase Primary No B B B B 10/XX/2017
information.
625488919 XXX XXX XXX 18770727 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2005 7/XX/2006 FL Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489274 XXX XXX XXX 18770852 credit 3 Missing Document: Flood Certificate not provided 6/XX/2005 MA Purchase Primary Yes C C C C 10/XX/2017
625489274 XXX XXX XXX 18770853 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 6/XX/2005 MA Purchase Primary Yes B B B B 10/XX/2017
625489274 XXX XXX XXX 18770854 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2005 6/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489274 XXX XXX XXX 18770855 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 6/XX/2005 MA Purchase Primary Yes C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625489274 XXX XXX XXX 18770856 compliance 2 (Doc Error) Initial GFE not provided 6/XX/2005 MA Purchase Primary Yes B B B B 10/XX/2017
625489274 XXX XXX XXX 18770857 credit 3 Missing Document: Missing Final 1003 6/XX/2005 MA Purchase Primary Yes C C C C 10/XX/2017
625489274 XXX XXX XXX 18770858 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2005 6/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
borrower within three (3) days of application.
625489274 XXX XXX XXX 18770859 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Per Itemization of Amount Financed, lender did not disclose $XXX Recording $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 6/XX/2005 6/XX/2006 MA Purchase Primary Yes B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. Service Fees, $XXX Wire Fee, and $XXX Courier Fee as pre-paid finance charges. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488320 XXX XXX XXX 18770918 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 7/XX/2007 IN Refinance - Cash-out - Other Investment Yes C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625488926 XXX XXX XXX 18771354 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2002 MD Purchase Primary No B B B B 10/XX/2017
an application date of 10/XX/2002 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 5/XX/2002.
625488926 XXX XXX XXX 18771355 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2002 11/XX/2003 MD Purchase Primary No B B B B 10/XX/2017
Loan Application Date.
625488926 XXX XXX XXX 18771357 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2002 11/XX/2003 MD Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488926 XXX XXX XXX 18771359 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 11/XX/2002 MD Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625489150 XXX XXX XXX 18771663 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 6/XX/2007 IL Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625489150 XXX XXX XXX 18771664 credit 3 Missing Document: Flood Certificate not provided 6/XX/2007 IL Purchase Primary No C C C C 10/XX/2017
625489150 XXX XXX XXX 18771665 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 6/XX/2007 IL Purchase Primary No C C C C 10/XX/2017
625489150 XXX XXX XXX 18771666 compliance 2 ARM Disclosure Compliant TIL variable rate disclosure: ARM loan program disclosure does not match terms TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 IL Purchase Primary No B B B B 10/XX/2017
of loan.
625489150 XXX XXX XXX 18771667 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 IL Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625489150 XXX XXX XXX 18771668 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 IL Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489150 XXX XXX XXX 18771669 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 6/XX/2007 6/XX/2008 IL Purchase Primary No B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488677 XXX XXX XXX 18771788 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX No 7/XX/2007 GA Refinance - Rate/Term Investment No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625488677 XXX XXX XXX 18771789 credit 3 Missing Document: Flood Certificate not provided No 7/XX/2007 GA Refinance - Rate/Term Investment No C C C C 10/XX/2017
625488677 XXX XXX XXX 18771790 compliance 3 Missing Final HUD-1: HUD-1 Not Signed or Stamped Used For Fee Testing Missing Final HUD-1: HUD-1 Not Signed or Stamped used for any applicable No 7/XX/2007 GA Refinance - Rate/Term Investment No D D D D 10/XX/2017
Federal, State or Local compliance testing.
625488677 XXX XXX XXX 18771791 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using No 7/XX/2007 GA Refinance - Rate/Term Investment No B B B B 10/XX/2017
an application date of 6/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 6/XX/2007.
625488883 XXX XXX XXX 18771953 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 5/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
625488883 XXX XXX XXX 18771954 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2005 5/XX/2006 MI Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625488883 XXX XXX XXX 18771955 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2005 5/XX/2006 MI Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625488883 XXX XXX XXX 18771956 compliance 2 Payment Stream Variance: Final Truth In Lending Disclosure has incorrect payment TILA APR - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2005 5/XX/2006 MI Purchase Primary No B B B B 10/XX/2017
stream. defense to foreclosure. Assignee liability.
625488883 XXX XXX XXX 18771957 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 5/XX/2005 MI Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625488999 XXX XXX XXX 18772571 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 4/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
within a reasonably practicable time after using credit score.
625488999 XXX XXX XXX 18772572 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2005 4/XX/2006 MI Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625488999 XXX XXX XXX 18772573 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 4/XX/2005 MI Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625488999 XXX XXX XXX 18772574 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2005 4/XX/2006 MI Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625488190 XXX XXX XXX 18772619 credit 3 Missing Document: Missing Final 1003 5/XX/2007 FL Purchase Primary No C C C C 10/XX/2017
625488190 XXX XXX XXX 18772620 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 5/XX/2007 FL Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625488190 XXX XXX XXX 18772621 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2007 5/XX/2008 FL Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625488190 XXX XXX XXX 18772622 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2007 5/XX/2008 FL Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625488175 XXX XXX XXX 18772721 credit 3 Missing Document: Flood Certificate not provided 5/XX/2007 CA Purchase Primary No C C C C 10/XX/2017
625488175 XXX XXX XXX 18772722 compliance 2 (Missing Data) Flood Hazard Zone Federal Compliance - (Missing Data) Flood Hazard Zone: Special Flood Hazard Zone 5/XX/2007 CA Purchase Primary No B B B B 10/XX/2017
indicator was not provided. The applicable flood zone related testing cannot be
performed.
625488175 XXX XXX XXX 18772723 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2007 5/XX/2008 CA Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625488175 XXX XXX XXX 18772724 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2007 5/XX/2008 CA Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489512 XXX XXX XXX 18773662 credit 3 Missing Document: Flood Certificate not provided 4/XX/2007 MN Refinance - Cash-out - Other Primary No C C C C 10/XX/2017
625489512 XXX XXX XXX 18773663 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 4/XX/2007 MN Refinance - Cash-out - Other Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625489512 XXX XXX XXX 18773664 compliance 2 (Missing Data) Flood Hazard Zone Federal Compliance - (Missing Data) Flood Hazard Zone: Special Flood Hazard Zone 4/XX/2007 MN Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
indicator was not provided. The applicable flood zone related testing cannot be
performed.
625489512 XXX XXX XXX 18773665 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2007 4/XX/2008 MN Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625489512 XXX XXX XXX 18773666 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2007 4/XX/2008 MN Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489512 XXX XXX XXX 18773667 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 4/XX/2007 4/XX/2010 MN Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. financed for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489407 XXX XXX XXX 18773668 credit 3 Missing Document: Flood Certificate not provided 3/XX/2007 CT Purchase Investment No C C C C 10/XX/2017
625489407 XXX XXX XXX 18773669 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2007 CT Purchase Investment No B B B B 10/XX/2017
an application date of 3/XX/2007 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 3/XX/2007.
625489407 XXX XXX XXX 18773670 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 3/XX/2007 CT Purchase Investment No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625489263 XXX XXX XXX 18773787 credit 3 Missing Document: Flood Certificate not provided 4/XX/2007 NJ Refinance - Cash-out - Other Primary Yes C C C C 10/XX/2017
625489263 XXX XXX XXX 18773788 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 4/XX/2007 NJ Refinance - Cash-out - Other Primary Yes B B B B 10/XX/2017
625489263 XXX XXX XXX 18773789 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2007 4/XX/2008 NJ Refinance - Cash-out - Other Primary Yes B B B B 10/XX/2017
borrower within three (3) days of application.
625489263 XXX XXX XXX 18773790 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine underdisclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 4/XX/2007 4/XX/2010 NJ Refinance - Cash-out - Other Primary Yes B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489263 XXX XXX XXX 18773791 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 4/XX/2007 NJ Refinance - Cash-out - Other Primary Yes C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625489263 XXX XXX XXX 18773792 compliance 2 (Doc Error) Initial GFE not provided 4/XX/2007 NJ Refinance - Cash-out - Other Primary Yes B B B B 10/XX/2017
625489263 XXX XXX XXX 18773793 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2007 4/XX/2008 NJ Refinance - Cash-out - Other Primary Yes B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625489051 XXX XXX XXX 18773994 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 5/XX/2005 OH Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625489051 XXX XXX XXX 18773995 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 5/XX/2005 OH Purchase Primary No B B B B 10/XX/2017
625489051 XXX XXX XXX 18773996 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2005 5/XX/2006 OH Purchase Primary No B B B B 10/XX/2017
borrower.
625489051 XXX XXX XXX 18773997 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2005 5/XX/2006 OH Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489051 XXX XXX XXX 18773998 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2005 OH Purchase Primary No B B B B 10/XX/2017
an application date of 4/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2004.
625488173 XXX XXX XXX 18774183 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2005 3/XX/2006 OH Refinance - Rate/Term Primary No B B B B 10/XX/2017
borrower.
625488173 XXX XXX XXX 18774184 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2005 3/XX/2006 OH Refinance - Rate/Term Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488173 XXX XXX XXX 18774185 compliance 2 (Doc Error) Initial GFE not provided 3/XX/2005 OH Refinance - Rate/Term Primary No B B B B 10/XX/2017
625488173 XXX XXX XXX 18774186 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 3/XX/2005 OH Refinance - Rate/Term Primary No B B B B 10/XX/2017
625488173 XXX XXX XXX 18774187 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine reason for under disclosure due to missing itemization of $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 3/XX/2005 3/XX/2008 OH Refinance - Rate/Term Primary No B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. amount financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488173 XXX XXX XXX 18774188 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 3/XX/2005 OH Refinance - Rate/Term Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625488474 XXX XXX XXX 18774516 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 11/XX/2004 MN Refinance - Cash-out - Debt Consolidation Primary No C C C C 10/XX/2017
625488474 XXX XXX XXX 18774517 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2004 11/XX/2005 MN Refinance - Cash-out - Debt Consolidation Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625488474 XXX XXX XXX 18774518 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2004 11/XX/2005 MN Refinance - Cash-out - Debt Consolidation Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488474 XXX XXX XXX 18774519 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 11/XX/2004 MN Refinance - Cash-out - Debt Consolidation Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625488400 XXX XXX XXX 18774675 credit 3 Missing Document: Flood Certificate not provided 3/XX/2007 AZ Purchase Primary No C C C C 10/XX/2017
625488400 XXX XXX XXX 18774676 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 AZ Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625488400 XXX XXX XXX 18774677 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 AZ Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488141 XXX XXX XXX 18774787 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 11/XX/2004 OH Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625488141 XXX XXX XXX 18774788 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2004 OH Purchase Primary No B B B B 10/XX/2017
an application date of 10/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 5/XX/2004.
625488141 XXX XXX XXX 18774789 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2004 OH Purchase Primary No B B B B 10/XX/2017
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488141 XXX XXX XXX 18774790 credit 2 Incorrect Appraisal Form type: Appraisal Form 1004/70 used for incorrect Subject Valuation Type: Appraisal / Valuation Report Date: 10/XX/2004 3 Family Appraisal Indicates property has guest house 11/XX/2004 OH Purchase Primary No B B B B 10/XX/2017
property type.
625487948 XXX XXX XXX 18774917 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 11/XX/2004 OH Refinance - Cash-out - Other Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625487948 XXX XXX XXX 18774918 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2004 OH Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625487948 XXX XXX XXX 18774919 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2004 11/XX/2005 OH Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625487948 XXX XXX XXX 18774920 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2004 OH Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625487948 XXX XXX XXX 18774921 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2004 11/XX/2005 OH Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625488059 XXX XXX XXX 18775066 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 11/XX/2004 IN Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625488059 XXX XXX XXX 18775067 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2004 11/XX/2005 IN Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625488642 XXX XXX XXX 18775239 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 11/XX/2004 MA Refinance - Cash-out - Other Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625488642 XXX XXX XXX 18775240 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2004 11/XX/2005 MA Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625488642 XXX XXX XXX 18775241 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2004 11/XX/2005 MA Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625487946 XXX XXX XXX 18775317 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Lender commitment letter indicates the Index used was 2.043%. The closest Index $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 12/XX/2004 12/XX/2005 NV Purchase Second Home No B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. available in our look-back period is 2.22%. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488626 XXX XXX XXX 18775378 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2007 1/XX/2008 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488626 XXX XXX XXX 18775379 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2007 1/XX/2008 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 10/XX/2017
borrower within three (3) days of application.
625489175 XXX XXX XXX 18775397 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2004 MD Purchase Primary No B B B B 10/XX/2017
an application date of 8/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 3/XX/2004.
625489175 XXX XXX XXX 18775398 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2004 9/XX/2005 MD Purchase Primary No B B B B 10/XX/2017
Loan Application Date.
625489175 XXX XXX XXX 18775399 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2004 9/XX/2005 MD Purchase Primary No B B B B 10/XX/2017
Loan Application Date.
625489352 XXX XXX XXX 18775408 compliance 3 Missing Final HUD-1: HUD-1 Not Signed or Stamped Used For Fee Testing Missing Final HUD-1: HUD-1 Not Signed or Stamped used for any applicable Yes 4/XX/2002 AZ Refinance - Rate/Term Primary No D D D D 10/XX/2017
Federal, State or Local compliance testing.
625489352 XXX XXX XXX 18775409 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 4/XX/2002 4/XX/2003 AZ Refinance - Rate/Term Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489352 XXX XXX XXX 18775410 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years Yes 4/XX/2002 4/XX/2005 AZ Refinance - Rate/Term Primary No B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488366 XXX XXX XXX 18775516 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 11/XX/2004 SC Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625488366 XXX XXX XXX 18775517 compliance 2 South Carolina Home Loan (Complaint Agency Disclosure Not Provided) South Carolina Home Loan: Borrower not provided with a document specifying the Exceptions occurring more than 6 years ago may be outside the states statute of 11/XX/2004 11/XX/2010 SC Purchase Primary No B B B B 10/XX/2017
agency designated to receive complaints or inquiries about the origination and limitations. Due to the potential remedies available to a court, this exception
making of the loan. carries elevated risk to an assignee during the initial 6 years after occurrence
of the violation. After the expiration of this 6 year period, the exception
retains risk for claims raised as a defense to foreclosure, but not at the same
level as during the initial 6 years for affirmative claims.
625488366 XXX XXX XXX 18775518 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2004 11/XX/2005 SC Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488366 XXX XXX XXX 18775519 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2004 11/XX/2005 SC Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625487988 XXX XXX XXX 18775877 credit 3 Missing Document: Missing Final 1003 9/XX/2004 FL Purchase Primary No C C C C 10/XX/2017
625487988 XXX XXX XXX 18775879 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 9/XX/2004 FL Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625487988 XXX XXX XXX 18775881 compliance 2 ARM Disclosure Compliant TIL variable rate disclosure: ARM loan program disclosure does not match terms TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2004 9/XX/2005 FL Purchase Primary No B B B B 10/XX/2017
of loan.
625487988 XXX XXX XXX 18775882 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2004 9/XX/2005 FL Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625487988 XXX XXX XXX 18775883 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2004 9/XX/2005 FL Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625487988 XXX XXX XXX 18775885 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Settlement fee of $XXX Courier Fee of $XXX and Wire Fee of $XXX not included in $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 9/XX/2004 9/XX/2005 FL Purchase Primary No B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. finance charges per TIL itemization. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488744 XXX XXX XXX 18776133 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 12/XX/2006 MA Refinance - Rate/Term Primary Yes C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625488744 XXX XXX XXX 18776134 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2006 12/XX/2007 MA Refinance - Rate/Term Primary Yes B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625489164 XXX XXX XXX 18776345 credit 3 Missing Document: Flood Certificate not provided 11/XX/2006 CA Refinance - Cash-out - Other Primary No C C C C 10/XX/2017
625489164 XXX XXX XXX 18776348 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2006 11/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625489164 XXX XXX XXX 18776350 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2006 11/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489164 XXX XXX XXX 18776351 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 11/XX/2006 CA Refinance - Cash-out - Other Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625489164 XXX XXX XXX 18776352 compliance 2 TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit 11/XX/2006 11/XX/2009 CA Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
(Circuit 2, 5, 7, 8, 9, 10 or DC) Model Form for a refinancing by the same creditor. The H-8 form was used, the courts, the continuing risk that the borrower may have an extended right to
H-9 form should have been used. rescind (3 additional years) if a creditor uses the incorrect Model Form
remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625488486 XXX XXX XXX 18776423 compliance 2 Michigan Consumer Mortgage Protection Act (Counseling Agencies List) Michigan Consumer Mortgage Protection Act: List of HUD-approved credit 8/XX/2004 MI Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
counseling agencies not provided to borrower.
625488307 XXX XXX XXX 18776680 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 11/XX/2006 FL Refinance - Cash-out - Other Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625488307 XXX XXX XXX 18776681 compliance 2 (Doc Error) Initial GFE not provided 11/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
625488307 XXX XXX XXX 18776682 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
an application date of 10/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 5/XX/2006.
625488307 XXX XXX XXX 18776683 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2006 11/XX/2007 FL Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489029 XXX XXX XXX 18777046 credit 3 Missing Document: Missing Final 1003 10/XX/2006 FL Refinance - Cash-out - Home Improvement Primary No C C C C 10/XX/2017
625489029 XXX XXX XXX 18777047 credit 3 Missing Document: Flood Certificate not provided 10/XX/2006 FL Refinance - Cash-out - Home Improvement Primary No C C C C 10/XX/2017
625489029 XXX XXX XXX 18777048 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2006 10/XX/2007 FL Refinance - Cash-out - Home Improvement Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625489029 XXX XXX XXX 18777049 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2006 10/XX/2007 FL Refinance - Cash-out - Home Improvement Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488193 XXX XXX XXX 18777204 credit 3 Missing Document: Flood Certificate not provided Flood Cert not found in file 10/XX/2006 SC Refinance - Cash-out - Debt Consolidation Primary No C C C C 10/XX/2017
625488193 XXX XXX XXX 18777205 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX Loan package from 2006, inspection date post 2016 is not available 10/XX/2006 SC Refinance - Cash-out - Debt Consolidation Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625488193 XXX XXX XXX 18777206 compliance 2 (Missing Data) Flood Hazard Zone Federal Compliance - (Missing Data) Flood Hazard Zone: Special Flood Hazard Zone 10/XX/2006 SC Refinance - Cash-out - Debt Consolidation Primary No B B B B 10/XX/2017
indicator was not provided. The applicable flood zone related testing cannot be
performed.
625488193 XXX XXX XXX 18777207 compliance 2 South Carolina Home Loan (Complaint Agency Disclosure Not Provided) South Carolina Home Loan: Borrower not provided with a document specifying the Exceptions occurring more than 6 years ago may be outside the states statute of 10/XX/2006 10/XX/2012 SC Refinance - Cash-out - Debt Consolidation Primary No B B B B 10/XX/2017
agency designated to receive complaints or inquiries about the origination and limitations. Due to the potential remedies available to a court, this exception
making of the loan. carries elevated risk to an assignee during the initial 6 years after occurrence
of the violation. After the expiration of this 6 year period, the exception
retains risk for claims raised as a defense to foreclosure, but not at the same
level as during the initial 6 years for affirmative claims.
625488829 XXX XXX XXX 18777260 credit 3 Missing Document: Missing Final 1003 8/XX/2004 CT Refinance - Cash-out - Debt Consolidation Primary No C C C C 10/XX/2017
625488829 XXX XXX XXX 18777261 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 8/XX/2004 CT Refinance - Cash-out - Debt Consolidation Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625488829 XXX XXX XXX 18777262 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2004 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B 10/XX/2017
an application date of 7/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 4/XX/2004.
625488829 XXX XXX XXX 18777263 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2004 8/XX/2005 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488829 XXX XXX XXX 18777264 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Finance charge under disclosed Finance charge under disclosed $XXX. Unable to $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 8/XX/2004 8/XX/2007 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. determine under disclosure. TIL itemization disclosed total prepaid fees in the for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
amount of $XXX. HUD reflects $XXX. The index value of 1.9160% was not available. liability.
The minimum index available of 2.04000% was used. The interest rate increased
from 7.25% to 7.375% from approval to closing.
625487934 XXX XXX XXX 18777265 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 11/XX/2006 TX Refinance - Cash-out - Other Second Home No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625487934 XXX XXX XXX 18777266 credit 3 Missing Document: Missing Final 1003 11/XX/2006 TX Refinance - Cash-out - Other Second Home No C C C C 10/XX/2017
625487934 XXX XXX XXX 18777267 credit 3 Missing Document: Flood Certificate not provided 11/XX/2006 TX Refinance - Cash-out - Other Second Home No C C C C 10/XX/2017
625488461 XXX XXX XXX 18777317 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2006 10/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488461 XXX XXX XXX 18777318 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2006 CA Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
an application date of 9/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 4/XX/2006.
625488461 XXX XXX XXX 18777319 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2006 CA Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488461 XXX XXX XXX 18777320 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2006 10/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
Loan Application Date.
625488503 XXX XXX XXX 18777441 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2002 3/XX/2003 UT Refinance - Cash-out - Debt Consolidation Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488503 XXX XXX XXX 18777442 compliance 2 ARM Disclosure Status Unable to determine if loan file contains ARM Disclosure due to missing TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2002 3/XX/2003 UT Refinance - Cash-out - Debt Consolidation Primary No B B B B 10/XX/2017
information.
625488613 XXX XXX XXX 18777462 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2006 IN Refinance - Rate/Term Primary Yes B B B B 10/XX/2017
an application date of 9/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 4/XX/2006.
625488613 XXX XXX XXX 18777463 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2006 IN Refinance - Rate/Term Primary Yes B B B B 10/XX/2017
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488613 XXX XXX XXX 18777464 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2006 10/XX/2007 IN Refinance - Rate/Term Primary Yes B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488613 XXX XXX XXX 18777465 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Final TIL payment stream reflects MI dropping off after 76 months, however the $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 10/XX/2006 10/XX/2009 IN Refinance - Rate/Term Primary Yes B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. HUD reflects MI dropping off after 77 months. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488613 XXX XXX XXX 18777466 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 10/XX/2006 IN Refinance - Rate/Term Primary Yes C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625488613 XXX XXX XXX 18777467 compliance 2 (Doc Error) Initial GFE not provided 10/XX/2006 IN Refinance - Rate/Term Primary Yes B B B B 10/XX/2017
625488837 XXX XXX XXX 18777750 credit 3 Missing Document: Missing Final 1003 10/XX/2006 CT Purchase Primary No C C C C 10/XX/2017
625488837 XXX XXX XXX 18777751 credit 3 Missing Document: Flood Certificate not provided 10/XX/2006 CT Purchase Primary No C C C C 10/XX/2017
625488837 XXX XXX XXX 18777752 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2006 CT Purchase Primary No B B B B 10/XX/2017
an application date of 9/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 9/XX/2006.
625488837 XXX XXX XXX 18777753 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2006 10/XX/2007 CT Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488837 XXX XXX XXX 18777754 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 10/XX/2006 CT Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625488837 XXX XXX XXX 18777755 compliance 2 (Doc Error) Initial GFE not provided 10/XX/2006 CT Purchase Primary No B B B B 10/XX/2017
625488055 XXX XXX XXX 18777811 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 10/XX/2006 AL Refinance - Cash-out - Other Second Home No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625488055 XXX XXX XXX 18777812 compliance 2 Acknowledgement of Borrower Receipt of Notice of Special Flood Hazard Disclosure FDPA Notification Rule: Creditor did not retain record of borrower's receipt of Liability for violations cannot be transferred to a subsequent purchaser of a 10/XX/2006 AL Refinance - Cash-out - Other Second Home No B B B B 10/XX/2017
Missing Notice of Special Flood Hazard Disclosure. loan.
625488055 XXX XXX XXX 18777813 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2006 AL Refinance - Cash-out - Other Second Home No B B B B 10/XX/2017
an application date of 9/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 9/XX/2006.
625488061 XXX XXX XXX 18777993 credit 3 Missing Document: Flood Certificate not provided 9/XX/2006 CA Refinance - Rate/Term Investment No C C C C 10/XX/2017
625488061 XXX XXX XXX 18777994 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2006 CA Refinance - Rate/Term Investment No B B B B 10/XX/2017
an application date of 9/XX/2006 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 9/XX/2006.
625488061 XXX XXX XXX 18777995 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 9/XX/2006 CA Refinance - Rate/Term Investment No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625487968 XXX XXX XXX 18778108 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 5/XX/2004 MI Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625487968 XXX XXX XXX 18778109 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2004 5/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
borrower.
625487968 XXX XXX XXX 18778110 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2004 5/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625487968 XXX XXX XXX 18778111 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL Itemiizatikon does not list the Origination fee of $XXX. As well it shows $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 5/XX/2004 5/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
calculated Finance Charge of $XXX in the amount of $XXX. the Closing fee of $XXX and the $XXX aplication fee as being paid by someone for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
other than the borrower. The payment stream is also off at month 121. The TIL liability.
stream has the amount of $XXX for 60 months. However, the calculated stream
shows it for 79 months.
625489435 XXX XXX XXX 18778208 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 5/XX/2004 MI Refinance - Cash-out - Other Investment No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625489435 XXX XXX XXX 18778209 compliance 2 Notice of Special Flood Hazard Disclosure Not Provided Timely FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Liability for violations cannot be transferred to a subsequent purchaser of a 5/XX/2004 MI Refinance - Cash-out - Other Investment No B B B B 10/XX/2017
Hazard Disclosure within a reasonable time prior to closing. loan.
625489435 XXX XXX XXX 18778210 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2004 MI Refinance - Cash-out - Other Investment No B B B B 10/XX/2017
an application date of 4/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 4/XX/2004.
625488373 XXX XXX XXX 18778332 credit 3 Missing Document: Flood Certificate not provided 9/XX/2006 MA Purchase Primary Yes C C C C 10/XX/2017
625488373 XXX XXX XXX 18778333 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2006 9/XX/2007 MA Purchase Primary Yes B B B B 10/XX/2017
borrower.
625488373 XXX XXX XXX 18778334 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2006 9/XX/2007 MA Purchase Primary Yes B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488373 XXX XXX XXX 18778335 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 9/XX/2006 MA Purchase Primary Yes C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625488694 XXX XXX XXX 18778529 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 8/XX/2006 RI Refinance - Cash-out - Other Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date: XX/XX/XXXX
625488694 XXX XXX XXX 18778530 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2006 8/XX/2007 RI Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625488694 XXX XXX XXX 18778531 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2006 8/XX/2007 RI Refinance - Cash-out - Other Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625489619 XXX XXX XXX 18778577 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2004 MI Purchase Primary No B B B B 10/XX/2017
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489619 XXX XXX XXX 18778578 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2004 4/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
borrower within three (3) days of application.
625489619 XXX XXX XXX 18778579 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2004 4/XX/2005 MI Purchase Primary No B B B B 10/XX/2017
CHARM Booklet, not provided to the borrower.
625489619 XXX XXX XXX 18778580 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 4/XX/2004 MI Purchase Primary No C C C C 10/XX/2017
most recent FEMA disaster. Inspection Date:
625487966 XXX XXX XXX 29371231 credit 3 Initial Rate Lock rate date is not documented in file. 4/XX/2012 CA Refinance - Cash-out - Other Primary No C C C C 7/XX/2023
625487966 XXX XXX XXX 29371232 compliance 2 (Missing Data) Last Rate Set Date Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario 4/XX/2012 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
between Creditor Application Date and Transaction Date used to determine rate
used for testing.
625487966 XXX XXX XXX 29371233 compliance 2 RESPA (2010) – Written Service Provider List Not Provided Timely RESPA (2010) - Borrower did not receive a list of service providers at the time RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2012 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
the Good Faith Estimate was provided. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489319 XXX XXX XXX 29371369 credit 3 Missing Document: Missing Final 1003 11/XX/2013 CA Refinance - Rate/Term Investment No C C C C 7/XX/2023
625489319 XXX XXX XXX 29371370 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2013 CA Refinance - Rate/Term Investment No B B B B 7/XX/2023
an application date of 10/XX/2013 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625488460 XXX XXX XXX 29371429 credit 3 Missing Document: Missing Final 1003 No 8/XX/2012 CA Purchase Investment No C C C C 7/XX/2023
625488460 XXX XXX XXX 29371430 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. No 8/XX/2012 CA Purchase Investment No B B B B 7/XX/2023
625488460 XXX XXX XXX 29371431 compliance 3 Missing Final HUD-1: HUD-1 Not Signed or Stamped Used For Fee Testing Material Missing Final HUD-1: HUD-1 Not Signed or Stamped used for any applicable No 8/XX/2012 CA Purchase Investment No D D D D 7/XX/2023
Federal, State or Local compliance testing.
625488460 XXX XXX XXX 29371432 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using No 8/XX/2012 CA Purchase Investment No B B B B 7/XX/2023
an application date of 07/XX/2012 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625489503 XXX XXX XXX 29371650 credit 3 Missing Document: Missing Final 1003 6/XX/2013 CA Refinance - Rate/Term Primary No C C C C 7/XX/2023
625489503 XXX XXX XXX 29371651 compliance 2 Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Loan Originator Compensation: Anti-Steering - Unable to determine Safe Harbor Assignee Liability: Civil actions that may be brought against a creditor may be 6/XX/2013 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023
Provided: Unable to determine Anti-Steering compliance/Safe Harbor due to Anti-Steering Disclosure not provided to borrower. maintained against any assignee only if the violation is apparent on the face of
the disclosure or other documents assigned, except where the assignment was
involuntary. This civil liability may include $XXX in the case of an individual
transaction, or the lesser of $XXX or 1% of the creditor's net worth in the case
of a class action (effective 1/XX/14, this amount increases to the lesser of
$XXX or 1%), as well as actual damages, court costs, and attorneys' fees. For an
anti-steering violation, the creditor may also be liable in an amount equal to
the sum of all finance charges and fees paid by the consumer, unless the
creditor demonstrates the failure to comply is not material. Notwithstanding any
other provision of law, when a creditor, assignee, or other holder or anyone
acting on behalf of the creditor, assignee, or holder, initiates a judicial or
nonjudicial foreclosure of the residential mortgage loan, or any other action to
collect the debt in connection with such loan, a consumer may assert a violation
as a matter of defense by recoupment or set off without regard for the time
limit on a private action for damages.
Effective 1/XX/2014 in addition to the aforementioned, the individual Loan
Originator could be liable for statutory damages. The maximum liability is the
greater of actual damages or 3 times the loan originator's compensation or gain,
plus the cost to the consumer of the action. The Dodd-Frank Act extended the
statute of limitations on TILA violations to 3 years from the date of the
violation.
625489503 XXX XXX XXX 29371652 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 6/XX/2013 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023
625489503 XXX XXX XXX 29371653 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2013 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023
an application date of 05/XX/2013 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625489503 XXX XXX XXX 29371654 compliance 2 Federal LO Compensation Dual Compensation Pre-Dodd Frank Test Loan Originator Compensation: Dual compensation received from both a consumer Assignee Liability: Civil actions that may be brought against a creditor may be 6/XX/2013 6/XX/2016 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023
and person other than consumer. maintained against any assignee only if the violation is apparent on the face of
the disclosure or other documents assigned, and where the assignment was
involuntary. This civil liability may include $XXX in the case of an individual
transaction, or the lesser of $XXX or 1% of the creditor's net worth in the case
of a class action as well as actual damages, court costs, and attorneys' fees.
For an anti-steering violation, the creditor may also be liable in an amount
equal to the sum of all finance charges and fees paid by the consumer, unless
the creditor demonstrates the failure to comply is not material. Notwithstanding
any other provision of law, when a creditor, assignee, or other holder or anyone
acting on behalf of the creditor, assignee, or holder, initiates a judicial or
non-judicial foreclosure of the residential mortgage loan, or any other action
to collect the debt in connection with such loan, a consumer may assert a
violation as a matter of defense by recoupment or set off without regard for the
time limit on a private action for damages.
625489503 XXX XXX XXX 29371655 compliance 2 SAFE Act - LO Company not licensed at time of application Unable to test LO company NMLS license due to missing information. Liability appears to be limited to originators/licensees. 6/XX/2013 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023
625489503 XXX XXX XXX 29371656 compliance 2 SAFE Act - Individual LO NMLS license status not approved Unable to test Individual Loan Originator license status due to missing 6/XX/2013 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023
information.
625489503 XXX XXX XXX 29371657 compliance 2 SAFE Act - Individual LO not licensed at time of application Unable to test Loan Originator license due to missing information. Liability appears to be limited to originators/licensees. 6/XX/2013 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023
625489503 XXX XXX XXX 29371658 compliance 2 SAFE Act - LO Company NMLS license status not approved Unable to test LO company status due to missing information. 6/XX/2013 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023
625489503 XXX XXX XXX 29371659 compliance 2 Safe Act NMLS - Missing Evidence of Initial Loan Application Date Secure and Fair Enforcement for Mortgage Licensing Act: Unable to determine Liability appears to be limited to originators/licensees. 6/XX/2013 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023
compliance with NMLSR timing requirements due to missing evidence of initial
loan application date.
625489503 XXX XXX XXX 29371660 compliance 2 RESPA - Initial GFE Not Provided Within 3 Business Days of Application Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2013 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023
Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489503 XXX XXX XXX 29371661 compliance 2 RESPA - Initial Escrow Account Statement Missing RESPA: Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2013 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023
within the statute or implementing regulation, Regulation X, for these type of
violations.
625489503 XXX XXX XXX 29371662 compliance 2 RESPA Servicing Disclosure: Servicing Disclosure Statement Not Provided Within 3 Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2013 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023
Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489503 XXX XXX XXX 29371663 compliance 2 TIL-MDIA - Initial TIL Not Provided within 3 Business Days of Application Unable to determine compliance with timing requirements due to missing Initial TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited 6/XX/2013 6/XX/2014 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023
Loan Application Date. as a defense to foreclosure. Assignee liability.
625489503 XXX XXX XXX 29371664 compliance 2 2011 TIL-MDIA - Introductory Escrow Payment Inaccurate Truth in Lending Act (MDIA 2011): The amount of taxes and insurance, including TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2013 6/XX/2016 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023
any mortgage insurance, on the Final TIL does not match the amount of taxes and defense to foreclosure. Assignee liability.
insurance, including any mortgage insurance, for the loan.
625489503 XXX XXX XXX 29371665 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - Introductory Total Payment (PITI) Truth in Lending Act (MDIA 2011): Total payment amount (PITI) on the Final TIL TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2013 6/XX/2016 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023
Inaccurate does not match the total payment amount for the loan. defense to foreclosure. Assignee liability.
625488816 XXX XXX XXX 29371931 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization did not disclose the sign in fees of $XXX and $XXX subordination $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 4/XX/2005 4/XX/2008 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
calculated Finance Charge of $XXX in the amount of $XXX. recording fee of $XXX and title courier fee of $XXX as prepaid finance charges. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
HUD disclosed prepaid interest fee as $XXX and itemization disclosed as $XXX. liability.
625488873 XXX XXX XXX 29371954 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. No 5/XX/1999 CA Purchase Primary No B B B B 7/XX/2023
Security Instrument Notary Date of 05/XX/1999 used as disbursement date for
compliance testing.
625488873 XXX XXX XXX 29371955 compliance 3 Missing Final HUD-1: No Document Used For Fee Testing Material Missing Final HUD-1. No document containing fees provided. Any applicable Received only page 1 and a HUD addendum, need page 2 of HUD to complete testing. No 5/XX/1999 CA Purchase Primary No D D D D 7/XX/2023 2023/XX/18: Full breakdown of final HUD can be found in the Title Insurance 2023/XX/18: Unclear what specific document the seller is referring to, however
Federal, State or Local compliance testing is unreliable. Document pages 45-48 SAMC does not accept escrow instructions or other similar documentation in lieu
of a complete, fully executed HUD-1. Exception remains.
625488873 XXX XXX XXX 29371956 compliance 2 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using No 5/XX/1999 CA Purchase Primary No B B B B 7/XX/2023
an application date of 04/XX/1999 which is 1 months prior to consummation. A
lookback was performed to determine this application date. Due to missing HUD-1
or Closing Disclosure, no fees were used in testing.
625488516 XXX XXX XXX 29371997 compliance 2 Missing Initial Loan Application Compliance Determined Application Date No evidence of application date located in file. Compliance tests were run using 2/XX/2014 CA Refinance - Cash-out - Other Investment No B B B B 7/XX/2023
an application date of 12/XX/2013. The source for this date is Initial
disclosures.
625488359 XXX XXX XXX 29372002 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 7/XX/2013 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
625488359 XXX XXX XXX 29372003 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2013 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
an application date of 06/XX/2013 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625488359 XXX XXX XXX 29372004 compliance 2 SAFE Act - LO Company not licensed at time of application Unable to test LO company NMLS license due to missing information. Liability appears to be limited to originators/licensees. 7/XX/2013 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
625488359 XXX XXX XXX 29372005 compliance 2 SAFE Act - Individual LO NMLS license status not approved Unable to test Individual Loan Originator license status due to missing 7/XX/2013 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
information.
625488359 XXX XXX XXX 29372006 compliance 2 SAFE Act - Individual LO not licensed at time of application Unable to test Loan Originator license due to missing information. Liability appears to be limited to originators/licensees. 7/XX/2013 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
625488359 XXX XXX XXX 29372007 compliance 2 SAFE Act - LO Company NMLS license status not approved Unable to test LO company status due to missing information. 7/XX/2013 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
625488359 XXX XXX XXX 29372008 compliance 2 Safe Act NMLS - Missing Evidence of Initial Loan Application Date Secure and Fair Enforcement for Mortgage Licensing Act: Unable to determine Liability appears to be limited to originators/licensees. 7/XX/2013 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
compliance with NMLSR timing requirements due to missing evidence of initial
loan application date.
625488359 XXX XXX XXX 29372009 compliance 2 RESPA (2010) - GFE Settlement charges Good Thru Date Less than 10 Days RESPA (2010): GFE does not provide minimum ten (10) business day availability RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2013 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
for estimate of charges and terms for all other settlement charges. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488359 XXX XXX XXX 29372010 compliance 2 RESPA - Initial GFE Not Provided Within 3 Business Days of Application Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2013 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488359 XXX XXX XXX 29372011 compliance 2 RESPA Servicing Disclosure: Servicing Disclosure Statement Not Provided Within 3 Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2013 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488359 XXX XXX XXX 29372012 compliance 2 TIL-MDIA - Initial TIL Not Provided within 3 Business Days of Application Unable to determine compliance with timing requirements due to missing Initial TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited 7/XX/2013 7/XX/2014 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
Loan Application Date. as a defense to foreclosure. Assignee liability.
625488359 XXX XXX XXX 29372013 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - Maximum In First 5 Years Change Date Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" date on the TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2013 7/XX/2016 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
Inaccurate (ARM loan) Final TIL does not match the date on which the first regular periodic payment defense to foreclosure. Assignee liability.
will be due and the earliest date on which that rate may apply.
625488359 XXX XXX XXX 29372014 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - Maximum In First 5 Years Interest Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" interest rate TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2013 7/XX/2016 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
Rate Inaccurate on the Final TIL does not match the maximum interest rate that may apply during defense to foreclosure. Assignee liability.
the first five (5) years of the loan.
625488359 XXX XXX XXX 29372015 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - Maximum In First 5 Years Total Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" total payment TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2013 7/XX/2016 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
Payment (PITI) Inaccurate amount (PITI) on the Final TIL does not match the maximum total payment on the defense to foreclosure. Assignee liability.
loan during the first five (5) years for the loan.
625488359 XXX XXX XXX 29372016 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - Maximum Ever Change Date Inaccurate Truth in Lending Act (MDIA 2011): The "Maximum Ever" date on the Final TIL does TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2013 7/XX/2016 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
not match the earliest date on which the maximum rate may apply. defense to foreclosure. Assignee liability.
625488359 XXX XXX XXX 29372017 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - First Adjustment Change Date Truth in Lending Act (MDIA 2011): The "First Adjustment" date on the Final TIL TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2013 7/XX/2016 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
Inaccurate does not match the first adjustment date for the loan. defense to foreclosure. Assignee liability.
625488359 XXX XXX XXX 29372018 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - Maximum In First 5 Years Interest Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" interest TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2013 7/XX/2016 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
Payment Inaccurate payment on the Final TIL does not match the maximum interest payment that may defense to foreclosure. Assignee liability.
apply during the first five (5) years of the loan.
625488359 XXX XXX XXX 29372019 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - Maximum In First 5 Years Principal Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" principal TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2013 7/XX/2016 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
Payment Inaccurate payment on the Final TIL does not match the maximum principal payment that may defense to foreclosure. Assignee liability.
apply during the first five (5) years of the loan.
625488359 XXX XXX XXX 29372020 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2013 7/XX/2014 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
application due to missing information.
625488359 XXX XXX XXX 29372021 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2013 7/XX/2014 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023
Loan Application Date.
625488359 XXX XXX XXX 29372022 credit 3 Missing Document: Missing Final 1003 7/XX/2013 CA Refinance - Cash-out - Other Primary No C C C C 7/XX/2023
625487915 XXX XXX XXX 29372087 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - Maximum Ever Change Date Inaccurate Truth in Lending Act (MDIA 2011): The "Maximum Ever" date on the Final TIL does TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2013 11/XX/2016 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023
not match the earliest date on which the maximum rate may apply. defense to foreclosure. Assignee liability.
625487915 XXX XXX XXX 29372088 compliance 2 ARM Disclosure Compliant Test TIL variable rate disclosure: ARM loan program disclosure does not match terms TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2013 11/XX/2014 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023
of loan.
625487915 XXX XXX XXX 29372089 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2013 11/XX/2014 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023
application due to missing information.
625487915 XXX XXX XXX 29372090 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2013 11/XX/2014 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023
CHARM Booklet, not provided to the borrower.
625487915 XXX XXX XXX 29372091 compliance 2 TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit 11/XX/2013 11/XX/2016 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023
(Circuit 2, 5, 7, 8, 9, 10 or DC) Model Form for a refinancing by the same creditor. The H-8 form was used, the courts, the continuing risk that the borrower may have an extended right to
H-9 form should have been used. rescind (3 additional years) if a creditor uses the incorrect Model Form
remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625487915 XXX XXX XXX 29372092 compliance 2 SAFE Act - Individual LO NMLS license status not approved Secure and Fair Enforcement for Mortgage Licensing Act: Individual Loan 11/XX/2013 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023
Originator not in approved license status to conduct loan origination
activities.
625487994 XXX XXX XXX 29372449 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX Property inspection report was not included in the file. 4/XX/2019 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 5/XX/2023 Yes Non QM 2023/XX/31: BPO provided reflecting no damage.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625487994 XXX XXX XXX 29372450 compliance 2 RESPA Disclosure - List of Homeownership Counseling Organizations Missing RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2019 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM 2023/XX/13: Document provided cannot be used to clear this condition. Please
Homeownership Counseling Organizations to borrower. within the statute or implementing regulation, Regulation X, for these type of provide the list of at least 10 counseling agencies, along with date list was
violations. obtained.
625487994 XXX XXX XXX 29372451 compliance 1 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2019 4/XX/2020 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Received; however, see updated condition as it was not provided
CHARM Booklet, not provided to the borrower. within 3 business days of application.
625487994 XXX XXX XXX 29372452 compliance 1 Check Loan Designation Match - ATR Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Failure is due to missing asset and income documentation which is waterfalling Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 4/XX/2019 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: VOE received. Loan approved under Portfolio Express which allowed
not match Due Diligence Loan Designation of ATR Fail. to ATR/QM testing. Lender approved loan as a portfolio express product. Designation to the TPR firm performing the loan level due diligence and to have stated assets. Condition cleared.
the TPR firm confirm said designation.
625487994 XXX XXX XXX 29372453 compliance 1 General Ability To Repay Provision Employment - W-2 Ability to Repay (Dodd-Frank 2014): Unable to verify current Wages/W-2 Failure is due to missing asset and income documentation which is waterfalling Assignee Liability: Violations can result in regular TILA damages (actual 4/XX/2019 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: VOE received. Loan approved under Portfolio Express which allowed
employment status using reasonably reliable third-party records. (XXX XXX/Wages) to ATR/QM testing. Lender approved loan as a portfolio express product. damages, statutory damages of up to $XXX costs, and attorney's fees) and stated assets. Condition cleared.
enhanced damages (an amount equal to the sum of all finance charges and fees
paid by the consumer, unless the creditor demonstrates that the failure to
comply is not material). A private right of action may be brought before the end
of the three-year period beginning on the date of the occurrence of the
violation. However, when a creditor, assignee, or other holder or anyone acting
on their behalf initiates a judicial or non-judicial foreclosure, or any other
action to collect the debt, a consumer may assert a violation as a matter of
defense by recoupment or set-off without regard to a time limit. The amount of
recoupment or set-off shall equal the amount to which the consumer would be
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625487994 XXX XXX XXX 29372455 compliance 1 ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy Verification appraisal was delivered to borrower was not provided. There is generally no Assignee Liability. 4/XX/2019 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Appraisal delivery received.
File) of the appraisal at least three (3) business days prior to closing, and
appraisal was not provided at or before closing. (Type:Primary/03/XX/2019)
625487994 XXX XXX XXX 29372456 credit 1 No evidence of fraud report in file Credit Report: Original // Borrower: XXX 4/XX/2019 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Received
625487994 XXX XXX XXX 29372457 credit 3 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement 4/XX/2019 CA Refinance - Rate/Term Primary No C C C C 7/XX/2023 Non QM
625487994 XXX XXX XXX 29372458 credit 1 Missing Document: Missing Final 1003 File is missing fully signed/dated final application. 4/XX/2019 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Received
625487994 XXX XXX XXX 29372460 credit 1 Missing Document: Rider - PUD not provided Executed PUD Rider not provided. 4/XX/2019 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Received
625487994 XXX XXX XXX 29372461 credit 1 Missing Document: Security Instrument - Subject Lien not provided Executed Security Instrument not provided. 4/XX/2019 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Received
625487994 XXX XXX XXX 29372462 credit 1 Missing Document: Rider - ARM not provided Executed ARM Rider not provided. 4/XX/2019 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Received
625487994 XXX XXX XXX 29372463 compliance 1 ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM Disclosure is missing from the file. TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2019 4/XX/2020 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Received; however, see updated condition as it was not provided
borrower. within 3 business days of application.
625487994 XXX XXX XXX 29372464 compliance 1 General Ability To Repay Provision Income and Assets - Assets Ability to Repay (Dodd-Frank 2014): Unable to verify assets using reasonably Failure is due to missing asset and income documentation which is waterfalling Assignee Liability: Violations can result in regular TILA damages (actual 4/XX/2019 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: VOE received. Loan approved under Portfolio Express which allowed
reliable third-party records. (XXX/Savings) to ATR/QM testing. Lender approved loan as a portfolio express product. damages, statutory damages of up to $XXX costs, and attorney's fees) and stated assets. Condition cleared.
enhanced damages (an amount equal to the sum of all finance charges and fees
paid by the consumer, unless the creditor demonstrates that the failure to
comply is not material). A private right of action may be brought before the end
of the three-year period beginning on the date of the occurrence of the
violation. However, when a creditor, assignee, or other holder or anyone acting
on their behalf initiates a judicial or non-judicial foreclosure, or any other
action to collect the debt, a consumer may assert a violation as a matter of
defense by recoupment or set-off without regard to a time limit. The amount of
recoupment or set-off shall equal the amount to which the consumer would be
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625487994 XXX XXX XXX 29372465 compliance 1 General Ability To Repay Provision Income and Assets - Assets Ability to Repay (Dodd-Frank 2014): Unable to verify assets using reasonably Failure is due to missing asset and income documentation which is waterfalling Assignee Liability: Violations can result in regular TILA damages (actual 4/XX/2019 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: VOE received. Loan approved under Portfolio Express which allowed
reliable third-party records. (XXX/401(k)/403(b) Account) to ATR/QM testing. Lender approved loan as a portfolio express product. damages, statutory damages of up to $XXX costs, and attorney's fees) and stated assets. Condition cleared.
enhanced damages (an amount equal to the sum of all finance charges and fees
paid by the consumer, unless the creditor demonstrates that the failure to
comply is not material). A private right of action may be brought before the end
of the three-year period beginning on the date of the occurrence of the
violation. However, when a creditor, assignee, or other holder or anyone acting
on their behalf initiates a judicial or non-judicial foreclosure, or any other
action to collect the debt, a consumer may assert a violation as a matter of
defense by recoupment or set-off without regard to a time limit. The amount of
recoupment or set-off shall equal the amount to which the consumer would be
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625487994 XXX XXX XXX 29372466 compliance 2 ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM disclosure provided 3/XX/2019, which was not within 3 days of application. TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2019 4/XX/2020 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
borrower within three (3) days of application.
625487994 XXX XXX XXX 29372467 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM disclosure provided 3/XX/2019, which was not within 3 days of application. TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2019 4/XX/2020 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625488997 XXX XXX XXX 29372629 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to applicant three (3) 11/XX/2014 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Consummation valuation to applicant three (3) business days prior to consummation. business days prior to consummation.
(Type:Primary/10/XX/2014)
625488997 XXX XXX XXX 29372630 compliance 2 RESPA Disclosure - HUD Settlement Cost Booklet Missing RESPA Disclosure Rule: Creditor did not provide HUD Settlement Cost Booklet. Creditor did not provide HUD Settlement Cost Booklet. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2014 CA Purchase Primary No B B B B 7/XX/2023 Non QM
within the statute or implementing regulation, Regulation X, for these type of
violations.
625488997 XXX XXX XXX 29372631 compliance 2 RESPA - Initial Escrow Account Statement Missing RESPA: Initial escrow account statement was not provided to the borrower. Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2014 CA Purchase Primary No B B B B 7/XX/2023 Non QM
within the statute or implementing regulation, Regulation X, for these type of
violations.
625488997 XXX XXX XXX 29372632 compliance 2 RESPA Disclosure - List of Homeownership Counseling Organizations Missing RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Creditor did not provide List of Homeownership Counseling Organizations to RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2014 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Homeownership Counseling Organizations to borrower. borrower. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488997 XXX XXX XXX 29372633 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The property is located in FEMA Disaster area. Provide a post-disaster 11/XX/2014 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/01: PDI provided, exception cleared.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage. The inspection must include exterior
Disaster Name: XXX photos and the property must be re-inspected on or after XX/XX/XXXX declared end
Disaster Declaration Date: XX/XX/XXXX date.
625488997 XXX XXX XXX 29372634 compliance 2 (Doc Error) GFE Error: Changed Circumstance not provided. GFE Date: 11/XX/2014 Changed Circumstance not provided for GFE dated 11/XX/2014 Changed Circumstance not provided in file. 11/XX/2014 CA Purchase Primary No B B B B 7/XX/2023 Non QM
from GFE dated 10/XX/2014
625488997 XXX XXX XXX 29372635 credit 1 Verification(s) of employment is not within 10 business days of the Note. Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: Verification of employment is not within 10 business days of the Note. 11/XX/2014 CA Purchase Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/02: VVOEprovided showing confirmation of continued employment on
01/XX/2005 11/XX/2014.
625488997 XXX XXX XXX 29372636 credit 3 Guideline Issue:Insufficient asset documentation. Financial Institution: XXX // Account Type: Savings / Account Number: XXX Two months bank statements were not provided as required per the guidelines. 11/XX/2014 CA Purchase Primary No C C C C 7/XX/2023 Non QM
625488955 XXX XXX XXX 29372687 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX 2/XX/2021 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor QM 2023/XX/01: BPO provided reflects no damage.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488955 XXX XXX XXX 29372688 credit 3 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement E-sign Consent Agreement not provided. 2/XX/2021 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor QM
625488955 XXX XXX XXX 29372689 compliance 2 ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy Verification of appraisal was delivered to borrower was not provided There is generally no Assignee Liability. 2/XX/2021 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM
File) of the appraisal at least three (3) business days prior to closing, and
appraisal was not provided at or before closing. (Type:Primary/01/XX/2021)
625488955 XXX XXX XXX 29372691 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Credit Repot Fee was last disclosed $XXX on LE but disclosed as$XXX on Final CD. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 2/XX/2021 2/XX/2022 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM
Report Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no File does not contain COC for this file Cure provided at closing liability.
cure was provided to the borrower. (7520)
625488955 XXX XXX XXX 29372692 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Flood Flood Certification Fee was not disclosed on Loan Estimate but was disclosed as TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 2/XX/2021 2/XX/2022 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM
Certification (Initial Fee). Fee Amount of $XXX exceeds tolerance of $XXX. $XXX on the final CD. File does not a valid COC for this fee cure provided at liability.
Insufficient or no cure was provided to the borrower. (7531) closing.
625488955 XXX XXX XXX 29372693 compliance 2 ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM loan program disclosure not provided to the borrower within three (3) days TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2021 2/XX/2022 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM
borrower within three (3) days of application. of application.
625488955 XXX XXX XXX 29372694 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2021 2/XX/2022 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM 2023/XX/30: Missing CHARM Booklet provided within 3 days of application.
CHARM Booklet, not provided to the borrower within three (3) days of the borrower within three (3) days of application.
application.
625488955 XXX XXX XXX 29372695 credit 2 Loans with an application date after 10/XX/2020 using a LIBOR Index are not Index: LIBOR - 1 Year (Daily); Note Date: 02/XX/2021 2/XX/2021 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM
Agency Salable.
625488317 XXX XXX XXX 29372696 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX Post Disaster Inspection (PDI) document is missing. 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488317 XXX XXX XXX 29372697 credit 3 REO Documents are missing. Insurance Verification, Statement, Tax Verification document missing for 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023
property address XXX, CA
625488317 XXX XXX XXX 29372698 credit 3 REO Documents are missing. Insurance Verification, Lease Agreement, Statement, Tax Verification document 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023
missing for property address XXX, AZ
625488317 XXX XXX XXX 29372699 credit 3 REO Documents are missing. Insurance Verification, Lease Agreement, Statement, Tax Verification document 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023
missing for property Address: XXX, NV
625488317 XXX XXX XXX 29372700 credit 3 REO Documents are missing. Insurance Verification, Lease Agreement, Statement, Tax Verification document 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023
missing for property Address: XXX, AZ:
625488317 XXX XXX XXX 29372701 credit 3 REO Documents are missing. Insurance Verification, Lease Agreement, Statement, Tax Verification document 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023
missing for property Address: XXX, AZ
625488317 XXX XXX XXX 29372702 credit 3 Income Docs Missing: Borrower: XXX 1065 (2014), 1065 (2015), 1099-SSA (2014), 1099-SSA (2015), K-1 All income documentation is missing for all borrowers. 2015/2014 signed/dated 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 2023/XX/08: File is missing all personal & business income documentation.
(2014), K-1 (2015), VVOE - Employment Only, W-2 (2015), W-2 (2016) personal and business tax returns and K1's, year to date P&L's/Balance sheets, Condition remains.
third party verification dated within 30 days prior to note date, all income
documentation for any additional income being used and award letters. Unable to
determine all borrowers' income and business structure due to missing
documentation.
625488317 XXX XXX XXX 29372703 credit 3 Income Docs Missing: Borrower: XXX 1065 (2014), 1065 (2015), K-1 (2014), K-1 (2015), VVOE - All income documentation is missing for all borrowers. 2015/2014 signed/dated 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 2023/XX/08: File is missing all personal & business income documentation.
Employment Only personal and business tax returns and K1's, year to date P&L's/Balance sheets, Condition remains.
third party verification dated within 30 days prior to note date, all income
documentation for any additional income being used and award letters. Unable to
determine all borrowers' income and business structure due to missing
documentation.
625488317 XXX XXX XXX 29372704 credit 3 Income Docs Missing: Borrower: XXX 1065 (2014), 1065 (2015), K-1 (2014), K-1 (2015), VVOE - All income documentation is missing for all borrowers. 2015/2014 signed/dated 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 2023/XX/08: File is missing all personal & business income documentation.
Employment Only, W-2 (2014), W-2 (2015) personal and business tax returns and K1's, year to date P&L's/Balance sheets, Condition remains.
third party verification dated within 30 days prior to note date, all income
documentation for any additional income being used and award letters. Unable to
determine all borrowers' income and business structure due to missing
documentation.
625488317 XXX XXX XXX 29372705 credit 3 Income documentation requirements not met. All income documentation is missing for all borrowers. 2015/2014 signed/dated 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 2023/XX/08: File is missing all personal & business income documentation.
personal and business tax returns and K1's, year to date P&L's/Balance sheets, Condition remains.
third party verification dated within 30 days prior to note date, all income
documentation for any additional income being used and award letters. Unable to
determine all borrowers' income and business structure due to missing
documentation.
625488317 XXX XXX XXX 29372706 credit 3 REO Documents are missing. Address: XXX, CA Insurance Verification, Lease Agreement, Tax Verification 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023 2023/XX/08: EXCEPTION HISTORY - Exception Explanation was updated on 09/XX/2023
PRIOR Exception Explanation: Insurance Verification, Lease Agreement, Statement,
Tax Verification
625488317 XXX XXX XXX 29372707 credit 3 REO Documents are missing. Address: XXX, NV Insurance Verification, Lease Agreement, Statement, Tax 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023
Verification
625488317 XXX XXX XXX 29372708 credit 3 REO Documents are missing. Address: XXX, AZ Insurance Verification, Lease Agreement, Statement, Tax 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023
Verification
625488317 XXX XXX XXX 29372709 credit 3 REO Documents are missing. Address: XXX, AZ Insurance Verification, Lease Agreement, Statement, Tax 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023
Verification
625488317 XXX XXX XXX 29372710 credit 3 REO Documents are missing. Address: XXX, AZ Insurance Verification, Lease Agreement, Statement, Tax 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023
Verification
625488317 XXX XXX XXX 29372711 credit 3 REO Documents are missing. Address: XXX, CA Insurance Verification, Statement, Tax Verification 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023
625488317 XXX XXX XXX 29372712 credit 3 REO Documents are missing. Address: XXX, CA Insurance Verification, Statement, Tax Verification 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023
625488317 XXX XXX XXX 29372713 credit 3 REO Documents are missing. Address: XXX, NV Insurance Verification, Lease Agreement, Statement, Tax 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023
Verification
625488317 XXX XXX XXX 29372714 credit 3 REO Documents are missing. Address: XXX, CA Insurance Verification 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023
625488317 XXX XXX XXX 29372715 credit 3 REO Documents are missing. Address: XXX, CA Insurance Verification, Statement, Tax Verification 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023
625488317 XXX XXX XXX 29372716 credit 3 Guideline Requirement: PITIA reserves months discrepancy. Calculated PITIA months reserves of 0.00 is less than Guideline PITIA months Borrower has insufficient assets to cover funds to close and extended reserves 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023
reserves of 48.00. required.
625488317 XXX XXX XXX 29372717 credit 3 Asset documentation requirements not met. File is missing sufficient asset documentation to cover funds to close and 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023
required extensive reserves due to properties owned.
625488317 XXX XXX XXX 29372718 credit 3 Aged document: Asset Account date is more than 90 days prior to Closing. Financial Institution: XXX // Account Type: Individual Retirement Account (IRA) Both accounts exceeds the 90 age of document reflected in the lender guidelines. 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023
/ Account Number: XXX, Financial Institution: XXX // Account Type: Stocks /
Account Number: XXX
625488317 XXX XXX XXX 29372719 credit 3 Available for Closing is insufficient to cover Cash From Borrower. Documented qualifying Assets for Closing of $XXX is less than Cash From Borrower Borrower's are missing sufficient asset documentation to cover funds to close. 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023
$XXX.
625488317 XXX XXX XXX 29372720 credit 3 AUS/Guideline Findings: All conditions were not met File is missing sufficient assets, all income documents for all borrowers, REO 7/XX/2016 CA Purchase Investment No C C C C 7/XX/2023
supporting documentation.
625489389 XXX XXX XXX 29372735 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX Subject property was appraised on XX/XX/XXXX prior to the FEMA disaster ( XXX) 6/XX/2020 CA Purchase Primary No A A A A 7/XX/2023 5/XX/2023 Yes Safe Harbor QM 2023/XX/31: BPO provided reflecting no damage.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX dated XX/XX/XXXX through XX/XX/XXXX. File is missing a property inspection dated
Disaster Name: XXX after the disaster, or the lender's Rep and Warranty attestation along with
Disaster Declaration Date: XX/XX/XXXX visible confirmation that the subject property was not damaged
625489389 XXX XXX XXX 29372736 property 1 Loan is to be securitized. The only valuation provided was a Drive by. It is 6/XX/2020 CA Purchase Primary No A A A A 7/XX/2023 5/XX/2023 Yes Safe Harbor QM 2023/XX/31: Client not securitizing loan.
interpreted that this Drive By was used in lieu of URAR and that this file is
missing the secondary valuation (GSE COVID19)
625489389 XXX XXX XXX 29372737 compliance 2 ECOA Appraisal - Appraisal Provided Prior to Date Performed ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is Date valuation provided to applicant is prior to the date when valuation was 6/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM
prior to the date when valuation was performed. Unable to determine compliance performed. Unable to determine compliance with appraisal timing requirements
with appraisal timing requirements. (Type:Primary/05/XX/2020)
625489389 XXX XXX XXX 29372738 compliance 2 TRID Final Closing Disclosure Contact Information - Lender TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure Final Closing Disclosure provided on 06/XX/2020, page (5) missing Lender contact TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 6/XX/2020 6/XX/2021 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM
provided on 06/XX/2020 did not disclose the required Lender Contact Information name. liability.
(Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/06/XX/2020)
625489389 XXX XXX XXX 29372739 compliance 2 TRID Final Closing Disclosure Payment Adjusts Every TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Loan Terms: Final Closing Disclosure provided on 06/XX/2020 with an increasing TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 6/XX/2020 6/XX/2021 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM
on 06/XX/2020 with an increasing payment disclosed the frequency of adjustments payment disclosed the frequency of adjustments that does not match the actual Assignee liability.
that does not match the actual adjustment period for the loan. adjustment period for the loan
(Final/06/XX/2020)
625489389 XXX XXX XXX 29372740 compliance 2 TRID Initial Closing Disclosure Timing without Waiver TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure not provided to Borrower(s) at least three (3) business days TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 6/XX/2020 6/XX/2021 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM
at least three (3) business days prior to closing. (Initial/06/XX/2020) prior to closing liability.
625489389 XXX XXX XXX 29372742 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, was not provided TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2020 6/XX/2021 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM
CHARM Booklet, not provided to the borrower. to the borrower.
625489110 XXX XXX XXX 29372778 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX 6/XX/2016 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/01: BPO provided reflects no damage.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625489110 XXX XXX XXX 29372779 compliance 2 TRID Final Closing Disclosure Finance Charge TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Finance charge is under disclosed by $XXX. Unable to determine the cause for the TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2016 6/XX/2019 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
provided on 05/XX/2016 disclosed an inaccurate Finance Charge on page 5 that under disclosure due to missing the itemization of the amount financed. defense to foreclosure. Assignee liability.
does not match the actual Finance Charge for the loan (fee amounts included in
Finance Charge calculation are based on Closing Disclosure dated 05/XX/2016).
(Final/05/XX/2016)
625489110 XXX XXX XXX 29372780 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Verification appraisal was delivered to borrower was not provided. 6/XX/2016 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
Consummation valuation to applicant three (3) business days prior to consummation.
(Type:Primary/05/XX/2016)
625489110 XXX XXX XXX 29372782 compliance 2 TRID Final Closing Disclosure Non Escrow Costs Year 1 Underdisclosed - Pre TILA-RESPA Integrated Disclosure - Loan Disclosures: Non Escrowed Property Costs HOA costs of $XXX per month were not included in the non-escrowed property costs TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 6/XX/2016 6/XX/2017 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
October 2018 over Year 1 of on Final Closing Disclosure provided on 05/XX/2016 are on page 4 of the CD liability.
underdisclosed. (Final/05/XX/2016)
625489110 XXX XXX XXX 29372783 credit 1 The verification of employment is not within 10 business days of the Note. Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: 6/XX/2016 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/18: VVOE missing, however the file contains sufficient 3rd party 2023/XX/21: AUS states to "Perform and document a verbal verification of
10/XX/2013 verification/documentation supporting use of income. A written verification of employmentt for each borrower within 10 business days prior to the note date for
employment was obtained, dated 5/XX/2016, 14 days within date of note. Receipt all borrowers not using self-employment income for qualifying" Borrower is not
of income with paystub dated 5/XX/16; pay period ending 5/XX/16 is also included self-employed, Guidelines state same requirement for Hourly, Salary and
in loan file. DU allow a third- party verification of employment to be Commission income. Exception remains.
acceptable but not dated more than 35 days old as of the note date.
Loan file contains written verification of employment dated 5/XX/2016 and the 2023/XX/14: Cleared. Switched to Non qm guides
most recent paystub dated 5/XX/2016, sufficient per the latest DU
approve/eligible submitted 5/XX/2016.
2023/XX/25: Agree with error, but don't agree with ATR impact based on overall
file risk & quality.
625489110 XXX XXX XXX 29372784 credit 3 File does not contain documentation from lender/seller confirming the condo is Valuation Type: Appraisal / Valuation Report Date: 05/XX/2016 File is missing documentation verifying the subject property condo is 6/XX/2016 CA Refinance - Rate/Term Primary No C C C C 7/XX/2023 Non QM
warrantable. warrantable.
625489110 XXX XXX XXX 29372785 compliance 2 Missing Document: Missing Lender's Initial 1003 Missing signed and dated initial 1003. 6/XX/2016 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM 2023/XX/25: Missing signed and dated initial application.
625489110 XXX XXX XXX 29372786 credit 3 Income documentation requirements not met. The VVOE is not dated within 10 business days of the note date. 6/XX/2016 CA Refinance - Rate/Term Primary No C C C C 7/XX/2023 Non QM 2023/XX/18: N/A; Duplicative Exception 2023/XX/21: AUS states to "Perform and document a verbal verification of
employmentt for each borrower within 10 business days prior to the note date for
2023/XX/25: Duplicate and/or waterfall exception all borrowers not using self-employment income for qualifying" Borrower is not
self-employed, Guidelines state same requirement for Hourly, Salary and
Commission income. Exception remains.
2023/XX/27: Unable to clear. Per lender guides, a VVOE dated within 10 days
prior to the note date is required.
625489110 XXX XXX XXX 29372787 compliance 1 QM Employment History - Current and/or Previous Employment Documentation lacks Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two Failure due to missing VVOE dated within 10 business days prior to note for 6/XX/2016 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/14: Loan has been re designated to Non QM
Date Info years employment history for current and/or prior employment. (XXX/12401140) borrower's current employment as required per AUS.
625489110 XXX XXX XXX 29372788 compliance 1 Income/Asset Guideline Deficiency - ATR Impact Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to Failure due to missing VVOE dated within 10 business days prior to note for 6/XX/2016 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/18: N/A; Duplicative Exception 2023/XX/21: AUS states to "Perform and document a verbal verification of
income and/or asset doc requirements which could result in a risk to the borrower's current employment as required per AUS. employmentt for each borrower within 10 business days prior to the note date for
borrower's ability to repay. (Exception is eligible to be regraded with 2023/XX/25: Duplicate and/or waterfall exception all borrowers not using self-employment income for qualifying" Borrower is not
compensating factors.) self-employed, Guidelines state same requirement for Hourly, Salary and
Commission income. Exception remains.
2023/XX/14: Loan has been re designated to Non QM
625489110 XXX XXX XXX 29372789 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Temporary Failure due to missing VVOE dated within 10 business days prior to note for Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 6/XX/2016 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/18: N/A; Duplicative Exception 2023/XX/21: AUS states to "Perform and document a verbal verification of
SHQM (GSE/Agency Eligible) does not match Due Diligence Loan Designation of ATR borrower's current employment as required per AUS. Designation to the TPR firm performing the loan level due diligence and to have employmentt for each borrower within 10 business days prior to the note date for
Risk. the TPR firm confirm said designation. 2023/XX/25: Duplicate and/or waterfall exception all borrowers not using self-employment income for qualifying" Borrower is not
self-employed, Guidelines state same requirement for Hourly, Salary and
Commission income. Exception remains.
2023/XX/14: Loan has been re designated to Non QM
625489110 XXX XXX XXX 29372790 compliance 1 QM DTI Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and Failure due to missing VVOE dated within 10 business days prior to note for Although this issue is subject to a 3 year SOL for affirmative claims under 6/XX/2016 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/18: N/A; Duplicative Exception 2023/XX/14: Loan has been re designated to Non QM
the images do not provide evidence loan is eligible for purchase, guarantee or borrower's current employment as required per AUS. TILA, AMC does not adjust grading taking into account TILA SOL for exceptions
insurance by the appropriate agency. under ATR, given the potential for enhanced damages when asserting an ability to 2023/XX/25: Duplicate and/or waterfall exception
repay defense in response to an action to collect a debt by recoupment or
set-off.
625489110 XXX XXX XXX 29372791 compliance 1 General Ability To Repay Provision Investor Guidelines Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Failure due to missing income documents. 6/XX/2016 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/18: N/A; Duplicative Exception 2023/XX/21: AUS states to "Perform and document a verbal verification of
guideline components, the loan is at ATR risk. employmentt for each borrower within 10 business days prior to the note date for
2023/XX/25: Duplicate and/or waterfall exception all borrowers not using self-employment income for qualifying" Borrower is not
self-employed, Guidelines state same requirement for Hourly, Salary and
Commission income. Exception remains.
2023/XX/14: Loan has been re designated to Non QM
625489110 XXX XXX XXX 29372792 compliance 2 Check Restated Loan Designation Match - General Ability to Repay Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did Loan has been re designated to Non QM Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 6/XX/2016 CA Refinance - Rate/Term Primary No B B A A 7/XX/2023 Non QM
not match. However, the updated Loan Designation of Non QM matches the Due Designation to the TPR firm performing the loan level due diligence and to have
Diligence Loan Designation of Non QM. the TPR firm confirm said designation.
625488292 XXX XXX XXX 29372800 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX Post Disaster Inspection Report is missing from file. 3/XX/2015 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Temporary SHQM (GSE/Agency Eligible) 2023/XX/01: BPO provided reflects no damage.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488292 XXX XXX XXX 29372801 compliance 2 ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Missing ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Borrower was not provided with Right to Receive Appraisal Disclosure. There is generally no Assignee Liability. 3/XX/2015 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Temporary SHQM (GSE/Agency Eligible)
Receive a Copy" appraisal disclosure to consumer.
625488292 XXX XXX XXX 29372802 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement The Affiliated Business Arrangement Disclosure in file is dated 03/XX/2015 which RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2015 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Temporary SHQM (GSE/Agency Eligible)
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. is more than 3 business days after the application date of 02/XX/2015. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488292 XXX XXX XXX 29372803 compliance 2 RESPA Servicing Disclosure: Servicing Disclosure Statement Not Provided Within 3 RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure The RESPA Servicing Disclosure in file is dated 03/XX/2015 which is more than 3 RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2015 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Temporary SHQM (GSE/Agency Eligible)
Business Days of Application Statement to applicant within three (3) business days of application. business days after the application date of 02/XX/2015. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488292 XXX XXX XXX 29372804 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Disclosure reflects Finance Charge of $XXX but calculated Finance Charge of $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 3/XX/2015 3/XX/2018 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Temporary SHQM (GSE/Agency Eligible)
calculated Finance Charge of $XXX in the amount of $XXX. $XXX. Variance is $XXX. Lender to provide corrected TIL and copy of letter sent for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
to borrower explaining changes. liability.
625488292 XXX XXX XXX 29372806 compliance 2 (Doc Error) GFE Error: There is no evidence that the interest rate was locked The only Good Faith Estimate in file reflects the interest rate as not locked. 3/XX/2015 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Temporary SHQM (GSE/Agency Eligible)
prior to closing
625488628 XXX XXX XXX 29372900 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The property is located in FEMA Disaster area. Provide a post-disaster 4/XX/2016 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 6/XX/2023 Yes Temporary SHQM (GSE/Agency Eligible) 2023/XX/01: BPO provided reflects no damage.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage. The inspection must include exterior
Disaster Name: XXX photos and the property must be re-inspected on or after XX/XX/XXXX declared end
Disaster Declaration Date: XX/XX/XXXX date.
625488628 XXX XXX XXX 29372901 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Loan Discount Points Fee was last disclosed as $XXX on LE but disclosed as $XXX TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 4/XX/2016 4/XX/2017 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Temporary SHQM (GSE/Agency Eligible)
Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or on Final Closing Disclosure. File does not contain a valid COC for this fee, nor liability.
no cure was provided to the borrower. (7200) evidence of cure in file. A copy of refund check, proof of delivery, and a copy
of the letter of explanation sent to the borrower disclosing the changes made.
625488628 XXX XXX XXX 29372902 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Verification appraisal was delivered to borrower was not provided. 4/XX/2016 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Temporary SHQM (GSE/Agency Eligible)
Consummation valuation to applicant three (3) business days prior to consummation.
(Type:Primary/03/XX/2016)
625488628 XXX XXX XXX 29372903 compliance 2 TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total 10% tolerance was exceeded by $XXX due to increase of title fees. No valid COC 4/XX/2016 4/XX/2017 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Temporary SHQM (GSE/Agency Eligible)
amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no provided, nor evidence of cure in file. Provide a post-close CD disclosing the
cure was provided to the borrower. (0) tolerance cure to include $XXX, a copy of refund check, proof of delivery, and a
copy of the letter of explanation sent to the borrower disclosing the changes
made.
625488768 XXX XXX XXX 29373184 compliance 2 TRID Initial Closing Disclosure Timing without Waiver TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure Issue Date 2017/XX/26 which is not provided at least three TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 10/XX/2017 10/XX/2018 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B 7/XX/2023 Non QM
at least three (3) business days prior to closing. (Initial/10/XX/2017) (3) business days prior to closing. liability.
625488768 XXX XXX XXX 29373185 credit 3 Income Docs Missing: Borrower: XXX 1040 - Schedule C (2016) File is missing 2016 Schedule C for Co-Borrower. 10/XX/2017 CA Refinance - Cash-out - Debt Consolidation Primary No C C C C 7/XX/2023 Non QM
625488768 XXX XXX XXX 29373186 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA Disaster area post-close. A 10/XX/2017 CA Refinance - Cash-out - Debt Consolidation Primary No A A A A 7/XX/2023 5/XX/2023 Yes Non QM 2023/XX/31: BPO dated 5/XX/23 showing no damage to property has been received.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX post-disaster inspection verifying there was no damage to the subject property
Disaster Name: XXX is required once a declared end date is identified.
Disaster Declaration Date: XX/XX/XXXX
625488768 XXX XXX XXX 29373187 compliance 2 ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the Application date is 09/XX/2017 and docuemnt was provided on 09/XX/2017. TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2017 10/XX/2018 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B 7/XX/2023 Non QM
borrower within three (3) days of application.
625488768 XXX XXX XXX 29373188 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Application date is 09/XX/2017 and docuemnt was provided on 09/XX/2017. TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2017 10/XX/2018 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B 7/XX/2023 Non QM
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625488768 XXX XXX XXX 29373189 compliance 2 Self-Employed Tax Return Recency - ATR Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or File is missing income verification for B2 - 1065 Q Communication Third Party 10/XX/2017 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B 7/XX/2023 Non QM
personal tax returns provided are not the most recent. Application Date verification and Schedule C for year 2016.
09/XX/2017, Most Recent Tax Return End Date 12/XX/2015, Tax Return Due Date
04/XX/2017. (XXX XXX/Schedule C)
625488768 XXX XXX XXX 29373190 compliance 2 RESPA Disclosure - List of Homeownership Counseling Organizations Missing RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Loan file contains the one page acknowledgment from Borrowers; however, the RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2017 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B 7/XX/2023 Non QM
Homeownership Counseling Organizations to borrower. actual list containing the required 10 counseling agencies was not provided. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488012 XXX XXX XXX 29373317 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX 1/XX/2018 CA Purchase Primary No A A A A 7/XX/2023 5/XX/2023 Yes ATR Risk 2023/XX/31: BPO dated 5/XX/23 showing no damage to property has been received.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488012 XXX XXX XXX 29373319 credit 3 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement 1/XX/2018 CA Purchase Primary No C C C C 7/XX/2023 ATR Risk
625488012 XXX XXX XXX 29373320 compliance 1 S-Corp Income Documentation Test Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not The personal tax returns are not signed and dated by the borrower, causing the 1/XX/2018 CA Purchase Primary No A A A A 7/XX/2023 10/XX/2023 Yes ATR Risk 2023/XX/18: 2015/2016 Personal tax returns are not signed, however the tax 2023/XX/28: Trailing documents reviewed unable to clear.
sufficient (S-Corp). (XXX XXX/S-Corp) loan to waterfall through the QM Testing. transcripts for 2015/2016 are in file therefore tax returns do not need to be
signed. 2023/XX/21: Self-employment income not sufficient due to missing most recent
fully executed and complete Personal Tax Returns (2016 and 2015). Verified 2014,
2023/XX/25: Disagree with interpretation of ATR requirements. XXX guidelines 2015 and 2106 Tax Transcripts are provided. Fully executed P&L provided January
allow use of validated IRS tax returns in lieu of signed tax returns/financials. - November 2017. Portfolio Programs reflect when tax returns are in file the
See RLU-NA section 302-2.1.4. Borrower must sign the tax returns at or before closing unless the tax
transcripts have been obtained directly from the IRS. The Exception Remains due
to the Non QM DTI of 43.56% moderately exceeding the guideline maximum of 43%
resulting in the signed tax return requirement.
2023/XX/27: Loan submitted with a Loan Designation of Safe Harbor QM. Based on
Safe Harbor requirements, signed and dated tax returns are required. Condition
remains.
2023/XX/03: Client elects to restate loan to NonQM.
625488012 XXX XXX XXX 29373321 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Signed and dated business tax returns for the most recent year (2017) is not Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 1/XX/2018 CA Purchase Primary No A A A A 7/XX/2023 10/XX/2023 Yes ATR Risk 2023/XX/18: Loan closed 1/XX/2018 therefore 2017 personal/business tax returns 2023/XX/13: Update: File is missing signed/dated personal tax returns.
QM does not match Due Diligence Loan Designation of ATR Risk. provided., causing the loan to waterfall through the QM Testing. Designation to the TPR firm performing the loan level due diligence and to have would not be provided. 2015/2016 Personal and business tax returns are in file
the TPR firm confirm said designation. but are not signed, however the tax transcripts for 2015/2016 are in file 2023/XX/28: Trailing documents reviewed unable to clear
therefore tax returns do not need to be signed.
2023/XX/21: Self-employment income not sufficient due to missing most recent
2023/XX/25: Disagree with interpretation of ATR requirements. XXX guidelines fully executed and complete Personal Tax Returns (2016 and 2015). Verified 2014,
allow use of validated IRS tax returns in lieu of signed tax returns/financials. 2015 and 2106 Tax Transcripts are provided. Fully executed P&L provided January
See RLU-NA section 302-2.1.4. - November 2017. Portfolio Programs reflect when tax returns are in file the
Borrower must sign the tax returns at or before closing unless the tax
transcripts have been obtained directly from the IRS. The Exception Remains due
to the Non QM DTI of 43.56% moderately exceeding the guideline maximum of 43%
resulting in the signed tax return requirement.
2023/XX/27: Loan submitted with a Loan Designation of Safe Harbor QM. Based on
Safe Harbor requirements, signed and dated tax returns are required. Condition
remains.
2023/XX/03: Client elects to restate loan to NonQM.
625488012 XXX XXX XXX 29373322 compliance 2 RESPA - Initial Escrow Account Statement Missing RESPA: Initial escrow account statement was not provided to the borrower. Disclosure: Initial Escrow Account Statement is not provided in file. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 1/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 ATR Risk
within the statute or implementing regulation, Regulation X, for these type of
violations.
625488012 XXX XXX XXX 29373323 compliance 2 RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling List of Homeownership Counseling Organizations was not provided to borrower RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 1/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 ATR Risk
Within 3 Business Days of Application Organizations not provided to applicant within three (3) business days of within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
application. violations.
625488012 XXX XXX XXX 29373325 compliance 1 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2018 1/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 7/XX/2023 Yes ATR Risk 2023/XX/30: Missing CHARM Booklet provided within 3 days of application.
CHARM Booklet, not provided to the borrower.
2023/XX/28: Application Disclosure Package Receipt Confirmation.
625488012 XXX XXX XXX 29373326 compliance 1 General Ability To Repay Provision Investor Qualification Method not Matching Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender The guidelines require 10/1 ARMS to be quaiflied using the Note rate, causing 1/XX/2018 CA Purchase Primary No A A A A 7/XX/2023 10/XX/2023 Yes ATR Risk 2023/XX/13: Per lender guides, a 10/1 ARM qualification method is the note rate
ATR does not match the ATR payment calculation methods under 1026.43(c)(5). the loan to waterfall through the QM Testing.. which is non compliant under 1026.43(c)(5).
2023/XX/01: Reviewed the Trailing documentation and the provided documents are
not sufficient to clear. Exception remains.
2023/XX/03: Updated qualification method.
625488012 XXX XXX XXX 29373327 compliance 1 General Ability To Repay Provision Non QM DTI moderately exceeds Guidelines Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the The guidelines require 10/1 ARMS to be quaiflied using the Note rate, which 1/XX/2018 CA Purchase Primary No A A A A 7/XX/2023 10/XX/2023 Yes ATR Risk 2023/XX/18: The final DTI per the final 1008 is 42.303/42.520% which consists of 2023/XX/28: Trailing documents reviewed unable to clear.
1026.43(c)(5) of 43.56% moderately exceeds the guideline maximum of 43.00%. (DTI results in a DTI of 43.75% that exceeds the QM maximum DTI of 43%, causing the $XXX PITIA and $XXX all other payments against the calculated income of $XXX.
Exception is eligible to be regraded with compensating factors.) loan to waterfall through the QM Testing. Which includes the Note rate of 3.875%. 2023/XX/01: EXCEPTION HISTORY - Exception Detail was updated on 08/XX/2023 PRIOR
Exception Detail: Ability to Repay (Dodd-Frank 2014): The DTI calculated in
2023/XX/25: Disagree; system automatically calculates the greater of fully accordance with the 1026.43(c)(5) of 43.75% moderately exceeds the guideline
indexed rate at fully am payment or the note rate at fully am payment. System maximum of 43.00%. (DTI Exception is eligible to be regraded with compensating
generated final 1003/08 states DTI is within max allowed parameters. factors.)
2023/XX/21: Non-Qualified Mortgage qualifying rate is the greater of the fully
indexed rate at fully amortized payment (4.26075%). or the Note Rate at the
fully amortized payment (3.875%). The Non QM qualifying rate results in a DTI of
43.56% moderately exceeding the guideline maximum of 43%. Exception remains.
2023/XX/27: DD is unable to clear. The standard qualification method reflects a
DTI of 43.56%. Condition remains.
2023/XX/03: Updated qualification method.
625488012 XXX XXX XXX 29373328 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Provide evidence the Consumer Handbook on Adjustable Rate Mortgages, CHARM TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2018 1/XX/2019 CA Purchase Primary No B B B B 7/XX/2023 ATR Risk
CHARM Booklet, not provided to the borrower within three (3) days of Booklet, was provided to the borrower within three (3) days of application.
application.
625488012 XXX XXX XXX 29373329 compliance 3 Check Loan Designation Match - ATR Risk Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Client elects to restate loan to NonQM. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 1/XX/2018 CA Purchase Primary No C C B B 7/XX/2023 ATR Risk
not match Due Diligence Loan Designation of ATR Risk. Designation to the TPR firm performing the loan level due diligence and to have
the TPR firm confirm said designation.
625488012 XXX XXX XXX 29373330 compliance 3 General ATR Provision Investor and Non QM DTIs match and both moderately exceed Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Able to be waived down with compensating factors. 1/XX/2018 CA Purchase Primary No C C C C 7/XX/2023 ATR Risk
Guidelines Lenders Guidelines and 1026.43(c)(5) of 43.55954% moderately exceeds the
guideline maximum of 43.00%. (DTI Exception is eligible to be regraded with
compensating factors.)
625488012 XXX XXX XXX 29373331 credit 3 Guideline Requirement: Investor qualifying total debt ratio discrepancy. Calculated investor qualifying total debt ratio of 43.55954% exceeds Guideline May be waived down with compensating factors. 1/XX/2018 CA Purchase Primary No C C C C 7/XX/2023 ATR Risk
total debt ratio of 43.00000%.
625488604 XXX XXX XXX 29373470 property 3 Appraiser's license or certification was not active at the time of the Valuation Type: Appraisal / Valuation Report Date: 07/XX/2015 Appraiser's license or certification was not active at the time of the 8/XX/2015 CA Refinance - Rate/Term Investment No C C C C 7/XX/2023
appraisal. appraisal.
625488604 XXX XXX XXX 29373471 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The property is located in FEMA Disaster Area. Provide a post-disaster 8/XX/2015 CA Refinance - Rate/Term Investment No A A A A 7/XX/2023 5/XX/2023 Yes 2023/XX/31: BPO dated 5/XX/23 showing no damage to property has been received.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage from disaster. The inspection must
Disaster Name: XXX include exterior photos and the property must be re-inspected on or after
Disaster Declaration Date: XX/XX/XXXX XX/XX/XXXX declared end date.
625488604 XXX XXX XXX 29373472 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Verification appraisal was delivered to borrower was not provided. 8/XX/2015 CA Refinance - Rate/Term Investment No B B B B 7/XX/2023
Consummation valuation to applicant three (3) business days prior to consummation.
(Type:Primary/07/XX/2015)
625488604 XXX XXX XXX 29373473 compliance 2 ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Not Provided ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to The Right to Receive Copy of Appraisal Disclosure was not provided to borrower There is generally no Assignee Liability. 8/XX/2015 CA Refinance - Rate/Term Investment No B B B B 7/XX/2023
Timely Receive a Copy" appraisal disclosure to applicant within three (3) business days within 3 days of initial application.
of application or determination of first lien status.
625488604 XXX XXX XXX 29373474 credit 3 REO Documents are missing. Address: XXX, CA Statement Mortgage statement missing for XXX, CA. 8/XX/2015 CA Refinance - Rate/Term Investment No C C C C 7/XX/2023
625489056 XXX XXX XXX 29373561 compliance 2 RESPA Disclosure - List of Homeownership Counseling Organizations Missing RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of List of Homeownership Counseling Organizations is missing in file RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2019 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM
Homeownership Counseling Organizations to borrower. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489056 XXX XXX XXX 29373562 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The property is located in FEMA Disaster area. Provide a post-disaster 6/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 5/XX/2023 Yes Safe Harbor QM 2023/XX/31: BPO provided reflecting no damage.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage. The inspection must include exterior
Disaster Name: XXX photos and the property must be re-inspected on or after XX/XX/XXXX declared end
Disaster Declaration Date: XX/XX/XXXX date.
625489056 XXX XXX XXX 29373563 property 1 The loan is to be securitized and the appraisal certification was not included Valuation Type: Appraisal / Valuation Report Date: 06/XX/2019 The file is missing a copy of the secondary valuation required for 6/XX/2019 CA Purchase Primary No A A A A 7/XX/2023 5/XX/2023 Yes Safe Harbor QM 2023/XX/31: Client not securitizing loan.
in the provided valuation. Securitization valuations are required to be securitization purposes.
FIRREA/USPAP compliant.
625488725 XXX XXX XXX 29373671 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX Post Disaster Inspection Document Needed 9/XX/2017 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/01: Received BPO confirming no damage.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488725 XXX XXX XXX 29373672 credit 3 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement E- Sign Consent Document Missing 9/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 Non QM
625488725 XXX XXX XXX 29373673 compliance 2 General Ability To Repay Provision Investor Qualification Method not Matching Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender The guidelines require 7/1 ARMS to be qualified using the Note rate, causing the 9/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Non QM
ATR does not match the ATR payment calculation methods under 1026.43(c)(5). loan to waterfall through the QM Testing.
625489322 XXX XXX XXX 29373692 compliance 2 Missing Document: Missing Lender's Initial 1003 12/XX/2014 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM 2023/XX/25: Missing signed and dated initial application.
625489322 XXX XXX XXX 29373693 compliance 2 RESPA Disclosure - HUD Settlement Cost Booklet Missing RESPA Disclosure Rule: Creditor did not provide HUD Settlement Cost Booklet. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2014 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM
within the statute or implementing regulation, Regulation X, for these type of
violations.
625489322 XXX XXX XXX 29373694 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2014 12/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM
CHARM Booklet, not provided to the borrower.
625489322 XXX XXX XXX 29373695 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each File is missing evidence the borrower received the appraisal at least 3 business 12/XX/2014 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM
Consummation valuation to applicant three (3) business days prior to consummation. days prior to the closing date
(Type:Primary/12/XX/2014)
625489322 XXX XXX XXX 29373696 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - Maximum Ever Change Date Inaccurate Truth in Lending Act (MDIA 2011): The "Maximum Ever" date on the Final TIL does TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 12/XX/2014 12/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM
not match the earliest date on which the maximum rate may apply. defense to foreclosure. Assignee liability.
625489322 XXX XXX XXX 29373697 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX 12/XX/2014 CA Purchase Primary No A A A A 7/XX/2023 5/XX/2023 Yes Safe Harbor QM 2023/XX/31: BPO provided reflects no damage.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625489322 XXX XXX XXX 29373698 compliance 2 (Doc Error) GFE Error: Changed Circumstance not provided. GFE Date: 12/XX/2014 Changed Circumstance not provided for GFE dated 12/XX/2014 12/XX/2014 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM
from GFE dated 11/XX/2014
625488492 XXX XXX XXX 29373730 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to applicant three (3) 6/XX/2017 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Non QM
Consummation valuation to applicant three (3) business days prior to consummation. business days prior to consummation. (Type:Primary/05/XX/2017)
(Type:Primary/05/XX/2017)
625488492 XXX XXX XXX 29373731 compliance 1 General Ability To Repay Provision Investor Qualification Method not Matching Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender The Qualification Method used by the lender does not match the ATR payment 6/XX/2017 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/04: qual method updated
ATR does not match the ATR payment calculation methods under 1026.43(c)(5). calculation methods under 1026.43(c)(5).
625488492 XXX XXX XXX 29373732 compliance 2 Self-Employed Tax Return Recency - ATR Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or Self Employed Tax Returns - The business or personal tax returns provided are 6/XX/2017 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Non QM
personal tax returns provided are not the most recent. Application Date not the most recent. Application Date 05/XX/2017, Most Recent Tax Return End
05/XX/2017, Most Recent Tax Return End Date 12/XX/2015, Tax Return Due Date Date 12/XX/2015, Tax Return Due Date 04/XX/2017. (XXX XXX/Schedule C)
04/XX/2017. (XXX XXX/Schedule C)
625488492 XXX XXX XXX 29373733 compliance 2 Self-Employed Tax Return Recency - ATR Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or Self Employed Tax Returns - The business or personal tax returns provided are 6/XX/2017 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Non QM
personal tax returns provided are not the most recent. Application Date not the most recent. Application Date 05/XX/2017, Most Recent Tax Return End
05/XX/2017, Most Recent Tax Return End Date 12/XX/2015, Tax Return Due Date Date 12/XX/2015, Tax Return Due Date 03/XX/2017. (XXX XXX/S-Corp)
03/XX/2017. (XXX XXX/S-Corp)
625488492 XXX XXX XXX 29373734 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2017 6/XX/2018 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Non QM
application due to missing information. application due to missing information.
625488492 XXX XXX XXX 29373735 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2017 6/XX/2018 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Non QM
CHARM Booklet, not provided to the borrower. the borrower.
625488492 XXX XXX XXX 29373736 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX 6/XX/2017 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/01: Received BPO confirming no damage.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488492 XXX XXX XXX 29373737 credit 3 Insufficient Coverage: Hazard insurance coverage amount is insufficient. 6/XX/2017 CA Refinance - Cash-out - Other Primary No C C C C 7/XX/2023 Non QM
625488492 XXX XXX XXX 29373738 credit 3 REO Documents are missing. Address: XXX, CA, Address: XXX, CA, Address: XXX, CA Insurance Verification, Tax 6/XX/2017 CA Refinance - Cash-out - Other Primary No C C C C 7/XX/2023 Non QM
Verification
Statement
Lease Agreement, Statement
625489105 XXX XXX XXX 29373844 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to applicant three (3) 12/XX/2016 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM
Consummation valuation to applicant three (3) business days prior to consummation. business days prior to consummation.
(Type:Primary/12/XX/2016)
625489105 XXX XXX XXX 29373845 compliance 2 RESPA - Initial Escrow Account Statement Missing RESPA: Initial escrow account statement was not provided to the borrower. Initial escrow account statement disclosure is missing in file. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2016 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM
within the statute or implementing regulation, Regulation X, for these type of
violations.
625489105 XXX XXX XXX 29373846 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet Disclosure is missing in file. Please provide. TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2016 12/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM
CHARM Booklet, not provided to the borrower.
625489105 XXX XXX XXX 29373848 credit 3 Missing Document: Purchase Agreement / Sales Contract not provided Purchase Contract is missing in file. Please provide. 12/XX/2016 CA Purchase Primary No D D D D 7/XX/2023 Safe Harbor QM
625489105 XXX XXX XXX 29373849 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX Post Disaster Inspection report is missing in file. 12/XX/2016 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor QM 2023/XX/01: Received BPO confirming no damage.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625489105 XXX XXX XXX 29373850 credit 3 Guideline Requirement: Loan to value discrepancy. Calculated loan to value percentage of XX% exceeds Guideline loan to value Per lender guides, for an extended LTV of XX%, borrower must have a 740 fico 12/XX/2016 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor QM
percentage of 75.00000%. which they do not have. Max LTV is 75% per lender guides.
625488703 XXX XXX XXX 29373851 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The most recent valuation inspection is dated prior to the most recent FEMA 9/XX/2017 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/01: Received BPO confirming no damage.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX disaster.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488703 XXX XXX XXX 29373852 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Consumer Handbook on Adjustable-Rate Mortgages, CHARM Booklet, not provided to TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2017 9/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Non QM
CHARM Booklet, not provided to the borrower. the borrower.
625488703 XXX XXX XXX 29373853 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Evidence of borrowers receipt of the appraisal prior to closing was not 9/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Consummation valuation to applicant three (3) business days prior to consummation. provided.
(Type:Primary/08/XX/2017)
625488703 XXX XXX XXX 29373854 compliance 2 TRID Final Closing Disclosure Will Not Have Escrow - Reason TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure Violation was cured on the PCCD dated 03/XX/2018, however for a full remediation TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 9/XX/2017 9/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Non QM
provided on 09/XX/2017 incorrectly disclosed whether the loan will have an cure, a copy of the letter to the borrower explaining the error is required, liability.
escrow account. (Final/09/XX/2017) however is missing from the file.
625488703 XXX XXX XXX 29373856 credit 3 Missing Document: HELOC Agreement not provided The Heloc agreement for the 2nd lien is missing from the file. 9/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 Non QM
625488703 XXX XXX XXX 29373857 credit 3 Missing Document: Note - Subordinate Lien not provided Second mortgage Note is mssing. 9/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 Non QM
625488703 XXX XXX XXX 29373858 credit 3 Income Docs Missing: Borrower: XXX Balance Sheet Per lender guides, a year to date Balance Sheet through the most recent quarter 9/XX/2017 CA Purchase Primary No C C C C 7/XX/2023 Non QM
prior to the note date is required however is missing.
625488703 XXX XXX XXX 29373859 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of Date of disclosure or evidence of when borrower received the disclosure is TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2017 9/XX/2018 CA Purchase Primary No B B B B 7/XX/2023 Non QM
application due to missing information. missing.
625488176 XXX XXX XXX 29373961 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX Most Recent Valuation Inspection Date: XX/XX/XXXX 4/XX/2016 CA Purchase Primary No C C C C 7/XX/2023 Safe Harbor QM 2023/XX/01: BPO inspector unable to access property to determine condition.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX Disaster End Date: XX/XX/XXXX Finding remains open.
Disaster Name: XXX Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX Disaster Declaration Date: XX/XX/XXXX
625488176 XXX XXX XXX 29373962 compliance 2 RESPA - Initial Escrow Account Statement Missing RESPA: Initial escrow account statement was not provided to the borrower. Initial escrow account statement was not provided to the borrower missing in RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2016 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM
file within the statute or implementing regulation, Regulation X, for these type of
violations.
625488176 XXX XXX XXX 29373964 compliance 2 TRID Final Closing Disclosure Total Of Payments TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Post closing CD cured the violation, however for a full remediation, a copy of TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 4/XX/2016 4/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 Safe Harbor QM
provided on 04/XX/2016 disclosed an inaccurate Total of Payments on page 5 that the letter to the borrower explaining the error would be required. defense to foreclosure. Assignee liability.
does not match the actual total of payments for the loan (fee amounts included
in TOP calculation are based on Closing Disclosure dated 04/XX/2016). The
disclosed Total of Payments in the amount of $XXX is under disclosed by $XXX
compared to the calculated total of payments of $XXX which exceeds the $XXX per
month threshold. (Final/04/XX/2016)
625489258 XXX XXX XXX 29374445 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX Latest inspection is prior latest FEMA disaster declaration. 7/XX/2016 CA Purchase Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/31: The BPO provided does not indicate no damage and there are no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX photos.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX 2023/XX/01: Trailing docs did not contain any docs to clear this exception.
625489258 XXX XXX XXX 29374446 credit 3 File does not contain documentation from lender/seller confirming the condo is Valuation Type: Appraisal / Valuation Report Date: 06/XX/2016 Evidence of warrantable condo is missing from file. Missing lender approval. 7/XX/2016 CA Purchase Primary No C C C C 7/XX/2023 ATR Fail
warrantable.
625489258 XXX XXX XXX 29374448 compliance 3 General Ability To Repay Provision Employment - Partnership Test Ability-to-Repay (Dodd-Frank 2014): Unable to verify current Partnership status This is due to missing the balance sheet for this business and the verbal VOE. Assignee Liability: Violations can result in regular TILA damages (actual 7/XX/2016 CA Purchase Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/18: Dispute: XXX. XXX, XXX, XXX, and XXX. verified active by secretary 2023/XX/13: No new documentation provided, exceptions remain.
due to missing Tax Return/Transcript for the most recent year, and one of these damages, statutory damages of up to $XXX costs, and attorney's fees) and of state on 7/XX/16 vs. note date 7/XX/16. Balance Sheet as of 5/XX/16 for XXX,
docs is required yet missing: Audited/Third Party P&L, CPA Letter, or other enhanced damages (an amount equal to the sum of all finance charges and fees XXX, XXX uploaded under Closing Package/MISC/Items to send with Closing Package 2023/XX/28: Trailing docs did not contain any docs to clear this exception.
Third Party Verification. (XXX XXX/Partnership) paid by the consumer, unless the creditor demonstrates that the failure to 8/XX/16 3:56pm.
comply is not material). A private right of action may be brought before the end 2023/XX/21: Trailing docs did not contain any docs to clear this exception.
of the three-year period beginning on the date of the occurrence of the 2023/XX/05: N/A; Duplicative Exception
violation. However, when a creditor, assignee, or other holder or anyone acting 2023/XX/06: Reviewed original file and all trailing docs. The remaining
on their behalf initiates a judicial or non-judicial foreclosure, or any other documentation is missing and listed per entity. XXX: year to date Balance sheet.
action to collect the debt, a consumer may assert a violation as a matter of XXX: year to date Balance sheet and third party verification dated within lender
defense by recoupment or set-off without regard to a time limit. The amount of required timeframe verifying dates of operation. XXX: year to date Balance
recoupment or set-off shall equal the amount to which the consumer would be Sheet.
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625489258 XXX XXX XXX 29374449 compliance 3 General Ability To Repay Provision Employment - Partnership Test Ability-to-Repay (Dodd-Frank 2014): Unable to verify current Partnership status This is due to missing the balance sheet for this business and the verbal VOE. Assignee Liability: Violations can result in regular TILA damages (actual 7/XX/2016 CA Purchase Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/18: same as above: Dispute: XXX. XXX, XXX, XXX, and XXX. verified active 2023/XX/28: Trailing docs did not contain any docs to clear this exception.
due to most recent Tax Return end date is older than 120 days before Closing damages, statutory damages of up to $XXX costs, and attorney's fees) and by secretary of state on 7/XX/16 vs. note date 7/XX/16. Balance Sheet as of
Date, and one of these docs is required yet missing: Audited/Third Party P&L, enhanced damages (an amount equal to the sum of all finance charges and fees 5/XX/16 for XXX, XXX, XXX 2023/XX/21: Trailing docs did not contain any docs to clear this exception.
CPA Letter, or other Third Party Verification. (XXX XXX/Partnership) paid by the consumer, unless the creditor demonstrates that the failure to
comply is not material). A private right of action may be brought before the end 2023/XX/05: Self-Employment documentation uploaded. 2023/XX/06: Reviewed original file and all trailing docs. The remaining
of the three-year period beginning on the date of the occurrence of the documentation is missing and listed per entity. XXX: year to date Balance sheet.
violation. However, when a creditor, assignee, or other holder or anyone acting XXX: year to date Balance sheet and third party verification dated within lender
on their behalf initiates a judicial or non-judicial foreclosure, or any other required timeframe verifying dates of operation. XXX: year to date Balance
action to collect the debt, a consumer may assert a violation as a matter of Sheet.
defense by recoupment or set-off without regard to a time limit. The amount of
recoupment or set-off shall equal the amount to which the consumer would be
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625489258 XXX XXX XXX 29374452 compliance 2 TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Ten Percent Fee Tolerance increased without a valid change of circumstance. Cure 7/XX/2016 7/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 ATR Fail
amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no was not provided.
cure was provided to the borrower. (0)
625489258 XXX XXX XXX 29374453 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal fee increased without a valid change of circumstance. Cure was not TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 7/XX/2016 7/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 ATR Fail
Appraisal Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no provided. liability.
cure was provided to the borrower. (7506)
625489258 XXX XXX XXX 29374454 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Credit report increased without a valid change of circumstance. Cure was not TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 7/XX/2016 7/XX/2017 CA Purchase Primary No B B B B 7/XX/2023 ATR Fail
Report Re-Issue Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient provided at closing. liability.
or no cure was provided to the borrower. (75117)
625489258 XXX XXX XXX 29374455 compliance 1 Partnership Income Documentation Test Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not This is due to missing a balance sheet for YTD. 7/XX/2016 CA Purchase Primary No A A A A 7/XX/2023 10/XX/2023 Yes ATR Fail 2023/XX/18: same as above. Dispute: XXX. XXX, XXX, XXX, and XXX. verified active 2023/XX/28: Trailing docs did not contain any docs to clear this exception.
sufficient (Partnership). (XXX XXX/Partnership) by secretary of state on 7/XX/16 vs. note date 7/XX/16. Balance Sheet as of
5/XX/16 for XXX, XXX, XXX 2023/XX/21: Trailing docs did not contain any docs to clear this exception.
2023/XX/05: Balance Sheets uploaded. 2023/XX/06: Reviewed original file and all trailing docs. The remaining
documentation is missing and listed per entity. XXX: year to date Balance sheet.
XXX: year to date Balance sheet and third party verification dated within lender
required timeframe verifying dates of operation. XXX: year to date Balance
Sheet.
2023/XX/03: Client elects to restate loan designation to Non QM.
625489258 XXX XXX XXX 29374456 compliance 1 Partnership Income Documentation Test Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not This is due to missing a balance sheet for YTD. 7/XX/2016 CA Purchase Primary No A A A A 7/XX/2023 10/XX/2023 Yes ATR Fail 2023/XX/18: same as above. Dispute: XXX. XXX, XXX, XXX, and XXX. verified active 2023/XX/28: Trailing docs did not contain any docs to clear this exception.
sufficient (Partnership). (XXX XXX/Partnership) by secretary of state on 7/XX/16 vs. note date 7/XX/16. Balance Sheet as of
5/XX/16 for XXX, XXX 2023/XX/21: Trailing docs did not contain any docs to clear this exception.
2023/XX/05: N/A; Duplicative Exception 2023/XX/06: Reviewed original file and all trailing docs. The remaining
documentation is missing and listed per entity. XXX: year to date Balance sheet.
XXX: year to date Balance sheet and third party verification dated within lender
required timeframe verifying dates of operation. XXX: year to date Balance
Sheet.
2023/XX/03: Client elects to restate loan designation to Non QM.
625489258 XXX XXX XXX 29374457 compliance 1 Partnership Income Documentation Test Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not This is due to missing the balance sheet for this business and the verbal VOE. 7/XX/2016 CA Purchase Primary No A A A A 7/XX/2023 10/XX/2023 Yes ATR Fail 2023/XX/18: Dispute: Balance Sheets were not required for real estate 2023/XX/28: Trailing docs did not contain any docs to clear this exception.
sufficient (Partnership). (XXX XXX/Partnership) pass-through companies such as XXX in 2016.
Concur: No VOE in file. 2023/XX/21: Trailing docs did not contain any docs to clear this exception.
2023/XX/25: Agree with error 2023/XX/26: No supporting trailing documentation was provided to clear this
exception. Exception remains.
2023/XX/03: Client elects to restate loan designation to Non QM.
625489258 XXX XXX XXX 29374458 compliance 1 Partnership Income Documentation Test Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not This is due to missing the balance sheet for this business and the verbal VOE. 7/XX/2016 CA Purchase Primary No A A A A 7/XX/2023 10/XX/2023 Yes ATR Fail 2023/XX/18: N/A; Duplicative Exception 2023/XX/28: Trailing docs did not contain any docs to clear this exception.
sufficient (Partnership). (XXX XXX/Partnership)
2023/XX/25: Duplicate and/or waterfall exception 2023/XX/21: Trailing docs did not contain any docs to clear this exception.
2023/XX/27: Reviewed trailing documentation. Documents necessary to clear the
conditions were not provided. Exception remains.
2023/XX/03: Client elects to restate loan designation to Non QM.
625489258 XXX XXX XXX 29374459 compliance 1 S-Corp Income Documentation Test Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not This is due to missing the 2014 W2. 7/XX/2016 CA Purchase Primary No A A A A 7/XX/2023 10/XX/2023 Yes ATR Fail 2023/XX/18: Concur: Unable to locate 2014 W2 for XXX from XXX. 2014 1040s does 2023/XX/21: Trailing docs did not contain any docs to clear this exception.
sufficient (S-Corp). (XXX XXX/S-Corp) not include a statement page identifying source of W2 income.
2023/XX/26: No supporting trailing documentation was provided to clear this
2023/XX/25: Agree with error exception. Exception remains.
2023/XX/03: Client elects to restate loan designation to Non QM.
625489258 XXX XXX XXX 29374460 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 7/XX/2016 CA Purchase Primary No A A A A 7/XX/2023 10/XX/2023 Yes ATR Fail 2023/XX/18: Final DTI per the final 1008 is 16.94% which consists of $XXX PITIA 2023/XX/21: Trailing docs did not contain any docs to clear this exception.
QM does not match Due Diligence Loan Designation of ATR Fail. Designation of ATR Fail due to missing income documents. Designation to the TPR firm performing the loan level due diligence and to have and $XXX all other payments against the calculated income of $XXX/mo.
the TPR firm confirm said designation. 2023/XX/06: Reviewed original file and all trailing docs. The remaining
2023/XX/05: 1003s & 1008; UW Workbook uploaded. documentation is missing and listed per entity. Seon Investment: year to date
Balance sheet. Dany Investment: year to date Balance sheet and third party
verification dated within lender required timeframe verifying dates of
operation. Ethan Development: year to date Balance Sheet.
2023/XX/03: Client elects to restate loan designation to Non QM.
625489258 XXX XXX XXX 29374461 credit 3 Income Docs Missing: Borrower: XXX, Borrower: XXX Balance Sheet, Third Party Verification Missing the balance sheet for businesses, XXX; XXX; XXX. Verbal VOE missing for 7/XX/2016 CA Purchase Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/18: N/A; Duplicative Exception 2023/XX/28: Only the 2014 W2 was provided. Condition remains.
Balance Sheet, Third Party Verification businesses, XXX. missing 2014 W2 for XXX
2023/XX/25: Duplicate and/or waterfall exception 2023/XX/01: EXCEPTION HISTORY - Exception Explanation was updated on 08/XX/2023
PRIOR Exception Explanation: Balance Sheet, Third Party Verification, W-2 (2014)
Balance Sheet, Third Party Verification
2023/XX/21: Trailing docs did not contain any docs to clear this exception.
2023/XX/27: Reviewed trailing documentation. Documents necessary to clear the
conditions were not provided. Exception remains.
625489258 XXX XXX XXX 29374462 credit 3 REO Documents are missing. Address: XXX, CA HOA Verification, Insurance Verification Missing for the non-subject REO 7/XX/2016 CA Purchase Primary No C C C C 7/XX/2023 ATR Fail 2023/XX/18: Concur: unable to locate HOA/insurance verification on Monte Mar. 2023/XX/21: Trailing docs did not contain any docs to clear this exception.
2023/XX/25: Agree with error 2023/XX/26: No supporting trailing documentation was provided to clear this
exception. Exception remains.
625489258 XXX XXX XXX 29374463 compliance 3 Check Loan Designation Match - ATR Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Client elects to restate loan designation to Non QM. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 7/XX/2016 CA Purchase Primary No C C B B 7/XX/2023 ATR Fail
not match Due Diligence Loan Designation of ATR Fail. Designation to the TPR firm performing the loan level due diligence and to have
the TPR firm confirm said designation.
625488002 XXX XXX XXX 29374541 compliance 2 RESPA Disclosure - HUD Settlement Cost Booklet Missing RESPA Disclosure Rule: Creditor did not provide HUD Settlement Cost Booklet. Missing HUD Settlement Cost Booklet.. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2014 CA Purchase Primary No B B B B 7/XX/2023 Non QM
within the statute or implementing regulation, Regulation X, for these type of
violations.
625488002 XXX XXX XXX 29374542 compliance 2 RESPA - Initial Escrow Account Statement Missing RESPA: Initial escrow account statement was not provided to the borrower. Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2014 CA Purchase Primary No B B B B 7/XX/2023 Non QM
within the statute or implementing regulation, Regulation X, for these type of
violations.
625488002 XXX XXX XXX 29374543 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - Maximum Ever Change Date Inaccurate Truth in Lending Act (MDIA 2011): The "Maximum Ever" date on the Final TIL does TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2014 5/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Non QM
not match the earliest date on which the maximum rate may apply. defense to foreclosure. Assignee liability.
625488002 XXX XXX XXX 29374544 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Missing CHARM Booklet Disclosure. TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2014 5/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Non QM
CHARM Booklet, not provided to the borrower.
625488002 XXX XXX XXX 29374545 compliance 1 Sole Proprietorship Income Documentation Test Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not Loan file is missing a YTD P&L statement and a Balance Sheet for the 5/XX/2014 CA Purchase Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/18: P and L through March 2014 in file, Bal Sheet not required for 2023/XX/02: Trailing docs did not contain any docs to clear this exception.
sufficient (Sole Proprietorship). (XXX XXX/Schedule C) co-borrower's business. schedule C business that is service related
2023/XX/22: Safe Harbor requires a year to date balance sheet and third party
2023/XX/25: Disagree with interpretation of ATR requirements. XXX guidelines verification dated within lenders required time frame reflecting the dates of
(RLU-NA section 302-2.1.3) state YTD Balance Sheets are not required for operation and that the business was in good standing at the time of closing.
Schedule C businesses unless the business carries an inventory. Condition remains.
2023/XX/14: Loan redesignated to NonQM.
625488002 XXX XXX XXX 29374546 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each As per Appraisal acknowledgement document signed on closing borrower did not 5/XX/2014 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Consummation valuation to applicant three (3) business days prior to consummation. select any option.
(Type:Primary/05/XX/2014)
625488002 XXX XXX XXX 29374547 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Loan considered to be at ATR Risk due to missing income documentation for the Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 5/XX/2014 CA Purchase Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/18: N/A; Duplicative Exception 2023/XX/02: Trailing docs did not contain any docs to clear this exception.
QM does not match Due Diligence Loan Designation of ATR Risk. co-borrower and the DTI issue. Designation to the TPR firm performing the loan level due diligence and to have
the TPR firm confirm said designation. 2023/XX/25: Duplicate and/or waterfall exception 2023/XX/22: Trailing docs did not contain any docs to clear this exception.
2023/XX/14: Loan redesignated to NonQM.
625488002 XXX XXX XXX 29374548 compliance 2 Missing Document: Missing Lender's Initial 1003 Missing signed and dated Initial 1003. 5/XX/2014 CA Purchase Primary No B B B B 7/XX/2023 Non QM
625488002 XXX XXX XXX 29374549 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA disaster area. 5/XX/2014 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/01: BPO provided does not reflect damage.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX A post disaster inspection verifying there was no damage to the subject property
Disaster Name: XXX is required.
Disaster Declaration Date: XX/XX/XXXX
625488002 XXX XXX XXX 29374551 credit 3 Verification(s) of employment is not within 10 business days of the Note. Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: Missing Verification of Employment for borrower XXX. 5/XX/2014 CA Purchase Primary No C C C C 7/XX/2023 Non QM 2023/XX/18: VOE for XXX located under VOE uploaded with a completion date 2023/XX/02: WVOE provided is dated 04/XX/2014 and the note date is 05/XX/2014.
01/XX/2009 5/XX/14 (page 7 of 13) Condition remains for missing VVOE dated within 10 business days of the note
date.
2023/XX/25: Agree with error based on timing, but don't agree that a missing VOE
significantly changes ATR impact based on the overall risk & quality of the 2023/XX/22: VOE in file is dated 04/XX/2014. Condition remains.
transaction.
2023/XX/26: No supporting trailing documentation was provided to clear this
exception. Exception remains.
625488002 XXX XXX XXX 29374552 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - Maximum In First 5 Years Taxes and Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" amount of taxes Final TIL first five years escrow payment amount of $XXX is less than calculated TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2014 5/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Insurance Inaccurate and insurance, including any mortgage insurance, on the Final TIL does not match payment amount of $XXX. defense to foreclosure. Assignee liability.
the maximum escrow payment on the loan during the first five (5) years of the
loan.
625488002 XXX XXX XXX 29374553 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - Maximum In First 5 Years Total Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" total payment Final TIL first five years total payment amount of $XXX is less than calculated TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2014 5/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Payment (PITI) Inaccurate amount (PITI) on the Final TIL does not match the maximum total payment on the payment amount of $XXX. There is a variance of $XXX. defense to foreclosure. Assignee liability.
loan during the first five (5) years for the loan.
625488002 XXX XXX XXX 29374554 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - Maximum Ever Escrow Amount Inaccurate Truth in Lending Act (MDIA 2011): The "Maximum Ever" amount of taxes and The "Maximum Ever" amount $XXX of taxes and insurance, including any mortgage TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2014 5/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Non QM
insurance, including any mortgage insurance, on the Final TIL does not match the insurance, on the Final TIL does not match the maximum escrow payment that may defense to foreclosure. Assignee liability.
maximum escrow payment that may apply during the life of the loan. apply during the life of the loan.
625488002 XXX XXX XXX 29374555 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - Maximum Ever Total Payment (PITI) Truth in Lending Act (MDIA 2011): The "Maximum Ever" total payment amount (PITI) The "Maximum Ever" total payment amount of (PITI) in the amount of $XXXon the TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2014 5/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Inaccurate on the Final TIL does not match the maximum total payment on the loan during the Final TIL does not match the calculated amount of $XXX. There is a variance of defense to foreclosure. Assignee liability.
life of the loan. $XXX.
625488002 XXX XXX XXX 29374556 compliance 2 2011 TIL-MDIA - Introductory Escrow Payment Inaccurate Truth in Lending Act (MDIA 2011): The amount of taxes and insurance, including The amount of taxes and insurance, including any mortgage insurance in the TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2014 5/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Non QM
any mortgage insurance, on the Final TIL does not match the amount of taxes and amount of $XXX on the Final TIL does not match the calculated amount of $XXX. defense to foreclosure. Assignee liability.
insurance, including any mortgage insurance, for the loan. There is a variance of $XXX.
625488002 XXX XXX XXX 29374557 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - Introductory Total Payment (PITI) Truth in Lending Act (MDIA 2011): Total payment amount (PITI) on the Final TIL Total payment amount of $XXX(PITI) on the Final TIL does not match the TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2014 5/XX/2015 CA Purchase Primary No B B B B 7/XX/2023 Non QM
Inaccurate does not match the total payment amount for the loan. calculated amount of $XXX. There is a variance of $XXX. defense to foreclosure. Assignee liability.
625488002 XXX XXX XXX 29374558 compliance 1 General Ability To Repay Provision Investor Guidelines Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more The loan is at ATR Risk due to the missing income/employment documentation and 5/XX/2014 CA Purchase Primary No A A A A 7/XX/2023 9/XX/2023 Yes Non QM 2023/XX/18: N/A; Duplicative Exception 2023/XX/02: Trailing docs did not contain any docs to clear this exception.
guideline components, the loan is at ATR risk. the DTI issue.
2023/XX/25: Duplicate and/or waterfall exception 2023/XX/22: Trailing docs did not contain any docs to clear this exception.
2023/XX/14: Loan redesignated to NonQM.
625488002 XXX XXX XXX 29374560 compliance 2 Check Restated Loan Designation Match - General Ability to Repay Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did Loan redesignated to NonQM. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 5/XX/2014 CA Purchase Primary No B B A A 7/XX/2023 Non QM
not match. However, the updated Loan Designation of Non QM matches the Due Designation to the TPR firm performing the loan level due diligence and to have
Diligence Loan Designation of Non QM. the TPR firm confirm said designation.
625489450 XXX XXX XXX 29374938 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA Disaster area post-close. A 3/XX/2017 CA Refinance - Rate/Term Investment No A A A A 7/XX/2023 6/XX/2023 Yes 2023/XX/01: BPO provided. No damage noted. Cleared.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX post-disaster inspection verifying there was no damage to the subject property
Disaster Name: XXX is required.
Disaster Declaration Date: XX/XX/XXXX
625488924 XXX XXX XXX 29375266 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to applicant three (3) 12/XX/2017 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Safe Harbor QM
Consummation valuation to applicant three (3) business days prior to consummation. business days prior to consummation.
(Type:Primary/11/XX/2017)
625488924 XXX XXX XXX 29375268 credit 3 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement E-sign Consent Agreement is missing. 12/XX/2017 CA Refinance - Cash-out - Other Primary No C C C C 7/XX/2023 Safe Harbor QM
625488924 XXX XXX XXX 29375269 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX Property Inspection report is required as available inspection report was issued 12/XX/2017 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Safe Harbor QM 2023/XX/01: Received BPO confirming no damage.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX before Disaster Declaration date.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488924 XXX XXX XXX 29375270 credit 2 Incorrect Appraisal Form type: Appraisal Form 1004C/70B used for incorrect Valuation Type: Appraisal / Valuation Report Date: 11/XX/2017 Single Family Appraisal Form 1004C/70B updated as per the document. 12/XX/2017 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Safe Harbor QM
Subject property type. Detached
625489615 XXX XXX XXX 29375366 credit 1 Missing Document: Missing Final 1003 The file is missing a copy of Final 1003 Application. 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Received
625489615 XXX XXX XXX 29375367 credit 1 Missing Document: Appraisal not provided The file is missing a copy of Appraisal Report 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Received appraisal.
625489615 XXX XXX XXX 29375368 credit 1 Missing Document: Flood Certificate not provided The file is missing a copy of Flood Certificate Report. 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Received flood cert.
625489615 XXX XXX XXX 29375369 credit 1 Missing Document: Credit Report not provided The file is missing a copy of Credit Report 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Received credit report.
625489615 XXX XXX XXX 29375370 credit 1 Missing Document: Fraud Report not provided The file is missing a copy of Fraud Report 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Received fraud report.
625489615 XXX XXX XXX 29375371 credit 1 Missing Document: Occupancy Certificate not provided The is missing a copy of Occupancy Certificate 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Received
625489615 XXX XXX XXX 29375372 credit 1 FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not Disaster Name: XXX The property is located in a FEMA disaster area. Provide a post-disaster 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/01: Received BPO confirming no damage.
been inspected. Disaster Declaration Date: XX/XX/XXXX inspection verifying there was no damage. The inspection must include exterior
Disaster End Date: XX/XX/XXXX photos and the property must be re-inspected on or after XX/XX/XXXX declared end
date.
625489615 XXX XXX XXX 29375373 credit 1 AUS/Guideline Findings: All conditions were not met The file is missing a copy of Credit and Fraud Report, required by guidelines, 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/27: Trailing docs did not contain any docs to clear this exception.
and the DTI ratio exceeds the maximum allowed.
2023/XX/03: Received required documentation. Condition cleared.
625489615 XXX XXX XXX 29375374 credit 1 Income Docs Missing: Borrower: XXX 4506-T (2016), 4506-T (2017), VVOE - Employment Only, W-2 (2017) The file is missing a copy of 4506-T (2016), 4506-T (2017), VVOE - Employment 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/27: 4506T was provided. Condition remains for missing VVOE.
Only, W-2 (2017)
2023/XX/03: Received required documentation. Condition cleared.
625489615 XXX XXX XXX 29375375 credit 1 No evidence of fraud report in file Credit Report: Original // Borrower: XXX The file is missing a copy of Fraud Report 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Received fraud report
625489615 XXX XXX XXX 29375376 credit 1 REO Documents are missing. Address: XXX, CA Insurance Verification, Statement, Tax Verification The file is missing a copy of Hazard Insurance, Mortgage Statement and Tax 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/27: Trailing docs did not contain any docs to clear this exception.
Certificate
2023/XX/03: Received required documentation. Condition cleared.
625489615 XXX XXX XXX 29375377 compliance 1 QM Employment History - Current Employment Documentation lacks Date Info Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two The file is missing the most recent W-2 and a VVOE to verify the employment 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/03: Received required documentation. Condition cleared.
years current employment. (XXX/12403215) dates, causing the loan to waterfall through the QM Testing.
625489615 XXX XXX XXX 29375378 compliance 3 Rental Income Documentation - Schedule E Method Test Qualified Mortgage (Dodd-Frank 2014): Rental income documentation requirement QM requires a lease agreement, which is missing from the loan file, causing the 12/XX/2018 CA Refinance - Cash-out - Other Primary No C C C C 7/XX/2023 Non QM 2023/XX/18: Concur, unable to locate lease for property which was a self-rental 2023/XX/22: No additional documentation provided. Exception remains.
not met for XXX. Lease Agreement and/or Tax Return not provided. (XXX/Schedule loan to waterfall through the QM Testing. to the borrower's 100% owned business and therefore the rent is offset by a
E) rental expense for the business.
625489615 XXX XXX XXX 29375379 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 12/XX/2018 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Non QM
625489615 XXX XXX XXX 29375380 compliance 1 General Ability To Repay Provision Credit History Ability to Repay (Dodd-Frank 2014): Unable to verify debt obligations using Unable to verify debt obligations using reasonably reliable third-party records Assignee Liability: Violations can result in regular TILA damages (actual 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Received credit report.
reasonably reliable third-party records. due to the missing credit report from the loan file. damages, statutory damages of up to $XXX costs, and attorney's fees) and
enhanced damages (an amount equal to the sum of all finance charges and fees
paid by the consumer, unless the creditor demonstrates that the failure to
comply is not material). A private right of action may be brought before the end
of the three-year period beginning on the date of the occurrence of the
violation. However, when a creditor, assignee, or other holder or anyone acting
on their behalf initiates a judicial or non-judicial foreclosure, or any other
action to collect the debt, a consumer may assert a violation as a matter of
defense by recoupment or set-off without regard to a time limit. The amount of
recoupment or set-off shall equal the amount to which the consumer would be
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625489615 XXX XXX XXX 29375381 compliance 1 General Ability To Repay Provision Employment - W-2 Ability to Repay (Dodd-Frank 2014): Unable to verify current Wages/W-2 The file is missing the most recent W-2 and a VVOE to verify the employment Assignee Liability: Violations can result in regular TILA damages (actual 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/03: Received required documentation. Condition cleared.
employment status using reasonably reliable third-party records. (XXX XXX/Wages) dates, causing the loan to waterfall through the QM Testing. damages, statutory damages of up to $XXX costs, and attorney's fees) and
enhanced damages (an amount equal to the sum of all finance charges and fees
paid by the consumer, unless the creditor demonstrates that the failure to
comply is not material). A private right of action may be brought before the end
of the three-year period beginning on the date of the occurrence of the
violation. However, when a creditor, assignee, or other holder or anyone acting
on their behalf initiates a judicial or non-judicial foreclosure, or any other
action to collect the debt, a consumer may assert a violation as a matter of
defense by recoupment or set-off without regard to a time limit. The amount of
recoupment or set-off shall equal the amount to which the consumer would be
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625489615 XXX XXX XXX 29375382 compliance 1 General Ability To Repay Provision Investor Qualification Method not Matching Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender The guidelines require 10/1 ARMS to be qualified using the Note rate, causing 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/03: Received required documentation. Condition cleared.
ATR does not match the ATR payment calculation methods under 1026.43(c)(5). the loan to waterfall through the QM Testing.
625489615 XXX XXX XXX 29375383 compliance 1 Income/Asset Guideline Deficiency - ATR Impact Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to Due to missing income documentation and origination credit report the ability to 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/13: Received credit report and 2017 W2; however, other income
income and/or asset doc requirements which could result in a risk to the repay is not supported, causing the loan to waterfall through the QM Testing. documentation remains missing (separate exceptions for these items). Finding
borrower's ability to repay. (Exception is eligible to be regraded with remains open as not all items yet received.
compensating factors.)
2023/XX/01: Trailing docs did not contain any docs to clear this exception.
2023/XX/03: Received required documentation. Condition cleared.
625489615 XXX XXX XXX 29375385 compliance 3 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Due to missing income documentation and origination credit report the ability to Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 12/XX/2018 CA Refinance - Cash-out - Other Primary No C C B B 7/XX/2023 Non QM 2023/XX/18: Missing lease document per finding above. 2023/XX/22: No additional documentation provided. Exception remains.
QM does not match Due Diligence Loan Designation of Non QM. repay is not supported, causing the loan to waterfall through the QM Testing. Designation to the TPR firm performing the loan level due diligence and to have
the TPR firm confirm said designation. 2023/XX/22: EXCEPTION HISTORY - Exception Detail was updated on 08/XX/2023 PRIOR
Exception Detail: Qualified Mortgage (Dodd-Frank 2014): Originator Loan
Designation of Safe Harbor QM does not match Due Diligence Loan Designation of
ATR Fail.
625489615 XXX XXX XXX 29375386 compliance 1 QM DTI Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and Due to missing income documentation and origination credit report the ability to Although this issue is subject to a 3 year SOL for affirmative claims under 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/03: Received required documentation. Condition cleared.
the images do not provide evidence loan is eligible for purchase, guarantee or repay is not supported, causing the loan to waterfall through the QM Testing. TILA, AMC does not adjust grading taking into account TILA SOL for exceptions
insurance by the appropriate agency. under ATR, given the potential for enhanced damages when asserting an ability to
repay defense in response to an action to collect a debt by recoupment or
set-off.
625489615 XXX XXX XXX 29375387 compliance 1 QM Required Credit Report Not Provided to Evidence Debts Qualified Mortgage (Dodd-Frank 2014): The loan file does not contain a Credit The credit report is missing from the loan file, causing the loan to waterfall 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Received credit report.
report to evidence the consumers outstanding liabilities. (XXX/12403215) through the QM Testing.
625489615 XXX XXX XXX 29375388 compliance 2 TILA-RESPA Integrated Disclosure: application date on or after 10/XX/2015, no TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images Loan Estimate not provided within loan images to evidence delivery to the TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 12/XX/2018 12/XX/2019 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Non QM
Loan Estimates in the Loan File to evidence delivery to the Borrower(s). The earliest Closing Disclosure Borrower(s). The earliest Closing Disclosure provided in the loan file was used liability.
provided in the loan file was used as the estimated baseline for Tolerance as the estimated baseline for Tolerance Testing. Depending on the actual values
Testing. Depending on the actual values on the initial Loan Estimate, a fee on the initial Loan Estimate, a fee tolerance cure of up to $XXX may be
tolerance cure of up to $XXX may be required. required.
625489615 XXX XXX XXX 29375389 compliance 2 ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM loan program disclosure not provided to the borrower. TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2018 12/XX/2019 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Non QM
borrower.
625489615 XXX XXX XXX 29375390 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2018 12/XX/2019 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Non QM 2023/XX/30: Missing CHARM Booklet provided within 3 days of application.
CHARM Booklet, not provided to the borrower. the borrower.
625489615 XXX XXX XXX 29375391 compliance 2 TRID Final Closing Disclosure Product Testing TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure General Information: Final Closing Disclosure provided on 12/XX/2018 disclosed a TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 12/XX/2018 12/XX/2019 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Non QM
provided on 12/XX/2018 disclosed a Product that does not match the actual Product that does not match the actual product for the loan. Additional AIR/AP liability.
product for the loan. Additional AIR/AP table failures could apply for loans table failures could apply for loans with an adjustable rate or adjustable
with an adjustable rate or adjustable payment with incorrect Product disclosure. payment with incorrect Product disclosure.
(Final/12/XX/2018)
625489615 XXX XXX XXX 29375392 credit 1 Income documentation requirements not met. Loan file is missing 2 year previous W-2's,and VVOE as required. 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/03: Received required documentation. Condition cleared.
625489615 XXX XXX XXX 29375393 credit 1 Verification(s) of employment is not within 10 business days of the Note. Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: VVOE was not provided. 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/03: Received required documentation. Condition cleared.
12/XX/2002
625489615 XXX XXX XXX 29375394 compliance 1 General Ability To Repay Provision Investor Guidelines Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Loan file is missing 2 year previous W-2's,and VVOE as required. 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/03: Received required documentation. Condition cleared.
guideline components, the loan is at ATR risk.
625489615 XXX XXX XXX 29375395 credit 1 Guideline Requirement: Investor qualifying total debt ratio discrepancy. Calculated investor qualifying total debt ratio of 46.59173% exceeds Guideline Guidelines allowed for a max DTI of 43.00%. Due to missing prior 2 years W-2's 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/03: Received required documentation. Condition cleared.
total debt ratio of 43.00000%. or 1040 tax returns, VVOE and origination credit report, the calculated DTI
46.59173% exceeds allowed DTI.
625489615 XXX XXX XXX 29375396 compliance 1 General Ability To Repay Provision Non QM DTI significantly exceeds Guidelines Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Guidelines allowed for a max DTI of 43.00%. Due to missing prior 2 years W-2's 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/03: Received required documentation. Condition cleared.
1026.43(c)(5) of 49.68% significantly exceeds the guideline maximum of 43.00%. or 1040 tax returns, VVOE and origination credit report, the calculated DTI
(DTI Exception requires compelling compensating factors to consider regrading to 46.59173% exceeds allowed DTI, causing the loan to waterfall through the QM
EV2-B.) Testing.
625489615 XXX XXX XXX 29375397 credit 1 Asset documentation requirements not met. The guidelines do not allow for cash proceeds to be used as verified assets. The 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/03: Received required documentation. Condition cleared.
borrower has no assets verified to meet the reserve requirement.
625489615 XXX XXX XXX 29375398 credit 1 Guideline Requirement: PITIA reserves months discrepancy. Calculated PITIA months reserves of is less than Guideline PITIA months reserves The guidelines do not allow for cash proceeds to be used as verified assets. The 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/03: Received required documentation. Condition cleared.
of 6.00. borrower has no assets verified to meet the reserve requirement.
625489615 XXX XXX XXX 29375399 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Nothing in the loan file to evidence delivery of the appraisal to the borrower. 12/XX/2018 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Non QM
Consummation valuation to applicant three (3) business days prior to consummation.
(Type:Primary/11/XX/2018)
625489615 XXX XXX XXX 29375400 credit 1 The verification of employment is required and was not found in file. Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: 12/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/03: Received required documentation. Condition cleared.
12/XX/2002
625489561 XXX XXX XXX 29375432 compliance 2 Missing Document: Missing Lender's Initial 1003 Missing signed and dated Initial Loan Application. 9/XX/2015 CA Refinance - Cash-out - Other Investment No B B B B 7/XX/2023
625489561 XXX XXX XXX 29375433 credit 3 Missing Document: Approval not provided The Approval document was not provided. 9/XX/2015 CA Refinance - Cash-out - Other Investment No C C C C 7/XX/2023
625489561 XXX XXX XXX 29375434 credit 3 Missing Document: Flood Certificate not provided Missing Flood Certificate. 9/XX/2015 CA Refinance - Cash-out - Other Investment No C C C C 7/XX/2023
625489561 XXX XXX XXX 29375435 credit 3 Missing Document: Occupancy Certificate not provided Occupancy Certificate was not provided. 9/XX/2015 CA Refinance - Cash-out - Other Investment No C C C C 7/XX/2023
625489561 XXX XXX XXX 29375436 credit 3 Verification(s) of employment is not within 10 business days of the Note. Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: Missing borrower(s) Verification of employment within 10 days of the Note. 9/XX/2015 CA Refinance - Cash-out - Other Investment No C C C C 7/XX/2023
06/XX/1992
625489561 XXX XXX XXX 29375437 compliance 2 ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Not Provided ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to "Right to Receive a Copy" appraisal disclosure was not provided to borrower(s) There is generally no Assignee Liability. 9/XX/2015 CA Refinance - Cash-out - Other Investment No B B B B 7/XX/2023
Timely Receive a Copy" appraisal disclosure to applicant within three (3) business days within three (3) business days of application.
of application or determination of first lien status.
625489561 XXX XXX XXX 29375438 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA disaster area. 9/XX/2015 CA Refinance - Cash-out - Other Investment No A A A A 7/XX/2023 6/XX/2023 Yes 2023/XX/01: Received BPO confirming no damage.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX A post disaster inspection verifying there was no damage to the subject property
Disaster Name: XXX is required.
Disaster Declaration Date: XX/XX/XXXX
625488798 XXX XXX XXX 29375569 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX Most recent Inspection date not provided 10/XX/2020 CA Purchase Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/01: Received BPO confirming no damage.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488798 XXX XXX XXX 29375570 credit 3 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement 10/XX/2020 CA Purchase Primary No C C C C 7/XX/2023 Non QM
625488798 XXX XXX XXX 29375571 credit 2 Evidence of Taxpayer Consent is Missing, and Taxpayer documentation is present. 10/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Non QM
625488798 XXX XXX XXX 29375572 compliance 2 TRID Initial Closing Disclosure Timing without Waiver TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure not provided to Borrower(s) at least three (3) business days TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 10/XX/2020 10/XX/2021 CA Purchase Primary No B B B B 7/XX/2023 Non QM
at least three (3) business days prior to closing. (Initial/10/XX/2020) prior to closing liability.
625488798 XXX XXX XXX 29375574 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower. TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2020 10/XX/2021 CA Purchase Primary No B B B B 7/XX/2023 Non QM 2023/XX/30: Missing CHARM Booklet provided within 3 days of application.
CHARM Booklet, not provided to the borrower.
625488798 XXX XXX XXX 29375575 compliance 2 ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy There is no evidence the appraisal was provided to the borrower at closing. There is generally no Assignee Liability. 10/XX/2020 CA Purchase Primary No B B B B 7/XX/2023 Non QM
File) of the appraisal at least three (3) business days prior to closing, and
appraisal was not provided at or before closing. (Type:Primary/09/XX/2020)
625488755 XXX XXX XXX 29375994 credit 3 File does not contain documentation from lender/seller confirming the condo is Valuation Type: Appraisal / Valuation Report Date: 06/XX/2015 File does not contain documentation from lender/seller confirming the condo is 8/XX/2015 CA Refinance - Rate/Term Primary No C C C C 7/XX/2023 Non QM
warrantable. warrantable.
625488755 XXX XXX XXX 29375995 compliance 2 Missing Document: Missing Lender's Initial 1003 File is missing a fully executed initial application. 8/XX/2015 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM 2023/XX/29: Missing Initial signed/dated 1003.
2023/XX/30: Missing Signed/dated Initial 1003.
625488755 XXX XXX XXX 29375996 credit 3 Missing Document: Approval not provided 8/XX/2015 CA Refinance - Rate/Term Primary No C C C C 7/XX/2023 Non QM
625488755 XXX XXX XXX 29375997 compliance 2 ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM loan program disclosure not provided to the borrower within three (3) days TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2015 8/XX/2016 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
borrower within three (3) days of application. of application.
625488755 XXX XXX XXX 29375998 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet Disclosure is required to mitigate this exception. TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2015 8/XX/2016 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM 2023/XX/30: Missing CHARM Booklet provided within 3 days of application.
CHARM Booklet, not provided to the borrower.
625488755 XXX XXX XXX 29375999 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each As per Appraisal acknowledgement document signed on closing borrower did not 8/XX/2015 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
Consummation valuation to applicant three (3) business days prior to consummation. select any option
(Type:Primary/06/XX/2015)
625488755 XXX XXX XXX 29376000 compliance 2 RESPA Servicing Disclosure: Servicing Disclosure Statement Not Provided Within 3 RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure RESPA disclosure signed at close 8/XX/2015. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2015 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
Business Days of Application Statement to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489119 XXX XXX XXX 29376048 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX 8/XX/2018 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/01: PDI provided, exception cleared.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625489119 XXX XXX XXX 29376049 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2018 8/XX/2019 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
CHARM Booklet, not provided to the borrower.
625489119 XXX XXX XXX 29376050 compliance 2 TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Truth in Lending Act: Actual Date(s) on Notice of Right to Cancel occurs prior TILA ROR - 3yrs for rescindable transactions. 8/XX/2018 8/XX/2021 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
Date to expected date(s).
625489119 XXX XXX XXX 29376051 compliance 2 Self-Employed Tax Return Recency - ATR Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or This EV 2 exception is for informational purposes due to the 2017 taxes are on 8/XX/2018 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
personal tax returns provided are not the most recent. Application Date extension.
07/XX/2018, Most Recent Tax Return End Date 12/XX/2016, Tax Return Due Date
03/XX/2018. (XXX XXX/S-Corp)
625489119 XXX XXX XXX 29376052 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title Zero Percent Fee Tolerance exceeded for Title - Recording Service Fee. Fee TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 8/XX/2018 8/XX/2019 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
- Recording Service Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Amount of $XXX exceeds tolerance of $XXX. Insufficient or no cure was provided liability.
Insufficient or no cure was provided to the borrower. (75197) to the borrower.
625489119 XXX XXX XXX 29376053 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee. Fee Amount of TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 8/XX/2018 8/XX/2019 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
- Endorsement Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or $XXX exceeds tolerance of $XXX. Insufficient or no cure was provided to the liability.
no cure was provided to the borrower. (7564) borrower. (7564)
625487932 XXX XXX XXX 29376324 credit 3 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement Copy of e-sign agreement document is not available in file. 7/XX/2017 CA Refinance - Rate/Term Primary No C C C C 7/XX/2023 Non QM
625487932 XXX XXX XXX 29376325 property 3 Missing Document: Appraisal was made "subject to" and Form 1004D/442 was not Valuation Type: Appraisal / Valuation Report Date: 06/XX/2017 442 was not provided. 7/XX/2017 CA Refinance - Rate/Term Primary No C C C C 7/XX/2023 Non QM
provided.
625487932 XXX XXX XXX 29376326 compliance 2 Self-Employed Tax Return Recency - ATR Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or The business or personal tax returns provided are not the most recent. 7/XX/2017 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
personal tax returns provided are not the most recent. Application Date Application Date 05/XX/2017, Most Recent Tax Return End Date 12/XX/2015, Tax
05/XX/2017, Most Recent Tax Return End Date 12/XX/2015, Tax Return Due Date Return Due Date 04/XX/2017
04/XX/2017. (XXX XXX/Schedule C)
625487932 XXX XXX XXX 29376327 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Zero percent fee tolerance exceeded. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 7/XX/2017 7/XX/2018 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
Appraisal Re-Inspection Fee. Fee Amount of $XXX exceeds tolerance of $XXX. liability.
Insufficient or no cure was provided to the borrower. (75103)
625487932 XXX XXX XXX 29376328 credit 3 Refi Purpose reflects Rate/Term and cash out greater than the lesser of 2% of Cash to Borrower: ; Total Cash Out: $XXX; Refi Purpose: Rate/Term Borrower received total cash out of $XXX, which is greater than the lessor of 7/XX/2017 CA Refinance - Rate/Term Primary No C C C C 7/XX/2023 Non QM
the loan amount or $XXX. $XXX or 2% of the loan amount.
625487932 XXX XXX XXX 29376329 credit 3 Aged document: Asset Account date is more than 90 days prior to Closing. Financial Institution: XXX // Account Type: 401(k)/403(b) Account / Account 7/XX/2017 CA Refinance - Rate/Term Primary No C C C C 7/XX/2023 Non QM
Number: XXX
625488558 XXX XXX XXX 29376397 credit 1 REO Documents are missing. Address: XXX, CA HOA Verification HOA Verification is missing for 2661 Beach Road Pelican 35, Watsonville, CA. 8/XX/2019 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Risk 2023/XX/18: Agree with findings. The July 2019 HOA quarterly statement from XXX 2023/XX/22: HOA document located in file.
is in loan file. The quarterly payment is $XXX ($XXX annually). The annual HOA
dues were not accounted for in the schedule E rental income analysis for the
property in question. Adding the annual payment of $XXX would result in monthly
negative cashflow of $XXX vs $XXX revising the total net rental income from $XXX
to $XXX. Revised qualifying income would be $XXX. Revised DTI would be 49.675%
consisting of $XXX PITI payment against revised income of $XXX.
625488558 XXX XXX XXX 29376398 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA Disaster area post-close. A 8/XX/2019 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 6/XX/2023 Yes ATR Risk 2023/XX/01: PDI provided, exception cleared.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX post-disaster inspection verifying there was no damage to the subject property
Disaster Name: XXX is required.
Disaster Declaration Date: XX/XX/XXXX
625488558 XXX XXX XXX 29376399 compliance 3 Check Loan Designation Match - ATR Risk Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Originator Loan Designation of Non QM does not match Due Diligence Loan Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 8/XX/2019 CA Refinance - Rate/Term Primary No C C B B 7/XX/2023 ATR Risk 2023/XX/18: Although HOA dues were errorneously excluded from debt service which 2023/XX/22: The guidelines require the subject payment to use the greater of the
not match Due Diligence Loan Designation of ATR Risk. Designation due to DTI Discrepancy. Designation to the TPR firm performing the loan level due diligence and to have causes excessived DTI, ATR is still met as borrowers residual income is $XXX per Note rate or the fully-indexed rate amortized over the remaining 23 years,
the TPR firm confirm said designation. mos resulting in a qualifying DTI ratio of 52%. The DTI exceeds the maximum allowed
by more than 5% and is not eligible to be waived regraded.
2023/XX/25: Agree with error, but don't agree with ATR impact based on overall
file risk & quality. 2023/XX/26: No supporting trailing documentation was provided to clear this
exception. Exception remains.
625488558 XXX XXX XXX 29376400 compliance 3 General ATR Provision Investor and Non QM DTIs match and both significantly Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Calculated DTI of 52.48% exceeds guideline limit of DTI 45%. 8/XX/2019 CA Refinance - Rate/Term Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/18: Already addressed above. Justifications for DTI exception- Per final 2023/XX/22: The guidelines require the subject payment to use the greater of the
exceed Guidelines Lenders Guidelines and 1026.43(c)(5) of 52.60415% significantly exceeds the 1008; Low LTV XXX% and Liquidity, post close reserves equal to 150 months PITI Note rate or the fully-indexed rate amortized over the remaining 23 years,
guideline maximum of 45.00%. (DTI Exception requires compelling compensating resulting in a qualifying DTI ratio of 52%. The DTI exceeds the maximum allowed
factors to consider regrading to EV2-B.) 2023/XX/25: Agree with error, but don't agree with ATR impact based on overall by more than 5% and is not eligible to be waived regraded.
file risk & quality.
2023/XX/26: No supporting trailing documentation was provided to clear this
exception. Exception remains.
625488558 XXX XXX XXX 29376401 compliance 2 TRID Initial Closing Disclosure Timing without Waiver TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure not provided to Borrower(s) at least three (3) business days TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 8/XX/2019 8/XX/2020 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 ATR Risk
at least three (3) business days prior to closing. (Initial/08/XX/2019) prior to closing. liability.
625488558 XXX XXX XXX 29376402 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $XXX TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 8/XX/2019 8/XX/2020 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 ATR Risk
Appraisal Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no exceeds tolerance of $XXX. liability.
cure was provided to the borrower. (7506)
625488558 XXX XXX XXX 29376403 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Zero Percent Fee Tolerance exceeded for Credit Report Fee. Fee Amount of $XXX TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 8/XX/2019 8/XX/2020 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 ATR Risk
Report Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no exceeds tolerance of $XXX. liability.
cure was provided to the borrower. (7520)
625488558 XXX XXX XXX 29376404 credit 3 Guideline Requirement: Investor qualifying total debt ratio discrepancy. Calculated investor qualifying total debt ratio of 52.60415% exceeds Guideline Calculated DTI of 52.48% exceeds guideline limit of DTI 45%. 8/XX/2019 CA Refinance - Rate/Term Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/18: N/A; Duplicative Exception 2023/XX/22: The guidelines require the subject payment to use the greater of the
total debt ratio of 45.00000%. Note rate or the fully-indexed rate amortized over the remaining 23 years,
2023/XX/25: Agree with error, but don't agree with ATR impact based on overall resulting in a qualifying DTI ratio of 52%. The DTI exceeds the maximum allowed
file risk & quality. by more than 5% and is not eligible to be waived regraded.
2023/XX/26: No supporting trailing documentation was provided to clear this
exception. Exception remains.
625488558 XXX XXX XXX 29376405 compliance 3 General Ability To Repay Provision Investor Guidelines Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Loan has ATR failure due to DTI discrepancy. 8/XX/2019 CA Refinance - Rate/Term Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/18: Already addressed above. Justifications for DTI exception- Per final 2023/XX/22: The guidelines require the subject payment to use the greater of the
guideline components, the loan is at ATR risk. 1008; Low LTV XXX% and Liquidity, post close reserves equal to 150 months PITI Note rate or the fully-indexed rate amortized over the remaining 23 years,
resulting in a qualifying DTI ratio of 52%. The DTI exceeds the maximum allowed
2023/XX/25: Agree with error, but don't agree with ATR impact based on overall by more than 5% and is not eligible to be waived regraded.
file risk & quality.
2023/XX/26: No supporting trailing documentation was provided to clear this
exception. Exception remains.
625488746 XXX XXX XXX 29376614 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX 5/XX/2017 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes ATR Risk 2023/XX/01: BPO provided. No damage noted. Cleared.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488746 XXX XXX XXX 29376615 credit 3 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement E-sign consent agreement is missing 5/XX/2017 CA Refinance - Cash-out - Other Primary No C C C C 7/XX/2023 ATR Risk
625488746 XXX XXX XXX 29376616 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each 5/XX/2017 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 ATR Risk
Consummation valuation to applicant three (3) business days prior to consummation.
(Type:Primary/03/XX/2017)
625488746 XXX XXX XXX 29376617 compliance 2 General Ability To Repay Provision Investor Qualification Method not Matching Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender 10/1 ARM qualified at Note rate per guidelines. 5/XX/2017 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 ATR Risk
ATR does not match the ATR payment calculation methods under 1026.43(c)(5).
625488746 XXX XXX XXX 29376618 compliance 2 RESPA Disclosure - List of Homeownership Counseling Organizations Missing RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2017 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 ATR Risk
Homeownership Counseling Organizations to borrower. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488746 XXX XXX XXX 29376620 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2017 5/XX/2018 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 ATR Risk
CHARM Booklet, not provided to the borrower.
625488746 XXX XXX XXX 29376621 compliance 3 Check Loan Designation Match - ATR Risk Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 5/XX/2017 CA Refinance - Cash-out - Other Primary No C C B B 7/XX/2023 ATR Risk 2023/XX/18: Agree 2023/XX/21: Per lenders final 1003, loan was approved with a 44.871% DTI.
not match Due Diligence Loan Designation of ATR Risk. Designation to the TPR firm performing the loan level due diligence and to have Condition remains.
the TPR firm confirm said designation. 2023/XX/25: Disagree. Final 1003/08 provided show that final qualifying DTI was
36.121% dated 4/XX/2017. DTI >44% is from previous/earlier reviews but was 2023/XX/15: Received updated 1008, however it appears the lender did not include
not final approved DTI. the REO liabilities in the DTI. Condition remains.
2023/XX/27: Reviewed trailing documentation. Documents necessary to clear the
conditions were not provided. Exception remains.
625488746 XXX XXX XXX 29376622 credit 1 REO Documents are missing. Address: XXX, TN Statement 5/XX/2017 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 8/XX/2023 Yes ATR Risk 2023/XX/18: property identified as an apartment complex/commercial property - 2023/XX/21: Credit report used for P&I payment. Condition cleared.
used 1040 for expenses, loss includedi n ratios
625488746 XXX XXX XXX 29376623 credit 3 Guideline Requirement: Investor qualifying total debt ratio discrepancy. Calculated investor qualifying total debt ratio of 44.69592% exceeds Guideline Loan was approved at 44.7% exceeding 44% maximum DTI. 5/XX/2017 CA Refinance - Cash-out - Other Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/18: Max DTI for program is 43%, Uwer calcuated DTI at 40.870% 2023/XX/21: Per lenders final 1003, loan was approved with a 44.871% DTI.
total debt ratio of 44.00000%. Condition remains.
2023/XX/25: Disagree. Final 1003/08 provided show that final qualifying DTI was
36.121% dated 4/XX/2017. DTI >44% is from previous/earlier reviews but was 2023/XX/15: Received updated 1008, however it appears the lender did not include
not final approved DTI. the REO liabilities in the DTI. Condition remains.
2023/XX/27: Reviewed trailing documentation. Documents necessary to clear the
conditions were not provided. Exception remains.
625488746 XXX XXX XXX 29376624 compliance 3 General ATR Provision Investor and Non QM DTIs don't match and both moderately Ability to Repay (Dodd-Frank 2014): The DTIs calculated in accordance with the 5/XX/2017 CA Refinance - Cash-out - Other Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/18: Agree 2023/XX/21: Per lenders final 1003, loan was approved with a 44.871% DTI.
exceed Guidelines Lenders Guidelines of 44.69592% and based on 1026.43(c)(5) of 48.85% moderately Condition remains.
exceed the guideline maximum of 44.00%. (DTI Exception is eligible to be 2023/XX/25: Disagree. Final 1003/08 provided show that final qualifying DTI was
regraded with compensating factors.) 36.121% dated 4/XX/2017. DTI >44% is from previous/earlier reviews but was 2023/XX/15: Received updated 1008, however it appears the lender did not include
not final approved DTI. the REO liabilities in the DTI. Condition remains.
2023/XX/27: Reviewed trailing documentation. Documents necessary to clear the
conditions were not provided. Exception remains.
625488746 XXX XXX XXX 29376625 compliance 3 General Ability To Repay Provision Investor Guidelines Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Waterfall due to DTI. 5/XX/2017 CA Refinance - Cash-out - Other Primary No C C C C 7/XX/2023 ATR Risk 2023/XX/18: Agree 2023/XX/21: Per lenders final 1003, loan was approved with a 44.871% DTI.
guideline components, the loan is at ATR risk. Condition remains.
2023/XX/25: Disagree. Final 1003/08 provided show that final qualifying DTI was
36.121% dated 4/XX/2017. DTI >44% is from previous/earlier reviews but was 2023/XX/15: Received updated 1008, however it appears the lender did not include
not final approved DTI. the REO liabilities in the DTI. Condition remains.
2023/XX/27: Reviewed trailing documentation. Documents necessary to clear the
conditions were not provided. Exception remains.
625489716 XXX XXX XXX 29376706 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/02: Received BPO. Condition cleared.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625489716 XXX XXX XXX 29376707 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 11/XX/2018 12/XX/2019 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Non QM
CHARM Booklet, not provided to the borrower.
625489716 XXX XXX XXX 29376708 credit 1 Missing Document: Flood Certificate not provided Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Exception cleared.
625489716 XXX XXX XXX 29376709 credit 1 Missing Document: Credit Report not provided Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Received
625489716 XXX XXX XXX 29376710 credit 1 Missing Document: Occupancy Certificate not provided Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Exception cleared.
625489716 XXX XXX XXX 29376711 compliance 3 Missing Document: Note - Subject Lien not provided Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No D D D D 7/XX/2023 Non QM
625489716 XXX XXX XXX 29376712 credit 3 Insufficient Coverage: Hazard insurance coverage amount is insufficient. HOI coverage is insufficient by $XXX. Provide updated policy reflecting minimum Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No C C C C 7/XX/2023 Non QM
coverage of $XXX OR Provide copy of insurer's replacement cost estimate
supporting current coverage amount.
625489716 XXX XXX XXX 29376713 credit 1 Income Docs Missing: Borrower: XXX 4506-T (2016), 4506-T (2017), Award Letter / Continuance Letter, Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Exception cleared.
Paystubs, W-2 (2016), W-2 (2017)
625489716 XXX XXX XXX 29376714 credit 1 Guideline Issue:Insufficient asset documentation. Financial Institution: XXX // Account Type: Stocks / Account Number: XXX Guidelines require 2 months asset statements, only one month provided in file. Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Exception cleared.
625489716 XXX XXX XXX 29376715 compliance 1 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: FACTA disclosure received
625489716 XXX XXX XXX 29376716 compliance 2 RESPA - Initial Escrow Account Statement Missing RESPA: Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Non QM
within the statute or implementing regulation, Regulation X, for these type of
violations.
625489716 XXX XXX XXX 29376717 compliance 1 General Ability To Repay Provision Income and Assets - Other Income Doc Source Ability to Repay (Dodd-Frank 2014): Unable to verify alternate income source Missing income documentation for retirement income. Assignee Liability: Violations can result in regular TILA damages (actual Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Exception cleared.
Null using reasonably reliable third-party records. (XXX Retired/Social Security) damages, statutory damages of up to $XXX costs, and attorney's fees) and
enhanced damages (an amount equal to the sum of all finance charges and fees
paid by the consumer, unless the creditor demonstrates that the failure to
comply is not material). A private right of action may be brought before the end
of the three-year period beginning on the date of the occurrence of the
violation. However, when a creditor, assignee, or other holder or anyone acting
on their behalf initiates a judicial or non-judicial foreclosure, or any other
action to collect the debt, a consumer may assert a violation as a matter of
defense by recoupment or set-off without regard to a time limit. The amount of
recoupment or set-off shall equal the amount to which the consumer would be
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625489716 XXX XXX XXX 29376718 compliance 1 Check Loan Designation Match - ATR Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Due to missing income and asset documentation. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: All missing income and asset documentation has been received.
not match Due Diligence Loan Designation of ATR Fail. Designation to the TPR firm performing the loan level due diligence and to have
the TPR firm confirm said designation.
625489716 XXX XXX XXX 29376719 compliance 1 General Ability To Repay Provision Credit History Ability to Repay (Dodd-Frank 2014): Unable to verify debt obligations using Credit report missing in loan file Assignee Liability: Violations can result in regular TILA damages (actual Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Credit report received
reasonably reliable third-party records. damages, statutory damages of up to $XXX costs, and attorney's fees) and
enhanced damages (an amount equal to the sum of all finance charges and fees
paid by the consumer, unless the creditor demonstrates that the failure to
comply is not material). A private right of action may be brought before the end
of the three-year period beginning on the date of the occurrence of the
violation. However, when a creditor, assignee, or other holder or anyone acting
on their behalf initiates a judicial or non-judicial foreclosure, or any other
action to collect the debt, a consumer may assert a violation as a matter of
defense by recoupment or set-off without regard to a time limit. The amount of
recoupment or set-off shall equal the amount to which the consumer would be
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625489716 XXX XXX XXX 29376720 compliance 1 General Ability To Repay Provision Income and Assets - Wages Ability to Repay (Dodd-Frank 2014): Unable to verify income due to, missing W-2, Missing income documentation for all income sources used to qualify. Assignee Liability: Violations can result in regular TILA damages (actual Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Exception cleared.
Paystub, LES, ETS or WVOE. (XXX XXX/Wages) damages, statutory damages of up to $XXX costs, and attorney's fees) and
enhanced damages (an amount equal to the sum of all finance charges and fees
paid by the consumer, unless the creditor demonstrates that the failure to
comply is not material). A private right of action may be brought before the end
of the three-year period beginning on the date of the occurrence of the
violation. However, when a creditor, assignee, or other holder or anyone acting
on their behalf initiates a judicial or non-judicial foreclosure, or any other
action to collect the debt, a consumer may assert a violation as a matter of
defense by recoupment or set-off without regard to a time limit. The amount of
recoupment or set-off shall equal the amount to which the consumer would be
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625489716 XXX XXX XXX 29376722 compliance 1 TRID Closing Disclosure Status Test TILA-RESPA Integrated Disclosure: Closing Disclosure not provided or Closing No CD's in file are executed by the borrower to determine received date. High Cost or Anti-Predatory Lending Testing impact, therefore no SOL Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/02: Final CD was provided.
Disclosure not provided prior to closing. Any applicable Federal, State or Local considerations.
compliance testing is unreliable or not performed. Loan is subject to high cost For TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a
testing. defense to foreclosure. Assignee liability.
625489716 XXX XXX XXX 29376723 compliance 1 Right of Rescission Timing - Receipt Date Missing Missing Final Closing Disclosure Received Date. Unable to determine compliance No CD's in file are executed by the borrower to determine received date. TILA ROR - 3yrs for rescindable transactions. Yes 11/XX/2018 12/XX/2021 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/02: Final CD was provided.
with rescission timing requirements.
625489716 XXX XXX XXX 29376724 property 3 Missing Document: Appraisal was made "subject to" and Form 1004D/442 was not Valuation Type: Appraisal / Valuation Report Date: 10/XX/2018 Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No C C C C 7/XX/2023 Non QM
provided.
625489716 XXX XXX XXX 29376725 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of ARM Disclosure in the file does not contain a date provided. TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 11/XX/2018 12/XX/2019 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Non QM
application due to missing information.
625489716 XXX XXX XXX 29376726 compliance 2 ECOA Appraisal Disclosure - ECOA Timing ECOA - File does not evidence the consumer was provided with the right to Evidence of borrower's earlier receipt of the disclosure was not provided. Yes 11/XX/2018 12/XX/2019 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Non QM
receive a copy of the Appraisal Disclosure within 3 days of the loan application
date.
625489716 XXX XXX XXX 29376727 compliance 2 RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling The Fraud Report reflects an application date of 10/XX/2018, disclosure not RESPA (Sections 4 and 5) contains no explicit assignee liability provisions Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Non QM
Within 3 Business Days of Application Organizations not provided to applicant within three (3) business days of provided within 3 business days of application. within the statute or implementing regulation, Regulation X, for these type of
application. violations.
625489716 XXX XXX XXX 29376728 compliance 2 TRID Loan Estimate Timing TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the The Fraud Report reflects an application date of 10/XX/2018, disclosure not TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee Yes 11/XX/2018 12/XX/2019 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Non QM
mail to Borrower(s) within three (3) business days of application. provided within 3 business days of application. liability.
(Initial/10/XX/2018)
625489716 XXX XXX XXX 29376729 credit 1 Asset documentation requirements not met. File is missing required bank statements as required by lender guides to support Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Exception cleared.
required reserves.
625489716 XXX XXX XXX 29376730 credit 1 Income documentation requirements not met. File is missing required income documents as listed in lender guides. Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Exception cleared.
625489716 XXX XXX XXX 29376731 compliance 1 Income/Asset Guideline Deficiency - ATR Impact Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to File is missing critical documentation to complete DD review: credit report, Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Exception cleared.
income and/or asset doc requirements which could result in a risk to the current paystubs, most recent 2 years W2's, bank statements, award letter and
borrower's ability to repay. (Exception is eligible to be regraded with 4506's.
compensating factors.)
625489716 XXX XXX XXX 29376732 credit 1 AUS/Guideline Findings: All conditions were not met File is missing critical documentation to complete DD review: credit report, Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Exception cleared.
current paystubs, most recent 2 years W2's, bank statements, award letter and
4506's.
625489716 XXX XXX XXX 29376733 compliance 2 Missing Document: Missing Lender's Initial 1003 File is missing a fully executed initial application Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Non QM
625489716 XXX XXX XXX 29376734 compliance 1 General Ability To Repay Provision Investor Guidelines Do Not Address 8 ATR Ability to Repay (Dodd-Frank 2014): Guidelines provided do not address all 8 Failure due to missing income and asset documentation and the subject note. Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: All missing income and asset documentation has been received.
Factors factors of ATR.
625489716 XXX XXX XXX 29376735 compliance 1 General Ability To Repay Provision Investor Guidelines Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Failure due to missing income and asset documentation and subject note. Yes 11/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/13: Credit report received
guideline components, the loan is at ATR risk.
625489716 XXX XXX XXX 29376737 compliance 1 ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 11/XX/2018 12/XX/2019 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 8/XX/2023 Yes Non QM 2023/XX/02: Final CD was provided.
borrower within three (3) days of application.
625489716 XXX XXX XXX 29376738 compliance 2 TRID Final Closing Disclosure AIR Table Minimum Interest Rate TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing Page 4 shows minimum rate of 2.25%, loan rate is 4.50%. TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee Yes 11/XX/2018 12/XX/2019 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Non QM
Disclosure provided on 11/XX/2018 disclosed a Minimum Interest Rate that does liability.
not match the actual minimum interest rate for the loan. (Final/11/XX/2018)
625489716 XXX XXX XXX 29376739 compliance 2 TRID Final Closing Disclosure Projected P&I Min Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Page 1 shows minimum payment of $XXX and calculated payment is $XXX. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a Yes 11/XX/2018 12/XX/2021 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Non QM
Subsequent Payments provided on 11/XX/2018 disclosed a periodic principal and interest payment for defense to foreclosure. Assignee liability.
payment stream 3 that does not match the actual payment for the loan.
(ProjSeq:3/2211341)
625489716 XXX XXX XXX 29376740 compliance 2 TRID Final Closing Disclosure Projected P&I Min Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Page 1 shows minimum payment of $XXX and calculated payment is $XXX. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a Yes 11/XX/2018 12/XX/2021 CA Refinance - Cash-out - Other Primary No B B B B 7/XX/2023 Non QM
Subsequent Payments provided on 11/XX/2018 disclosed a periodic principal and interest payment for defense to foreclosure. Assignee liability.
payment stream 4 that does not match the actual payment for the loan.
(ProjSeq:4/2211342)
625488685 XXX XXX XXX 29376900 credit 3 File does not contain documentation from lender/seller confirming the condo is Valuation Type: Appraisal / Valuation Report Date: 09/XX/2018 The loan file does not contain evidence the Condo is warrantable. 10/XX/2018 CA Refinance - Cash-out - Other Primary No C C C C 7/XX/2023 Non QM
warrantable.
625488685 XXX XXX XXX 29376901 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The property is located in FEMA Disaster area. Provide a post-disaster 10/XX/2018 CA Refinance - Cash-out - Other Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/01: BPO provided. No damage noted. Cleared.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage. The inspection must include exterior
Disaster Name: XXX photos and the property must be re-inspected on or after XX/XX/XXXX declared end
Disaster Declaration Date: XX/XX/XXXX date
625489324 XXX XXX XXX 29377060 compliance 2 Missing Document: Missing Lender's Initial 1003 The initial 1003 was not signed by the borrower. 10/XX/2014 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
625489324 XXX XXX XXX 29377061 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX Property was not in FEMA Disaster at the time of closing thus it not reported. 10/XX/2014 CA Refinance - Rate/Term Primary No A A A A 7/XX/2023 6/XX/2023 Yes Non QM 2023/XX/01: BPO provided. No damage noted. Cleared.
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625489324 XXX XXX XXX 29377062 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to applicant three (3) 10/XX/2014 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
Consummation valuation to applicant three (3) business days prior to consummation. business days prior to consummation.
(Type:Primary/09/XX/2014)
625489324 XXX XXX XXX 29377063 compliance 2 RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling List of Homeownership Counseling Organizations not provided to applicant within RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2014 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
Within 3 Business Days of Application Organizations not provided to applicant within three (3) business days of three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
application. violations.
625489324 XXX XXX XXX 29377064 compliance 2 TIL-MDIA - Initial TIL Not Provided within 3 Business Days of Application Truth in Lending Act (Early TIL Disclosure): Initial TIL was not sent within Initial TIL was not sent within three (3) business days of the creditor TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited 10/XX/2014 10/XX/2015 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
three (3) business days of the creditor application date. application date. No TIL available within the 3 days of application date as a defense to foreclosure. Assignee liability.
625489324 XXX XXX XXX 29377065 compliance 2 ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM loan program disclosure not provided to the borrower. TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2014 10/XX/2015 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
borrower.
625489324 XXX XXX XXX 29377066 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2014 10/XX/2015 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
CHARM Booklet, not provided to the borrower. the borrower.
625489324 XXX XXX XXX 29377067 compliance 2 RESPA - Initial GFE Not Provided Within 3 Business Days of Application RESPA: Initial GFE not provided to Borrower(s) within three (3) business days of Initial GFE not provided to Borrower(s) within three (3) business days of RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2014 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
Application Date. Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489324 XXX XXX XXX 29377068 compliance 2 RESPA Servicing Disclosure: Servicing Disclosure Statement Not Provided Within 3 RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure Creditor did not provide Servicing Disclosure Statement to applicant within RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2014 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
Business Days of Application Statement to applicant within three (3) business days of application. three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489324 XXX XXX XXX 29377069 compliance 2 ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Not Provided ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to There is generally no Assignee Liability. 10/XX/2014 CA Refinance - Rate/Term Primary No B B B B 7/XX/2023 Non QM
Timely Receive a Copy" appraisal disclosure to applicant within three (3) business days
of application or determination of first lien status.
625489326 XXX XXX XXX 31520391 compliance 2 New York Late Charge Percent Testing New York Late Charge: Note late charge percent of 5.00000% exceeds the state Note late charge percent of 5.00000% exceeds the state maximum of 2% 2/XX/2020 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
maximum of 2%.
625489326 XXX XXX XXX 31520392 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Zero percent tolerance fee exceeded for Transfer Tax Fee. Fee was last disclosed TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 2/XX/2020 2/XX/2021 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
Transfer Tax. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no as $XXX on LE but disclosed as $XXX on Final Closing Disclosure. The file does liability.
cure was provided to the borrower. (8304) not contain a valid COC for this fee, nor a cure.
625488457 XXX XXX XXX 31454214 compliance 2 TRID Final Closing Disclosure Amount Financed Test TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure The disclosed Amount Financed in the amount of $XXX is over disclosed by $XXX TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 12/XX/2022 12/XX/2023 TX Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
provided on 12/XX/2022 disclosed an Amount Financed disclosed an inaccurate compared to the calculated Amount Financed of $XXX and the disclosed Finance defense to foreclosure. Assignee liability.
Amount Financed. The disclosed Amount Financed in the amount of $XXX is over Charge is not accurate within applicable tolerances for Amount Financed to be
disclosed by $XXX compared to the calculated Amount Financed of $XXX and the considered accurate (fee amounts included in Amount Financed and Finance Charge
disclosed Finance Charge is not accurate within applicable tolerances for Amount calculations are based on Closing Disclosure dated 12/XX/2022).
Financed to be considered accurate (fee amounts included in Amount Financed and (Final/12/XX/2022)
Finance Charge calculations are based on Closing Disclosure dated 12/XX/2022).
(Final/12/XX/2022)
625488457 XXX XXX XXX 31454215 compliance 2 TRID Final Closing Disclosure Finance Charge TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure The disclosed Finance Charge in the amount of $XXX is under disclosed by $XXX TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 12/XX/2022 12/XX/2023 TX Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
provided on 12/XX/2022 disclosed an inaccurate Finance Charge on page 5 that compared to the calculated Finance Charge of $XXX which exceeds the $XXX defense to foreclosure. Assignee liability.
does not match the actual Finance Charge for the loan. The disclosed Finance threshold (fee amounts included in Finance Charge calculation are based on
Charge in the amount of $XXX is under disclosed by $XXX compared to the Closing Disclosure dated 12/XX/2022). (Final/12/XX/2022)
calculated Finance Charge of $XXX which exceeds the $XXX threshold (fee amounts
included in Finance Charge calculation are based on Closing Disclosure dated
12/XX/2022). (Final/12/XX/2022)
625488457 XXX XXX XXX 31454217 compliance 2 TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Recording fee was increased on 08/XX/2022 Loan Estimate and again on 12/XX/2022 12/XX/2022 12/XX/2023 TX Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no CD with no valid change evident.
cure was provided to the borrower. (0)
625488457 XXX XXX XXX 31454219 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Valid cure document or Change of circumstance not provided. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 12/XX/2022 12/XX/2023 TX Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or liability.
no cure was provided to the borrower. (7200)
625488457 XXX XXX XXX 31454220 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Valid cure document or Change of circumstance not provided. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 12/XX/2022 12/XX/2023 TX Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
Certificate Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or liability.
no cure was provided to the borrower. (77159)
625488457 XXX XXX XXX 31467969 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each 12/XX/2022 TX Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
Consummation valuation to applicant three (3) business days prior to consummation.
(Type:Primary/12/XX/2022)
625488621 XXX XXX XXX 31464073 compliance 2 TRID Initial Closing Disclosure Timing without Waiver TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure not provided to Borrower within three business days prior to TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 3/XX/2022 3/XX/2023 IL Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
at least three (3) business days prior to closing. (Initial/03/XX/2022) closing. liability.
625489666 XXX XXX XXX 31452413 compliance 2 Missing Document: Missing Lender's Initial 1003 5/XX/2023 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
625489666 XXX XXX XXX 31454010 property 3 Appraiser's license or certification was not active at the time of the Valuation Type: Appraisal / Valuation Report Date: 04/XX/2023 The initial appraisal was completed prior to the license expiration date. There 5/XX/2023 NY Purchase Primary No C C C C 8/XX/2024 Safe Harbor QM (APOR)
appraisal. was no change in value from the initial to the final appraisal.
625489666 XXX XXX XXX 31454254 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each 5/XX/2023 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
Consummation valuation to applicant three (3) business days prior to consummation.
(Type:Primary/04/XX/2023)
625489666 XXX XXX XXX 31454255 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each 5/XX/2023 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
Consummation valuation to applicant three (3) business days prior to consummation.
(Client:5048/01/XX/2023)
625489666 XXX XXX XXX 31454271 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan No valid COC provided, nor evidence of cure in file. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 5/XX/2023 5/XX/2024 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or liability.
no cure was provided to the borrower. (7200)
625489666 XXX XXX XXX 31454272 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for No valid COC provided, nor evidence of cure in file. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 5/XX/2023 5/XX/2024 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
Appraisal Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no liability.
cure was provided to the borrower. (7308)
625489666 XXX XXX XXX 31454273 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit No valid COC provided, nor evidence of cure in file. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 5/XX/2023 5/XX/2024 NY Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
Report Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no liability.
cure was provided to the borrower. (7520)
625487953 XXX XXX XXX 31458628 credit 3 Missing Document: Fraud Report not provided 10/XX/2019 MA Purchase Primary Yes C C C C 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
625487953 XXX XXX XXX 31458888 compliance 2 ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy There is generally no Assignee Liability. 10/XX/2019 MA Purchase Primary Yes B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
File) of the appraisal at least three (3) business days prior to closing, and
appraisal was not provided at or before closing. (Type:Primary/04/XX/2019)
625487953 XXX XXX XXX 31458891 compliance 2 TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Ten Percent Fee Tolerance of $XXX exceeds tolerance allowed of $XXX plus 10%. No 10/XX/2019 10/XX/2020 MA Purchase Primary Yes B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no valid change of circumstance nor cure was provided to the borrower.
cure was provided to the borrower. (0)
625489722 XXX XXX XXX 31466065 credit 1 Missing Document: AUS not provided AUS is missing 5/XX/2023 CA Refinance - Cash-out - Other Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/10: Exception cleared. Final AUS submission has been provided.
625489722 XXX XXX XXX 31466098 compliance 1 General QM Provision Income and Assets - Wages General QM: Unable to verity income due to, missing W-2, Paystub, LES, ETS or Failure due to AUS missing and agency salable being No. 5/XX/2023 CA Refinance - Cash-out - Other Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/03: 9/3-Loan approved under digital refinance program. AUS verifies and 2024/XX/05: Unable to determine loan requirements due to missing final LP
WVOE. (XXX/Wages) no documentation required. However WVOE in file. XXX findings.
2024/XX/06: 9/6-LPA findings. XXX 2024/XX/10: Exception cleared. Final AUS submission was provided.
625489722 XXX XXX XXX 31466102 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Failure due to Aus missing and agency salable being No. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 5/XX/2023 CA Refinance - Cash-out - Other Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/03: 9/3-Loan approved under digital refinance program. AUS verifies and 2024/XX/05: Unable to determine loan requirements due to missing final LP
QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. Designation to the TPR firm performing the loan level due diligence and to have no documentation required. However WVOE in file. XXX findings.
the TPR firm confirm said designation.
2024/XX/06: 9/6--Appeal: Re-uploading LP findings. XXX 2024/XX/10: Exception cleared. Final AUS submission was provided.
625489722 XXX XXX XXX 31466103 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee was last disclosed as $XXX on Loan Estimate but disclosed as $XXX TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 5/XX/2023 5/XX/2024 CA Refinance - Cash-out - Other Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
Appraisal Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no on Final Closing Disclosure. File does not contain a valid Change of liability.
cure was provided to the borrower. (7506) circumstance for this fee, nor evidence of cure in file.
625489722 XXX XXX XXX 31515292 credit 1 AUS/Guideline Findings: All conditions were not met Aus is missing. 5/XX/2023 CA Refinance - Cash-out - Other Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/10: Exception cleared. Final AUS submission has been provided.
625488358 XXX XXX XXX 31493926 credit 3 FHA - Informed Consumer Choice Disclosure was not provided to borrower within 3 Disclosure: FHA - Informed Consumer Choice Disclosure (Government Documents) FHA - Informed Consumer Choice Disclosure not provided to borrower within 3 9/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 HUD Safe Harbor QM
business days of the loan application. business days of the loan application. Document was signed on 03/XX/2022.
625488358 XXX XXX XXX 31493958 credit 3 Missing Document: Purchase Agreement / Sales Contract not provided 9/XX/2022 OH Purchase Primary No D D D D 8/XX/2024 HUD Safe Harbor QM
625488358 XXX XXX XXX 31493979 credit 2 FHA - Real Estate Certification was provided at or after closing. Disclosure: FHA - Real Estate Certification (Government Documents) Provided FHA - Real Estate Certification is not provided in the file 9/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 HUD Safe Harbor QM
Date: 06/XX/2024; Consummation Date: 09/XX/2022
625488358 XXX XXX XXX 31494070 credit 3 Missing Document: Verification of Identification not provided Loan was originated as FHA. A required Verification of Identification document 9/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 HUD Safe Harbor QM
was not provided.
625488358 XXX XXX XXX 31494076 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to applicant three business 9/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 HUD Safe Harbor QM
Consummation valuation to applicant three (3) business days prior to consummation. days prior to consummation. A signed and dated appraisal delivery waiver was not
(Type:Primary/03/XX/2022) provided.
625488358 XXX XXX XXX 31494079 compliance 2 Ohio Consumer Sales Practices Act (Acknowledgement of Receipt of Home Mortgage Ohio Consumer Sales Practices Act: Acknowledgement of Receipt of Home Mortgage Acknowledgement of Receipt of Home Mortgage Loan Information Document not The Consumer Sales Practices Act (CSPA) generally does not provide for assignee 9/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 HUD Safe Harbor QM
Loan Information Document Not Retained by Lender) Loan Information Document not retained by lender. retained by lender. liability. The Act provides that no claim or defense may be asserted under the
Act by the Attorney General or any consumer against a purchaser or assignee of a
mortgage loan for value for any action under the statute unless: (a) the
violation was committed by the purchaser or assignee; or (b) the assignee or
purchaser is affiliated by common control with the seller of the loan at the
time the loan was purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant
injunctions, and levy monetary fines. Additionally, the CSPA provides borrowers
with a private right of action. Therefore, it is possible that any action
commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law
as part of the private right of action, a court could reform the loan terms
which could impact purchasers. Therefore, if the seller cannot be compelled to
repurchase the loan, the assignee could face exposure.
625488358 XXX XXX XXX 31494080 compliance 2 Ohio Consumer Sales Practices Act (Right Not To Close Disclosure Not Provided) Ohio Consumer Sales Practices Act: Borrower not provided Right Not To Close Right Not To Close Disclosure was not provided. "The Consumer Sales Practices Act (CSPA) generally does not provide for assignee 9/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 HUD Safe Harbor QM
Disclosure. liability. The Act provides that no claim or defense may be asserted under the
Act by the Attorney General or any consumer against a purchaser or assignee of a
mortgage loan for value for any action under the statute unless: (a) the
violation was committed by the purchaser or assignee; or (b) the assignee or
purchaser is affiliated by common control with the seller of the loan at the
time the loan was purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant
injunctions, and levy monetary fines. Additionally, the CSPA provides borrowers
with a private right of action. Therefore, it is possible that any action
commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law
as part of the private right of action, a court could reform the loan terms
which could impact purchasers. Therefore, if the seller cannot be compelled to
repurchase the loan, the assignee could face exposure."
625488358 XXX XXX XXX 31494083 compliance 2 TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Ten Percent Fee Tolerance exceeded. Total amount of $XXX exceeds tolerance of 9/XX/2022 9/XX/2023 OH Purchase Primary No B B B B 8/XX/2024 HUD Safe Harbor QM
amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no $XXX plus 10% or $XXX. No valid changed circumstance was provided.
cure was provided to the borrower. (0) Insufficient cure provided for all closing costs above the legal limit.
625488358 XXX XXX XXX 31494084 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee. Fee Amount TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 9/XX/2022 9/XX/2023 OH Purchase Primary No B B B B 8/XX/2024 HUD Safe Harbor QM
Appraisal Re-Inspection Fee. Fee Amount of $XXX exceeds tolerance of $XXX. of $XXX exceeds tolerance of $XXX. No valid changed circumstance was provided. liability.
Insufficient or no cure was provided to the borrower. (75103) Insufficient cure provided for all closing costs above the legal limit.
625488358 XXX XXX XXX 31494085 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Mortgage Insurance Premium. Fee Amount of $XXX exceeds tolerance of $XXX.No TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 9/XX/2022 9/XX/2023 OH Purchase Primary No B B B B 8/XX/2024 HUD Safe Harbor QM
Mortgage Insurance Premium. Fee Amount of $XXX exceeds tolerance of $XXX. valid changed circumstance was provided. Insufficient cure provided for all liability.
Insufficient or no cure was provided to the borrower. (7591) closing costs above the legal limit.
625488358 XXX XXX XXX 31494165 credit 2 Loan has been identified as FHA/VA/USDA Mortgage Type: FHA 9/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 HUD Safe Harbor QM
625488358 XXX XXX XXX 31501453 credit 2 FHA - Initial HUD Addendum to the Loan Application 92900-A was not provided Disclosure: FHA - Initial HUD Addendum to the Loan Application 92900-A 9/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 HUD Safe Harbor QM
within three days of the application date. (Government Documents)
625488358 XXX XXX XXX 31501477 credit 3 Important Notice to Homebuyer (92900-B) is missing. Disclosure: FHA - Important Notice to Homebuyer (92900-B) (Government Documents) 9/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 HUD Safe Harbor QM
625488358 XXX XXX XXX 31501523 credit 3 FHA - Final HUD Addendum to the Loan Application 92900-A is not compliant. Disclosure: FHA - Final HUD Addendum to the Loan Application 92900-A (Government FHA - Final HUD Addendum to the Loan Application 92900-A (Government Documents): 9/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 HUD Safe Harbor QM
Documents) FHA - Final HUD Addendum to the Loan Application 92900-A is not compliant. To be
compliant, borrower(s) signature(s) MUST be on both Part IV and Part V of Page
2, along with a signature on Page 4. The DE Signature and CHUMS ID is required
for a Manual Underwrite. The lender MUST sign page 1 and 4.
625489225 XXX XXX XXX 31493487 credit 3 Income Docs Missing: Borrower: XXX 1065 (2020), K-1 (2020) K-1 document and 1065 not provided for XXX. 11/XX/2021 NY Purchase Second Home No C C C C 8/XX/2024 Non QM
625489225 XXX XXX XXX 31493488 compliance 1 Partnership Income Documentation Test Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not 1120S and Schedule K1 missing for XXX. 11/XX/2021 NY Purchase Second Home No A A A A 8/XX/2024 9/XX/2024 Yes Non QM 2024/XX/17: Designation has been restated.
sufficient (Partnership). (XXX XXX/Partnership)
625489225 XXX XXX XXX 31493489 compliance 1 S-Corp Income Documentation Test Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not 1120S and Schedule K1 missing for XXX. 11/XX/2021 NY Purchase Second Home No A A A A 8/XX/2024 9/XX/2024 Yes Non QM 2024/XX/17: Designation has been restated.
sufficient (S-Corp). (XXX XXX/S-Corp)
625489225 XXX XXX XXX 31493491 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor 1120S and Schedule K1 missing for XXX which caused the loan test as Non QM. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 11/XX/2021 NY Purchase Second Home No A A A A 8/XX/2024 9/XX/2024 Yes Non QM 2024/XX/17: Designation has been restated.
QM does not match Due Diligence Loan Designation of Non QM. Designation to the TPR firm performing the loan level due diligence and to have
the TPR firm confirm said designation.
625489225 XXX XXX XXX 31493492 compliance 1 QM DTI Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and Loan is waterfalling due to missing income documents for the self employed Although this issue is subject to a 3 year SOL for affirmative claims under 11/XX/2021 NY Purchase Second Home No A A A A 8/XX/2024 9/XX/2024 Yes Non QM 2024/XX/17: Designation has been restated.
the images do not provide evidence loan is eligible for purchase, guarantee or income. TILA, AMC does not adjust grading taking into account TILA SOL for exceptions
insurance by the appropriate agency. under ATR, given the potential for enhanced damages when asserting an ability to
repay defense in response to an action to collect a debt by recoupment or
set-off.
625489225 XXX XXX XXX 31493496 compliance 2 TRID Loan Estimate Timing TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the Loan Estimate not delivered or placed in the mail to Borrower within three TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 11/XX/2021 11/XX/2022 NY Purchase Second Home No B B B B 8/XX/2024 Non QM
mail to Borrower(s) within three (3) business days of application. business days of application. liability.
(Initial/09/XX/2021)
625489225 XXX XXX XXX 31667528 compliance 2 Check Restated Loan Designation Match - General Ability to Repay Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did Designation has been restated. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 11/XX/2021 NY Purchase Second Home No B B A A 9/XX/2024 Non QM
not match. However, the updated Loan Designation of Non QM matches the Due Designation to the TPR firm performing the loan level due diligence and to have
Diligence Loan Designation of Non QM. the TPR firm confirm said designation.
625488582 XXX XXX XXX 31465142 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Affiliated Business Arrangement Disclosure to applicant within three (3) RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2021 CA Refinance - Cash-out - Other Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488582 XXX XXX XXX 31465143 compliance 2 TRID Lender Credit Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure:Zero Percent Fee Tolerance exceeded for Lender 0% tolerance was exceeded by -$XXX due to Increase of Lender Credits. No valid TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 12/XX/2021 12/XX/2022 CA Refinance - Cash-out - Other Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
Credits. Final Lender Credit of $XXX exceeds tolerance of -$XXX. Insufficient or COC provided, nor evidence of cure in file. liability.
no cure was provided to the borrower. (9300)
625488582 XXX XXX XXX 31465144 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan 0% tolerance was exceeded by $XXX due to Increase of Loan Discount Points. No TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 12/XX/2021 12/XX/2022 CA Refinance - Cash-out - Other Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or valid COC provided, nor evidence of cure in file. liability.
no cure was provided to the borrower. (7200)
625488649 XXX XXX XXX 31492632 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. Missing Facta Disclosure. There is no Assignee Liability. 1/XX/2022 OR Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
625488649 XXX XXX XXX 31505379 compliance 2 ECOA Appraisal - Appraisal Provided Prior to Date Performed ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is 1/XX/2022 OR Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
prior to the date when valuation was performed. Unable to determine compliance
with appraisal timing requirements. (Type:Primary/01/XX/2022)
625489416 XXX XXX XXX 31466295 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Verification appraisal was delivered to borrower was not provided. 10/XX/2021 CA Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (43-Q)
Consummation valuation to applicant three (3) business days prior to consummation.
(Type:Primary/09/XX/2021)
625488214 XXX XXX XXX 31469799 credit 3 REO Documents are missing. Address: XXX, WA HOA Verification, Insurance Verification, Statement, Tax 10/XX/2021 WA Refinance - Cash-out - Other Primary No C C C C 8/XX/2024 Safe Harbor QM (APOR)
Verification
625488214 XXX XXX XXX 31469866 credit 3 1003/Declarations: D. 1. Have you or will you be applying for a mortgage loan on Borrower: XXX 10/XX/2021 WA Refinance - Cash-out - Other Primary No C C C C 8/XX/2024 Safe Harbor QM (APOR)
another property (not the property securing this loan) on or before closing this
transaction that is not disclosed on this loan application? was entered Yes.
Unable to determine qualification without this information.
625488214 XXX XXX XXX 31469873 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each 10/XX/2021 WA Refinance - Cash-out - Other Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
Consummation valuation to applicant three (3) business days prior to consummation.
(Type:Primary/10/XX/2021)
625488214 XXX XXX XXX 31469885 credit 3 Tax Return end date is more than 90 days prior to note date. P&L was not found Borrower: XXX // Employment Type: Employment / Income Type: Sole Proprietor / 10/XX/2021 WA Refinance - Cash-out - Other Primary No C C C C 8/XX/2024 Safe Harbor QM (APOR)
in file. (GSE COVID-19) Start Date: 01/XX/2019 Note Date: 10/XX/2021;
Calendar End Date: 12/XX/2020;
625488214 XXX XXX XXX 31515155 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Loan designation mismatch due to COVID overlay Guidelines regarding missing 2021 Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 10/XX/2021 WA Refinance - Cash-out - Other Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/04: 9/XX/24 - Appeal: see page 335 D 0201 of the file in Clarity the P&L 2024/XX/06: Exception cleared.
QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Risk. YTD P&L. Designation to the TPR firm performing the loan level due diligence and to have Statement for 2021... XXX
the TPR firm confirm said designation.
625488214 XXX XXX XXX 31515156 compliance 1 Income/Asset Guideline Deficiency - QM Impact General QM: There are guideline deficiencies related to income and/or asset doc File is missing 2021 YTD P&L required by the COVID overlays Guidelines. 10/XX/2021 WA Refinance - Cash-out - Other Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/04: 9/XX/24 - Appeal: see page 335 D 0201 of the file in Clarity the P&L 2024/XX/06: Exception cleared.
requirements which could result in a risk to the borrower's ability to repay. Statement for 2021... XXX
(Exception is eligible to be regraded with compensating factors.)
625488214 XXX XXX XXX 31515158 credit 1 Income documentation requirements not met. File is missing 2021 YTD P&L required by the COVID overlays Guidelines. 10/XX/2021 WA Refinance - Cash-out - Other Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/06: Exception cleared.
625488214 XXX XXX XXX 31515160 compliance 1 General QM Provision Investor Guidelines Violation General QM: Based on the loan failing one or more guideline components, the loan File is missing 2021 YTD P&L required by the COVID overlays Guidelines. 10/XX/2021 WA Refinance - Cash-out - Other Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/04: 9/XX/24 - Appeal: see page 335 D 0201 of the file in Clarity the P&L 2024/XX/06: Exception cleared.
is at QM risk. Statement for 2021... XXX
625488875 XXX XXX XXX 31471447 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. FACTA Credit Score Disclosure was not provided. There is no Assignee Liability. 4/XX/2022 AZ Purchase Second Home No B B B B 8/XX/2024 Safe Harbor QM (APOR)
625488875 XXX XXX XXX 31471448 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor The DTI exceeds AUS maximum allowable. The AUS reflects omitted debts, but Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 4/XX/2022 AZ Purchase Second Home No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/03: 9/XX/2024: Appeal. Please refer to Clarity for evidence or payoff 2024/XX/05: The final LP findings appear to be missing. The LP findings reflect
QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Risk. evidence to support the omissions was not provided. Including the debts in the Designation to the TPR firm performing the loan level due diligence and to have &/or 0 balance statements of the following debts doc # XXX (XXX), Doc # XXX a DTI of 13%, but the 1008 reflects a DTI of 48.44% which is inline with the
DTI calculation brings the DTI to 73.77% and out of tolerance. the TPR firm confirm said designation. (XXX), Doc # XXX (XXX), Doc # XXX (XXX), Doc # XXX (XXX). XXX calculated DTI of 48.89%(after the omitted debt payments).
2024/XX/06: 9/XX/2024: Appeal. Please see attached LP AUS approval with 48% 2024/XX/09: Difference in DTI Ratio due to HOA amount. As per Appraisal document
Total DTI. XXX monthly HOA amount is $XXX. HOA amount as per Final 1003, provided AUS and 1008
state $XXX. Please provide updated AUS and supporting documents for HOA which
has HOA amount of $XXX if any. Calculated DTI is 48.44 and provided AUS reflects
DTI is 48.00 %. Exception remains.
2024/XX/09: Small DTI variance within acceptable tolerance.
625488875 XXX XXX XXX 31471449 compliance 1 General QM Provision Investor and QM DTIs match and both significantly exceed General QM: The DTI calculated in accordance with the Lenders Guidelines and The DTI exceeds AUS maximum allowable. The AUS reflects omitted debts, but 4/XX/2022 AZ Purchase Second Home No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/03: 9/XX/2024: Appeal. Please refer to Clarity for evidence or payoff 2024/XX/05: The final LP findings appear to be missing. The LP findings reflect
Guidelines 1026.43(e) of 48.89450% significantly exceeds the guideline maximum of 16.00%. evidence to support the omissions was not provided. Including the debts in the &/or 0 balance statements of the following debts doc # XXX (XXX), Doc # XXX a DTI of 13%, but the 1008 reflects a DTI of 48.44% which is inline with the
(DTI Exception requires compelling compensating factors to consider regrading to DTI calculation brings the DTI to 73.77% and out of tolerance. (XXX), Doc # XXX (XXX), Doc # XXX (XXX), Doc # XXX (XXX). XXX calculated DTI of 48.89%(after the omitted debt payments).
EV2-B.)
2024/XX/06: 9/XX/2024: Appeal. Please see attached LP AUS approval with 48% 2024/XX/05: EXCEPTION HISTORY - Exception Detail was updated on 09/XX/2024 PRIOR
Total DTI. XXX Exception Detail: General QM: The DTI calculated in accordance with the Lenders
Guidelines and 1026.43(e) of 73.77116% significantly exceeds the guideline
maximum of 16.00%. (DTI Exception requires compelling compensating factors to
consider regrading to EV2-B.)
2024/XX/09: Difference in DTI Ratio due to HOA amount. As per Appraisal document
monthly HOA amount is $XXX. HOA amount as per Final 1003, provided AUS and 1008
state $XXX. Please provide updated AUS and supporting documents for HOA which
has HOA amount of $XXX if any. Calculated DTI is 48.44 and provided AUS reflects
DTI is 48.00 %. Exception remains.
2024/XX/09: AUS (LP) received. DTI updated as per received AUS. Exception
cleared
625488875 XXX XXX XXX 31471457 compliance 2 TRID Loan Estimate Timing TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the Loan Estimate not delivered or placed in the mail to Borrower within three TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 4/XX/2022 4/XX/2023 AZ Purchase Second Home No B B B B 8/XX/2024 Safe Harbor QM (APOR)
mail to Borrower(s) within three (3) business days of application. business days of application. liability.
(Initial/04/XX/2022)
625488875 XXX XXX XXX 31471513 credit 1 AUS Findings: Investor qualifying total debt ratio discrepancy. Calculated investor qualifying total debt ratio of 48.89450% exceeds AUS total The DTI exceeds AUS maximum allowable. The AUS reflects omitted debts, but 4/XX/2022 AZ Purchase Second Home No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/06: 9/XX/2024: Appeal. Please see attached LP AUS approval with 48% 2024/XX/05: EXCEPTION HISTORY - Exception Explanation was updated on 09/XX/2024
debt ratio of 48.00000%. evidence to support the omissions was not provided. Including the debts in the Total DTI. LL PRIOR Exception Explanation: Calculated investor qualifying total debt ratio of
DTI calculation brings the DTI to 73.77% and out of tolerance. 73.77116% exceeds AUS total debt ratio of 13.00000%.
2024/XX/09: Difference in DTI Ratio due to HOA amount. As per Appraisal document
monthly HOA amount is $XXX. HOA amount as per Final 1003, provided AUS and 1008
state $XXX. Please provide updated AUS and supporting documents for HOA which
has HOA amount of $XXX if any. Calculated DTI is 48.44 and provided AUS reflects
DTI is 48.00 %. Exception remains.
2024/XX/09: EXCEPTION HISTORY - Exception Explanation was updated on 09/XX/2024
PRIOR Exception Explanation: Calculated investor qualifying total debt ratio of
48.89450% exceeds AUS total debt ratio of 13.00000%.
2024/XX/09: Small DTI variance within acceptable tolerance.
625488875 XXX XXX XXX 31471531 compliance 1 General QM Provision Investor Guidelines Violation General QM: Based on the loan failing one or more guideline components, the loan The DTI exceeds AUS maximum allowable. The AUS reflects omitted debts, but 4/XX/2022 AZ Purchase Second Home No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/03: 9/XX/2024: Appeal. Please refer to Clarity for evidence or payoff 2024/XX/05: The final LP findings appear to be missing. The LP findings reflect
is at QM risk. evidence to support the omissions was not provided. Including the debts in the &/or 0 balance statements of the following debts doc # XXX (XXX), Doc # XXX a DTI of 13%, but the 1008 reflects a DTI of 48.44% which is inline with the
DTI calculation brings the DTI to 73.77% and out of tolerance. Additionally, the (XXX), Doc # XXX (XXX), Doc # XXX (XXX), Doc # XXX (XXX). XXX calculated DTI of 48.89%(after the omitted debt payments).
final AUS appears to be missing. The DTI on the AUS does not match the 1008.
2024/XX/03: 9/XX/2024: Appeal. Please refer to Clarity for evidence or payoff 2024/XX/09: Difference in DTI Ratio due to HOA amount. As per Appraisal document
&/or 0 balance statements of the following debts doc # XXX (XXX), Doc # XXX monthly HOA amount is $XXX. HOA amount as per Final 1003, provided AUS and 1008
(XXX), Doc # XXX (XXX), Doc # XXX (XXX), Doc # XXX (XXX). AUS final approval in state $XXX. Please provide updated AUS and supporting documents for HOA which
Clarity Doc #D 427. There was a print display issue on the LP approval related has HOA amount of $XXX if any. Calculated DTI is 48.44 and provided AUS reflects
to the housing DTI and total DTI around the time that these loans were DTI is 48.00 %. Exception remains.
originated. Using the information on the LP approval: proposed housing = $XXX,
Total income = $XXX Total monthly debt = $XXX will result in DTI of 2024/XX/09: Small DTI variance within acceptable tolerance.
12.968/48.444%, matching the Uniform Underwriting and transmittal summary in
Clarity doc #D 0410. - XXX
2024/XX/06: 9/XX/2024: Appeal. Please see attached LP AUS approval with 48%
Total DTI. XXX
625488875 XXX XXX XXX 31498880 credit 1 AUS/Guideline Findings: All conditions were not met The DTI exceeds AUS maximum allowable. The AUS reflects omitted debts, but 4/XX/2022 AZ Purchase Second Home No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/06: 9/XX/2024: Appeal. Please see attached LP AUS approval with 48% 2024/XX/05: The final LP findings appear to be missing. The LP findings reflect
evidence to support the omissions was not provided. Including the debts in the Total DTI. LL a DTI of 13%, but the 1008 reflects a DTI of 48.44% which is inline with the
DTI calculation brings the DTI to 73.77% and out of tolerance. Additionally, the calculated DTI of 48.89%(after the omitted debt payments).
final AUS appears to be missing. The DTI on the AUS does not match the 1008.
2024/XX/09: Difference in DTI Ratio due to HOA amount. As per Appraisal document
monthly HOA amount is $XXX. HOA amount as per Final 1003, provided AUS and 1008
state $XXX. Please provide updated AUS and supporting documents for HOA which
has HOA amount of $XXX if any. Calculated DTI is 48.44 and provided AUS reflects
DTI is 48.00 %. Exception remains.
2024/XX/09: Small DTI variance within acceptable tolerance.
625488875 XXX XXX XXX 31609705 compliance 1 General QM Provision Investor and QM DTIs match and both moderately exceed General QM: The DTI calculated in accordance with the Lenders Guidelines and Discrepancy in DTI due to HOA amount . As per final 1003, AUS and 1008 hoa 4/XX/2022 AZ Purchase Second Home No A A A A 9/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/09: EXCEPTION HISTORY - Exception Detail was updated on 09/XX/2024 PRIOR
Guidelines 1026.43(e) of 48.89450% moderately exceeds the guideline maximum of 48.00%. (DTI amount is different than appraisal documents. Exception Detail: General QM: The DTI calculated in accordance with the Lenders
Exception is eligible to be regraded with compensating factors.) Guidelines and 1026.43(e) of 48.89450% moderately exceeds the guideline maximum
of 48.44%. (DTI Exception is eligible to be regraded with compensating factors.)
2024/XX/09: Small DTI variance within acceptable tolerance.
625488585 XXX XXX XXX 31466665 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 6/XX/2022 NY Refinance - Cash-out - Other Investment No B B B B 8/XX/2024
625487936 XXX XXX XXX 31464351 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to applicant three (3) 5/XX/2021 PA Purchase Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
Consummation valuation to applicant three (3) business days prior to consummation. business days prior to consummation.
(Type:Primary/05/XX/2021)
625487936 XXX XXX XXX 31464355 compliance 2 TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien TRID Final Closing Disclosure 05/XX/2021 on a first lien purchase transaction Final Closing Disclosure 05/XX/2021 on a first lien purchase transaction did not 5/XX/2021 5/XX/2022 PA Purchase Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
did not disclose any Seller paid fees/charges on page 2. (Points and Fees disclose any Seller paid fees/charges on page 2
testing limited to Borrower paid fees.) (Final/05/XX/2021)
625487936 XXX XXX XXX 31516089 compliance 2 (Missing Data) Last Rate Set Date Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario 5/XX/2021 PA Purchase Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
between Creditor Application Date and Transaction Date used to determine rate
used for testing.
625489360 XXX XXX XXX 31468812 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Loan designation discrepancy due to Points and Fees on subject loan is in excess Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 5/XX/2022 NC Refinance - Cash-out - Other Primary No A A A A 8/XX/2024 9/XX/2024 Yes Non QM 2024/XX/16: Wish to re-state lender designation to NonQM. 2024/XX/16: Designation has been restated.
QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. of the allowable maximum. Designation to the TPR firm performing the loan level due diligence and to have
the TPR firm confirm said designation.
625489360 XXX XXX XXX 31468813 compliance 1 QM Points and Fees 2021 Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of Points and Fees on subject loan of 3.04726% is in excess of the allowable 5/XX/2022 NC Refinance - Cash-out - Other Primary No A A A A 8/XX/2024 9/XX/2024 Yes Non QM 2024/XX/05: Appeal: Per LAS bona fide testing, which tested using the lenders 2024/XX/11: The compliance report in file includes an undiscounted rate of
3.04726% is in excess of the allowable maximum of 3.00000% of the Federal Total maximum of 3.00000% of the Federal Total Loan Amount. Points and Fees total $XXX Compliance Ease Undiscounted Rate, provides for a .125% rate reduction. Please 5.625% but is missing the undiscounted rate price. Please provide the
Loan Amount. Points and Fees total $XXX on a Federal Total Loan Amount of $XXX on a Federal Total Loan Amount of $XXX vs. an allowable total of $XXX advise threshold used or why bona fide exclusion was not applied to QM testing. undiscounted rate price, which is the amount of points that the borrower would
vs. an allowable total of $XXX (an overage of $XXX or .04726%). have paid for the undiscounted rate of 5.625%.
2024/XX/16: Designation has been restated.
625489360 XXX XXX XXX 31468814 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Zero Percent Fee Tolerance exceeded for Loan Discount Points. Fee Amount of $XXX TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 5/XX/2022 5/XX/2023 NC Refinance - Cash-out - Other Primary No B B B B 8/XX/2024 Non QM
Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or exceeds tolerance of $XXX. No valid changed circumstance was provided. No cure liability.
no cure was provided to the borrower. (7200) was provided to the Borrower.
625489360 XXX XXX XXX 31663354 compliance 2 Check Restated Loan Designation Match - General Ability to Repay Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did Designation has been restated. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 5/XX/2022 NC Refinance - Cash-out - Other Primary No B B A A 9/XX/2024 Non QM
not match. However, the updated Loan Designation of Non QM matches the Due Designation to the TPR firm performing the loan level due diligence and to have
Diligence Loan Designation of Non QM. the TPR firm confirm said designation.
625488397 XXX XXX XXX 31467176 compliance 1 QM Points and Fees 2021 Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of Points and Fees on subject loan of 3.90558 is in excess of the allowable maximum 10/XX/2021 IL Refinance - Rate/Term Primary No A A A A 8/XX/2024 9/XX/2024 Yes Non QM 2024/XX/05: Please see undiscounted rate on Mavent report in file (D0113- page 4 2024/XX/11: The bona fide discount point exclusion looks like this:
3.90558% is in excess of the allowable maximum of 3.00000% of the Federal Total of 3.00000% of the Federal Total Loan Amount. Points and Fees total $XXX on a of 25). Rate reduction of > .125%. Please advise threshold used or why Undiscounted Starting Rate – 3.625%
Loan Amount. Points and Fees total $XXX on a Federal Total Loan Amount of $XXX Federal Total Loan Amount of $XXX vs an allowable total of $XXX, an overage of excluded points were not applied to QM testing. Note Rate – 3.125%
vs. an allowable total of $XXX (an overage of $XXX or .90558%). $XXX or .90558%. Compliance Report in file reflect a Pass for Points and Fees. Loan Discounts (page 2 of CD) – 2.75%
Undiscounted Starting Rate Price – 0.125%
3.625 - 3.125 = 0.5
2.75 – 0.125 = 2.625
0.5 / 2.625 = 0.19 does not meet deal setting of 0.25 to be considered bona fide
and therefore excludable.
2024/XX/16: Designation has been restated.
625488397 XXX XXX XXX 31467177 compliance 2 TRID Final Closing Disclosure Non Escrow Costs Year 1 Underdisclosed - October TILA-RESPA Integrated Disclosure - Loan Disclosures: Non Escrowed Property Costs Non- Escrowed Property Cost over Year 1 on Final Closing Disclosure provided on TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 10/XX/2021 10/XX/2022 IL Refinance - Rate/Term Primary No B B B B 8/XX/2024 Non QM
2018 over Year 1 of on Final Closing Disclosure provided on 10/XX/2021 are 10/XX/2021 are under disclosed. liability.
underdisclosed. (Final/10/XX/2021)
625488397 XXX XXX XXX 31467179 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Originator Loan Designation of Safe Harbor QM (APOR) updated from guidelines. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 10/XX/2021 IL Refinance - Rate/Term Primary No A A A A 8/XX/2024 9/XX/2024 Yes Non QM 2024/XX/16: Wish to re-state lender designation to NonQM. 2024/XX/16: Designation has been restated.
QM (APOR) does not match Due Diligence Loan Designation of QM (APOR) Fail. Loan DEIGNATION discrepancy due to Points and Fees over by .09558% Designation to the TPR firm performing the loan level due diligence and to have
the TPR firm confirm said designation.
625488397 XXX XXX XXX 31663343 compliance 2 Check Restated Loan Designation Match - General Ability to Repay Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did Designation has been restated. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 10/XX/2021 IL Refinance - Rate/Term Primary No B B A A 9/XX/2024 Non QM
not match. However, the updated Loan Designation of Non QM matches the Due Designation to the TPR firm performing the loan level due diligence and to have
Diligence Loan Designation of Non QM. the TPR firm confirm said designation.
625488878 XXX XXX XXX 31469808 compliance 2 Missing Document: Missing Lender's Initial 1003 8/XX/2021 IL Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
625488878 XXX XXX XXX 31470190 credit 3 REO Documents are missing. Address: XXX, IL HOA Verification 8/XX/2021 IL Refinance - Rate/Term Primary No C C C C 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
625488878 XXX XXX XXX 31470535 compliance 2 TRID Lender Credit Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure:Zero Percent Fee Tolerance exceeded for Lender No valid COC provided, nor evidence of cure in file. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 8/XX/2021 8/XX/2022 IL Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
Credits. Final Lender Credit of -$XXX exceeds tolerance of -$XXX. Insufficient liability.
or no cure was provided to the borrower. (9300)
625488234 XXX XXX XXX 31466939 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 11/XX/2021 CA Refinance - Rate/Term Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
625488234 XXX XXX XXX 31516296 credit 3 Un-audited P&L Statement provided. Average monthly deposits on the business Borrower: XXX // Employment Type: Employment / Income Type: S-Corp (>= 25%) / 11/XX/2021 CA Refinance - Rate/Term Primary No C C C C 8/XX/2024 Safe Harbor QM (APOR)
Account statements do not support the average monthly income on the YTD P&L Start Date: 06/XX/2018
Statement. (GSE COVID-19)
625489486 XXX XXX XXX 31492069 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 10/XX/2021 WI Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
625489412 XXX XXX XXX 31492201 compliance 2 (Missing Data) Last Rate Set Date Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario Rate Set Date is missing. 5/XX/2022 IL Purchase Primary No B B B B 8/XX/2024 HUD Safe Harbor QM
between Creditor Application Date and Transaction Date used to determine rate
used for testing.
625489412 XXX XXX XXX 31492202 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re- Inspection Fee increased from $XXX to $XXX, an increase of $XXX, TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 5/XX/2022 5/XX/2023 IL Purchase Primary No B B B B 8/XX/2024 HUD Safe Harbor QM
Appraisal Re-Inspection Fee. Fee Amount of $XXX exceeds tolerance of $XXX. without a Changed Circumstance form in file. A cure of $XXX was provided. liability.
Insufficient or no cure was provided to the borrower. (75103)
625489412 XXX XXX XXX 31492212 credit 2 Loan has been identified as FHA/VA/USDA Mortgage Type: FHA Mortgage Type is FHA documentation in file 5/XX/2022 IL Purchase Primary No B B B B 8/XX/2024 HUD Safe Harbor QM
625488388 XXX XXX XXX 31492519 credit 3 Missing Document: AUS not provided File is missing final AUS; final 1008 showing AUS approved was used for review. 1/XX/2022 IL Refinance - Cash-out - Other Primary No C C C C 8/XX/2024 Safe Harbor QM (APOR)
625488388 XXX XXX XXX 31492521 credit 3 AUS/Guideline Findings: All conditions were not met AUS is missing in file. 1/XX/2022 IL Refinance - Cash-out - Other Primary No C C C C 8/XX/2024 Safe Harbor QM (APOR)
625488388 XXX XXX XXX 31492535 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Zero percent tolerance Loan Discount Points Fee disclosed as $XXX on Loan TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 1/XX/2022 1/XX/2023 IL Refinance - Cash-out - Other Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or Estimate dated 10/XX/2021 but disclosed as $XXX on Final Closing Disclosure. A liability.
no cure was provided to the borrower. (7200) valid COC nor cure were not provided.
625488894 XXX XXX XXX 31493081 credit 3 FHA MIP Error (Non-Borrower Paid): Date Issued: 03/XX/2022 Calculated FHA upfront premium of $XXX does not match 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor QM (43-Q)
the mortgage insurance premium collected on the Closing Disclosure of .
625488894 XXX XXX XXX 31493083 credit 3 Real Estate Certification is missing. Disclosure: FHA - Real Estate Certification (Government Documents) 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor QM (43-Q)
625488894 XXX XXX XXX 31493085 credit 3 Lead Based Paint Attachment - Attached to Purchase Contract is missing. Disclosure: FHA - Lead Based Paint Attachment - Attached to Purchase Contract Lead Based Paint attachment not provided 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor QM (43-Q)
(Government Documents)
625488894 XXX XXX XXX 31493088 credit 3 CAIVRS Authorization is missing. Disclosure: CAIVRS Authorization (Government Documents) CAIVRS Authorization not provided 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor QM (43-Q)
625488894 XXX XXX XXX 31493091 credit 2 Loan has been identified as FHA/VA/USDA Mortgage Type: FHA 3/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (43-Q)
625488894 XXX XXX XXX 31493094 property 3 Missing Document: Appraisal was made "subject to" and Form 1004D/442 was not Valuation Type: Appraisal / Valuation Report Date: 02/XX/2022 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor QM (43-Q)
provided.
625488894 XXX XXX XXX 31493099 compliance 2 Loan was originated as FHA insured and compliance was evaluated using the 3/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (43-Q)
originally intended loan type though the loan is no longer FHA insured
625488894 XXX XXX XXX 31493133 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Acopy of each valuation to applicant three (3) business days prior to 3/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (43-Q)
Consummation valuation to applicant three (3) business days prior to consummation. consummation
(Type:Secondary/02/XX/2022)
625488894 XXX XXX XXX 31493134 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each A copy of each valuation to applicant three (3) business days prior to 3/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (43-Q)
Consummation valuation to applicant three (3) business days prior to consummation. consummation
(Client:5228/01/XX/2022)
625488894 XXX XXX XXX 31493135 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. ACTA Credit Score Disclosure not provided There is no Assignee Liability. 3/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (43-Q)
625488894 XXX XXX XXX 31493136 compliance 2 RESPA Disclosure - List of Homeownership Counseling Organizations Missing RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of List of Homeownership Counseling Organizations to borrower not provided RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (43-Q)
Homeownership Counseling Organizations to borrower. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488894 XXX XXX XXX 31493137 compliance 2 Ohio Consumer Sales Practices Act (Acknowledgement of Receipt of Home Mortgage Ohio Consumer Sales Practices Act: Acknowledgement of Receipt of Home Mortgage Acknowledgement of Receipt of Home Mortgage Loan Information Document not The Consumer Sales Practices Act (CSPA) generally does not provide for assignee 3/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (43-Q)
Loan Information Document Not Retained by Lender) Loan Information Document not retained by lender. provided liability. The Act provides that no claim or defense may be asserted under the
Act by the Attorney General or any consumer against a purchaser or assignee of a
mortgage loan for value for any action under the statute unless: (a) the
violation was committed by the purchaser or assignee; or (b) the assignee or
purchaser is affiliated by common control with the seller of the loan at the
time the loan was purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant
injunctions, and levy monetary fines. Additionally, the CSPA provides borrowers
with a private right of action. Therefore, it is possible that any action
commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law
as part of the private right of action, a court could reform the loan terms
which could impact purchasers. Therefore, if the seller cannot be compelled to
repurchase the loan, the assignee could face exposure.
625488894 XXX XXX XXX 31493138 compliance 2 Ohio Consumer Sales Practices Act (Right Not To Close Disclosure Not Provided) Ohio Consumer Sales Practices Act: Borrower not provided Right Not To Close Right Not To Close Disclosure not provided "The Consumer Sales Practices Act (CSPA) generally does not provide for assignee 3/XX/2022 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (43-Q)
Disclosure. liability. The Act provides that no claim or defense may be asserted under the
Act by the Attorney General or any consumer against a purchaser or assignee of a
mortgage loan for value for any action under the statute unless: (a) the
violation was committed by the purchaser or assignee; or (b) the assignee or
purchaser is affiliated by common control with the seller of the loan at the
time the loan was purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant
injunctions, and levy monetary fines. Additionally, the CSPA provides borrowers
with a private right of action. Therefore, it is possible that any action
commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law
as part of the private right of action, a court could reform the loan terms
which could impact purchasers. Therefore, if the seller cannot be compelled to
repurchase the loan, the assignee could face exposure."
625488894 XXX XXX XXX 31493140 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Survey Zero Percent Fee Tolerance exceeded for Survey Fee. Fee Amount of $XXX exceeds TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 3/XX/2022 3/XX/2023 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (43-Q)
Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no cure was tolerance of $XXX. Insufficient or no cure was provided to the borrower. liability.
provided to the borrower. (75174)
625488894 XXX XXX XXX 31493141 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Zero Percent Fee Tolerance exceeded for Credit Report Fee. Fee Amount of $XXX TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 3/XX/2022 3/XX/2023 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (43-Q)
Report Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no exceeds tolerance of $XXX. Insufficient or no cure was provided to the borrower liability.
cure was provided to the borrower. (7520)
625488894 XXX XXX XXX 31493142 compliance 3 HUD QM AU Finding Fail HUD Qualified Mortgage (Dodd-Frank 2014): Subject loan is not eligible to be Subject loan is not eligible to be insured or guaranteed by FHA. 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor QM (43-Q)
insured or guaranteed by FHA.
625488894 XXX XXX XXX 31493143 compliance 3 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of HUD Safe Originator Loan Designation of HUD Safe Harbor QM does not match Due Diligence Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 3/XX/2022 OH Purchase Primary No C C B B 8/XX/2024 Safe Harbor QM (43-Q)
Harbor QM does not match Due Diligence Loan Designation of Safe Harbor QM Loan Designation of Safe Harbor QM Designation to the TPR firm performing the loan level due diligence and to have
(43-Q). the TPR firm confirm said designation.
625488894 XXX XXX XXX 31493146 credit 3 Guideline Requirement: Combined High loan to value discrepancy. Calculated high loan to value percentage of XX% exceeds Guideline high loan to 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor QM (43-Q)
value percentage of 95.00000%
625488894 XXX XXX XXX 31493147 credit 3 Guideline Requirement: Loan to value discrepancy. Calculated loan to value percentage of XX% exceeds Guideline loan to value 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor QM (43-Q)
percentage of 95.00000%.
625488894 XXX XXX XXX 31493148 credit 3 Guideline Requirement: Combined loan to value discrepancy. Calculated combined loan to value percentage of XX% exceeds Guideline combined 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor QM (43-Q)
loan to value percentage of 95.00000%.
625488894 XXX XXX XXX 31493149 credit 3 Guideline Requirement: PITIA reserves months discrepancy. Calculated PITIA months reserves of 3.29 is less than Guideline PITIA months 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor QM (43-Q)
reserves of 6.00.
625488894 XXX XXX XXX 31493150 credit 3 Recent sale within 90 days is not eligible per FHA guidelines. Valuation Type: Appraisal / Valuation Report Date: 02/XX/2022 Last Sale Date: 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor QM (43-Q)
11/XX/2021; Case Number Assignment Date: 01/XX/2022
625488894 XXX XXX XXX 31493151 credit 3 Recent sale within 90 days is not eligible per FHA guidelines. Valuation Type: Appraisal / Valuation Report Date: 02/XX/2022 Last Sale Date: 3/XX/2022 OH Purchase Primary No C C C C 8/XX/2024 Safe Harbor QM (43-Q)
11/XX/2021; Case Number Assignment Date: 01/XX/2022
625489050 XXX XXX XXX 31470948 compliance 2 TRID Initial Closing Disclosure Timing without Waiver TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure not provided to Borrower at least three business days prior TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 10/XX/2021 10/XX/2022 IL Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
at least three (3) business days prior to closing. (Initial/10/XX/2021) to closing. liability.
625488882 XXX XXX XXX 31468301 compliance 2 ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Missing ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to There is generally no Assignee Liability. 7/XX/2022 IL Purchase Investment No B B B B 8/XX/2024
Receive a Copy" appraisal disclosure to consumer.
625488882 XXX XXX XXX 31468302 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 7/XX/2022 IL Purchase Investment No B B B B 8/XX/2024
625488882 XXX XXX XXX 31517747 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to applicant three business 7/XX/2022 IL Purchase Investment No B B B B 8/XX/2024
Consummation valuation to applicant three (3) business days prior to consummation. days prior to consummation.
(Type:Primary/07/XX/2022)
625488211 XXX XXX XXX 31492954 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Waterfall due income asset documents are not provided in file Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 9/XX/2020 CO Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM 2024/XX/05: 9.5.24 Appeal attached final uw approval,XXX, income + assets in AMC 2024/XX/05: Exception cleared. Documentation provided that Borrower's were
QM does not match Due Diligence Loan Designation of Non QM. Designation to the TPR firm performing the loan level due diligence and to have pages 406-416 of 1265 D-0165 XXX partnership TR 2019 -1065, pages 417-437 of removed from XXX.
the TPR firm confirm said designation. 1265 D-0179 XXX partnership TR 2018 -1065 kindly review,recind, advise, thank
you XXX. please see uploads
625488211 XXX XXX XXX 31492956 compliance 1 Partnership Income Documentation Test Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not Third Party Verification on Partnership is missing from the loan file. 9/XX/2020 CO Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM 2024/XX/05: 9.5.24 Appeal attached final uw approval, XXX, income + assets in 2024/XX/05: Exception cleared. Documentation provided that Borrower's were
sufficient (Partnership). (XXX/Partnership) AMC pages 406-416 of 1265 D-0165 XXX partnership TR 2019 -1065, pages 417-437 of removed from XXX.
1265 D-0179 XXX partnership TR 2018 -1065 kindly review,recind,advise, thank you
XXX.
625488211 XXX XXX XXX 31492957 compliance 1 Partnership Income Documentation Test Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not Third Party Verification on Partnership is missing from the loan file. 9/XX/2020 CO Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM 2024/XX/05: 9.5.24 Appeal attached final uw approval,XXX, income + assets in AMC 2024/XX/05: Exception cleared. Documentation provided that Borrower's were
sufficient (Partnership). (XXX/Partnership) pages 406-416 of 1265 D-0165 XXX partnership TR 2019 -1065, pages 417-437 of removed from XXX.
1265 D-0179 XXX partnership TR 2018 -1065 kindly review,recind, advise, thank
you XXX. p;easwe see uploads
625488026 XXX XXX XXX 31492025 credit 3 Borrower(s) is not a U.S. Citizen, and the guideline required documentation was Borrower: XXX, Borrower: XXX Employment Authorization, Resident Alien Card, Passport and VISA missing in loan 12/XX/2020 CA Purchase Primary No C C C C 8/XX/2024 Safe Harbor QM
not provided. file.
625488026 XXX XXX XXX 31492026 credit 3 Missing Document: Verification of Non-US Citizen Status not provided Employment Authorization, Resident Alien Card, Passport and VISA missing in loan 12/XX/2020 CA Purchase Primary No C C C C 8/XX/2024 Safe Harbor QM
file.
625487956 XXX XXX XXX 31493834 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. Missing Facta Disclosure. There is no Assignee Liability. 3/XX/2021 CA Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
625488434 XXX XXX XXX 31492434 credit 3 Missing Document: Fraud Report not provided Fraud Report is missing. 1/XX/2020 NY Refinance - Rate/Term Primary No C C C C 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
625488434 XXX XXX XXX 31492499 compliance 2 TRID Interim Closing Disclosure Timing Test TILA-RESPA Integrated Disclosure – Corrected Closing Disclosure provided on or Missing Initial Closing Disclosure. TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 1/XX/2020 1/XX/2021 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
after 01/XX/2020 contains a change in APR and was not received by borrower at liability.
least three (3) business days prior to consummation
625488434 XXX XXX XXX 31492500 compliance 2 TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Ten Percent Fee Tolerance exceeded. Total amount of $XXX exceeds tolerance of 1/XX/2020 1/XX/2021 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no $XXX. No Valid Change circumstance in file.
cure was provided to the borrower. (0)
625488434 XXX XXX XXX 31492502 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Credit Report Fee on closing disclosure is $XXX and on loan estimate $XXX. No TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 1/XX/2020 1/XX/2021 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
Report Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no Valid Change circumstance in file. liability.
cure was provided to the borrower. (7520)
625488434 XXX XXX XXX 31492503 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. RTC is missing. TILA ROR - 3yrs for rescindable transactions. 1/XX/2020 1/XX/2023 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
625488654 XXX XXX XXX 31467294 credit 3 Available for Closing is insufficient to cover Cash From Borrower. Documented qualifying Assets for Closing of $XXX is less than Cash From Borrower No asset verification provided. Per final Closing Disclosure, funds from 11/XX/2020 CA Refinance - Rate/Term Primary No C C C C 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
$XXX. borrower are $XXX. Additionally, source of fees paid prior to closing ($XXX) are
not verified.
625488654 XXX XXX XXX 31514926 compliance 2 ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy Neither evidence of appraisal delivery nor compliant acknowledgment of receipt There is generally no Assignee Liability. 11/XX/2020 CA Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
File) of the appraisal at least three (3) business days prior to closing, and signed at closing is provided.
appraisal was not provided at or before closing. (Type:Primary/11/XX/2020)
625488253 XXX XXX XXX 31469734 credit 3 Insufficient Coverage: Hazard insurance coverage amount is insufficient. HOI coverage is insufficient by $XXX. Provide verification of policy with 1/XX/2021 NY Refinance - Cash-out - Other Primary No C C C C 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
sufficient coverage OR provide copy of insurer's replacement cost estimate
supporting current coverage amount.
625488253 XXX XXX XXX 31469794 compliance 2 TRID Final Closing Disclosure Amount Financed Test TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Final Closing Disclosure reflects Amount Finance of $XXX but calculated Amount TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 1/XX/2021 1/XX/2024 NY Refinance - Cash-out - Other Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
provided on 01/XX/2021 disclosed an Amount Financed disclosed an inaccurate Finance of $XXX. Variance = $XXX. Lender to provide corrected CD and copy of defense to foreclosure. Assignee liability.
Amount Financed. The disclosed Amount Financed in the amount of $XXX is over letter sent to borrower explaining changes.
disclosed by $XXX compared to the calculated Amount Financed of $XXX and the
disclosed Finance Charge is not accurate within applicable tolerances for Amount
Financed to be considered accurate (fee amounts included in Amount Financed and
Finance Charge calculations are based on Closing Disclosure dated 01/XX/2021).
(Final/XX/20/2021)
625488253 XXX XXX XXX 31469795 compliance 2 TRID Final Closing Disclosure Finance Charge TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Final Closing Disclosure reflects Finance Charge of $XXX but calculated Finance TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 1/XX/2021 1/XX/2024 NY Refinance - Cash-out - Other Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
provided on 01/XX/2021 disclosed an inaccurate Finance Charge on page 5 that Charge of $XXX.Variance = -$XXX. Lender to provide corrected CD and copy of defense to foreclosure. Assignee liability.
does not match the actual Finance Charge for the loan. The disclosed Finance letter sent to borrower explaining changes.
Charge in the amount of $XXX is under disclosed by $XXX compared to the
calculated Finance Charge of $XXX which exceeds the $XXX threshold (fee amounts
included in Finance Charge calculation are based on Closing Disclosure dated
01/XX/2021). (Final/XX/20/2021)
625488253 XXX XXX XXX 31469796 compliance 2 TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Total amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or 1/XX/2021 1/XX/2022 NY Refinance - Cash-out - Other Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no no cure was provided to the borrower. (0)
cure was provided to the borrower. (0)
625488253 XXX XXX XXX 31469797 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee was last disclosed as $.00 on LE but disclosed as $XXX on Final TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 1/XX/2021 1/XX/2022 NY Refinance - Cash-out - Other Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
Appraisal Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no Closing Disclosure. File does not contain a valid COC for this fee, cure liability.
cure was provided to the borrower. (7506) provided at closing.
625488530 XXX XXX XXX 31492208 compliance 2 ECOA Appraisal - Appraisal Provided Prior to Date Performed ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is The file is missing documentation verifying the borrowers received a copy of the 11/XX/2019 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
prior to the date when valuation was performed. Unable to determine compliance appraisal within 3 business days of closing.
with appraisal timing requirements. (Type:Primary/10/XX/2019)
625488530 XXX XXX XXX 31492211 compliance 2 TRID Revised Loan Estimate Timing Before Closing TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on 11/XX/2019 Revised Loan Estimate provided on 11/XX/2019 not received by borrower within TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 11/XX/2019 11/XX/2020 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
not received by borrower at least four (4) business days prior to closing. timeframe of 4 days. It was signed on 11/XX/2019. liability.
(Interim/11/XX/2019)
625488903 XXX XXX XXX 31506887 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Fee amount disclosed in Final CD issued 1/XX/2020 with no valid Change of TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 1/XX/2020 1/XX/2021 NY Refinance - Cash-out - Other Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
Originator Compensation. Fee Amount of $XXX exceeds tolerance of $XXX. Circumstance evident. liability.
Insufficient or no cure was provided to the borrower. (7326)
625488903 XXX XXX XXX 31506904 compliance 2 TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Recording fee amount increased in Final CD issued 1/XX/2020 with no valid Change 1/XX/2020 1/XX/2021 NY Refinance - Cash-out - Other Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no of Circumstance evident.
cure was provided to the borrower. (0)
625488903 XXX XXX XXX 31506942 compliance 2 TRID Interim Closing Disclosure Timing Test TILA-RESPA Integrated Disclosure – Corrected Closing Disclosure provided on or Final CD issued 1/XX/2020 provided to and received by Borrower on 1/XX/2020 TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 1/XX/2020 1/XX/2021 NY Refinance - Cash-out - Other Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
after 01/XX/2020 contains a change in APR and was not received by borrower at closing date. Revised CD issued 1/XX/2020 is incomplete. Closing Date is not liability.
least three (3) business days prior to consummation disclosed. Sections of pages 1, 3, 4 and 5 are blank/incomplete.
625488464 XXX XXX XXX 31492371 credit 3 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement 1/XX/2020 NY Refinance - Cash-out - Other Primary No C C C C 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
625488464 XXX XXX XXX 31499640 compliance 2 TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Ten Percent Fee Tolerance exceeded. Total amount of $XXX exceeds tolerance of 1/XX/2020 1/XX/2021 NY Refinance - Cash-out - Other Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no $XXX plus 10% or $XXX. No valid changed circumstance was provided. No cure was
cure was provided to the borrower. (0) provided to the Borrower.
625489192 XXX XXX XXX 31491841 compliance 2 TRID Initial Loan Estimate Timing Electronically Provided TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) Loan Estimate not delivered to Borrower within three business days of TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 2/XX/2020 2/XX/2021 CO Purchase Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
within three (3) business days of application. Initial Loan Estimate dated application. liability.
01/XX/2020 was electronically provided without or prior to borrower's consent to
receive electronic disclosures. Failure to comply with the provisions of the
E-Sign Act and failure to provide good faith estimate of fees timely may result
in additional fee tolerance violations. (Initial/01/XX/2020)
625488821 XXX XXX XXX 31492537 credit 3 Missing Document: Fraud Report not provided Fraud Report is missing in file. 11/XX/2019 NY Refinance - Cash-out - Other Primary No C C C C 8/XX/2024 Non QM
625488821 XXX XXX XXX 31492573 compliance 3 QM Points and Fees Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of Points and Fees on subject loan of 4.31292% is in excess of the allowable 11/XX/2019 NY Refinance - Cash-out - Other Primary No C C C C 8/XX/2024 Yes Non QM 2024/XX/06: Appeal: See D0256 Mavent Report reflecting lenders undiscounted 2024/XX/10: With the undiscounted rate of 4.5%, the points and fees are exceeded
4.30530% is in excess of the allowable maximum of 3.00000% of the Federal Total maximum of 3.00000% of the Federal Total Loan Amount. Points and Fees total $XXX interest rate of 4.5%. Up to 2 Bona Fide discount points are excludable as each by $XXX.
Loan Amount. Points and Fees total $XXX on a Federal Total Loan Amount of $XXX on a Federal Total Loan Amount of $XXX vs. an allowable total of $XXX (an point reduced the rate by 0.2083% which exceeds the threshold to be considered
vs. an allowable total of $XXX (an overage of $XXX or 1.30530%). overage of $XXX or 1.31292%). bona fide. $XXX (or 2%) of the discount point fee is excludable.
625488821 XXX XXX XXX 31499183 compliance 3 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Temporary Loan designation mismatch due to loan failing QM Points and Fees testing. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 11/XX/2019 NY Refinance - Cash-out - Other Primary No C C B B 8/XX/2024 Non QM
SHQM (GSE/Agency Eligible) does not match Due Diligence Loan Designation of Non Designation to the TPR firm performing the loan level due diligence and to have
QM. the TPR firm confirm said designation.
625488937 XXX XXX XXX 31467967 property 3 Missing Document: Appraisal was made "subject to" and Form 1004D/442 was not Valuation Type: Appraisal / Valuation Report Date: 02/XX/2021 5/XX/2021 MA Purchase Primary Yes C C C C 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
provided.
625488278 XXX XXX XXX 31492286 compliance 2 TRID Initial Closing Disclosure Timing without Waiver TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Initial Closing Disclosure not provided to Borrower at least three business days TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 4/XX/2019 4/XX/2020 NY Refinance - Cash-out - Other Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
at least three (3) business days prior to closing. (Final/04/XX/2019) prior to closing.. liability.
625488278 XXX XXX XXX 31492305 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $XXX TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 4/XX/2019 4/XX/2020 NY Refinance - Cash-out - Other Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
Appraisal Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no exceeds tolerance of $XXX. No valid changed circumstance was provided. liability.
cure was provided to the borrower. (7506) Insufficient cure provided for all closing costs above the legal limit.
625488278 XXX XXX XXX 31503164 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Zero Percent Fee Tolerance exceeded for Attorney's Fee (Closing Agent and TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 4/XX/2019 4/XX/2020 NY Refinance - Cash-out - Other Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
Attorney's Fee (Closing Agent and Other). Fee Amount of $XXX exceeds tolerance Other). Fee Amount of $XXX exceeds tolerance of $XXX. No valid changed liability.
of $XXX. Insufficient or no cure was provided to the borrower. (7742) circumstance was provided. Insufficient cure provided for all closing costs
above the legal limit.
625488593 XXX XXX XXX 31494916 compliance 2 QM Employment History - Current Employment Documentation lacks Date Info Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two The documentation entered for this income source lacks sufficient date/duration 12/XX/2019 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Safe Harbor QM
years current employment. (XXX/14070622) information to verify the 2 year history as required by Appendix Q.
625488593 XXX XXX XXX 31494920 compliance 2 (Missing Data) Last Rate Set Date Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario Initial Rate Lock Date not provided. 12/XX/2019 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Safe Harbor QM
between Creditor Application Date and Transaction Date used to determine rate
used for testing.
625488593 XXX XXX XXX 31494922 compliance 3 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Temporary Loan designation of Temporary SHQM does not match due to missing verbal Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 12/XX/2019 NY Refinance - Rate/Term Primary No C C B B 8/XX/2024 Safe Harbor QM
SHQM (GSE/Agency Eligible) does not match Due Diligence Loan Designation of Safe verification of employment within 10 business days of the note date. Designation to the TPR firm performing the loan level due diligence and to have
Harbor QM. the TPR firm confirm said designation.
625488593 XXX XXX XXX 31494923 compliance 2 RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling List of Homeownership Counseling Organizations not provided to applicant within RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2019 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Safe Harbor QM
Within 3 Business Days of Application Organizations not provided to applicant within three (3) business days of three business days of application. within the statute or implementing regulation, Regulation X, for these type of
application. violations.
625488593 XXX XXX XXX 31494924 compliance 2 TRID Loan Estimate Timing TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the Application date is 08/XX/2019, earliest Loan Estimate in file is 08/XX/2019. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 12/XX/2019 12/XX/2020 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Safe Harbor QM
mail to Borrower(s) within three (3) business days of application. liability.
(Initial/08/XX/2019)
625488593 XXX XXX XXX 31494925 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Zero Percent Fee Tolerance exceeded for Reinspection Fee. Fee Amount of $XXX TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 12/XX/2019 12/XX/2020 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Safe Harbor QM
Reinspection Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or exceeds tolerance of $XXX. A valid COC, nor cure were provided. liability.
no cure was provided to the borrower. (7552)
625488593 XXX XXX XXX 31494929 credit 3 The verification of employment is not within 10 business days of the Note. Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: Missing verbal verification of employment within 10 business days of the note 12/XX/2019 NY Refinance - Rate/Term Primary No C C C C 8/XX/2024 Safe Harbor QM
01/XX/2017 date.
625488593 XXX XXX XXX 31499509 credit 3 Income documentation requirements not met. Missing verbal verification of employment within 10 business days of the note 12/XX/2019 NY Refinance - Rate/Term Primary No C C C C 8/XX/2024 Safe Harbor QM
date.
625488593 XXX XXX XXX 31535256 credit 3 Income Docs Missing: Borrower: XXX VVOE - Employment Only 12/XX/2019 NY Refinance - Rate/Term Primary No C C C C 8/XX/2024 Safe Harbor QM
625488593 XXX XXX XXX 31535263 compliance 2 ECOA Appraisal - Appraisal Provided Prior to Date Performed ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is 12/XX/2019 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Safe Harbor QM
prior to the date when valuation was performed. Unable to determine compliance
with appraisal timing requirements. (Type:Primary/10/XX/2019)
625489039 XXX XXX XXX 31492639 compliance 2 TRID Initial Closing Disclosure Timing without Waiver TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure not provided to Borrower(s) at least three (3) business days TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 2/XX/2020 2/XX/2021 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
at least three (3) business days prior to closing. (Initial/02/XX/2020) prior to closing. liability.
625489039 XXX XXX XXX 31492640 compliance 2 TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Ten Percent Fee Tolerance exceeded. Total amount of $XXX exceeds tolerance of 2/XX/2020 2/XX/2021 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no $XXX plus 10% or $XXX. Insufficient or no cure was provided to the borrower. (0)
cure was provided to the borrower. (0)
625488747 XXX XXX XXX 31493453 credit 3 Missing Document: Fraud Report not provided File is missing Fraud report 2/XX/2020 NV Purchase Primary No C C C C 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
625488747 XXX XXX XXX 31493472 credit 3 Missing Document: Bankruptcy Documents not provided Bankruptcy Documents not provided. 2/XX/2020 NV Purchase Primary No C C C C 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
625488747 XXX XXX XXX 31493473 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each No evidence in file showing borrower receive copy of appraisal. 2/XX/2020 NV Purchase Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
Consummation valuation to applicant three (3) business days prior to consummation.
(Type:Primary/01/XX/2020)
625488747 XXX XXX XXX 31493474 compliance 2 (Missing Data) Last Rate Set Date Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario Rate lock document not provided. 2/XX/2020 NV Purchase Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
between Creditor Application Date and Transaction Date used to determine rate
used for testing.
625488747 XXX XXX XXX 31493475 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no cure was TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 2/XX/2020 2/XX/2021 NV Purchase Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
Discount Points. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or provided to the borrower. liability.
no cure was provided to the borrower. (7200)
625488747 XXX XXX XXX 31493476 compliance 2 TRID Initial Closing Disclosure Timing without Waiver TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure not provided to Borrower(s) at least three (3) business days TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 2/XX/2020 2/XX/2021 NV Purchase Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
at least three (3) business days prior to closing. (Initial/01/XX/2020) prior to closing. (Initial/01/XX/2020) liability.
625488732 XXX XXX XXX 31468764 credit 3 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement 3/XX/2020 FL Purchase Primary No C C C C 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
625489245 XXX XXX XXX 31493733 compliance 3 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Temporary Loan Designation is determined to be Temporary HPML. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 12/XX/2020 CT Purchase Primary No C C B B 8/XX/2024 Temporary HPQM (GSE/Agency Eligible)
SHQM (GSE/Agency Eligible) does not match Due Diligence Loan Designation of Designation to the TPR firm performing the loan level due diligence and to have
Temporary HPQM (GSE/Agency Eligible). the TPR firm confirm said designation.
625489608 XXX XXX XXX 31492394 compliance 2 TRID Closing Disclosure Issue Date Not Provided TILA-RESPA Integrated Disclosure: Closing Disclosure estimated to be provided on Date issued not completed on Closing Disclosure. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 4/XX/2019 4/XX/2022 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
04/XX/2019 did not disclose the actual Date Issued. Unable to conclusively defense to foreclosure. Assignee liability.
determine Final Closing disclosure to use to test for compliance with applicable
TRID timing requirements, TRID fee tolerance testing or accuracy of disclosures
at or before consummation due to missing Issue Date. Tested using an estimated
Date Issued based on best information available. (Interim/04/XX/2019)
625489608 XXX XXX XXX 31492396 compliance 2 TRID Closing Disclosure Issue Date Not Provided TILA-RESPA Integrated Disclosure: Closing Disclosure estimated to be provided on Date issued not completed on Closing Disclosure. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 4/XX/2019 4/XX/2022 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
04/XX/2019 did not disclose the actual Date Issued. Unable to conclusively defense to foreclosure. Assignee liability.
determine Final Closing disclosure to use to test for compliance with applicable
TRID timing requirements, TRID fee tolerance testing or accuracy of disclosures
at or before consummation due to missing Issue Date. Tested using an estimated
Date Issued based on best information available. (Initial/04/XX/2019)
625489608 XXX XXX XXX 31492397 compliance 2 TRID Final Closing Disclosure Amount Financed Test TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Finance Charge disclosed is $XXX. Calculated finance charge is $XXX Variance of TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 4/XX/2019 4/XX/2022 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
provided on 04/XX/2019 disclosed an Amount Financed disclosed an inaccurate $XXX. defense to foreclosure. Assignee liability.
Amount Financed. The disclosed Amount Financed in the amount of $XXX is over
disclosed by $XXX compared to the calculated Amount Financed of $XXX and the
disclosed Finance Charge is not accurate within applicable tolerances for Amount
Financed to be considered accurate (fee amounts included in Amount Financed and
Finance Charge calculations are based on Closing Disclosure dated 04/XX/2019).
(Final/04/XX/2019)
625489608 XXX XXX XXX 31492399 compliance 2 TRID Final Closing Disclosure Finance Charge TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Finance Charge disclosed is $XXX. Calculated finance charge is $XXX Variance of TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 4/XX/2019 4/XX/2022 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
provided on 04/XX/2019 disclosed an inaccurate Finance Charge on page 5 that $XXX. defense to foreclosure. Assignee liability.
does not match the actual Finance Charge for the loan. The disclosed Finance
Charge in the amount of $XXX is under disclosed by $XXX compared to the
calculated Finance Charge of $XXX which exceeds the $XXX threshold (fee amounts
included in Finance Charge calculation are based on Closing Disclosure dated
04/XX/2019). (Final/04/XX/2019)
625489608 XXX XXX XXX 31492400 compliance 2 TRID Initial Closing Disclosure Timing without Waiver TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Proof of earlier delivery not found in file. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 4/XX/2019 4/XX/2020 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
at least three (3) business days prior to closing. (Initial/04/XX/2019) liability.
625489608 XXX XXX XXX 31492402 compliance 2 TRID Interim Closing Disclosure Timing Test TILA-RESPA Integrated Disclosure – Corrected Closing Disclosure provided on or Proof of delivery not found in file. TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 4/XX/2019 4/XX/2020 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
after 04/XX/2019 contains a change in APR and was not received by borrower at liability.
least three (3) business days prior to consummation
625489608 XXX XXX XXX 31492403 compliance 2 TRID Lender Credit Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure:Zero Percent Fee Tolerance exceeded for Lender Lender Credit was last disclosed as -$XXX on LE but disclosed as- $XXX on Final TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 4/XX/2019 4/XX/2020 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
Credits. Final Lender Credit of -$XXX exceeds tolerance of -$XXX. Insufficient Closing Disclosure. File does not contain a valid Change of Circumstance for liability.
or no cure was provided to the borrower. (9300) this fee, nor evidence of cure in file.
625489608 XXX XXX XXX 31492405 compliance 2 TRID Revised Loan Estimate Issue and Received Date > Closing Disclosure Issue TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on or after the Loan Estimate provided after the date of Closing Disclousre. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 4/XX/2019 4/XX/2020 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
and Received Date date the Closing Disclosure was provided. (The Revised Loan Estimate was liability.
received on or after the Closing Disclosure.) (Interim/04/XX/2019)
625489608 XXX XXX XXX 31492406 compliance 2 TRID Revised Loan Estimate Timing Before Closing TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on 04/XX/2019 Proof of receipt not in file. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 4/XX/2019 4/XX/2020 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
not received by borrower at least four (4) business days prior to closing. liability.
(Interim/04/XX/2019)
625489608 XXX XXX XXX 31492407 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Service Charge Fee was not disclosed on Loan Estimate. File does not contain a TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 4/XX/2019 4/XX/2020 NY Refinance - Rate/Term Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
Service Charges. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or valid Change of Circumstance for this fee, nor evidence of cure. liability.
no cure was provided to the borrower. (7527)
625489608 XXX XXX XXX 31501649 credit 3 Missing Document: Note - Subordinate Lien not provided 4/XX/2019 NY Refinance - Rate/Term Primary No C C C C 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
625489631 XXX XXX XXX 31494358 compliance 2 (Missing Data) Last Rate Set Date Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario 6/XX/2021 GA Purchase Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
between Creditor Application Date and Transaction Date used to determine rate
used for testing.
625488787 XXX XXX XXX 31492084 credit 3 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement 9/XX/2019 TX Purchase Primary No C C C C 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
625488787 XXX XXX XXX 31492160 compliance 2 ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy No evidence in file of when the borrower received a copy of the dated There is generally no Assignee Liability. 9/XX/2019 TX Purchase Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
File) of the appraisal at least three (3) business days prior to closing, and 08/XX/2019.
appraisal was not provided at or before closing. (Type:Primary/08/XX/2019)
625488787 XXX XXX XXX 31492163 compliance 2 TRID Final Closing Disclosure APR TILA-RESPA Integrated Disclosure - Loan Calculations: APR of XX.XX% on Final Loan Calculations: APR of XX.XX% on Final Closing Disclosure provided on TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2019 9/XX/2020 TX Purchase Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
Closing Disclosure provided on 09/XX/2019 is under-disclosed from the calculated 09/XX/2019 is under-disclosed from the calculated APR of XX.XX% outside of defense to foreclosure. Assignee liability.
APR of XX.XX% outside of 0.125% tolerance. (Final/09/XX/2019) 0.125% tolerance.
625488787 XXX XXX XXX 31492164 compliance 2 TRID Final Closing Disclosure Finance Charge TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Final Closing Disclosure provided on 09/XX/2019 disclosed an inaccurate Finance TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2019 9/XX/2020 TX Purchase Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
provided on 09/XX/2019 disclosed an inaccurate Finance Charge on page 5 that Charge on page 5 that does not match the actual Finance Charge for the loan. The defense to foreclosure. Assignee liability.
does not match the actual Finance Charge for the loan. The disclosed Finance disclosed Finance Charge in the amount of $XXX is under disclosed by $XXX
Charge in the amount of $XXX is under disclosed by $XXX compared to the compared to the calculated Finance Charge of $XXX which exceeds the $XXX
calculated Finance Charge of $XXX which exceeds the $XXX threshold (fee amounts threshold (fee amounts included in Finance Charge calculation are based on
included in Finance Charge calculation are based on Closing Disclosure dated Closing Disclosure dated 09/XX/2019).
09/XX/2019). (Final/09/XX/2019)
625488787 XXX XXX XXX 31492165 compliance 2 TRID Final Closing Disclosure Principal and Interest TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided The interest rate on the Note does not match the interest rate on Final CD which TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2019 9/XX/2020 TX Purchase Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
on 09/XX/2019 disclosed a Principal and Interest Payment that does not match the increases the P&I and DTI. defense to foreclosure. Assignee liability.
actual payment for the loan. (Final/09/XX/2019)
625488787 XXX XXX XXX 31492166 compliance 2 TRID Final Closing Disclosure Projected P&I Min Payment Fixed Rate Subsequent TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure P&I ($XXX) from Note document not matched with Final CD($XXX) TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2019 9/XX/2020 TX Purchase Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
Payments provided on 09/XX/2019 disclosed a periodic principal and interest payment for The interest rate on the Note does not match the interest rate on Final CD which defense to foreclosure. Assignee liability.
payment stream 2 that does not match the actual payment for the loan. increases the P&I and DTI.
(ProjSeq:2/2545236)
625488787 XXX XXX XXX 31492167 compliance 2 TRID Final Closing Disclosure Projected P&I Payment Min Payment Fixed Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure P&I ($XXX) from Note document not matched with Final CD($XXX) TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2019 9/XX/2020 TX Purchase Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
Initial Payment provided on 09/XX/2019 disclosed a periodic principal and interest payment for defense to foreclosure. Assignee liability.
payment stream 1 that does not match the actual payment for the loan.
(ProjSeq:1/2545235)
625488787 XXX XXX XXX 31492168 compliance 2 TRID Final Closing Disclosure Total Of Payments TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Loan Calculations: Final Closing Disclosure provided on 09/XX/2019 disclosed an TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2019 9/XX/2020 TX Purchase Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
provided on 09/XX/2019 disclosed an inaccurate Total of Payments on page 5 that inaccurate Total of Payments on page 5 that does not match the actual total of defense to foreclosure. Assignee liability.
does not match the actual total of payments for the loan (fee amounts included payments for the loan (fee amounts included in TOP calculation are based on
in TOP calculation are based on Closing Disclosure dated 09/XX/2019). The Closing Disclosure dated 09/XX/2019). The disclosed Total of Payments in the
disclosed Total of Payments in the amount of $XXX is under disclosed by $XXX amount of $XXX is under disclosed by $XXX compared to the calculated total of
compared to the calculated total of payments of $XXX which exceeds the $XXX payments of $XXX which exceeds the $XXX threshold.
threshold. (Final/09/XX/2019)
625488787 XXX XXX XXX 31492169 compliance 2 TRID Initial Closing Disclosure Timing without Waiver TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Closing Disclosure not provided to Borrower(s) at least three (3) business days TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 9/XX/2019 9/XX/2020 TX Purchase Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
at least three (3) business days prior to closing. (Initial/09/XX/2019) prior to closing. liability.
625489599 XXX XXX XXX 31520674 compliance 2 RESPA - Initial Escrow Account Statement Missing RESPA: Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2021 IL Purchase Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
within the statute or implementing regulation, Regulation X, for these type of
violations.
625489708 XXX XXX XXX 31470113 credit 3 Missing Document: Fraud Report not provided 12/XX/2019 FL Refinance - Cash-out - Other Primary No C C C C 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
625488158 XXX XXX XXX 31469410 compliance 1 Self Employed Financial Strength Qualified Mortgage (Dodd-Frank 2014): Financial strength of self-employed Most recent year income reported on 2018 Schedule C is more than 20% less than 1/XX/2020 FL Refinance - Rate/Term Primary No A A A A 8/XX/2024 9/XX/2024 Yes Temporary SHQM (GSE/Agency Eligible) 2024/XX/05: Appeal. The declining income is acknowledged; however, the income 2024/XX/05: Exception cleared.
business reflects annual earnings that significantly decline over the analysis 2017 Schedule C income. used was calculated from the lowest year's income. Borrower is retired with SSI
period. (XXX XXX/Schedule C) $XXX and VA pension $XXX and reports schedule C income from earnings as a XXX
$XXX. Earnings are approved at $XXX or $XXX as shown on Sched C (for the lower
year, prior year wass $XXX). This income is extremenly reasonable given
retirement status and could easily increase with hours. Income is also supported
by one month bank stmt showing $XXX deposits. Documentation also includes
Transcripts and signed Tax Preparer letter for support. Income is reasonably
calculated and adequately documented.
625488158 XXX XXX XXX 31469411 compliance 1 Sole Proprietorship Income Documentation Test Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not 1040s not signed and dated. 1/XX/2020 FL Refinance - Rate/Term Primary No A A A A 8/XX/2024 9/XX/2024 Yes Temporary SHQM (GSE/Agency Eligible) 2024/XX/05: Appeal. Income is adequately documented. Transcripts are present 2024/XX/05: Exception cleared.
sufficient (Sole Proprietorship). (XXX XXX/Schedule C) which negates need for signed tax returns and Tax Preparer letter is present to
support Schedule C income from earnings as a waitress.
625488158 XXX XXX XXX 31469413 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor The Originator Loan Designation is Safe Harbor QM. However, the Due Diligence Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 1/XX/2020 FL Refinance - Rate/Term Primary No A A A A 8/XX/2024 9/XX/2024 Yes Temporary SHQM (GSE/Agency Eligible) 2024/XX/05: Appeal. Income is adequately documented. Transcripts are present 2024/XX/05: Exception cleared.
QM does not match Due Diligence Loan Designation of Non QM. Loan Designation is Non QM due to the following issue(s): Most recent year Designation to the TPR firm performing the loan level due diligence and to have which negates need for signed tax returns and Tax Preparer letter to support
income reported on 2018 Schedule C is more than 20% less than 2017 Schedule C the TPR firm confirm said designation. Schedule C income from earnings as a XXX. Total income approved at $XXX is
income; 1040s not signed and dated. further supported by bank stmt with $XXX monthly deposits.
625488158 XXX XXX XXX 31469414 compliance 1 QM DTI Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and Total Debt to Income Ratio exceeds 43% Although this issue is subject to a 3 year SOL for affirmative claims under 1/XX/2020 FL Refinance - Rate/Term Primary No A A A A 8/XX/2024 9/XX/2024 Yes Temporary SHQM (GSE/Agency Eligible) 2024/XX/05: Appeal. Income is adequately documented. Transcripts are present 2024/XX/05: Exception cleared.
the images do not provide evidence loan is eligible for purchase, guarantee or TILA, AMC does not adjust grading taking into account TILA SOL for exceptions which negates need for signed tax returns and Tax Preparer letter to support
insurance by the appropriate agency. under ATR, given the potential for enhanced damages when asserting an ability to Schedule C income from earnings as a XXX. Total income approved at $XXX is
repay defense in response to an action to collect a debt by recoupment or further supported by bank stmt with $XXX monthly deposits.
set-off.
625489424 XXX XXX XXX 31492587 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Verification appraisal was delivered to borrower was not provided. 2/XX/2019 MO Purchase Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
Consummation valuation to applicant three (3) business days prior to consummation.
(Type:Primary/02/XX/2019)
625489424 XXX XXX XXX 31492591 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no cure was TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 2/XX/2019 2/XX/2020 MO Purchase Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
- Abstract / Title Search. Fee Amount of $XXX exceeds tolerance of $XXX. provided to the borrower. liability.
Insufficient or no cure was provided to the borrower. (75178)
625489424 XXX XXX XXX 31492592 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no cure was TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 2/XX/2019 2/XX/2020 MO Purchase Primary No B B B B 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
- Examination Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or provided to the borrower. liability.
no cure was provided to the borrower. (7727)
625489652 XXX XXX XXX 31492197 credit 3 Missing Document: Hazard Insurance Policy not provided 7/XX/2021 WI Refinance - Cash-out - Other Primary No C C C C 8/XX/2024 Temporary SHQM (GSE/Agency Eligible)
625488206 XXX XXX XXX 31492745 compliance 2 TRID Final Closing Disclosure Amount Financed Test TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Final Closing Disclosure provided on 08/XX/2023 disclosed an Amount Financed TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2023 8/XX/2024 FL Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
provided on 08/XX/2023 disclosed an Amount Financed disclosed an inaccurate disclosed an inaccurate Amount Financed. The disclosed Amount Financed in the defense to foreclosure. Assignee liability.
Amount Financed. The disclosed Amount Financed in the amount of $XXX is over amount of $XXX is over disclosed by $XXX compared to the calculated Amount
disclosed by $XXX compared to the calculated Amount Financed of $XXX and the Financed of $XXX and the disclosed Finance Charge is not accurate within
disclosed Finance Charge is not accurate within applicable tolerances for Amount applicable tolerances for Amount Financed to be considered accurate (fee amounts
Financed to be considered accurate (fee amounts included in Amount Financed and included in Amount Financed and Finance Charge calculations are based on Closing
Finance Charge calculations are based on Closing Disclosure dated 08/XX/2023). Disclosure dated 08/XX/2023).
(Final/08/XX/2023)
625488206 XXX XXX XXX 31492746 compliance 2 TRID Final Closing Disclosure Finance Charge TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Final Closing Disclosure provided on 08/XX/2023 disclosed an inaccurate Finance TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2023 8/XX/2024 FL Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
provided on 08/XX/2023 disclosed an inaccurate Finance Charge on page 5 that Charge on page 5 that does not match the actual Finance Charge for the loan. The defense to foreclosure. Assignee liability.
does not match the actual Finance Charge for the loan. The disclosed Finance disclosed Finance Charge in the amount of $XXX is under disclosed by $XXX
Charge in the amount of $XXX is under disclosed by $XXX compared to the compared to the calculated Finance Charge of $XXX which exceeds the $XXX
calculated Finance Charge of $XXX which exceeds the $XXX threshold (fee amounts threshold (fee amounts included in Finance Charge calculation are based on
included in Finance Charge calculation are based on Closing Disclosure dated Closing Disclosure dated 08/XX/2023).
08/XX/2023). (Final/08/XX/2023)
625488206 XXX XXX XXX 31492751 credit 3 Missing Document: Verification of Identification not provided Verification of Identification is missing 8/XX/2023 FL Purchase Primary No C C C C 8/XX/2024 Safe Harbor QM (APOR)
625488962 XXX XXX XXX 31493683 credit 1 Guideline Issue:Insufficient asset documentation. Financial Institution: XXX // Account Type: Money Markets / Account Number: XXX, Two months bank accounts required for XXX accounts. File contains one month 12/XX/2023 FL Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes HUD Safe Harbor QM 2024/XX/06: Account is not needed for qualification. Exception is clear.
Financial Institution: XXX // Account Type: Checking / Account Number: XXX statement for each account.
625488962 XXX XXX XXX 31493849 credit 3 Mortgage Insurance Certificate and Mortgage Insurance Evidence are missing. Insurance Certificate and Mortgage Insurance Evidence are missing. 12/XX/2023 FL Purchase Primary No C C C C 8/XX/2024 HUD Safe Harbor QM
625488962 XXX XXX XXX 31493989 compliance 2 RESPA Disclosure - List of Homeownership Counseling Organizations Missing RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2023 FL Purchase Primary No B B B B 8/XX/2024 HUD Safe Harbor QM
Homeownership Counseling Organizations to borrower. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488962 XXX XXX XXX 31493992 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of HUD Safe Originator Loan Designation discrepancy due to missing 2 months bank statements Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 12/XX/2023 FL Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes HUD Safe Harbor QM 2024/XX/04: Appeal: The Final LP approval required a total of $XXX in verified 2024/XX/06: Account is not needed for qualification. Exception is clear.
Harbor QM does not match Due Diligence Loan Designation of ATR Risk. for XXX. Designation to the TPR firm performing the loan level due diligence and to have assets. The three XXX accounts totaled approximately $XXX so the XXX account was
the TPR firm confirm said designation. not required. The final LP is attached for review confirming only XXX of the XXX
listed was required to be documented.
2024/XX/04: LP
625488962 XXX XXX XXX 31493995 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 12/XX/2023 FL Purchase Primary No B B B B 8/XX/2024 HUD Safe Harbor QM
625488962 XXX XXX XXX 31506083 credit 2 Loan has been identified as FHA/VA/USDA 12/XX/2023 FL Purchase Primary No B B B B 8/XX/2024 HUD Safe Harbor QM
625488962 XXX XXX XXX 31506161 credit 3 Initial HUD Addendum 92900-A is missing. Disclosure: FHA - Initial HUD Addendum to the Loan Application 92900-A 12/XX/2023 FL Purchase Primary No C C C C 8/XX/2024 HUD Safe Harbor QM
(Government Documents)
625488962 XXX XXX XXX 31506230 compliance 1 Non Taxable Income Qualified Mortgage (Dodd-Frank 2014): Percentage of non-taxable income added Waterfall due to missing 2 months bank statements for XXX, causing the loan to 12/XX/2023 FL Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes HUD Safe Harbor QM 2024/XX/06: Please see XXX's response regarding assets under exception ID 2024/XX/06: Income has been updated. Exception is clear.
exceeds borrower tax rate. (XXX Retired/Pension) waterfall through the QM testing. 31493992 above
625488962 XXX XXX XXX 31506231 compliance 1 Overtime Bonus 2Yr Calc Qualified Mortgage (Dodd-Frank 2014): Use of Overtime/Bonus income for less than Waterfall due to missing 2 months bank statements for XXX, causing the loan to 12/XX/2023 FL Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes HUD Safe Harbor QM 2024/XX/06: Please see XXX's response regarding assets under exception ID 2024/XX/06: Income updated. Exception is clear.
two (2) years not justified or documented in writing. (XXX XXX/Overtime) waterfall through the QM testing. 31493992 above
625488962 XXX XXX XXX 31506232 compliance 1 QM Employment History - Current Employment Documentation lacks Date Info Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two Waterfall due to missing 2 months bank statements for XXX, causing the loan to 12/XX/2023 FL Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes HUD Safe Harbor QM 2024/XX/06: Account is not needed for qualification. Exception is clear.
years current employment. (XXX/14058209) waterfall through the QM testing.
625488962 XXX XXX XXX 31506234 compliance 1 HUD QM AU Finding Fail HUD Qualified Mortgage (Dodd-Frank 2014): Subject loan is not eligible to be Waterfall due to missing 2 months bank statements for XXX, causing the loan to 12/XX/2023 FL Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes HUD Safe Harbor QM 2024/XX/06: Please see XXX's response regarding assets under exception ID 2024/XX/06: Account is not needed for qualification. Exception is clear.
insured or guaranteed by FHA. waterfall through the QM testing. 31493992 above
625488962 XXX XXX XXX 31506236 compliance 1 Income/Asset Guideline Deficiency - ATR Impact Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to Waterfall due to missing 2 months bank statements for XXX, causing the loan to 12/XX/2023 FL Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes HUD Safe Harbor QM 2024/XX/06: Please see XXX's response regarding assets under exception ID 2024/XX/06: Account is not needed for qualification. Exception is clear.
income and/or asset doc requirements which could result in a risk to the waterfall through the QM testing. 31493992 above
borrower's ability to repay. (Exception is eligible to be regraded with
compensating factors.)
625488962 XXX XXX XXX 31506238 compliance 1 QM DTI Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and Waterfall due to missing 2 months bank statements for XXX, causing the loan to Although this issue is subject to a 3 year SOL for affirmative claims under 12/XX/2023 FL Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes HUD Safe Harbor QM 2024/XX/06: Please see XXX's response regarding assets under exception ID 2024/XX/06: Account is not needed for qualification. Exception is clear.
the images do not provide evidence loan is eligible for purchase, guarantee or waterfall through the QM testing. TILA, AMC does not adjust grading taking into account TILA SOL for exceptions 31493992 above
insurance by the appropriate agency. under ATR, given the potential for enhanced damages when asserting an ability to
repay defense in response to an action to collect a debt by recoupment or
set-off.
625488962 XXX XXX XXX 31506622 credit 1 Asset documentation requirements not met. File is missing 2 months consecutive bank statement for the XXX accounts. 12/XX/2023 FL Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes HUD Safe Harbor QM 2024/XX/06: Account is not needed for qualification. Exception is clear.
625488962 XXX XXX XXX 31506643 compliance 1 General Ability To Repay Provision Investor Guidelines Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Waterfall due to missing 2 months bank statements for XXX, causing the loan to 12/XX/2023 FL Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes HUD Safe Harbor QM 2024/XX/06: Please see XXX's response regarding assets under exception ID 2024/XX/06: Account is not needed for qualification. Exception is clear.
guideline components, the loan is at ATR risk. waterfall through the QM testing. 31493992 above
625489635 XXX XXX XXX 31470182 compliance 1 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Zero Percent Fee Tolerance exceeded Extension fee. Fee Amount of $XXX exceeds TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 10/XX/2023 10/XX/2024 NC Refinance - Cash-out - Other Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/03: Appeal – Lock expiration 10/XX/23 at 5pm per the LE, loan closed 2024/XX/04: SitusAMC received rebuttal, however we also require valid COC or
Extension Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no previously disclosed amount of $XXX. A valid COC, nor a cure tolerance were liability. 10/XX/23. The Lock Extension Fee of $XXX is allowable to retain the rate and can rate lock extension document to re-evaluate the exception. A valid Changed
cure was provided to the borrower. (7349) provided. be confirmed Circumstance or cure is required. Cure consists of Corrected CD, LOE to
on the CFPB web site. - XXX borrower, proof of mailing and copy of refund check.
2024/XX/04: Appeal - Please see TPO Mavent report run on 10/XX/23 capturing CIC 2024/XX/05: SitusAMC received LOS snips to verify the change.
for the added rate dependent cost to extend the borrower’s lock. Please also see
XXX Loan Manager registration information showing the lock extension on
10/XX/23. Borrower signed final CD on 10/XX/23. TRID does not require the use of
a specific form to document Change in Circumstance. The information provided
documents what fee changed, why it changed and when it changed. - XXX
625489490 XXX XXX XXX 31493765 compliance 1 ECOA Appraisal Disclosure - ECOA Timing ECOA - File does not evidence the consumer was provided with the right to File does not evidence the consumer was provided with the right to receive a 9/XX/2023 9/XX/2024 NY Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/09: SitusAMC received proof of application date.
receive a copy of the Appraisal Disclosure within 3 days of the loan application copy of the Appraisal Disclosure within 3 days of the loan application date.
date.
625489490 XXX XXX XXX 31493811 compliance 1 TRID Final Closing Disclosure Homeowners Insurance Included In Escrow Test TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing Disclosure provided on 09/XX/2023 incorrectly disclosed whether TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 9/XX/2023 9/XX/2024 NY Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/03: Please see IEADS. Property is a co-op and only Walls-In coverage of 2024/XX/05: Escrowed amount is correct.
provided on 09/XX/2023 incorrectly disclosed whether Homeowners Insurance is Homeowners Insurance is included in escrow. liability. XXX per month is escrowed. Final CD indicates YES in projected payments.
included in escrow. (Final/09/XX/2023)
625489490 XXX XXX XXX 31493812 compliance 1 TRID Final Closing Disclosure Property Taxes Included In Escrow TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing Disclosure provided on 09/XX/2023 incorrectly disclosed whether TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 9/XX/2023 9/XX/2024 NY Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/03: Please see IEADS uploaded on exception 31493811. Property is a co-op 2024/XX/05: Property taxes are included in HOA Dues as a CO-OP.
provided on 09/XX/2023 incorrectly disclosed whether property taxes are included property taxes are included in escrow. liability. and only Walls-In coverage of XXX per month is escrowed. Final CD indicates YES
in escrow. (Final/09/XX/2023) in projected payments.
625489490 XXX XXX XXX 31493813 compliance 1 TRID Interim Closing Disclosure Timing Test TILA-RESPA Integrated Disclosure – Corrected Closing Disclosure provided on or Corrected Closing Disclosure provided on or after 09/XX/2023 contains a change TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 9/XX/2023 9/XX/2024 NY Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/03: Please identify CD in question. CD v5 and v6 both issued on 9/XX 2024/XX/04: Upon further review removed unsigned blank CD document(s) 0429
after 09/XX/2023 contains a change in APR and was not received by borrower at in APR and was not received by borrower at least three business days prior to liability. have APR of XX.XX%. estimated to be provided on 09/XX/2024, from testing.
least three (3) business days prior to consummation consummation.
625489490 XXX XXX XXX 31493814 compliance 1 TRID Loan Estimate Timing TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the Initial application date is 4/XX/2023 and initial loan estimate is 6/XX/2023 TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 9/XX/2023 9/XX/2024 NY Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/03: Please see attached system screen shot showing LE Required Date of 2024/XX/05: The application in file indicates a signature date of 4/8, matching
mail to Borrower(s) within three (3) business days of application. liability. 6/XX/23. This is the date the system captures the six pieces of information for loan ID numbers and all six pieces of application information. Please provide
(Initial/06/XX/2023) a TRID application and triggers the LE requirement. initial LE, or provide documentation as to why the 4/8 application is not valid.
2024/XX/05: Appeal: Please see D0236, D0134-D0136 and D0138 conditional approval 2024/XX/09: SitusAMC received proof of application date.
letters with no purchase property address identified. D0277 is the first
conditional approval letter following the purchase property address being
submitted to XXX. D0239 is the original URLA taken on 4/XX/23 and does not
contain the property address. This date will not change throughout the shopping
and loan process. The date the purchase property is identified to Chase is
captured as the LE required date previously provided triggering the LE to be
provided.
625489353 XXX XXX XXX 31492944 compliance 2 ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy There is generally no Assignee Liability. 9/XX/2023 IN Purchase Primary Yes B B B B 8/XX/2024 Safe Harbor QM (APOR)
File) of the appraisal at least three (3) business days prior to closing, and
appraisal was not provided at or before closing. (Type:Primary/08/XX/2023)
625488494 XXX XXX XXX 31473798 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 11/XX/2023 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
625488494 XXX XXX XXX 31473801 compliance 1 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Creditor did not provide Affiliated Business Arrangement Disclosure to applicant RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2023 OH Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/09: Exception cleared.
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within three business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488494 XXX XXX XXX 31473802 compliance 1 RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling List of Homeownership Counseling Organizations not provided to applicant within RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2023 OH Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/09: Exception cleared.
Within 3 Business Days of Application Organizations not provided to applicant within three (3) business days of three business days of application. within the statute or implementing regulation, Regulation X, for these type of
application. violations.
625488494 XXX XXX XXX 31473803 compliance 2 Ohio Consumer Sales Practices Act (Acknowledgement of Receipt of Home Mortgage Ohio Consumer Sales Practices Act: Acknowledgement of Receipt of Home Mortgage Acknowledgement of Receipt of Home Mortgage Loan Information Document not The Consumer Sales Practices Act (CSPA) generally does not provide for assignee 11/XX/2023 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
Loan Information Document Not Retained by Lender) Loan Information Document not retained by lender. retained by lender. liability. The Act provides that no claim or defense may be asserted under the
Act by the Attorney General or any consumer against a purchaser or assignee of a
mortgage loan for value for any action under the statute unless: (a) the
violation was committed by the purchaser or assignee; or (b) the assignee or
purchaser is affiliated by common control with the seller of the loan at the
time the loan was purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant
injunctions, and levy monetary fines. Additionally, the CSPA provides borrowers
with a private right of action. Therefore, it is possible that any action
commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law
as part of the private right of action, a court could reform the loan terms
which could impact purchasers. Therefore, if the seller cannot be compelled to
repurchase the loan, the assignee could face exposure.
625488494 XXX XXX XXX 31473804 compliance 2 Ohio Consumer Sales Practices Act (Right Not To Close Disclosure Not Provided) Ohio Consumer Sales Practices Act: Borrower not provided Right Not To Close Right not to close disclosure not provided to borrower. "The Consumer Sales Practices Act (CSPA) generally does not provide for assignee 11/XX/2023 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
Disclosure. liability. The Act provides that no claim or defense may be asserted under the
Act by the Attorney General or any consumer against a purchaser or assignee of a
mortgage loan for value for any action under the statute unless: (a) the
violation was committed by the purchaser or assignee; or (b) the assignee or
purchaser is affiliated by common control with the seller of the loan at the
time the loan was purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant
injunctions, and levy monetary fines. Additionally, the CSPA provides borrowers
with a private right of action. Therefore, it is possible that any action
commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law
as part of the private right of action, a court could reform the loan terms
which could impact purchasers. Therefore, if the seller cannot be compelled to
repurchase the loan, the assignee could face exposure."
625488494 XXX XXX XXX 31473805 compliance 1 TRID Loan Estimate Timing TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the Loan Estimate is not signed and dated for 10/XX/2023. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 11/XX/2023 11/XX/2024 OH Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/03: Appeal – Please see attached system screen shots provide 2024/XX/05: Application in file contains all 6 pieces of required information
mail to Borrower(s) within three (3) business days of application. liability. verification of electronic delivery / receipt within three (3) business days of and loan ID number matching final CD, to issue an LE. The application is dated
(Initial/10/XX/2023) application. (Initial 10/XX/2023). – XXX 9/15. Please provide initial LE for testing of documentation.
2024/XX/05: Appeal – The estimated property value of XXX also the (6th piece of 2024/XX/09: SitusAMC received lender certification and screen prints confirming
info) was not received on this purchase transaction until the Lender received application date with receipt of 6 pieces of information supported by contract
the sales contract on 10/XX/23, see also D0136. - XXX and prior pre-approval information.
2024/XX/06: Appeal - Property address, section 4 not available on the 9/XX/23
application see document print date 9/XX/23. See the 9/XX/23 application with
actual issue / print date of 10/XX/23 application with property address, 6th
piece of information. The print date specified can be located on the lower
portion of the page in the middle. - XXX
625488494 XXX XXX XXX 31473824 compliance 1 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax Fee was last disclosed as $XXX on Loan Estimate but disclosed as TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 11/XX/2023 11/XX/2024 OH Purchase Primary No A A A A 8/XX/2024 9/XX/2024 Yes Safe Harbor QM (APOR) 2024/XX/03: Appeal – Please see attached screen shots provide verification of 2024/XX/04: SituAMC received snips for timeline of disclosure of fee however,
Transfer Tax. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no $XXX on Final Closing Disclosure. File does not contain a valid Change of liability. Change of Circumstance vie electronic delivery to borrower for required fees the reason for adding the $XXX fee was not provided as to what changed
cure was provided to the borrower. (8304) circumstance for this fee, nor evidence of cure in file. change to include the $XXX Transfer Tax Fee. – SO circumstance occurred (as defined under 1026.19(e)(4)(A)-(F) that resulted in an
increase in closing costs.
2024/XX/04: Appeal – Per loan data fees changed due to the change in loan
amount, points and sales price. Lender paid Transfer tax went down resulting in 2024/XX/05: Change took place on 11/8. Any VCC must have a reason for the
an increase in the narrower paid Transfer tax. The change in loan amount is a change. SitusAMC is unable to accept a statement of change without a supporting
valid reason to revise loan fees. - SO reason for the change in fees. A change in pricing, rate, loan amount, borrower
requested changes, any changes must include a reason for the change that the
2024/XX/05: Appeal – VCC date 11/XX/23 – Lender received e-mail from borrower lender did not know, or could not have known about at initial disclosure. Please
that Amber Keriko was to be removed from the title. See also the purchase provide VCC for changes in transaction, that include explanation of reason for
contract available in file D0312 as updated 11/XX/23. - SO change.
2024/XX/06: SitusAMC received VCC dated 11/XX/24 for adding fee due to removed
title only borrower from vesting.
625488494 XXX XXX XXX 31505937 compliance 2 ECOA Appraisal - Appraisal Provided Prior to Date Performed ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is Delivery of appraisal not provided to the borrower within 3 days prior to 11/XX/2023 OH Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
prior to the date when valuation was performed. Unable to determine compliance closing.
with appraisal timing requirements. (Type:Primary/10/XX/2023)
625489526 XXX XXX XXX 31492958 compliance 2 ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy Borrower waived right to receive a copy of the appraisal at least three (3) There is generally no Assignee Liability. 10/XX/2023 WI Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
File) of the appraisal at least three (3) business days prior to closing, and business days prior to closing, and appraisal was not provided at or before
appraisal was not provided at or before closing. (Type:Primary/09/XX/2023) closing. (Type:Primary/09/XX/2023)
625489526 XXX XXX XXX 31492961 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. FACTA Disclosure not provided. There is no Assignee Liability. 10/XX/2023 WI Purchase Primary No B B B B 8/XX/2024 Safe Harbor QM (APOR)
625489726 XXX XXX XXX 34420734 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The property is located in a FEMA disaster area. Provide a post-disaster 10/XX/2019 IL Refinance - Limited Cash-out GSE Primary No A A A A 7/XX/2025 1/XX/2025 Yes Safe Harbor QM 2025/XX/07: Client provided BPO extract showing current inspection dates and no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage. The inspection must include exterior damage reported.
Disaster Name: XXX photos, and the property must be re-inspected on or after XX/XX/XXXX declared
Disaster Declaration Date: XX/XX/XXXX end date.
625487935 XXX XXX XXX 34420809 credit 2 Income Docs Missing: Borrower: XXX W-2 (2019) W-2 (2019) is missing in the file. 8/XX/2020 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM 2025/XX/14: Lender elects to waive with compensating factors.
625487935 XXX XXX XXX 34420810 compliance 2 TRID Revised Loan Estimate Issue and Received Date > Closing Disclosure Issue TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on or after the TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 8/XX/2020 8/XX/2021 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM 2025/XX/04: Client elected to waive
and Received Date date the Closing Disclosure was provided. (The Revised Loan Estimate was liability.
received on or after the Closing Disclosure.) (Interim/08/XX/2020)
625487935 XXX XXX XXX 34420811 compliance 2 QM Employment History - Current and/or Previous Employment Documentation lacks Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two Missing Employment Dates to verify two years employment history for current 8/XX/2020 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM 2025/XX/04: Client elected to waive
Date Info years employment history for current and/or prior employment. (XXX/14686997) and/or prior employment.
625487935 XXX XXX XXX 34420812 compliance 2 QM Employment History - Current and/or Previous Employment Documentation lacks Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two Missing Employment Dates to verify two years employment history for current 8/XX/2020 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM 2025/XX/04: Client elected to waive
Date Info years employment history for current and/or prior employment. (XXX/14694296) and/or prior employment.
625487935 XXX XXX XXX 34420814 credit 2 Income documentation requirements not met. File is missing verification of 2 Years Employment history for both Borrowers. 8/XX/2020 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM 2025/XX/14: Lender elects to waive with compensating factors.
625488220 XXX XXX XXX 34420847 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement 9/XX/2021 MA Purchase Second Home Yes B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM (APOR) 2025/XX/14: Client elects to waive with compensating factors.
625488220 XXX XXX XXX 34420848 compliance 2 Massachusetts Mortgage Lender and Broker Regulation (Ability to Repay not Massachusetts Mortgage Lender and Broker Regulation: File does not contain 9/XX/2021 MA Purchase Second Home Yes B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM (APOR) 2025/XX/04: Client elected to waive
Verified) evidence that analysis of borrower’s ability to repay was performed based on
verified income, obligations, assets, and/or employment using PITI payment based
on fully indexed rate and fully amortizing payment, if applicable
625488220 XXX XXX XXX 34420849 compliance 2 TRID Final Closing Disclosure Amount Financed Test TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Finance Charge disclosed is $XXX. Calculated finance charge is $XXX. Variance of TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2021 9/XX/2022 MA Purchase Second Home Yes B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM (APOR) 2025/XX/04: Client elected to waive
provided on 08/XX/2021 disclosed an Amount Financed disclosed an inaccurate 126.00. defense to foreclosure. Assignee liability.
Amount Financed. The disclosed Amount Financed in the amount of $XXX is over
disclosed by $XXX compared to the calculated Amount Financed of $XXX and the
disclosed Finance Charge is not accurate within applicable tolerances for Amount
Financed to be considered accurate (fee amounts included in Amount Financed and
Finance Charge calculations are based on Closing Disclosure dated 10/XX/2021).
(Final/08/XX/2021)
625488220 XXX XXX XXX 34420850 compliance 2 TRID Final Closing Disclosure Finance Charge TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Finance Charge disclosed is $XXX. Calculated finance charge is $XXX. Variance of TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2021 9/XX/2022 MA Purchase Second Home Yes B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM (APOR) 2025/XX/04: Client elected to waive
provided on 08/XX/2021 disclosed an inaccurate Finance Charge on page 5 that 126.00. defense to foreclosure. Assignee liability.
does not match the actual Finance Charge for the loan. The disclosed Finance
Charge in the amount of $XXX is under disclosed by $XXX compared to the
calculated Finance Charge of $XXX which exceeds the $XXX threshold (fee amounts
included in Finance Charge calculation are based on Closing Disclosure dated
10/XX/2021). (Final/08/XX/2021)
625488220 XXX XXX XXX 34420852 credit 2 REO Documents are missing. Address: XXX, MA HOA Verification The file is missing the mortgage HOA documentation for this property. Please 9/XX/2021 MA Purchase Second Home Yes B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM (APOR) 2025/XX/14: Client elects to waive with compensating factors.
provide for review.
625488220 XXX XXX XXX 34420853 credit 2 REO Documents are missing. Address: XXX, VT HOA Verification The file is missing the mortgage HOA documentation for this property. Please 9/XX/2021 MA Purchase Second Home Yes B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM (APOR) 2025/XX/14: Client elects to waive with compensating factors.
provide for review.
625489219 XXX XXX XXX 34420867 compliance 2 TRID Final Closing Disclosure Finance Charge TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure "Loan Calculations (pg 5) - one of these occurred: 1) Finance Charge is blank; TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2021 10/XX/2022 MA Refinance - Rate/Term Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM (APOR) 2025/XX/04: Client elected to waive
provided on 10/XX/2021 disclosed an inaccurate Finance Charge on page 5 that 2) Primary residence refinance and Calculated Finance Charge exceeds disclosed defense to foreclosure. Assignee liability.
does not match the actual Finance Charge for the loan. The disclosed Finance Finance Charge by more than $XXX; 3) Primary residence purchase or occupancy =
Charge in the amount of $XXX is under disclosed by $XXX compared to the Second Home and Calculated Finance Charge exceeds disclosed Finance Charge by
calculated Finance Charge of $XXX which exceeds the $XXX threshold (fee amounts more than $XXX."
included in Finance Charge calculation are based on Closing Disclosure dated
10/XX/2021). (Final/10/XX/2021)
625489219 XXX XXX XXX 34420868 credit 2 Verification(s) of employment is not within 10 business days of the Note. Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: Verification(s) of employment is not within 10 business days of the Note. 10/XX/2021 MA Refinance - Rate/Term Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM (APOR) 2025/XX/14: Client elects to waive with compensating factors.
01/XX/2020
625489219 XXX XXX XXX 34420869 compliance 2 TRID Final Closing Disclosure Total Of Payments TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Final Closing Disclosure provided on 10/XX/2021 disclosed an inaccurate Total of TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2021 10/XX/2022 MA Refinance - Rate/Term Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM (APOR) 2025/XX/04: Client elected to waive
provided on 10/XX/2021 disclosed an inaccurate Total of Payments on page 5 that Payments on page 5 that does not match the actual total of payments for the loan defense to foreclosure. Assignee liability.
does not match the actual total of payments for the loan (fee amounts included (fee amounts included in TOP calculation are based on Closing Disclosure dated
in TOP calculation are based on Closing Disclosure dated 10/XX/2021). The 10/XX/2021). The disclosed Total of Payments in the amount of $XXX is under
disclosed Total of Payments in the amount of $XXX is under disclosed by $XXX disclosed by $XXX compared to the calculated total of payments of $XXX which
compared to the calculated total of payments of $XXX which exceeds the $XXX exceeds the $XXX threshold. (Final/10/XX/2021)
threshold. (Final/10/XX/2021)
625489026 XXX XXX XXX 34420912 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA Disaster area. A post-disaster 2/XX/2017 FL Refinance - Rate/Term Second Home No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/10: BPO extract provided with current inspection dates indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage to the subject property is required. damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625489026 XXX XXX XXX 34420914 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement 2/XX/2017 FL Refinance - Rate/Term Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/21: Client elects to waive with compensating factors.
625489026 XXX XXX XXX 34420915 credit 2 REO Documents are missing. Address: XXX, FL, Address: XXX, IL, Address: XXX, IL Insurance Verification, 2/XX/2017 FL Refinance - Rate/Term Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/21: Client elects to waive with compensating factors.
Statement, Tax Verification
Insurance Verification
Insurance Verification
625489026 XXX XXX XXX 34420916 compliance 1 Flood Insurance Escrow - Flood not Escrowed for Property in Flood Zone Loan originated post December 2015, the subject property is in a flood zone, 2/XX/2017 FL Refinance - Rate/Term Second Home No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/10: Property is a condo and the Home Owners Association holds the flood 2025/XX/18: Flood in a blanket policy
flood insurance is not escrowed. insurance policy therefore there is no escrow needed
625489026 XXX XXX XXX 34420917 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title Title - Abstract / Title Search Fee was last disclosed as $XXX on the Loan TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 2/XX/2017 2/XX/2018 FL Refinance - Rate/Term Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
- Abstract / Title Search. Fee Amount of $XXX exceeds tolerance of $XXX. Estimate but was disclosed as $XXX on the Final Closing Disclosure. No valid COC liability.
Insufficient or no cure was provided to the borrower. (75178) was provided for this change, nor evidence of cure.
625489026 XXX XXX XXX 34420918 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title Title - Endorsement Fee was last disclosed as $XXX on the Loan Estimate but was TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 2/XX/2017 2/XX/2018 FL Refinance - Rate/Term Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
- Endorsement Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or disclosed as $XXX on the Final Closing Disclosure. No valid COC was provided for liability.
no cure was provided to the borrower. (7564) this change, nor evidence of cure.
625489026 XXX XXX XXX 34420919 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Tax Service Fee (Life Of Loan) was last disclosed as $XXX on the Loan Estimate TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 2/XX/2017 2/XX/2018 FL Refinance - Rate/Term Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Service Fee (Life Of Loan). Fee Amount of $XXX exceeds tolerance of $XXX. but was disclosed as $XXX on the Final Closing Disclosure. No valid COC was liability.
Insufficient or no cure was provided to the borrower. (7580) provided for this change, nor evidence of cure.
625488522 XXX XXX XXX 34420946 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX 10/XX/2019 IL Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/07: Client provided BPO extract showing current inspection dates and no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX damage reported.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488522 XXX XXX XXX 34420947 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each 10/XX/2019 IL Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Consummation valuation to applicant three (3) business days prior to consummation.
(Type:Primary/09/XX/2019)
625488522 XXX XXX XXX 34420948 compliance 2 TILA NMLSR - Originator Company Not Licensed at time of Application Truth in Lending Act (NMLSR Dodd- Frank 2014): Loan Originator Organization not "Assignee Liability: Civil actions that may be brought against a creditor may be 10/XX/2019 10/XX/2022 IL Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
NMLS licensed or registered at time of application. maintained against any assignee only if the violation is apparent on the face of
the disclosure or other documents assigned, except where the assignment was
voluntary. This civil liability may include $XXX in the case of an individual
transaction, or the lesser of $XXX or 1% of the creditor's net worth in the case
of a class action (effective 1/XX/14, this amount increases to the lesser of
$XXX or 1%), as well as actual damages, court costs, and attorneys' fees. For an
anti-steering violation, the creditor may also be liable in an amount equal to
the sum of all finance charges and fees paid by the consumer, unless the
creditor demonstrates the failure to comply is not material. Notwithstanding any
other provision of law, when a creditor, assignee, or other holder or anyone
acting on behalf of the creditor, assignee, or holder, initiates a judicial or
nonjudicial foreclosure of the residential mortgage loan, or any other action to
collect the debt in connection with such loan, a consumer may assert a violation
as a matter of defense by recoupment or set off without regard for the time
limit on a private action for damages.
Effective 1/XX/2014 in addition to the aforementioned, the individual Loan
Originator could be liable for statutory damages. The maximum liability is the
greater of actual damages or 3 times the loan originator's compensation or gain,
plus the cost to the consumer of the action. The Dodd-Frank Act extended the
statute of limitations on TILA violations to 3 years from the date of the
violation."
625488522 XXX XXX XXX 34420952 compliance 2 TRID Final Closing Disclosure AIR Table Index TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing Adjustable Interest Rate Table: Final Closing Disclosure provided on 10/XX/2019 TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 10/XX/2019 10/XX/2020 IL Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Disclosure provided on 10/XX/2019 did not disclose an accurate Index as did not disclose an accurate Index as reflected on the Note. liability.
reflected on the Note. (Final/10/XX/2019)
625488362 XXX XXX XXX 34420971 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA Disaster area. A post-disaster 11/XX/2019 IL Refinance - Rate/Term Primary No A A A A 7/XX/2025 1/XX/2025 Yes Safe Harbor QM 2025/XX/07: Client provided BPO extract showing current inspection dates and no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage to the subject property is required. damage reported.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488362 XXX XXX XXX 34420974 compliance 2 TRID Final Closing Disclosure Other Includes Insurance Costs TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 11/XX/2019 11/XX/2020 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM 2025/XX/04: Client elected to waive
provided on 11/XX/2019 disclosed whether Homeowners insurance is included in liability.
escrow in incorrect section. Creditor disclosed insurance to consumer in “Other”
section where regulation requires disclosure under “Homeowner’s Insurance”
section of Projected Payments table. Disclosure requirement met, non-material
exception for incorrect format/placement. (Final/11/XX/2019)
625488362 XXX XXX XXX 34420975 compliance 2 TRID Initial Loan Estimate Timing Electronically Provided TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) Initial Loan Estimate dated 09/XX/2019 was electronically provided prior to TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 11/XX/2019 11/XX/2020 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM 2025/XX/04: Client elected to waive
within three (3) business days of application. Initial Loan Estimate dated borrower's consent to receive electronic disclosures. liability.
09/XX/2019 was electronically provided without or prior to borrower's consent to
receive electronic disclosures. Failure to comply with the provisions of the
E-Sign Act and failure to provide good faith estimate of fees timely may result
in additional fee tolerance violations. (Initial/09/XX/2019)
625488362 XXX XXX XXX 34420976 compliance 2 QM Employment History - Current and/or Previous Employment Documentation lacks Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two VOE for the previous employment is missing 11/XX/2019 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM 2025/XX/04: Client elected to waive
Date Info years employment history for current and/or prior employment. (XXX/14555803)
625488761 XXX XXX XXX 34421017 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The property is located in a FEMA disaster area. Provide a post-disaster 12/XX/2019 IL Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Safe Harbor QM 2025/XX/10: BPO extract provided with current inspection dates indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage. The inspection must include exterior damage.
Disaster Name: XXX photos and the property must be re-inspected on or after XX/XX/XXXX declared end
Disaster Declaration Date: XX/XX/XXXX date.
625488761 XXX XXX XXX 34421018 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Verification appraisal was delivered to borrower was not provided. 12/XX/2019 IL Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM 2025/XX/04: Client elected to waive
Consummation valuation to applicant three (3) business days prior to consummation.
(Type:Primary/11/XX/2019)
625489456 XXX XXX XXX 34421033 compliance 1 (Missing Doc) Incomplete loan images/file The file is missing a copy of the 1007 Rent Comparison Schedule. 12/XX/2020 IL Refinance - Rate/Term Investment No A A A A 7/XX/2025 1/XX/2025 Yes 2024/XX/26: Refute - Documents loaded to Box in Folder: "Exception Support: 2025/XX/06: Additional documents provided.
Incomplete Loan Images or File"
625489456 XXX XXX XXX 34421034 credit 2 Missing Document: 1007 Rent Comparison Schedule not provided File is missing a copy of the 1007 Rent Comparison Schedule. 12/XX/2020 IL Refinance - Rate/Term Investment No B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/19: Client elects to waive with compensating factor.
625489651 XXX XXX XXX 34421035 compliance 1 (Missing Doc) Incomplete loan images/file The file is missing one or more of the core documents required for a review. 12/XX/2020 IL Refinance - Rate/Term Investment No A A A A 7/XX/2025 1/XX/2025 Yes 2024/XX/26: Refute - Documents loaded to Box in Folder: "Exception Support: 2025/XX/05: Sufficient documents have been provided for initial review.
Please provide a Note, Security Instrument, initial 1003, final 1003, an AUS, Incomplete Loan Images or File"
Approval or 1008, income verification, asset verification, an origination credit
report, final Title, and all issued LE's and CD's or TIL's, GFE's and HUD1's.
625489651 XXX XXX XXX 34421036 credit 2 REO Documents are missing. Address: XXX, IL, Address: XXX, IL, Address: XXX, IL Statement, Tax Verification 12/XX/2020 IL Refinance - Rate/Term Investment No B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/20: Statement, Tax Verification Statement, Tax Verification Statement,
Statement, Tax Verification Tax Verification
Statement, Tax Verification
625489651 XXX XXX XXX 34421037 property 1 Appraiser's license or certification was not active at the time of the Valuation Type: Appraisal / Valuation Report Date: 04/XX/2020 12/XX/2020 IL Refinance - Rate/Term Investment No A A A A 7/XX/2025 1/XX/2025 Yes 2025/XX/10: fraudguard shows appraiser license active/not expired at time of 2025/XX/16: Provided appraisers license reflecting active at time of origination
appraisal. closing. Uploaded to sharepoint
625489651 XXX XXX XXX 34421038 credit 2 AUS Findings: Investor qualifying total debt ratio discrepancy. Calculated investor qualifying total debt ratio of 44.91682% exceeds AUS total Insufficient Qualifying Income has resulted in a DTI discrepancy of 44.91%, 12/XX/2020 IL Refinance - Rate/Term Investment No B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/20: Insufficient Qualifying Income has resulted in a DTI discrepancy of
debt ratio of 27.78000%. exceeding the maximum AUS approved DTI ratio of $XXX% 44.91%, exceeding the maximum AUS approved DTI ratio of $XXX%
625489651 XXX XXX XXX 34421039 credit 2 Income documentation requirements not met. Insufficient Qualifying Income has resulted in a DTI discrepancy of 44.91%, 12/XX/2020 IL Refinance - Rate/Term Investment No B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/20: Insufficient Qualifying Income has resulted in a DTI discrepancy of
exceeding the maximum AUS approved DTI ratio of $XXX% 44.91%, exceeding the maximum AUS approved DTI ratio of $XXX%
625488900 XXX XXX XXX 34421043 compliance 2 TRID Final Closing Disclosure Property Costs Year 1 Overdisclosed - October 2018 TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Amount of Estimated Property Costs over Year 1 of $XXX on Final Closing TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 3/XX/2021 3/XX/2022 MO Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Construction Permanent Property Costs over Year 1 of 10,029.48 on Final Closing Disclosure provided on Disclosure provided on 03/XX/2021 are over disclosed. liability.
03/XX/2021 are overdisclosed. (Final/03/XX/2021)
625488900 XXX XXX XXX 34421044 compliance 2 TRID Final Closing Disclosure Finance Charge TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Final Closing Disclosure provided on 03/XX/2021 disclosed an inaccurate Finance TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2021 3/XX/2022 MO Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 03/XX/2021 disclosed an inaccurate Finance Charge on page 5 that Charge on page 5 that does not match the actual Finance Charge for the loan. The defense to foreclosure. Assignee liability.
does not match the actual Finance Charge for the loan. The disclosed Finance disclosed Finance Charge in the amount of $XXX is under disclosed by $XXX
Charge in the amount of $XXX is under disclosed by $XXX compared to the compared to the calculated Finance Charge of $XXX which exceeds the $XXX
calculated Finance Charge of $XXX which exceeds the $XXX threshold (fee amounts threshold.
included in Finance Charge calculation are based on Closing Disclosure dated
04/XX/2021). (Final/03/XX/2021)
625488900 XXX XXX XXX 34421046 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final Closing Disclosure provided on 03/XX/2021 with an increasing payment TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 3/XX/2021 3/XX/2022 MO Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 03/XX/2021 with an increasing payment disclosed the due date of the last disclosed the due date of the last payment of interest only that does not match Assignee liability.
payment of interest only that does not match the actual last payment for the the actual last payment for the loan.
loan. (Final/03/XX/2021)
625488900 XXX XXX XXX 34421047 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The most recent valuation inspection (10/XX/2020) is dated prior to the most 3/XX/2021 MO Refinance - Rate/Term Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/10: BPO extract provided with current inspection dates indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX recent FEMA disaster (07/XX/2022). damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488900 XXX XXX XXX 34421048 compliance 2 TRID Final Closing Disclosure Total Of Payments TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2021 3/XX/2022 MO Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 03/XX/2021 disclosed an inaccurate Total of Payments on page 5 that provided on 03/XX/2021 disclosed an inaccurate Total of Payments on page 5 that defense to foreclosure. Assignee liability.
does not match the actual total of payments for the loan (fee amounts included does not match the actual total of payments for the loan (fee amounts included
in TOP calculation are based on Closing Disclosure dated 04/XX/2021). The in TOP calculation are based on Closing Disclosure dated 04/XX/2021). The
disclosed Total of Payments in the amount of $XXX is under disclosed by $XXX disclosed Total of Payments in the amount of $XXX is under disclosed by $XXX
compared to the calculated total of payments of $XXX which exceeds the $XXX compared to the calculated total of payments of $XXX which exceeds the $XXX
threshold. (Final/03/XX/2021) threshold.
625489648 XXX XXX XXX 34421114 compliance 1 QM Employment History - Current Job after Gap Qualified Mortgage (Dodd-Frank 2014): Current Job History post-Gap with LOE, Waterfall due to employment gap is more than 6 months 12/XX/2020 IN Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/02: Letter of explanaction in file, layoff due to covid and searching 2025/XX/10: Appendix Q requires time on current employment after a gap to be
lacking 6 months on current job. XXX/14556530) for work. greater than 6 months. Borrower had only been with their employer for two months
at the time of closing. Exception remains open.
2025/XX/17: Loan has been re designated at client request
625489648 XXX XXX XXX 34421115 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Waterfall due to employment gap is more than 6 months Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 12/XX/2020 IN Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/02: Letter of explanaction in file, layoff due to covid and searching 2025/XX/10: Appendix Q requires time on current employment after a gap to be
QM does not match Due Diligence Loan Designation of Non QM. Designation to the TPR firm performing the loan level due diligence and to have for work. greater than 6 months. Borrower had only been with their employer for two months
the TPR firm confirm said designation. at the time of closing. Exception remains open.
2025/XX/17: Loan has been re designated at client request
625489648 XXX XXX XXX 34421116 compliance 2 TRID Final Closing Disclosure AIR Table Index TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing Final Closing Disclosure provided on 12/XX/2020 did not disclose an accurate TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 12/XX/2020 12/XX/2021 IN Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Disclosure provided on 12/XX/2020 did not disclose an accurate Index as Index as reflected on the Note. liability.
reflected on the Note. (Final/12/XX/2020)
625489648 XXX XXX XXX 34421118 compliance 2 Check Restated Loan Designation Match - General Ability to Repay Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did Loan has been re designated at client request Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 12/XX/2020 IN Purchase Primary Yes B B A A 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
not match. However, the updated Loan Designation of Non QM matches the Due Designation to the TPR firm performing the loan level due diligence and to have
Diligence Loan Designation of Non QM. the TPR firm confirm said designation.
625489094 XXX XXX XXX 34421128 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX 1/XX/2021 IL Refinance - Rate/Term Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/10: BPO extract provided with current inspection dates indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625489094 XXX XXX XXX 34421129 compliance 1 Commission Tax Documentation Qualified Mortgage (Dodd-Frank 2014): Commission income missing two years Commission income missing two years consecutive signed tax returns or tax 1/XX/2021 IL Refinance - Rate/Term Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/07: Appendix Q ended December of 2020 so tax returns were no longer 2025/XX/17: Loan has been re designated at client request
consecutive signed tax returns or tax transcripts (XXX XXX/Commission) transcripts required to verify commission income.
625489094 XXX XXX XXX 34421130 compliance 1 QM Employment History Qualified Mortgage (Dodd-Frank 2014): Employment history requirement not met. Complete 2 year employment history was not entered and/or documented as per 1/XX/2021 IL Refinance - Rate/Term Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/07: Final 1003 uploaded showing 2 year history. W2 from 2018 and 2019 2025/XX/17: Loan has been re designated at client request
(XXX/14556570) requirement for XXX provide a detailed breakdown of the income.
625489094 XXX XXX XXX 34421132 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Due to Missing Complete 2 year employment history was not entered and/or Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 1/XX/2021 IL Refinance - Rate/Term Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/07: Final 1003 uploaded showing 2 year history. W2 from 2018 and 2019 2025/XX/17: Loan has been re designated at client request
QM does not match Due Diligence Loan Designation of Non QM. documented as per requirement Designation to the TPR firm performing the loan level due diligence and to have for XXX provide a detailed breakdown of the income.
the TPR firm confirm said designation.
625489094 XXX XXX XXX 34421133 compliance 2 TRID Initial Loan Estimate Timing Electronically Provided TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) Loan Estimate not delivered to Borrower(s) within three (3) business days of TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 1/XX/2021 1/XX/2022 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
within three (3) business days of application. Initial Loan Estimate dated application. Initial Loan Estimate dated 11/XX/2020 was electronically provided liability.
11/XX/2020 was electronically provided without or prior to borrower's consent to without or prior to borrower's consent to receive electronic disclosures.
receive electronic disclosures. Failure to comply with the provisions of the Failure to comply with the provisions of the E-Sign Act and failure to provide
E-Sign Act and failure to provide good faith estimate of fees timely may result good faith estimate of fees timely may result in additional fee tolerance
in additional fee tolerance violations. (Initial/11/XX/2020) violations
625489094 XXX XXX XXX 34421134 compliance 2 Check Restated Loan Designation Match - General Ability to Repay Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did Loan has been re designated at client request Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 1/XX/2021 IL Refinance - Rate/Term Primary No B B A A 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
not match. However, the updated Loan Designation of Non QM matches the Due Designation to the TPR firm performing the loan level due diligence and to have
Diligence Loan Designation of Non QM. the TPR firm confirm said designation.
625488543 XXX XXX XXX 34421137 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX 3/XX/2021 MO Construction-Permanent Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/10: BPO extract provided with current inspection dates indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488543 XXX XXX XXX 34421138 credit 2 Purchase contract date not provided. 3/XX/2021 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/18: Client elects to waive without compensating factors.
625488543 XXX XXX XXX 34421139 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Creditor did not provide a copy of each valuation to applicant three (3) 3/XX/2021 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Consummation valuation to applicant three (3) business days prior to consummation. business days prior to consummation.
(Type:Primary/03/XX/2021)
625488543 XXX XXX XXX 34421141 compliance 2 TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing Disclosure provided on 03/XX/2021 disclosed an Estimated Total TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2021 3/XX/2022 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 03/XX/2021 disclosed an Estimated Total Monthly Payment for payment Monthly Payment for payment stream 2 that does not match the actual total defense to foreclosure. Assignee liability.
stream 2 that does not match the actual total payment for the loan. payment for the loan.
(ProjSeq:2/2645829)
625488543 XXX XXX XXX 34421142 compliance 2 TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing Disclosure provided on 03/XX/2021 disclosed an Estimated Total TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2021 3/XX/2022 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 03/XX/2021 disclosed an Estimated Total Monthly Payment for payment Monthly Payment for payment stream 3 that does not match the actual total defense to foreclosure. Assignee liability.
stream 3 that does not match the actual total payment for the loan. payment for the loan
(ProjSeq:3/2645830)
625488543 XXX XXX XXX 34421143 compliance 2 TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing Disclosure provided on 03/XX/2021 disclosed an Estimated Total TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2021 3/XX/2022 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 03/XX/2021 disclosed an Estimated Total Monthly Payment for payment Monthly Payment for payment stream 4 that does not match the actual total defense to foreclosure. Assignee liability.
stream 4 that does not match the actual total payment for the loan. payment for the loan
(ProjSeq:4/2645831)
625488543 XXX XXX XXX 34421144 compliance 2 TRID Final Closing Disclosure Estimated Total Minimum Payment Construction TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing Disclosure provided on 03/XX/2021 disclosed an Estimated Total TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2021 3/XX/2022 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Permanent Test provided on 03/XX/2021 disclosed an Estimated Total Monthly Payment for payment Monthly Payment for payment stream 1 that does not match the actual total defense to foreclosure. Assignee liability.
stream 1 that does not match the actual total payment for the loan. payment for the loan.
(ProjSeq:1/2645828)
625488543 XXX XXX XXX 34421145 compliance 2 TRID Final Closing Disclosure Payment Adjusts Every Starting In TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final Closing Disclosure provided on 03/XX/2021 with an increasing payment TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 3/XX/2021 3/XX/2022 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 03/XX/2021 with an increasing payment disclosed the due date of the first disclosed the due date of the first adjustment that does not match the actual Assignee liability.
adjustment that does not match the actual due date for the loan. due date for the loan.
(Final/03/XX/2021)
625488543 XXX XXX XXX 34421146 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final Closing Disclosure provided on 03/XX/2021 with an increasing payment TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 3/XX/2021 3/XX/2022 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 03/XX/2021 with an increasing payment disclosed the due date of the last disclosed the due date of the last payment of interest only that does not match Assignee liability.
payment of interest only that does not match the actual last payment for the the actual last payment for the loan.
loan. (Final/03/XX/2021)
625488543 XXX XXX XXX 34421147 compliance 2 TRID Final Closing Disclosure Property Costs Year 1 Overdisclosed - October 2018 TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Amount of Estimated Property Costs over Year 1 of XXX on Final Closing TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 3/XX/2021 3/XX/2022 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Construction Permanent Property Costs over Year 1 of XXX on Final Closing Disclosure provided on Disclosure provided on 03/XX/2021 are overdisclosed. (Final/03/XX/2021) liability.
03/XX/2021 are overdisclosed. (Final/03/XX/2021)
625488543 XXX XXX XXX 34421148 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet is missing TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2021 3/XX/2022 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
CHARM Booklet, not provided to the borrower.
625488543 XXX XXX XXX 34421149 compliance 2 ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM Disclosure is missing TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2021 3/XX/2022 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
borrower.
625488958 XXX XXX XXX 34421187 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA disaster area. A post disaster 2/XX/2021 IL Refinance - Cash-out - Other Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/10: BPO extract provided with current inspection dates indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage to the subject property is required damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488958 XXX XXX XXX 34421189 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Loan term is of 30 years, Note document shows 360 months which include 1 year of TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 2/XX/2021 2/XX/2022 IL Refinance - Cash-out - Other Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 02/XX/2021 with an increasing payment disclosed the due date of the last Interest only period due to Construction Permanent. Assignee liability.
payment of interest only that does not match the actual last payment for the
loan. (Final/02/XX/2021)
625488958 XXX XXX XXX 34421190 compliance 2 TRID Final Closing Disclosure Escrowed Property Costs Year 1 Overdisclosed - TILA-RESPA Integrated Disclosure - Loan Disclosures: Escrowed Property Costs Final Closing disclosure page 1 escrows as $XXX and page 2 lists escrows as $XXX TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 2/XX/2021 2/XX/2022 IL Refinance - Cash-out - Other Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
October 2018 Construction Permanent over Year 1 of XXX on Final Closing Disclosure provided on 02/XX/2021 are +$XXX total $ XXX, however page 4 total states $ XXX annually which comes liability.
overdisclosed. (Final/02/XX/2021) monthly $ 967.57.
625488958 XXX XXX XXX 34421195 compliance 2 TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing disclosure page 1 escrows as $XXX and page 2 lists escrows as $XXX TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 2/XX/2021 2/XX/2024 IL Refinance - Cash-out - Other Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 02/XX/2021 disclosed an Estimated Total Monthly Payment for payment +$XXX total $ XXX, however page 4 total states $ XXX annually which comes defense to foreclosure. Assignee liability.
stream 3 that does not match the actual total payment for the loan. monthly $ 967.57.
(ProjSeq:3/2647182)
625488958 XXX XXX XXX 34421196 compliance 2 TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing disclosure page 1 escrows as $XXX and page 2 lists escrows as $XXX TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 2/XX/2021 2/XX/2024 IL Refinance - Cash-out - Other Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 02/XX/2021 disclosed an Estimated Total Monthly Payment for payment +$XXX total $ XXX, however page 4 total states $ XXX annually which comes defense to foreclosure. Assignee liability.
stream 4 that does not match the actual total payment for the loan. monthly $ 967.57.
(ProjSeq:4/2647183)
625488958 XXX XXX XXX 34421197 compliance 2 TRID Final Closing Disclosure Projected P&I Min Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing Disclosure dated 02/XX/2021 Principal & Interest for Payment TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 2/XX/2021 2/XX/2024 IL Refinance - Cash-out - Other Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 02/XX/2021 disclosed a periodic principal and interest payment for Stream 3 is not matching due to Subject Transaction is 1 year Interest only due defense to foreclosure. Assignee liability.
payment stream 3 that does not match the actual payment for the loan. to Construction Permanent.
(ProjSeq:3/2647182)
625488958 XXX XXX XXX 34421198 compliance 2 TRID Final Closing Disclosure Total Of Payments TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Finance Charge disclosed is $XXX. Calculated finance charge is $XXX. Variance of TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 2/XX/2021 2/XX/2024 IL Refinance - Cash-out - Other Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 02/XX/2021 disclosed an inaccurate Total of Payments on page 5 that $XXX. defense to foreclosure. Assignee liability.
does not match the actual total of payments for the loan (fee amounts included
in TOP calculation are based on Closing Disclosure dated 02/XX/2021). The
disclosed Total of Payments in the amount of $XXX is under disclosed by $XXX
compared to the calculated total of payments of $XXX which exceeds the $XXX
threshold. (Final/02/XX/2021)
625489230 XXX XXX XXX 34421202 credit 1 Income Docs Missing: Borrower: XXX VVOE - Employment Only The Verification of current and previous employment dates, 10 days prior to 3/XX/2021 MO Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/12: VVOE provided
closing are missing from the loan file.
625489230 XXX XXX XXX 34421203 compliance 1 Check Loan Designation Match - ATR Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does The Verification of current and previous employment dates, 10 days prior to Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 3/XX/2021 MO Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/07: Using covid 19 guidelines getting paystub immediately preceding note 2025/XX/12: Changed the designation to non-QM
not match Due Diligence Loan Designation of ATR Fail. closing are missing from the loan file. Designation to the TPR firm performing the loan level due diligence and to have date was acceptable for verbal verification of employment. Would not need VVOE
the TPR firm confirm said designation. for previous employer
625489230 XXX XXX XXX 34421204 compliance 1 General Ability To Repay Provision Employment - W-2 Ability to Repay (Dodd-Frank 2014): Unable to verify current Wages/W-2 The Verification of current and previous employment dates, 10 days prior to Assignee Liability: Violations can result in regular TILA damages (actual 3/XX/2021 MO Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/07: Using covid 19 guidelines getting paystub immediately preceding note 2025/XX/12: Changed the designation to non-QM
employment status using reasonably reliable third-party records. (XXX XXX/Wages) closing are missing from the loan file. damages, statutory damages of up to $XXX costs, and attorney's fees) and date was acceptable for verbal verification of employment. Would not need VVOE
enhanced damages (an amount equal to the sum of all finance charges and fees for previous employer
paid by the consumer, unless the creditor demonstrates that the failure to
comply is not material). A private right of action may be brought before the end
of the three-year period beginning on the date of the occurrence of the
violation. However, when a creditor, assignee, or other holder or anyone acting
on their behalf initiates a judicial or non-judicial foreclosure, or any other
action to collect the debt, a consumer may assert a violation as a matter of
defense by recoupment or set-off without regard to a time limit. The amount of
recoupment or set-off shall equal the amount to which the consumer would be
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625489230 XXX XXX XXX 34421205 compliance 1 Income/Asset Guideline Deficiency - ATR Impact Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to The Verification of current and previous employment dates, 10 days prior to 3/XX/2021 MO Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/07: Using covid 19 guidelines getting paystub immediately preceding note 2025/XX/12: 1. Missing confirmation of the continuance of the bonus income will
income and/or asset doc requirements which could result in a risk to the closing are missing from the loan file. date was acceptable for verbal verification of employment. Would not need VVOE continue. 2. missing the gap of employment explanation from 9-2020 to 11-2020.
borrower's ability to repay. (Exception is eligible to be regraded with for previous employer
compensating factors.) 2025/XX/27: Exception cleared.
625489230 XXX XXX XXX 34421207 compliance 2 TRID Final Closing Disclosure Escrowed Property Costs Year 1 Overdisclosed - TILA-RESPA Integrated Disclosure - Loan Disclosures: Escrowed Property Costs Escrowed Property Costs Year 1 Over disclosed due to inclusion of mortgage TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 3/XX/2021 3/XX/2022 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
October 2018 Construction Permanent over Year 1 of XXX on Final Closing Disclosure provided on 03/XX/2021 are insurance. liability.
overdisclosed. (Final/03/XX/2021)
625489230 XXX XXX XXX 34421212 compliance 2 TRID Final Closing Disclosure Finance Charge TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Finance Charge disclosed is $XXX. Calculated finance charge is $XXX . Variance TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2021 3/XX/2022 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 03/XX/2021 disclosed an inaccurate Finance Charge on page 5 that of $XXX . Required Letter of Explanation, Proof of Delivery, Refund check for defense to foreclosure. Assignee liability.
does not match the actual Finance Charge for the loan. The disclosed Finance under disclosed amount, Corrected CD.
Charge in the amount of $XXX is under disclosed by $XXX compared to the
calculated Finance Charge of $XXX which exceeds the $XXX threshold (fee amounts
included in Finance Charge calculation are based on Closing Disclosure dated
03/XX/2021). (Final/03/XX/2021)
625489230 XXX XXX XXX 34421213 compliance 2 TRID Final Closing Disclosure Non Escrow Costs Year 1 Overdisclosed - October TILA-RESPA Integrated Disclosure - Loan Disclosures: Non Escrowed Property Costs Non Escrowed Property Costs over Year 1 of XXX on Final Closing Disclosure TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 3/XX/2021 3/XX/2022 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
2018 Construction Permanent over Year 1 of XXX on Final Closing Disclosure provided on 03/XX/2021 are provided on 03/XX/2021 are over disclosed. liability.
overdisclosed. (Final/03/XX/2021)
625489230 XXX XXX XXX 34421214 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final Closing Disclosure provided on 03/XX/2021 with an increasing payment TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 3/XX/2021 3/XX/2022 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 03/XX/2021 with an increasing payment disclosed the due date of the last disclosed the due date of the last payment of interest only that does not match Assignee liability.
payment of interest only that does not match the actual last payment for the the actual last payment for the loan
loan. (Final/03/XX/2021)
625489230 XXX XXX XXX 34421216 compliance 1 General Ability To Repay Provision Investor Guidelines Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more ATR failure due to Borrower current employment verification of employment is 3/XX/2021 MO Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/07: Using covid 19 guidelines getting paystub immediately preceding note 2025/XX/12: 1. Missing confirmation of the continuance of the bonus income will
guideline components, the loan is at ATR risk. missing. date was acceptable for verbal verification of employment. Would not need VVOE continue. 2. missing the gap of employment explanation from 9-2020 to 11-2020.
for previous employer
2025/XX/27: Exception cleared.
625489230 XXX XXX XXX 34421217 credit 1 Income documentation requirements not met. The Verification of current and previous employment dates, 10 days prior to 3/XX/2021 MO Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/18: Client elects to waive without compensating factors.
closing are missing from the loan file.
2025/XX/27: Reopened.
2025/XX/27: Exception cleared.
625489230 XXX XXX XXX 34421218 credit 1 Verification(s) of employment is not within 10 business days of the Note. Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: The Verification of current and previous employment dates, 10 days prior to 3/XX/2021 MO Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/12: VVOE provided
11/XX/2020 closing are missing from the loan file.
625489230 XXX XXX XXX 34421219 compliance 2 TRID Final Closing Disclosure Total Of Payments TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure The disclosed Total of Payments in the amount of $XXX is under disclosed by $XXX TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2021 3/XX/2022 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 03/XX/2021 disclosed an inaccurate Total of Payments on page 5 that compared to the calculated total of payments of $XXX which exceeds the $XXX defense to foreclosure. Assignee liability.
does not match the actual total of payments for the loan (fee amounts included threshold.
in TOP calculation are based on Closing Disclosure dated 03/XX/2021). The
disclosed Total of Payments in the amount of $XXX is under disclosed by $XXX
compared to the calculated total of payments of $XXX which exceeds the $XXX
threshold. (Final/03/XX/2021)
625489230 XXX XXX XXX 34421220 compliance 1 Check Loan Designation Match - ATR Risk Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does 1. Missing confirmation of the continuance of the bonus income will continue. 2. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 3/XX/2021 MO Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/21: Loan classified as General ATR. Borrower is in XXX and bonus income 2025/XX/27: Exception cleared.
not match Due Diligence Loan Designation of ATR Risk. missing the gap of employment explanation from 9-2020 to 11-2020. Designation to the TPR firm performing the loan level due diligence and to have is typical for the line of work. UW used combined W2 income from both prior
the TPR firm confirm said designation. employer and current employer and then averaged over 24 months. Portfolio policy
at that time required employment gap letters in excess of 60 days.
625489472 XXX XXX XXX 34421244 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA Disaster area. A post-disaster 6/XX/2021 MO Refinance - Rate/Term Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/10: BPO extract provided with current inspection dates indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage to the subject property is required. damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625489472 XXX XXX XXX 34421246 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each No evidence that borrower received a copy of appraisal 3 business days to 6/XX/2021 MO Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Consummation valuation to applicant three (3) business days prior to consummation. closing.
(Type:Primary/06/XX/2021)
625489472 XXX XXX XXX 34421248 compliance 2 TRID Final Closing Disclosure Escrowed Property Costs Year 1 Overdisclosed - TILA-RESPA Integrated Disclosure - Loan Disclosures: Escrowed Property Costs Escrowed Property Costs over Year 1 of XXX on Final Closing Disclosure provided TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 6/XX/2021 6/XX/2022 MO Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
October 2018 Construction Permanent over Year 1 of XXX on Final Closing Disclosure provided on 06/XX/2021 are on 06/XX/2021 are overdisclosed. liability.
overdisclosed. (Final/06/XX/2021)
625489472 XXX XXX XXX 34421253 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 6/XX/2021 6/XX/2024 MO Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
625489472 XXX XXX XXX 34421254 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final Closing Disclosure provided on 06/XX/2021 with an increasing payment TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 6/XX/2021 6/XX/2022 MO Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 06/XX/2021 with an increasing payment disclosed the due date of the last disclosed the due date of the last payment of interest only that does not match Assignee liability.
payment of interest only that does not match the actual last payment for the the actual last payment for the loan.
loan. (Final/06/XX/2021)
625489472 XXX XXX XXX 34421255 compliance 2 TRID Final Closing Disclosure Total Of Payments TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Disclosed Finance Charges are $XXX. Due Diligence Finance Charges are $XXX. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2021 6/XX/2024 MO Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 06/XX/2021 disclosed an inaccurate Total of Payments on page 5 that There is a variance of $XXX. defense to foreclosure. Assignee liability.
does not match the actual total of payments for the loan (fee amounts included
in TOP calculation are based on Closing Disclosure dated 06/XX/2021). The
disclosed Total of Payments in the amount of $XXX is under disclosed by $XXX
compared to the calculated total of payments of $XXX which exceeds the $XXX
threshold. (Final/06/XX/2021)
625487914 XXX XXX XXX 34421286 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX 5/XX/2021 IL Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/10: BPO extract provided with current inspection dates indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625487914 XXX XXX XXX 34421287 compliance 1 QM Employment History Qualified Mortgage (Dodd-Frank 2014): Employment history requirement not met. Missing VOEs for prior employment verifying two years employment. 5/XX/2021 IL Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: Correspondent TPO Portfolio ARM (p10cmt525). Closing Date 5/XX/2021. 2025/XX/17: Loan has been re designated at client request
(XXX/14557117) Prior VOEs are not required to document borrowers' previous employment.
625487914 XXX XXX XXX 34421288 compliance 1 QM Employment History - Current and/or Previous Employment Documentation lacks Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two Missing VOEs for prior employment verifying two years employment. 5/XX/2021 IL Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/17: Loan has been re designated at client request
Date Info years employment history for current and/or prior employment. (XXX/14557118)
625487914 XXX XXX XXX 34421290 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Missing VOEs for prior employment verifying two years employment. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 5/XX/2021 IL Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: Correspondent TPO Portfolio ARM (p10cmt525). Closing Date 5/XX/2021. 2025/XX/17: Loan has been re designated at client request
QM does not match Due Diligence Loan Designation of Non QM. Designation to the TPR firm performing the loan level due diligence and to have Prior VOEs are not required to document borrowers' previous employment.
the TPR firm confirm said designation.
625487914 XXX XXX XXX 34421291 compliance 2 Check Restated Loan Designation Match - General Ability to Repay Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did Loan has been re designated at client request Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 5/XX/2021 IL Purchase Primary No B B A A 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
not match. However, the updated Loan Designation of Non QM matches the Due Designation to the TPR firm performing the loan level due diligence and to have
Diligence Loan Designation of Non QM. the TPR firm confirm said designation.
625489294 XXX XXX XXX 34421295 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA Disaster area. Require a post-disaster 6/XX/2021 MO Refinance - Rate/Term Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/10: BPO extract provided with current inspection dates indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage to the subject property. damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625489294 XXX XXX XXX 34421297 compliance 2 TRID Final Closing Disclosure Escrowed Property Costs Year 1 Overdisclosed - TILA-RESPA Integrated Disclosure - Loan Disclosures: Escrowed Property Costs Mortgage insurance is not consider in initial escrow disclosure. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 6/XX/2021 6/XX/2022 MO Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
October 2018 Construction Permanent over Year 1 of XXX on Final Closing Disclosure provided on 06/XX/2021 are liability.
overdisclosed. (Final/06/XX/2021)
625489294 XXX XXX XXX 34421299 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Payment stream one includes only Interest payment. TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 6/XX/2021 6/XX/2022 MO Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 06/XX/2021 with an increasing payment disclosed the due date of the last Assignee liability.
payment of interest only that does not match the actual last payment for the
loan. (Final/06/XX/2021)
625489294 XXX XXX XXX 34421300 compliance 2 TRID Final Closing Disclosure Total Of Payments TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure The disclosed Total of Payments in the amount of $XXX is under disclosed by $XXX TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2021 6/XX/2024 MO Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 06/XX/2021 disclosed an inaccurate Total of Payments on page 5 that compared to the calculated total of payments of $XXX which exceeds the $XXX defense to foreclosure. Assignee liability.
does not match the actual total of payments for the loan (fee amounts included threshold.
in TOP calculation are based on Closing Disclosure dated 06/XX/2021). The
disclosed Total of Payments in the amount of $XXX is under disclosed by $XXX
compared to the calculated total of payments of $XXX which exceeds the $XXX
threshold. (Final/06/XX/2021)
625488659 XXX XXX XXX 34421313 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in FEMA disaster area. A post-disaster 1/XX/2022 IL Refinance - Rate/Term Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/10: BPO extract provided with current inspection dates indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage to the subject property is required. damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488659 XXX XXX XXX 34421315 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee was last disclosed as $XXX on LE but disclosed as $XXX on Final TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 1/XX/2022 1/XX/2023 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Appraisal Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no Closing Disclosure. File does not contain a valid COC for this fee, cure liability.
cure was provided to the borrower. (7506) provided at closing.
625488659 XXX XXX XXX 34421319 compliance 2 TRID Final Closing Disclosure Property Costs Year 1 Overdisclosed - October 2018 TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 1/XX/2022 1/XX/2023 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Construction Permanent Property Costs over Year 1 of 19,119.72 on Final Closing Disclosure provided on liability.
01/XX/2022 are overdisclosed. (Final/01/XX/2022)
625488659 XXX XXX XXX 34421320 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided CD disclosed 12 months of interest only payments. TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 1/XX/2022 1/XX/2023 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2024/XX/30: Per Exception Information , construction loan product with first 2024/XX/31: Final CD reflects page 1 Loan Terms - monthly principal & interest
on 01/XX/2022 with an increasing payment disclosed the due date of the last Assignee liability. year being interest only. Remaining yearts contain interest. Projected payments that "Includes only interest and no principal until mo. 12", however, the
payment of interest only that does not match the actual last payment for the indicates first year as interest only and remaining years with interest promissory note and const loan allonge reflect that the interest only period is
loan. (Final/01/XX/2022) included, Monthly Principal & Interest indicates only interest through month 12 for full 12 months and would be "until" mo 13". Corrected CD and LOE to
as does AP table. borrower.
2025/XX/16: As per CFPB guide. 2025/XX/17: SitusAMC received rebuttal on until period. However, Terms of the
(https://files.consumerfinance.gov/f/documents/cfpb_trid-combined-construction-l loan provide for a 12 month interest only period during construction phase which
oan-guide.pdf) "For a combined disclosure the timing of the end of the means the due date of the first principal and interest payment occurs on month
interest-only period is the due date of the last interest-only periodic payment 13 or year 2. Comment 37(b)(8)-2 provides: (ii) The dates required to be
the consumer will make before switching to principal and interest payments." Due disclosed by paragraphs (b)(6)(iii) shall be disclosed as the year in which the
date of 12th month and final interest only payment is the 12th month event occurs, counting from the due date of the initial periodic payment. Also
see page 23 of the combined construction loan guide
(https://files.consumerfinance.gov/f/documents/cfpb_trid-combined-construction-l
oan-guide.pdf) provided in the rebuttal. This page provides guidance and an
example for compliant disclosure for interest only period bullet. The example
provided is a 10 month interest only construction loan and on the second row of
the table the corresponding compliant disclosure is “Includes only interest and
no principal until mo. 11”. Note that the example does not list only interest
until month 10 on a 10 month construction loan. It discloses the 11th month, the
month the event (change to principal and interest) occurs as the period required
to be disclosed under 1026.37(b)(6)(iii) . Corrected CD and LOE to borrower.
2025/XX/04: Client elected to waive
625488266 XXX XXX XXX 34421372 compliance 2 QM Employment History - Current and/or Previous Employment Documentation lacks Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two Missing Employment Dates to verify two years employment history for current 7/XX/2021 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM (43-Q) 2025/XX/04: Client elected to waive
Date Info years employment history for current and/or prior employment. (XXX/14557195) and/or prior employment.
625488266 XXX XXX XXX 34421380 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA disaster area. A post disaster 7/XX/2021 IL Refinance - Rate/Term Primary No A A A A 7/XX/2025 1/XX/2025 Yes Safe Harbor QM (43-Q) 2025/XX/10: BPO extract provided with current inspection dates indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage to the subject property is required. damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488266 XXX XXX XXX 34421381 compliance 2 Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit 7/XX/2021 7/XX/2024 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM (43-Q) 2025/XX/04: Client elected to waive
Model Form for a refinance by a creditor that is not considered the original courts, the continuing risk that the borrower may have an extended right to
creditor. The H-9 form was used, the H-8 form should have been used. rescind (3 additional years) if a creditor uses the incorrect Model Form
remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625488916 XXX XXX XXX 34421411 credit 2 Purchase contract date not provided. Purchase contract date was not provided. 8/XX/2021 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/18: Client elects to waive with comp factors.
2025/XX/04: Client elected to waive
625488916 XXX XXX XXX 34421414 compliance 2 TRID Final Closing Disclosure AP Table Interest Only Payment TILA-RESPA Integrated Disclosure - Adjustable Payment Table: Final Closing Adjustable Payment Table: Final Closing Disclosure provided on 08/XX/2021 TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 8/XX/2021 8/XX/2022 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Disclosure provided on 08/XX/2021 incorrectly disclosed whether the loan incorrectly disclosed whether the loan contains Interest Only Payments. liability.
contains Interest Only Payments. (Final/08/XX/2021)
625488916 XXX XXX XXX 34421415 compliance 2 TRID Final Closing Disclosure AP Table Maximum Payment TILA-RESPA Integrated Disclosure - Adjustable Payment Table: Final Closing Adjustable Payment Table: Final Closing Disclosure provided on 08/XX/2021 TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 8/XX/2021 8/XX/2022 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Disclosure provided on 08/XX/2021 disclosed a Maximum Payment amount and period disclosed a Maximum Payment amount and period that does not match the actual liability.
that does not match the actual terms for the loan. (Final/08/XX/2021) terms for the loan.
625488916 XXX XXX XXX 34421416 compliance 2 TRID Final Closing Disclosure Escrowed Property Costs Year 1 Overdisclosed - TILA-RESPA Integrated Disclosure - Loan Disclosures: Escrowed Property Costs Loan Disclosures: Escrowed Property Costs over Year 1 of XXX on Final Closing TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 8/XX/2021 8/XX/2022 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
October 2018 Construction Permanent over Year 1 of XXX on Final Closing Disclosure provided on 08/XX/2021 are Disclosure provided on 08/XX/2021 are overdisclosed. liability.
overdisclosed. (Final/08/XX/2021)
625488916 XXX XXX XXX 34421418 compliance 2 TRID Final Closing Disclosure Estimated Total Maximum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Projected Payments: Final Closing Disclosure provided on 08/XX/2021 disclosed an TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2021 8/XX/2024 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 08/XX/2021 disclosed an Estimated Total Monthly Payment (Maximum) Estimated Total Monthly Payment (Maximum) for payment stream 3 that does not defense to foreclosure. Assignee liability.
for payment stream 3 that does not match the actual total payment for the loan. match the actual total payment for the loan.
(ProjSeq:3/2655341)
625488916 XXX XXX XXX 34421419 compliance 2 TRID Final Closing Disclosure Estimated Total Maximum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Projected Payments: Final Closing Disclosure provided on 08/XX/2021 disclosed an TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2021 8/XX/2024 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 08/XX/2021 disclosed an Estimated Total Monthly Payment (Maximum) Estimated Total Monthly Payment (Maximum) for payment stream 4 that does not defense to foreclosure. Assignee liability.
for payment stream 4 that does not match the actual total payment for the loan. match the actual total payment for the loan.
(ProjSeq:4/2655342)
625488916 XXX XXX XXX 34421420 compliance 2 TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Projected Payments: Final Closing Disclosure provided on 08/XX/2021 disclosed an TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2021 8/XX/2024 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 08/XX/2021 disclosed an Estimated Total Monthly Payment for payment Estimated Total Monthly Payment for payment stream 2 that does not match the defense to foreclosure. Assignee liability.
stream 2 that does not match the actual total payment for the loan. actual total payment for the loan.
(ProjSeq:2/2655340)
625488916 XXX XXX XXX 34421421 compliance 2 TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Projected Payments: Final Closing Disclosure provided on 08/XX/2021 disclosed an TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2021 8/XX/2024 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 08/XX/2021 disclosed an Estimated Total Monthly Payment for payment Estimated Total Monthly Payment for payment stream 3 that does not match the defense to foreclosure. Assignee liability.
stream 3 that does not match the actual total payment for the loan. actual total payment for the loan.
(ProjSeq:3/2655341)
625488916 XXX XXX XXX 34421422 compliance 2 TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Projected Payments: Final Closing Disclosure provided on 08/XX/2021 disclosed an TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2021 8/XX/2024 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 08/XX/2021 disclosed an Estimated Total Monthly Payment for payment Estimated Total Monthly Payment for payment stream 4 that does not match the defense to foreclosure. Assignee liability.
stream 4 that does not match the actual total payment for the loan. actual total payment for the loan.
(ProjSeq:4/2655342)
625488916 XXX XXX XXX 34421423 compliance 2 TRID Final Closing Disclosure Estimated Total Minimum Payment Construction TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Projected Payments: Final Closing Disclosure provided on 08/XX/2021 disclosed an TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2021 8/XX/2024 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Permanent Test provided on 08/XX/2021 disclosed an Estimated Total Monthly Payment for payment Estimated Total Monthly Payment for payment stream 1 that does not match the defense to foreclosure. Assignee liability.
stream 1 that does not match the actual total payment for the loan. actual total payment for the loan.
(ProjSeq:1/2655339)
625488916 XXX XXX XXX 34421424 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Loan Terms: Final Closing Disclosure provided on 08/XX/2021 with an increasing TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 8/XX/2021 8/XX/2022 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 08/XX/2021 with an increasing payment disclosed the due date of the last payment disclosed the due date of the last payment of interest only that does Assignee liability.
payment of interest only that does not match the actual last payment for the not match the actual last payment for the loan.
loan. (Final/08/XX/2021)
625488916 XXX XXX XXX 34421425 compliance 2 TRID Final Closing Disclosure Total Of Payments TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure The disclosed Total of Payments in the amount of $XXX is under disclosed by $XXX TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2021 8/XX/2024 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 08/XX/2021 disclosed an inaccurate Total of Payments on page 5 that compared to the calculated total of payments of $XXX which exceeds the $XXX defense to foreclosure. Assignee liability.
does not match the actual total of payments for the loan (fee amounts included threshold.
in TOP calculation are based on Closing Disclosure dated 09/XX/2021). The
disclosed Total of Payments in the amount of $XXX is under disclosed by $XXX
compared to the calculated total of payments of $XXX which exceeds the $XXX
threshold. (Final/08/XX/2021)
625488916 XXX XXX XXX 34421426 compliance 2 TRID Lender Credit Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure:Zero Percent Fee Tolerance exceeded for Lender Zero Percent Fee Tolerance exceeded for Lender Credits. Final Lender Credit of TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 8/XX/2021 8/XX/2022 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Credits. Final Lender Credit of -$XXX exceeds tolerance of -$XXX. Insufficient -$XXX exceeds tolerance of -$XXX. Insufficient or no cure was provided to the liability.
or no cure was provided to the borrower. (9300) borrower.
625488916 XXX XXX XXX 34421427 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan). Fee TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 8/XX/2021 8/XX/2022 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Service Fee (Life Of Loan). Fee Amount of $XXX exceeds tolerance of $XXX. Amount of $XXX exceeds tolerance of $XXX. Insufficient or no cure was provided liability.
Insufficient or no cure was provided to the borrower. (7580) to the borrower.
625488916 XXX XXX XXX 34421428 compliance 1 Check Loan Designation Match - ATR Risk Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does B1 Bonus income was not used in calculations as it is not two years worth. Due Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 8/XX/2021 IL Construction-Permanent Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/10: Paystub from previous employer in file showing bonus / incentive 2025/XX/22: Bonus income justification provided. Exception cleared.
not match Due Diligence Loan Designation of ATR Risk. diligence DTI calculations are 52.90% and lender DTI is 43.210%, causing a Loan Designation to the TPR firm performing the loan level due diligence and to have income. This proves bonus / incentive income has been received from previous
Designation discrepancy. the TPR firm confirm said designation. employment therefore covering required two-year history to use said income. this
was for General ATR designation on 1008. File meets General ATR requirements.
625488916 XXX XXX XXX 34421429 compliance 1 General Ability To Repay Provision Non QM DTI significantly exceeds Guidelines Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the B1 Bonus income was not used in calculations as it is not two years worth. Due 8/XX/2021 IL Construction-Permanent Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/10: Paystub from previous employer in file showing bonus / incentive 2025/XX/22: Bonus income justification provided. Exception cleared.
1026.43(c)(5) of 52.90% significantly exceeds the guideline maximum of 43.00%. diligence DTI calculations are 52.90% and lender DTI is 43.210%. income. This proves bonus / incentive income has been received from previous
(DTI Exception requires compelling compensating factors to consider regrading to employment therefore covering required two-year history to use said income. this
EV2-B.) was for General ATR designation on 1008. File meets General ATR requirements.
625488916 XXX XXX XXX 34421430 compliance 2 General Ability To Repay Provision Investor Qualification Method not Matching Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender 8/XX/2021 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
ATR does not match the ATR payment calculation methods under 1026.43(c)(5).
625488297 XXX XXX XXX 34421449 compliance 1 (Missing Doc) Incomplete loan images/file The file is missing one or more of the core documents required for a review. 7/XX/2021 MO Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Safe Harbor QM (43-Q) 2024/XX/26: Refute - Documents loaded to Box in Folder: "Exception Support: 2025/XX/04: Sufficient documentation has been provided for initial review.
Please provide a Note, Security Instrument, initial 1003, final 1003, an AUS, Incomplete Loan Images or File"
Approval or 1008, income verification, asset verification, an origination credit
report, final Title, and all issued LE's and CD's or TIL's, GFE's and HUD1's.
625488297 XXX XXX XXX 34421450 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX 7/XX/2021 MO Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Safe Harbor QM (43-Q) 2025/XX/17: BPO extract provided with current inspection dates showing no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488282 XXX XXX XXX 34421460 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX 12/XX/2021 IL Construction-Permanent Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/10: BPO extract provided with current inspection dates indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488282 XXX XXX XXX 34421461 credit 2 Purchase contract date not provided. 12/XX/2021 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/18: Client elects to waive with comp factors.
625488282 XXX XXX XXX 34421463 compliance 2 TRID Final Closing Disclosure Payment Adjusts Every Test TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Updated as per document TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 12/XX/2021 12/XX/2022 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 12/XX/2021 with an increasing payment did not disclose the frequency of Assignee liability.
adjustments. (Final/XX/20/2021)
625488282 XXX XXX XXX 34421464 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Updated as per document TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 12/XX/2021 12/XX/2022 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 12/XX/2021 with an increasing payment disclosed the due date of the last Assignee liability.
payment of interest only that does not match the actual last payment for the
loan. (Final/XX/20/2021)
625488282 XXX XXX XXX 34421466 compliance 2 TRID Final Closing Disclosure Property Costs Year 1 Overdisclosed - October 2018 TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 12/XX/2021 12/XX/2022 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Construction Permanent Property Costs over Year 1 of 39,648.12 on Final Closing Disclosure provided on liability.
12/XX/2021 are overdisclosed. (Final/XX/20/2021)
625488282 XXX XXX XXX 34421467 compliance 2 TRID Final Closing Disclosure AIR Table Index TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing Note reflects UST 1 year weekly. TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 12/XX/2021 12/XX/2022 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Disclosure provided on 12/XX/2021 did not disclose an accurate Index as liability.
reflected on the Note. (Final/XX/20/2021)
625488282 XXX XXX XXX 34421468 compliance 2 TRID Final Closing Disclosure Total Of Payments TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure TOP disclosed was $XXX. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 12/XX/2021 12/XX/2022 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 12/XX/2021 disclosed an inaccurate Total of Payments on page 5 that defense to foreclosure. Assignee liability.
does not match the actual total of payments for the loan (fee amounts included
in TOP calculation are based on Closing Disclosure dated 01/XX/2022). The
disclosed Total of Payments in the amount of $XXX is under disclosed by $XXX
compared to the calculated total of payments of $XXX which exceeds the $XXX
threshold. (Final/XX/20/2021)
625487964 XXX XXX XXX 34421489 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA disaster area. A post disaster 8/XX/2021 IL Refinance - Cash-out - Other Primary No A A A A 7/XX/2025 1/XX/2025 Yes Safe Harbor QM (APOR) 2025/XX/10: BPO extract provided with current inspection dates indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage to the subject property is required. damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488298 XXX XXX XXX 34421493 compliance 2 TRID Initial Loan Estimate Timing Electronically Provided TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) Evidence of earlier receipt not found. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 8/XX/2021 8/XX/2022 MN Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM (APOR) 2025/XX/04: Client elected to waive
within three (3) business days of application. Initial Loan Estimate dated liability.
07/XX/2021 was electronically provided without or prior to borrower's consent to
receive electronic disclosures. Failure to comply with the provisions of the
E-Sign Act and failure to provide good faith estimate of fees timely may result
in additional fee tolerance violations. (Initial/07/XX/2021)
625488992 XXX XXX XXX 34421495 property 1 Appraiser's license or certification was not active at the time of the Valuation Type: Appraisal / Valuation Report Date: 07/XX/2021 Appraiser's license or certification was not active at the time of the 8/XX/2021 IL Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/07: Property was inspected on 7/XX/2021 and Appraisal was completed on 2025/XX/12: Per ASC.gov, the issue date is 9-2023 and inspection date is 7-2021.
appraisal. appraisal. 7/XX/2021. Appraiser's License had an expiration date of 9/XX/2021. Missing the original issue date.
2025/XX/24: Cleared
625488992 XXX XXX XXX 34421496 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The latest dated appraisal inspection date is 07/XX/2021. There was a FEMA 8/XX/2021 IL Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/10: BPO extract provided with current inspection dates indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX disaster dated 07/XX/2024. Need a post-disaster inspection form indicating no damage.
Disaster Name: XXX damage to the subject property and must be dated after the disaster declaration.
Disaster Declaration Date: XX/XX/XXXX
625488992 XXX XXX XXX 34421497 credit 1 Insufficient Coverage: Hazard insurance coverage amount is insufficient. HOI coverage is insufficient by $XXX Provide updated policy reflecting minimum 8/XX/2021 IL Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: Borrower's previous employment (XXX, XXX and XXX) and co-borrower's 2025/XX/12: Condo insurance provided
coverage of $XXX OR Provide copy of insurer's replacement cost estimate previous employment (XXX) was documented with 2020 & 2019 W-2s. This is a condo
supporting current coverage amount. which includes building coverage in the condo master policy of $XXX/32 units =
$XXX in coverage.
625488992 XXX XXX XXX 34421498 compliance 1 Other Income - Not to be used for qualifying Qualified Mortgage (Dodd-Frank 2014): Income used to qualify borrower(s) not 8/XX/2021 IL Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/07: Note date is 9/XX/20. Findings state missing most recent signed and 2025/XX/12: Per Appendix Q guidelines, asset depletion income is not allowed.
permitted for use under Appendix Q. (XXX XXX/Asset Depletion) dated business tax returns or transcripts. Underwriter used a Global Cash Flow
for qualifying income. Portfolio guidelines allow and tax returns are not 2025/XX/17: Loan has been re designated at client request
required. Deadline to file 2019 tax returns was extended to 7/XX/2020, but that
was prior to the note date. 2020 tax returns are not in file
625488992 XXX XXX XXX 34421499 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each The file is missing proof of receipt of the updated appraisal with a report date 8/XX/2021 IL Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Consummation valuation to applicant three (3) business days prior to consummation. of 07/XX/2021. The appraisal is required to be received no less than three
(Type:Primary/07/XX/2021) business days prior to closing.
625488992 XXX XXX XXX 34421500 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each The file is missing proof of receipt of the updated appraisal with a report date 8/XX/2021 IL Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Consummation valuation to applicant three (3) business days prior to consummation. of 07/XX/2021. The appraisal is required to be received no less than three
(Client:17861/07/XX/2021) business days prior to closing.
625488992 XXX XXX XXX 34421502 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Certification Fee was last disclosed as $XXX on Loan Estimate but disclosed as TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 8/XX/2021 8/XX/2022 IL Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Certification Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or $XXX on Final Closing Disclosure dated 08/XX/2021. File does not contain a valid liability.
no cure was provided to the borrower. (7772) COC for this fee, nor evidence of cure in file.
625488992 XXX XXX XXX 34421503 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Loan Designation of Safe Harbor QM does not match Due Diligence Loan Designation Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 8/XX/2021 IL Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/07: Note date is 9/XX/20. Findings state missing most recent signed and 2025/XX/12: Per Appendix Q guidelines, asset depletion income is not allowed.
QM does not match Due Diligence Loan Designation of Non QM. of Non QM. Designation to the TPR firm performing the loan level due diligence and to have dated business tax returns or transcripts. Underwriter used a Global Cash Flow
the TPR firm confirm said designation. for qualifying income. Portfolio guidelines allow and tax returns are not 2025/XX/17: Loan has been re designated at client request
required. Deadline to file 2019 tax returns was extended to 7/XX/2020, but that
was prior to the note date. 2020 tax returns are not in file
625488992 XXX XXX XXX 34421504 compliance 2 Check Restated Loan Designation Match - General Ability to Repay Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did Loan has been re designated at client request Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 8/XX/2021 IL Purchase Primary No B B A A 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
not match. However, the updated Loan Designation of Non QM matches the Due Designation to the TPR firm performing the loan level due diligence and to have
Diligence Loan Designation of Non QM. the TPR firm confirm said designation.
625489305 XXX XXX XXX 34421514 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX 9/XX/2021 IL Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Safe Harbor QM (APOR) 2025/XX/10: BPO extract provided with current inspection dates indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488326 XXX XXX XXX 34421548 compliance 1 Check Loan Designation Match - ATR Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Waterfall due to missing signed and dated 1040 and third party verification for Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 2/XX/2022 MI Refinance - Rate/Term Second Home No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: 2020 & 2019 Tax Transcripts are in file and can be used in lieu of 2025/XX/21: Exception cleared.
not match Due Diligence Loan Designation of ATR Fail. borrower business XXX and co-borrower. Designation to the TPR firm performing the loan level due diligence and to have borrowers' signatures on Tax Returns. Third Party Verification of borrower's
the TPR firm confirm said designation. self-employment at XXX was verified using Verbal Verification of Employment
(document in file). No income used from XXX. Co-Borrower has a loss from XXX
self-employment, so Third Party Verification was not required.
625488326 XXX XXX XXX 34421549 compliance 1 General Ability To Repay Provision Employment - K-1 Less 25% Ability-to-Repay (Dodd-Frank 2014): Unable to verify current K-1 (Less than 25% Waterfall due to missing signed and dated 1040 and third party verification for Assignee Liability: Violations can result in regular TILA damages (actual 2/XX/2022 MI Refinance - Rate/Term Second Home No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: 2020 & 2019 Tax Transcripts are in file and can be used in lieu of 2025/XX/21: Exception cleared.
Ownership) status using reasonably reliable third-party records. (XXX borrower business XXX. damages, statutory damages of up to $XXX costs, and attorney's fees) and borrowers' signatures on Tax Returns. Third Party Verification of borrower's
XXX/Schedule K-1 less than 25 Percent) enhanced damages (an amount equal to the sum of all finance charges and fees self-employment at XXX was verified using Verbal Verification of Employment
paid by the consumer, unless the creditor demonstrates that the failure to (document in file). No income used from XXX. Co-Borrower has a loss from XXX
comply is not material). A private right of action may be brought before the end self-employment, so Third Party Verification was not required.
of the three-year period beginning on the date of the occurrence of the
violation. However, when a creditor, assignee, or other holder or anyone acting
on their behalf initiates a judicial or non-judicial foreclosure, or any other
action to collect the debt, a consumer may assert a violation as a matter of
defense by recoupment or set-off without regard to a time limit. The amount of
recoupment or set-off shall equal the amount to which the consumer would be
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625488326 XXX XXX XXX 34421550 compliance 1 General Ability To Repay Provision Income and Assets - K-1 Less 25% Ability to Repay (Dodd-Frank 2014): Unable to verify K-1 (Less than 25% Waterfall due to missing signed and dated 1040 and third party verification for Assignee Liability: Violations can result in regular TILA damages (actual 2/XX/2022 MI Refinance - Rate/Term Second Home No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: 2020 & 2019 Tax Transcripts are in file and can be used in lieu of 2025/XX/21: Exception cleared.
Ownership) income using reasonably reliable third-party records. (XXX borrower business XXX. damages, statutory damages of up to $XXX costs, and attorney's fees) and borrowers' signatures on Tax Returns. Third Party Verification of borrower's
XXX/Schedule K-1 less than 25 Percent) enhanced damages (an amount equal to the sum of all finance charges and fees self-employment at XXX was verified using Verbal Verification of Employment
paid by the consumer, unless the creditor demonstrates that the failure to (document in file). No income used from XXX. Co-Borrower has a loss from XXX
comply is not material). A private right of action may be brought before the end self-employment, so Third Party Verification was not required.
of the three-year period beginning on the date of the occurrence of the
violation. However, when a creditor, assignee, or other holder or anyone acting
on their behalf initiates a judicial or non-judicial foreclosure, or any other
action to collect the debt, a consumer may assert a violation as a matter of
defense by recoupment or set-off without regard to a time limit. The amount of
recoupment or set-off shall equal the amount to which the consumer would be
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625488326 XXX XXX XXX 34421551 compliance 1 General Ability To Repay Provision Income and Assets - Schedule C Ability to Repay (Dodd-Frank 2014): Unable to verify Sole Proprietorship income Waterfall due to missing third party verification. Assignee Liability: Violations can result in regular TILA damages (actual 2/XX/2022 MI Refinance - Rate/Term Second Home No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: 2020 & 2019 Tax Transcripts are in file and can be used in lieu of 2025/XX/21: Exception cleared. Two years signed and dated tax returns,
using reasonably reliable third-party records. (XXX XXX/Schedule C) damages, statutory damages of up to $XXX costs, and attorney's fees) and borrowers' signatures on Tax Returns. Third Party Verification of borrower's transcripts, thrid party verification, and YTD P&L Statement have been provided.
enhanced damages (an amount equal to the sum of all finance charges and fees self-employment at XXX was verified using Verbal Verification of Employment
paid by the consumer, unless the creditor demonstrates that the failure to (document in file). No income used from XXX. Co-Borrower has a loss from XXX
comply is not material). A private right of action may be brought before the end self-employment, so Third Party Verification was not required.
of the three-year period beginning on the date of the occurrence of the
violation. However, when a creditor, assignee, or other holder or anyone acting
on their behalf initiates a judicial or non-judicial foreclosure, or any other
action to collect the debt, a consumer may assert a violation as a matter of
defense by recoupment or set-off without regard to a time limit. The amount of
recoupment or set-off shall equal the amount to which the consumer would be
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625488326 XXX XXX XXX 34421552 compliance 1 Income/Asset Guideline Deficiency - ATR Impact Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to Waterfall due to missing signed and dated 1040 and third party verification for 2/XX/2022 MI Refinance - Rate/Term Second Home No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: 2020 & 2019 Tax Transcripts are in file and can be used in lieu of 2025/XX/21: Exception cleared.
income and/or asset doc requirements which could result in a risk to the borrower business XXX and co-borrower. borrowers' signatures on Tax Returns. Third Party Verification of borrower's
borrower's ability to repay. (Exception is eligible to be regraded with self-employment at XXX was verified using Verbal Verification of Employment
compensating factors.) (document in file). No income used from XXX. Co-Borrower has a loss from XXX
self-employment, so Third Party Verification was not required.
625488326 XXX XXX XXX 34421555 compliance 2 TRID Final Closing Disclosure AIR Table Index TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing Adjustable Interest Rate Table: Final Closing Disclosure provided on 02/XX/2022 TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 2/XX/2022 2/XX/2023 MI Refinance - Rate/Term Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Disclosure provided on 02/XX/2022 did not disclose an accurate Index as did not disclose an accurate Index as reflected on the Note. (Final/02/XX/2022) liability.
reflected on the Note. (Final/02/XX/2022)
625488326 XXX XXX XXX 34421557 compliance 2 TRID Final Closing Disclosure Property Costs Year 1 Overdisclosed - October 2018 TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Amount of Estimated Property Costs over Year 1 of XXX on Final Closing TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 2/XX/2022 2/XX/2023 MI Refinance - Rate/Term Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Construction Permanent Property Costs over Year 1 of XXX on Final Closing Disclosure provided on Disclosure provided on 02/XX/2022 are overdisclosed. (Final/02/XX/2022) liability.
02/XX/2022 are overdisclosed. (Final/02/XX/2022)
625488326 XXX XXX XXX 34421558 compliance 2 TRID Initial Loan Estimate Timing Electronically Provided TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) E-sign disclosure is provided on 01/XX/2022. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 2/XX/2022 2/XX/2023 MI Refinance - Rate/Term Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
within three (3) business days of application. Initial Loan Estimate dated liability.
12/XX/2021 was electronically provided without or prior to borrower's consent to
receive electronic disclosures. Failure to comply with the provisions of the
E-Sign Act and failure to provide good faith estimate of fees timely may result
in additional fee tolerance violations. (Initial/12/XX/2021)
625488326 XXX XXX XXX 34421559 compliance 1 General Ability To Repay Provision Investor Guidelines Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Waterfall due to missing signed and dated 1040 and third-party verification for 2/XX/2022 MI Refinance - Rate/Term Second Home No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: 2020 & 2019 Tax Transcripts are in file and can be used in lieu of 2025/XX/21: Exception cleared.
guideline components, the loan is at ATR risk. borrower business XXX and co-borrower. borrowers' signatures on Tax Returns. Third Party Verification of borrower's
self-employment at XXX was verified using Verbal Verification of Employment
(document in file). No income used from XXX. Co-Borrower has a loss from XXX
self-employment, so Third Party Verification was not required.
625488326 XXX XXX XXX 34421560 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final Closing Disclosure provided on 02/XX/2022 with an increasing payment TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 2/XX/2022 2/XX/2023 MI Refinance - Rate/Term Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 02/XX/2022 with an increasing payment disclosed the due date of the last disclosed the due date of the last payment of interest only that does not match Assignee liability.
payment of interest only that does not match the actual last payment for the the actual last payment for the loan. (Final/02/XX/2022)
loan. (Final/02/XX/2022)
625488326 XXX XXX XXX 34421561 credit 1 Income documentation requirements not met. Missing signed and date 1040 and third party verification for co-borrower and 2/XX/2022 MI Refinance - Rate/Term Second Home No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/18: Compensating Factors for waive and downgrade.
borrower business XXX.
2025/XX/21: Waived in error.
2025/XX/21: Exception cleared.
625488326 XXX XXX XXX 34421562 credit 1 Insufficient Coverage: Hazard insurance coverage amount is insufficient. Using the coverage listed on the insurance binder, the coverage shortage is $XXX 2/XX/2022 MI Refinance - Rate/Term Second Home No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: Original appraised value $XXX - $XXX site value =insurable value 2025/XX/21: The loan amount is $XXX - $XXX coverage = a $XXX shortfall.
$XXX. HOI policy in file has builders risk insurance of $XXX
2025/XX/21: Lender explanation/calculation provided. Acceptable.
625488849 XXX XXX XXX 34421606 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA disaster area. A post disaster 8/XX/2022 IL Refinance - Rate/Term Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/10: BPO extract provided with current inspection dates indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage to the subject property is required damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488849 XXX XXX XXX 34421607 compliance 2 TRID Final Closing Disclosure Will Have Escrow Account TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure Final Closing Disclosure provided on 08/XX/2022 incorrectly disclosed whether TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 8/XX/2022 8/XX/2023 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 08/XX/2022 incorrectly disclosed whether the loan will have an the loan will have an escrow account. liability.
escrow account. (Final/08/XX/2022)
625488849 XXX XXX XXX 34421608 compliance 2 TRID Final Closing Disclosure Will Not Have Escrow Account TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure Final Closing Disclosure provided on 08/XX/2022 incorrectly disclosed whether TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 8/XX/2022 8/XX/2023 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 08/XX/2022 incorrectly disclosed whether the loan will have an the loan will have an escrow account. liability.
escrow account. (Final/08/XX/2022)
625488849 XXX XXX XXX 34421609 compliance 2 TRID Lender Credit Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure:Zero Percent Fee Tolerance exceeded for Lender Lender Credits Fee was last disclosed as -$XXX on Loan Estimate but disclosed as TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 8/XX/2022 8/XX/2023 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Credits. Final Lender Credit of -$XXX exceeds tolerance of -$XXX. Insufficient $XXX on Final Closing Disclosure. File does not contain a valid Change of liability.
or no cure was provided to the borrower. (9300) circumstance for this fee, nor evidence of cure in file.
625488849 XXX XXX XXX 34421610 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Tax service Fee was last disclosed as $XXX on Loan Estimate but disclosed as TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 8/XX/2022 8/XX/2023 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Service Fee (Life Of Loan). Fee Amount of $XXX exceeds tolerance of $XXX. $XXX on Final Closing Disclosure. File does not contain a valid Change of liability.
Insufficient or no cure was provided to the borrower. (7580) circumstance for this fee, nor evidence of cure in file.
625488849 XXX XXX XXX 34421611 compliance 2 TRID Final Closing Disclosure Property Taxes Included In Escrow TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing disclosure Page1 indicates Flood insurance in escrow.. TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 8/XX/2022 8/XX/2023 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 08/XX/2022 incorrectly disclosed whether property taxes are included liability.
in escrow. (Final/08/XX/2022)
625488849 XXX XXX XXX 34421614 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final Closing Disclosure provided on 08/XX/2022 with an increasing payment TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 8/XX/2022 8/XX/2023 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/02: Construction loan product with first year being interest only. 2025/XX/02: SitusAMC received rebuttal that first year interest only. However,
on 08/XX/2022 with an increasing payment disclosed the due date of the last disclosed the due date of the last payment of interest only that does not match Assignee liability. Remaining yearts contain interest. Projected payments indicates first year as page 1 of final CD in Loan Terms - Monthly Principal & Interest states that
payment of interest only that does not match the actual last payment for the the actual last payment for the loan. interest only and remaining years with interest included, Monthly Principal & includes only interest and no principal "until" month 12. As this is 12 month
loan. (Final/08/XX/2022) Interest indicates only interest through month 12 as does AP table. interest only, the only interest would be included "until" month 13. 13th month
starts principal & interest payment. Corrected CD and LOE to borrower to cure.
2025/XX/16: As per CFPB guide.
(https://files.consumerfinance.gov/f/documents/cfpb_trid-combined-construction-l 2025/XX/17: SitusAMC received rebuttal on until period. However, Terms of the
oan-guide.pdf) "For a combined disclosure the timing of the end of the loan provide for a 12 month interest only period during construction phase which
interest-only period is the due date of the last interest-only periodic payment means the due date of the first principal and interest payment occurs on month
the consumer will make before switching to principal and interest payments." Due 13 or year 2. Comment 37(b)(8)-2 provides: (ii) The dates required to be
date of 12th and final interest only payment is the 12th month disclosed by paragraphs (b)(6)(iii) shall be disclosed as the year in which the
event occurs, counting from the due date of the initial periodic payment. Also
see page 23 of the combined construction loan guide
(https://files.consumerfinance.gov/f/documents/cfpb_trid-combined-construction-l
oan-guide.pdf) provided in the rebuttal. This page provides guidance and an
example for compliant disclosure for interest only period bullet. The example
provided is a 10 month interest only construction loan and on the second row of
the table the corresponding compliant disclosure is “Includes only interest and
no principal until mo. 11”. Note that the example does not list only interest
until month 10 on a 10 month construction loan. It discloses the 11th month, the
month the event (change to principal and interest) occurs as the period required
to be disclosed under 1026.37(b)(6)(iii) . Corrected CD and LOE to borrower.
2025/XX/04: Client elected to waive
625488849 XXX XXX XXX 34421615 compliance 1 TRID Final Closing Disclosure Total Of Payments TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Final Closing Disclosure provided on 08/XX/2022 disclosed an inaccurate Total of TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2022 8/XX/2025 IL Refinance - Rate/Term Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/02: Calculation is accurate. Amortization Calculator provided which 2025/XX/06: TOP accurate based on actual days interest on first payment
provided on 08/XX/2022 disclosed an inaccurate Total of Payments on page 5 that Payments on page 5 that does not match the actual total of payments for the defense to foreclosure. Assignee liability. shows $XXX in PPFC, $XXX Loan Costs,$XXX for MI. First year is interest only.
does not match the actual total of payments for the loan (fee amounts included loan. 3.008% index for 5.75% fully amortized rate. Difference provided seems to be
in TOP calculation are based on Closing Disclosure dated 08/XX/2022). The close to the difference in the first payment and second payment. First months
disclosed Total of Payments in the amount of $XXX is under disclosed by $XXX interest is not for the full month, but prorated from the day of disbursement on
compared to the calculated total of payments of $XXX which exceeds the $XXX a 360 day calculation. First payment is $XXX prorated.
threshold. (Final/08/XX/2022)
625488980 XXX XXX XXX 34421618 compliance 2 TRID Final Closing Disclosure AP Table Subsequent Changes Test TILA-RESPA Integrated Disclosure - Adjustable Payment Table: Final Closing Final Closing Disclosure provided on 09/XX/2022 disclosed a Subsequent Changes TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 9/XX/2022 9/XX/2023 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Disclosure provided on 09/XX/2022 disclosed a Subsequent Changes period that period that does not match the actual terms for the loan. liability.
does not match the actual terms for the loan. (Final/09/XX/2022)
625488980 XXX XXX XXX 34421619 compliance 2 TRID Final Closing Disclosure Escrowed Property Costs Year 1 Overdisclosed - TILA-RESPA Integrated Disclosure - Loan Disclosures: Escrowed Property Costs Escrowed Property Costs over Year 1 of XXX on Final Closing Disclosure provided TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 9/XX/2022 9/XX/2023 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
October 2018 Construction Permanent over Year 1 of XXX on Final Closing Disclosure provided on 09/XX/2022 are on 09/XX/2022 are over disclosed. liability.
overdisclosed. (Final/09/XX/2022)
625488980 XXX XXX XXX 34421621 compliance 2 TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing Disclosure provided on 09/XX/2022 disclosed an Estimated Total TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2022 9/XX/2023 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 09/XX/2022 disclosed an Estimated Total Monthly Payment for payment Monthly Payment for payment stream 3 that does not match the actual total defense to foreclosure. Assignee liability.
stream 3 that does not match the actual total payment for the loan. payment for the loan.
(ProjSeq:3/2654433)
625488980 XXX XXX XXX 34421622 compliance 2 TRID Final Closing Disclosure Mortgage Insurance Payment TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing Disclosure provided on 09/XX/2022 disclosed a mortgage insurance TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2022 9/XX/2023 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 09/XX/2022 disclosed a mortgage insurance payment for payment stream payment for payment stream 4 that does not match the actual payment for the defense to foreclosure. Assignee liability.
4 that does not match the actual payment for the loan. (ProjSeq:4/2654434) loan.
625488980 XXX XXX XXX 34421623 compliance 2 TRID Final Closing Disclosure Payment Adjusts Every Starting In TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final Closing Disclosure provided on 09/XX/2022 with an increasing payment TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 9/XX/2022 9/XX/2023 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 09/XX/2022 with an increasing payment disclosed the due date of the first disclosed the due date of the first adjustment that does not match the actual Assignee liability.
adjustment that does not match the actual due date for the loan. due date for the loan.
(Final/09/XX/2022)
625488980 XXX XXX XXX 34421624 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final Closing Disclosure provided on 09/XX/2022 with an increasing payment TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 9/XX/2022 9/XX/2023 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 09/XX/2022 with an increasing payment disclosed the due date of the last disclosed the due date of the last payment of interest only that does not match Assignee liability.
payment of interest only that does not match the actual last payment for the the actual last payment for the loan.
loan. (Final/09/XX/2022)
625488980 XXX XXX XXX 34421625 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX 9/XX/2022 IL Refinance - Rate/Term Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/10: BPO extract provided with current inspection dates indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488240 XXX XXX XXX 34421638 credit 1 Insufficient Coverage: Hazard insurance coverage amount is insufficient. Hazard Insurance Coverage Amount is insufficient by $XXX. 5/XX/2022 MN Refinance - Rate/Term Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: The figures were done correctly to show the total replacement cov on 2025/XX/13: As per Doc 1176 page no :1135 has Replacement/additional
the home. The home was written at the replacement value of $XXX and the policy coverage:925,000 - Dwelling: $XXX = Replacement cost: $XXX. However still we
includes an endorsement to add replacement coverage up to 125% which brings that have coverage short fall of $XXX. Exception remains.
value up to the $XXX figure.
2025/XX/21: Lender explanation/calculation provided. Acceptable.
The total coverage amount would have been :
Dwelling: $XXX
Other Structures: $XXX
Replacement/additional coverage: $XXX
Deductible: 1500
Total coverage: $XXX
As far as having adequate coverage the home is insured up to 125% of its
replacement value.
625488240 XXX XXX XXX 34421640 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final Closing Disclosure provided on 05/XX/2022 with an increasing payment TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 5/XX/2022 5/XX/2023 MN Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 05/XX/2022 with an increasing payment disclosed the due date of the last disclosed the due date of the last payment of interest only that does not match Assignee liability.
payment of interest only that does not match the actual last payment for the the actual last payment for the loan
loan. (Final/XX/20/2022)
625488240 XXX XXX XXX 34421641 compliance 2 TRID Final Closing Disclosure Property Costs Year 1 Overdisclosed - October 2018 TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Amount of Estimated Property Costs over Year 1 of XXX on Final Closing TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 5/XX/2022 5/XX/2023 MN Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Construction Permanent Property Costs over Year 1 of XXX on Final Closing Disclosure provided on Disclosure provided liability.
05/XX/2022 are overdisclosed. (Final/XX/20/2022)
625488306 XXX XXX XXX 34421663 compliance 2 TRID Closing Disclosure Issue Date Not Provided TILA-RESPA Integrated Disclosure: Closing Disclosure estimated to be provided on Issue Date Not Provided TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2022 10/XX/2023 IL Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM (APOR) 2025/XX/04: Client elected to waive
10/XX/2022 did not disclose the actual Date Issued. Unable to conclusively defense to foreclosure. Assignee liability.
determine Final Closing disclosure to use to test for compliance with applicable
TRID timing requirements, TRID fee tolerance testing or accuracy of disclosures
at or before consummation due to missing Issue Date. Tested using an estimated
Date Issued based on best information available. (Interim/10/XX/2022)
625488306 XXX XXX XXX 34421665 compliance 2 TRID Interim Closing Disclosure Timing Irregular Transactions Test TILA-RESPA Integrated Disclosure – Corrected Closing Disclosure provided on or Corrected Closing Disclosure provided on or after 10/XX/2022 contains a change TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 10/XX/2022 10/XX/2023 IL Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM (APOR) 2025/XX/04: Client elected to waive
after 10/XX/2022 contains a change in APR and was not received by borrower at in APR and was not received by borrower at least three (3) business days prior liability.
least three (3) business days prior to consummation to consummation
625488306 XXX XXX XXX 34421668 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The Subject property is located in a FEMA Disaster area . A post-Disaster 10/XX/2022 IL Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Safe Harbor QM (APOR) 2025/XX/10: BPO extract provided with current inspection dates indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage to the subject property required damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625489656 XXX XXX XXX 34421669 compliance 2 TRID Closing Disclosure: "Product" in Loan Details section is blank. Date Issued: 10/XX/2022, Date Issued: 10/XX/2022 Incomplete Closing disclosure in the file, provide attestation that this CD was 10/XX/2022 10/XX/2023 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
not issued to the borrower
625489656 XXX XXX XXX 34421670 credit 2 Missing Document: Purchase Agreement / Sales Contract not provided The purchase agreement is missing in the file. 10/XX/2022 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/06: Comp factors used to waive exception
625489656 XXX XXX XXX 34421671 compliance 2 TRID Closing Disclosure Issue Date Not Provided TILA-RESPA Integrated Disclosure: Closing Disclosure estimated to be provided on Closing Disclosure estimated to be provided on 10/XX/2022 did not disclose the TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2022 10/XX/2023 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
10/XX/2022 did not disclose the actual Date Issued. Unable to conclusively actual Date Issued. Incomplete Closing disclosure in the file, provide defense to foreclosure. Assignee liability.
determine Final Closing disclosure to use to test for compliance with applicable attestation that this CD was not issued to the borrower
TRID timing requirements, TRID fee tolerance testing or accuracy of disclosures
at or before consummation due to missing Issue Date. Tested using an estimated
Date Issued based on best information available. (Interim/10/XX/2022)
625489656 XXX XXX XXX 34421672 compliance 2 TRID Closing Disclosure Issue Date Not Provided TILA-RESPA Integrated Disclosure: Closing Disclosure estimated to be provided on Closing Disclosure estimated to be provided on 10/XX/2022 did not disclose the TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2022 10/XX/2023 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
10/XX/2022 did not disclose the actual Date Issued. Unable to conclusively actual Date Issued. Incomplete Closing disclosure in the file, provide defense to foreclosure. Assignee liability.
determine Final Closing disclosure to use to test for compliance with applicable attestation that this CD was not issued to the borrower
TRID timing requirements, TRID fee tolerance testing or accuracy of disclosures
at or before consummation due to missing Issue Date. Tested using an estimated
Date Issued based on best information available. (Initial/10/XX/2022)
625489656 XXX XXX XXX 34421673 compliance 2 TRID Final Closing Disclosure AIR Table Index TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing Final Closing Disclosure provided on 10/XX/2022 did not disclose an accurate TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 10/XX/2022 10/XX/2023 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Disclosure provided on 10/XX/2022 did not disclose an accurate Index as Index as reflected on the Note. liability.
reflected on the Note. (Final/10/XX/2022)
625489656 XXX XXX XXX 34421674 compliance 2 TRID Final Closing Disclosure AP Table Subsequent Changes Test TILA-RESPA Integrated Disclosure - Adjustable Payment Table: Final Closing Final Closing Disclosure provided on 10/XX/2022 did not disclose an accurate TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 10/XX/2022 10/XX/2023 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Disclosure provided on 10/XX/2022 disclosed a Subsequent Changes period that Index as reflected on the Note. liability.
does not match the actual terms for the loan. (Final/10/XX/2022)
625489656 XXX XXX XXX 34421675 compliance 2 TRID Final Closing Disclosure Escrowed Property Costs Year 1 Overdisclosed - TILA-RESPA Integrated Disclosure - Loan Disclosures: Escrowed Property Costs Loan Disclosures: Escrowed Property Costs over Year 1 of XXX on Final Closing TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 10/XX/2022 10/XX/2023 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
October 2018 Construction Permanent over Year 1 of XXX on Final Closing Disclosure provided on 10/XX/2022 are Disclosure provided on 10/XX/2022 are overdisclosed. liability.
overdisclosed. (Final/10/XX/2022)
625489656 XXX XXX XXX 34421676 compliance 2 TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing Disclosure provided on 10/XX/2022 disclosed an Estimated Total TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2022 10/XX/2023 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 10/XX/2022 disclosed an Estimated Total Monthly Payment for payment Monthly Payment for payment stream 3 that does not match the actual total defense to foreclosure. Assignee liability.
stream 3 that does not match the actual total payment for the loan. payment for the loan.
(ProjSeq:3/2654730)
625489656 XXX XXX XXX 34421677 compliance 2 TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing Disclosure provided on 10/XX/2022 disclosed an Estimated Total TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2022 10/XX/2023 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 10/XX/2022 disclosed an Estimated Total Monthly Payment for payment Monthly Payment for payment stream 4 that does not match the actual total defense to foreclosure. Assignee liability.
stream 4 that does not match the actual total payment for the loan. payment for the loan.
(ProjSeq:4/2654731)
625489656 XXX XXX XXX 34421678 compliance 2 TRID Final Closing Disclosure Mortgage Insurance Payment TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing Disclosure provided on 10/XX/2022 disclosed a mortgage insurance TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2022 10/XX/2023 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 10/XX/2022 disclosed a mortgage insurance payment for payment stream payment for payment stream 3 that does not match the actual payment for the defense to foreclosure. Assignee liability.
3 that does not match the actual payment for the loan. (ProjSeq:3/2654730) loan.
625489656 XXX XXX XXX 34421679 compliance 2 TRID Final Closing Disclosure Mortgage Insurance Payment TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing Disclosure provided on 10/XX/2022 disclosed a mortgage insurance TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2022 10/XX/2023 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 10/XX/2022 disclosed a mortgage insurance payment for payment stream payment for payment stream 4 that does not match the actual payment for the defense to foreclosure. Assignee liability.
4 that does not match the actual payment for the loan. (ProjSeq:4/2654731) loan.
625489656 XXX XXX XXX 34421680 compliance 2 TRID Final Closing Disclosure Payment Adjusts Every Starting In TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final Closing Disclosure provided on 10/XX/2022 with an increasing payment TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 10/XX/2022 10/XX/2023 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 10/XX/2022 with an increasing payment disclosed the due date of the first disclosed the due date of the first adjustment that does not match the actual Assignee liability.
adjustment that does not match the actual due date for the loan. due date for the loan.
(Final/10/XX/2022)
625489656 XXX XXX XXX 34421681 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final Closing Disclosure provided on 10/XX/2022 with an increasing payment TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 10/XX/2022 10/XX/2023 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 10/XX/2022 with an increasing payment disclosed the due date of the last disclosed the due date of the last payment of interest only that does not match Assignee liability.
payment of interest only that does not match the actual last payment for the the actual last payment for the loan.
loan. (Final/10/XX/2022)
625489656 XXX XXX XXX 34421682 compliance 2 TRID Final Closing Disclosure Payment Max Amount In Year TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final Closing Disclosure provided on 10/XX/2022 with an increasing payment TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 10/XX/2022 10/XX/2023 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 10/XX/2022 with an increasing payment disclosed the earliest date of the disclosed the earliest date of the maximum possible amount of principal and Assignee liability.
maximum possible amount of principal and interest that does not match the actual interest that does not match the actual earliest date for the loan.
earliest date for the loan. (Final/10/XX/2022)
625489228 XXX XXX XXX 34421699 credit 2 Guideline Requirement: Total cash-out discrepancy. HUD-1 total cash-out of $XXX is greater than Guideline total cash-out of $XXX. 10/XX/2022 MO Refinance - Cash-out - Other Primary No B B B B 7/XX/2025 1/XX/2025 Yes Safe Harbor QM (43-Q) 2025/XX/06: Comp factors used to waive exception.
625488853 XXX XXX XXX 34421700 compliance 1 QM Employment History Qualified Mortgage (Dodd-Frank 2014): Employment history requirement not met. Missing gap of employment letter from the borrower. 10/XX/2022 MN Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/17: Loan has been re designated at client request
(XXX/14557763)
625488853 XXX XXX XXX 34421701 compliance 1 QM Employment History Qualified Mortgage (Dodd-Frank 2014): Employment history requirement not met. Missing gap of employment letter for the borrower. 10/XX/2022 MN Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/17: Loan has been re designated at client request
(XXX/14557764)
625488853 XXX XXX XXX 34421702 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each 10/XX/2022 MN Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Consummation valuation to applicant three (3) business days prior to consummation.
(Type:Primary/09/XX/2022)
625488853 XXX XXX XXX 34421703 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Missing gap of employment letter from the borrower. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 10/XX/2022 MN Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/17: Loan has been re designated at client request
QM does not match Due Diligence Loan Designation of Non QM. Designation to the TPR firm performing the loan level due diligence and to have
the TPR firm confirm said designation.
625488853 XXX XXX XXX 34421705 compliance 2 TRID Final Closing Disclosure Mortgage Insurance Payment TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing Disclosure provided on 10/XX/2022 disclosed a mortgage insurance TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2022 10/XX/2023 MN Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 10/XX/2022 disclosed a mortgage insurance payment for payment stream payment for payment stream 4 that does not match the actual payment for the defense to foreclosure. Assignee liability.
4 that does not match the actual payment for the loan. (ProjSeq:4/2659333) loan.
625488853 XXX XXX XXX 34421706 compliance 2 Check Restated Loan Designation Match - General Ability to Repay Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did Loan has been re designated at client request Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 10/XX/2022 MN Purchase Primary No B B A A 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
not match. However, the updated Loan Designation of Non QM matches the Due Designation to the TPR firm performing the loan level due diligence and to have
Diligence Loan Designation of Non QM. the TPR firm confirm said designation.
625489685 XXX XXX XXX 34421709 compliance 2 TRID Final Closing Disclosure Payment Adjusts Every Starting In TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Loan term is of 30 years, Note document shows 360 months which include 1 year of TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 11/XX/2022 11/XX/2023 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 11/XX/2022 with an increasing payment disclosed the due date of the first Interest only period due to Construction Permanent. Assignee liability.
adjustment that does not match the actual due date for the loan.
(Final/11/XX/2022)
625489685 XXX XXX XXX 34421710 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Loan term is of 30 years, Note document shows 360 months which include 1 year of TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 11/XX/2022 11/XX/2023 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 11/XX/2022 with an increasing payment disclosed the due date of the last Interest only period due to Construction Permanent. Assignee liability.
payment of interest only that does not match the actual last payment for the
loan. (Final/11/XX/2022)
625489685 XXX XXX XXX 34421711 compliance 2 TRID Final Closing Disclosure Escrowed Property Costs Year 1 Overdisclosed - TILA-RESPA Integrated Disclosure - Loan Disclosures: Escrowed Property Costs Final Closing disclosure page 1 lists escrows as $XXX+$ XXX total $XXX, however TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 11/XX/2022 11/XX/2023 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
October 2018 Construction Permanent over Year 1 of XXX on Final Closing Disclosure provided on 11/XX/2022 are page 4 total states $XXX annually which comes monthly $XXX. liability.
overdisclosed. (Final/11/XX/2022)
625489685 XXX XXX XXX 34421712 compliance 2 TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing Disclosure provided on 11/XX/2022 disclosed an Estimated Total TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2022 11/XX/2023 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 11/XX/2022 disclosed an Estimated Total Monthly Payment for payment Monthly Payment for payment stream 3 that does not match the actual total defense to foreclosure. Assignee liability.
stream 3 that does not match the actual total payment for the loan. payment for the loan due Subject Transaction is 1 year Interest only due to
(ProjSeq:3/2654962) Construction Permanent.
625489685 XXX XXX XXX 34421713 compliance 2 TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing Disclosure provided on 11/XX/2022 disclosed an Estimated Total TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2022 11/XX/2023 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 11/XX/2022 disclosed an Estimated Total Monthly Payment for payment Monthly Payment for payment stream 4 that does not match the actual total defense to foreclosure. Assignee liability.
stream 4 that does not match the actual total payment for the loan. payment for the loan due Subject Transaction is 1 year Interest only due to
(ProjSeq:4/2654963) Construction Permanent.
625489685 XXX XXX XXX 34421714 compliance 2 TRID Final Closing Disclosure Total Of Payments TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Final Closing Disclosure provided on 11/XX/2022 disclosed an inaccurate Total of TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2022 11/XX/2023 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 11/XX/2022 disclosed an inaccurate Total of Payments on page 5 that Payments on page 5 that does not match the actual total of payments for the defense to foreclosure. Assignee liability.
does not match the actual total of payments for the loan (fee amounts included loan.
in TOP calculation are based on Closing Disclosure dated 11/XX/2022). The
disclosed Total of Payments in the amount of $XXX is under disclosed by $XXX
compared to the calculated total of payments of $XXX which exceeds the $XXX
threshold. (Final/11/XX/2022)
625488544 XXX XXX XXX 34421719 credit 1 Purchase contract date not provided. Purchase contract not provided 5/XX/2023 MO Construction-Permanent Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/21: Construction contract uploaded. 2025/XX/21: Received
625488544 XXX XXX XXX 34421720 compliance 2 TRID Final Closing Disclosure AIR Table Index TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing Adjustable Interest Rate Table Final Closing Disclosure provided on 05/XX/2023 TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 5/XX/2023 5/XX/2024 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Disclosure provided on 05/XX/2023 did not disclose an accurate Index as did not disclose an accurate Index as reflected on the Note liability.
reflected on the Note. (Final/05/XX/2023)
625488544 XXX XXX XXX 34421721 compliance 2 TRID Final Closing Disclosure AP Table Interest Only Payment TILA-RESPA Integrated Disclosure - Adjustable Payment Table: Final Closing Adjustable Payment Table: Final Closing Disclosure provided on 05/XX/2023 TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 5/XX/2023 5/XX/2024 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Disclosure provided on 05/XX/2023 incorrectly disclosed whether the loan incorrectly disclosed whether the loan contains Interest Only Payments. liability.
contains Interest Only Payments. (Final/05/XX/2023)
625488544 XXX XXX XXX 34421722 compliance 2 TRID Final Closing Disclosure AP Table Maximum Payment TILA-RESPA Integrated Disclosure - Adjustable Payment Table: Final Closing Final closing disclosure disclosed payment stream 4 Estimated Total Monthly TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 5/XX/2023 5/XX/2024 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Disclosure provided on 05/XX/2023 disclosed a Maximum Payment amount and period payment Maximum at $XXX. However payment is calculating at $XXX liability.
that does not match the actual terms for the loan. (Final/05/XX/2023)
625488544 XXX XXX XXX 34421723 compliance 2 TRID Final Closing Disclosure Escrowed Property Costs Year 1 Overdisclosed - TILA-RESPA Integrated Disclosure - Loan Disclosures: Escrowed Property Costs Escrowed Property Costs over Year 1 of $XXX is over disclosed. Monthly Taxes TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 5/XX/2023 5/XX/2024 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
October 2018 Construction Permanent over Year 1 of XXX on Final Closing Disclosure provided on 05/XX/2023 are ($XXX) and Insurance ($XXX) totaling $XXX. liability.
overdisclosed. (Final/05/XX/2023)
625488544 XXX XXX XXX 34421725 compliance 2 TRID Final Closing Disclosure Estimated Total Maximum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final closing disclosure disclosed payment stream 3 Estimated Total Monthly TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2023 5/XX/2024 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 05/XX/2023 disclosed an Estimated Total Monthly Payment (Maximum) payment Maximum at $XXX. However payment is calculating at $XXX. defense to foreclosure. Assignee liability.
for payment stream 3 that does not match the actual total payment for the loan.
(ProjSeq:3/2658119)
625488544 XXX XXX XXX 34421726 compliance 2 TRID Final Closing Disclosure Estimated Total Maximum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final closing disclosure disclosed payment stream 4 Estimated Total Monthly TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2023 5/XX/2024 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 05/XX/2023 disclosed an Estimated Total Monthly Payment (Maximum) payment at $XXX. However payment is calculating at $XXX. defense to foreclosure. Assignee liability.
for payment stream 4 that does not match the actual total payment for the loan.
(ProjSeq:4/2658120)
625488544 XXX XXX XXX 34421727 compliance 2 TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final closing disclosure disclosed payment stream 3 Estimated Total Monthly TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2023 5/XX/2024 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 05/XX/2023 disclosed an Estimated Total Monthly Payment for payment payment at $XXX. However payment is calculating at $XXX. defense to foreclosure. Assignee liability.
stream 3 that does not match the actual total payment for the loan.
(ProjSeq:3/2658119)
625488544 XXX XXX XXX 34421728 compliance 2 TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final closing disclosure disclosed payment stream 2 Estimated Total Monthly TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2023 5/XX/2024 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 05/XX/2023 disclosed an Estimated Total Monthly Payment for payment payment at $XXX. However payment is calculating at XXX. defense to foreclosure. Assignee liability.
stream 4 that does not match the actual total payment for the loan.
(ProjSeq:4/2658120)
625488544 XXX XXX XXX 34421729 compliance 2 TRID Final Closing Disclosure Non Escrow Costs Year 1 Overdisclosed - October TILA-RESPA Integrated Disclosure - Loan Disclosures: Non Escrowed Property Costs Based on appraisal provided HOA dues are $XXX per year $XXX monthly. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 5/XX/2023 5/XX/2024 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
2018 Construction Permanent over Year 1 of XXX on Final Closing Disclosure provided on 05/XX/2023 are liability.
overdisclosed. (Final/05/XX/2023)
625488544 XXX XXX XXX 34421730 compliance 2 TRID Final Closing Disclosure Payment Adjusts Every Starting In TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided First payment adjustment does not match the due date for the loan. TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 5/XX/2023 5/XX/2024 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 05/XX/2023 with an increasing payment disclosed the due date of the first Assignee liability.
adjustment that does not match the actual due date for the loan.
(Final/05/XX/2023)
625488544 XXX XXX XXX 34421731 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Data updated as per Final Closing Disclosure provided on 05/XX/2023 TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 5/XX/2023 5/XX/2024 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 05/XX/2023 with an increasing payment disclosed the due date of the last Assignee liability.
payment of interest only that does not match the actual last payment for the
loan. (Final/05/XX/2023)
625489403 XXX XXX XXX 34421733 compliance 2 TRID Final Closing Disclosure Escrowed Property Costs Year 1 Overdisclosed - TILA-RESPA Integrated Disclosure - Loan Disclosures: Escrowed Property Costs Loan Disclosures: Escrowed Property Costs over Year 1 of XXX on Final Closing TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 9/XX/2023 9/XX/2024 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
October 2018 Construction Permanent over Year 1 of XXX on Final Closing Disclosure provided on 09/XX/2023 are Disclosure provided on 09/XX/2023 are over disclosed. liability.
overdisclosed. (Final/09/XX/2023)
625489403 XXX XXX XXX 34421734 compliance 2 TRID Final Closing Disclosure Non Escrow Costs Year 1 Overdisclosed - October TILA-RESPA Integrated Disclosure - Loan Disclosures: Non Escrowed Property Costs Non Escrowed Property Costs over Year 1 of XXX on Final Closing Disclosure TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 9/XX/2023 9/XX/2024 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
2018 Construction Permanent over Year 1 of XXX on Final Closing Disclosure provided on 09/XX/2023 are provided on 09/XX/2023 are over disclosed. liability.
overdisclosed. (Final/09/XX/2023)
625489403 XXX XXX XXX 34421735 compliance 2 TRID Final Closing Disclosure AP Table Maximum Payment TILA-RESPA Integrated Disclosure - Adjustable Payment Table: Final Closing The CD indicates that the 1st year of payments are interest only during the TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 9/XX/2023 9/XX/2024 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Disclosure provided on 09/XX/2023 disclosed a Maximum Payment amount and period construction period. The note does not reflect the interest only payments. liability.
that does not match the actual terms for the loan. (Final/09/XX/2023)
625489403 XXX XXX XXX 34421736 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided The CD indicates that the 1st year of payments are interest only during the TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 9/XX/2023 9/XX/2024 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 09/XX/2023 with an increasing payment disclosed the due date of the last construction period. The note does not reflect the interest only payments. Assignee liability.
payment of interest only that does not match the actual last payment for the
loan. (Final/09/XX/2023)
625489403 XXX XXX XXX 34421737 compliance 2 TRID Final Closing Disclosure Payment Max Amount TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided The CD indicates that the 1st year of payments are interest only during the TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 9/XX/2023 9/XX/2024 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 09/XX/2023 with an increasing payment disclosed the maximum possible amount construction period. The note does not reflect the interest only payments. Assignee liability.
of principal and interest that does not match the actual maximum amount for the
loan. (Final/09/XX/2023)
625489403 XXX XXX XXX 34421738 compliance 2 TRID Final Closing Disclosure Payment Max Amount In Year TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided The CD indicates that the 1st year of payments are interest only during the TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 9/XX/2023 9/XX/2024 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 09/XX/2023 with an increasing payment disclosed the earliest date of the construction period. The note does not reflect the interest only payments. Assignee liability.
maximum possible amount of principal and interest that does not match the actual
earliest date for the loan. (Final/09/XX/2023)
625489403 XXX XXX XXX 34421739 compliance 2 TRID Final Closing Disclosure Projected P&I Min Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure The CD indicates that the 1st year of payments are interest only during the TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2023 9/XX/2024 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 09/XX/2023 disclosed a periodic principal and interest payment for construction period. The note does not reflect the interest only payments. defense to foreclosure. Assignee liability.
payment stream 3 that does not match the actual payment for the loan.
(ProjSeq:3/2655213)
625489403 XXX XXX XXX 34421740 compliance 2 TRID Final Closing Disclosure Projected P&I Min Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure The CD indicates that the 1st year of payments are interest only during the TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2023 9/XX/2024 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 09/XX/2023 disclosed a periodic principal and interest payment for construction period. The note does not reflect the interest only payments. defense to foreclosure. Assignee liability.
payment stream 4 that does not match the actual payment for the loan.
(ProjSeq:4/2655214)
625489403 XXX XXX XXX 34421741 compliance 2 TRID Final Closing Disclosure AIR Table Subsequent Change Frequency TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing The CD indicates that the 1st year of payments are interest only during the TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 9/XX/2023 9/XX/2024 MO Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Disclosure provided on 09/XX/2023 disclosed a Subsequent Changes frequency that construction period. The note does not reflect the interest only payments. liability.
does not match the actual subsequent change frequency for the loan.
(Final/09/XX/2023)
625489304 XXX XXX XXX 34421754 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA disaster area. A post disaster 12/XX/2016 MA Refinance - Cash-out - Other Investment Yes A A A A 7/XX/2025 1/XX/2025 Yes 2025/XX/07: Client provided BPO extract with current dates and indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage to the subject property is required. damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625489304 XXX XXX XXX 34421755 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Verification of appraisal was delivered to borrower not provided in file. 12/XX/2016 MA Refinance - Cash-out - Other Investment Yes B B B B 7/XX/2025 3/XX/2025 Yes 2025/XX/04: Client elected to waive
Consummation valuation to applicant three (3) business days prior to consummation.
(Client:18451/11/XX/2016)
625489705 XXX XXX XXX 34421761 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement 3/XX/2017 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factor.
625489705 XXX XXX XXX 34421762 credit 2 REO Documents are missing. Address: Costa Rica, Insurance Verification, Statement, Tax Verification 3/XX/2017 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factor .
625488429 XXX XXX XXX 34421774 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The property is located in a FEMA disaster area. Provide a post-disaster 5/XX/2017 RI Purchase Investment No A A A A 7/XX/2025 1/XX/2025 Yes 2025/XX/07: Client provided BPO extract with current dates and indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage. The inspection must include exterior damage.
Disaster Name: XXX photos and the property must be re-inspected on or after XX/XX/XXXX declared end
Disaster Declaration Date: XX/XX/XXXX date.
625488429 XXX XXX XXX 34421775 credit 2 Income Docs Missing: Borrower: XXX 1065 (2016), K-1 (2016), P&L Statement The 1065 (2016), K-1 (2016), and year-to-date P&L Statement were not received 5/XX/2017 RI Purchase Investment No B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
for XXX. Also, missing a year-to-date P&L for XXX.
625488395 XXX XXX XXX 34421804 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement E-Sign Consent Agreement is not provided. 1/XX/2018 MA Refinance - Cash-out - Other Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/14: Client elects to waive with compensating factor.
625488395 XXX XXX XXX 34421805 compliance 1 C-Corp Income Documentation Test Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not Self-employed income documentation not sufficient (C-Corp). (XXX XXX/C-Corp 1/XX/2018 MA Refinance - Cash-out - Other Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: See attached 1120s that were signed at closing. P&L. We agree that 2025/XX/12: Per standard Appendix Q guidelines, missing a YTD balance sheet
sufficient (C-Corp). (XXX XXX/C-Corp 1120) 1120) P&L was not signed. Compensating Factors In same line of work for 15 years. XXX%
CLTV. Lower housing payment. 2025/XX/14: Client restates designation to Non-QM
2025/XX/14: This is a C corp. Balance sheet would not be required 4. General
Documentation Requirements for Self-Employed Consumers.
Self-employed consumers must provide the following documentation:
a. Signed, dated individual tax returns, with all applicable tax schedules for
the most recent two years;
b. For a corporation, "S" corporation, or partnership, signed copies of Federal
business income tax returns for the last two years, with all applicable tax
schedules; and
c. Year to date profit and loss (P&L) statement and balance sheet.
625488395 XXX XXX XXX 34421807 compliance 2 ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM loan program disclosure not provided to the borrower. TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2018 1/XX/2019 MA Refinance - Cash-out - Other Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
borrower.
625488395 XXX XXX XXX 34421808 compliance 1 QM Employment History - Current Employment Documentation lacks Date Info Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two Verified data updated as per provided documents. 1/XX/2018 MA Refinance - Cash-out - Other Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/14: Client restates designation to Non-QM
years current employment. (XXX/14686929)
625488395 XXX XXX XXX 34421809 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 1/XX/2018 MA Refinance - Cash-out - Other Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: See attached 1120s that were signed at closing. P&L. We agree that 2025/XX/12: Per standard Appendix Q guidelines, missing a YTD balance sheet
QM does not match Due Diligence Loan Designation of Non QM. Designation of Non QM. Designation to the TPR firm performing the loan level due diligence and to have P&L was not signed. Compensating Factors In same line of work for 15 years. XXX%
the TPR firm confirm said designation. CLTV. Lower housing payment. 2025/XX/14: Client restates designation to Non-QM
625488395 XXX XXX XXX 34421810 compliance 2 TRID Revised Loan Estimate Timing Before Closing TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on 01/XX/2018 Verified data updated as per provided documents. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 1/XX/2018 1/XX/2019 MA Refinance - Cash-out - Other Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
not received by borrower at least four (4) business days prior to closing. liability.
(Interim/01/XX/2018)
625488395 XXX XXX XXX 34421811 compliance 2 General Ability To Repay Provision Investor Qualification Method not Matching Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender The Qualification Method used by the lender does not match the ATR payment 1/XX/2018 MA Refinance - Cash-out - Other Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
ATR does not match the ATR payment calculation methods under 1026.43(c)(5). calculation methods under 1026.43(c)(5).
625488395 XXX XXX XXX 34421812 compliance 1 Appendix Q Liabilities – Invalid Exclusion Basis Qualified Mortgage (Dodd-Frank 2014): One or more liabilities have been excluded PSW in file for the exclusion of the deferred student loan payments. 1/XX/2018 MA Refinance - Cash-out - Other Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/14: Client restates designation to Non-QM
from DTI calculation for a prohibited reason.
625488395 XXX XXX XXX 34421813 compliance 2 Check Restated Loan Designation Match - General Ability to Repay Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did Client restates designation to Non-QM Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 1/XX/2018 MA Refinance - Cash-out - Other Primary Yes B B A A 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
not match. However, the updated Loan Designation of Non QM matches the Due Designation to the TPR firm performing the loan level due diligence and to have
Diligence Loan Designation of Non QM. the TPR firm confirm said designation.
625489309 XXX XXX XXX 34421824 compliance 2 ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Not Provided ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Right to Receive a Copy of appraisal is not provided to applicant within three There is generally no Assignee Liability. 2/XX/2018 MA Purchase Investment Yes B B B B 7/XX/2025 3/XX/2025 Yes 2025/XX/04: Client elected to waive
Timely Receive a Copy" appraisal disclosure to applicant within three (3) business days (3) business days of application.
of application or determination of first lien status.
625489491 XXX XXX XXX 34421845 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement E-sign Consent Agreement is missing. 12/XX/2019 MA Purchase Second Home Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/14: Client elects to waive with compensating factor.
625489491 XXX XXX XXX 34421846 compliance 1 Other Income - Not to be used for qualifying Qualified Mortgage (Dodd-Frank 2014): Income used to qualify borrower(s) not Income used to qualify borrower(s) not permitted for use under Appendix Q. (XXX 12/XX/2019 MA Purchase Second Home Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/14: Client restates designation to Non-QM
permitted for use under Appendix Q. (XXX XXX/Asset Depletion) XXX/Asset Depletion)
625489491 XXX XXX XXX 34421847 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 12/XX/2019 MA Purchase Second Home Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/14: Client restates designation to Non-QM
QM does not match Due Diligence Loan Designation of Non QM. Designation of Non QM. Designation to the TPR firm performing the loan level due diligence and to have
the TPR firm confirm said designation.
625489491 XXX XXX XXX 34421849 compliance 2 TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total The Recording fee was previiously disclosed to the borrower on the Loan estimate 12/XX/2019 12/XX/2020 MA Purchase Second Home Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no as $XXX but it increased on the closing disclosure as $XXX with no cure provided
cure was provided to the borrower. (0) to the borrower. Insufficient or no cure was provided to the borrowe
625489491 XXX XXX XXX 34421850 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit The Credit report fee was previiously disclosed to the borrower on the Loan TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 12/XX/2019 12/XX/2020 MA Purchase Second Home Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Report Fee. Fee Amount of $XXX exceeds tolerance of $XXX. Insufficient or no estimate as $XXX but it increased on the closing disclosure as $XXX with no cure liability.
cure was provided to the borrower. (7520) provided to the borrower. Insufficient or no cure was provided to the borrowe
625489491 XXX XXX XXX 34421851 compliance 2 TRID Final Closing Disclosure Will Not Have Escrow - Reason TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure Loan Disclosures: Final Closing Disclosure provided on 12/XX/2019 incorrectly TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 12/XX/2019 12/XX/2020 MA Purchase Second Home Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 12/XX/2019 incorrectly disclosed whether the loan will have an disclosed whether the loan will have an escrow account. liability.
escrow account. (Final/12/XX/2019)
625489491 XXX XXX XXX 34421853 compliance 2 Check Restated Loan Designation Match - General Ability to Repay Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did Client restates designation to Non-QM Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 12/XX/2019 MA Purchase Second Home Yes B B A A 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
not match. However, the updated Loan Designation of Non QM matches the Due Designation to the TPR firm performing the loan level due diligence and to have
Diligence Loan Designation of Non QM. the TPR firm confirm said designation.
625489223 XXX XXX XXX 34421935 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement 4/XX/2020 MA Purchase Primary Yes B B B B 7/XX/2025 1/XX/2025 Yes Temporary SHQM (GSE/Agency Eligible) 2025/XX/14: Client elects to waive with compensating factors.
625489223 XXX XXX XXX 34421937 credit 2 This loan closed during the COVID-19 affected timeframe. Asset Account date is Financial Institution: XXX // Account Type: Individual Retirement Account (IRA) 4/XX/2020 MA Purchase Primary Yes B B B B 7/XX/2025 1/XX/2025 Yes Temporary SHQM (GSE/Agency Eligible) 2025/XX/14: Client elects to waive with compensating factors.
more than 60 days prior to the Note date or notary date. / Account Number: XXX Note Date: 04/XX/2020; Notary Date: 04/XX/2020
625489068 XXX XXX XXX 34421970 credit 2 REO Documents are missing. Address: XXX, MA Statement Provide Mortgage statement for the property 15-17 Elliot Road, rental property 5/XX/2020 MA Refinance - Cash-out - Other Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/14: Client elects to waive with compensating factors.
is missing.
625489068 XXX XXX XXX 34421972 compliance 2 General Ability To Repay Provision Investor Qualification Method not Matching Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender The Qualification Method used by the lender does not match the ATR payment 5/XX/2020 MA Refinance - Cash-out - Other Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
ATR does not match the ATR payment calculation methods under 1026.43(c)(5). calculation methods.
625489068 XXX XXX XXX 34421973 compliance 2 Massachusetts Home Loan - Borrower's Interest Tangible Net Benefit Worksheet Not Massachusetts Home Loan: No evidence in loan file of document or worksheet Tangible Net Benefit Worksheet is missing in the file. The regulations do not clarify the enforcement provisions of Mass. Gen. L. c. 5/XX/2020 5/XX/2023 MA Refinance - Cash-out - Other Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
in File indicating how the lender determined that the home loan is in the borrower's 183. Accordingly, the consequences of a compliance failure remain unclear. In
interest. particular, it is probable that a violation of the "borrower's interest"
standard can be raised as a defense to, or otherwise impede, foreclosure. Also,
it is possible that a violation of the "borrower's interest" standard would
constitute a violation of the Massachusetts unfair and deceptive acts and
practices statute.
625489068 XXX XXX XXX 34421974 compliance 2 TRID Initial Loan Estimate Timing Electronically Provided TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) Loan Estimate not delivered to Borrower(s) within three (3) business days of TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 5/XX/2020 5/XX/2021 MA Refinance - Cash-out - Other Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
within three (3) business days of application. Initial Loan Estimate dated application. Initial Loan Estimate dated 03/XX/2020 was electronically provided liability.
03/XX/2020 was electronically provided without or prior to borrower's consent to without or prior to borrower's consent to receive electronic disclosures.
receive electronic disclosures. Failure to comply with the provisions of the
E-Sign Act and failure to provide good faith estimate of fees timely may result
in additional fee tolerance violations. (Initial/03/XX/2020)
625488739 XXX XXX XXX 34422006 compliance 2 TILA NMLSR - Individual Originator License Status Not Approved Truth in Lending Act (NMLSR Dodd- Frank 2014): Individual Loan Originator not in 7/XX/2020 7/XX/2023 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
approved license status to conduct loan origination activities.
625488739 XXX XXX XXX 34422007 compliance 2 Massachusetts Late Charge Percent Testing Massachusetts Late Charge: Note late charge percent of 5.00000% exceeds the 7/XX/2020 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
state maximum of 3%.
625488739 XXX XXX XXX 34422010 compliance 2 ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM loan program disclosure not provided to the borrower within three (3) days TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2020 7/XX/2021 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
borrower within three (3) days of application. of application.
625488739 XXX XXX XXX 34422011 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement 7/XX/2020 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/14: Lender elects to waive with compensating factors.
625489264 XXX XXX XXX 34422013 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement E-sign Consent Agreement is missing. 6/XX/2020 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/14: Lender elects to waive with compensating factors.
625489264 XXX XXX XXX 34422014 compliance 1 Commission History less than one year Qualified Mortgage (Dodd-Frank 2014): Commission income earned for less than one 6/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2024/XX/26: We agree. Qualified on base income and on half of commission. DTI 2025/XX/02: Lender provided justification. Exception is clear.
(1) year not considered effective income and no valid exceptions. would be 50.8 with just base income. Solid Credit, Large 40% downpayment and XXX
(XXX/Commission) in reserves.
625489264 XXX XXX XXX 34422015 compliance 1 Commission Paystub Timing Qualified Mortgage (Dodd-Frank 2014): Commission income. Missing date of most 6/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2024/XX/26: We agree. Qualified on base income and on half of commission. DTI 2025/XX/02: Income verification provided. Exception is clear.
recent paystub. (XXX/Commission) would be 50.8 with just base income. Solid Credit, Large 40% downpayment and XXX
in reserves.
625489264 XXX XXX XXX 34422016 compliance 1 Commission Tax Documentation Qualified Mortgage (Dodd-Frank 2014): Commission income missing two years 6/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2024/XX/26: We agree. Qualified on base income and on half of commission. DTI 2025/XX/02: Lender agrees, Refer to buyer.
consecutive signed tax returns or tax transcripts (XXX/Commission) would be 50.8 with just base income. Solid Credit, Large 40% downpayment and XXX
in reserves. 2025/XX/08: Client agrees with the exception.
2025/XX/03: We agree 2025/XX/09: Client agrees with the exception.
2025/XX/06: We agree 2025/XX/14: Client restates designation to Non-QM
2025/XX/09: Refer to Buyer.
625489264 XXX XXX XXX 34422017 compliance 1 QM Employment History - Current and/or Previous Employment Documentation lacks Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two Borrower has less than two years of employment and was in college previously. 6/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/14: Client restates designation to Non-QM
Date Info years employment history for current and/or prior employment. (XXX/14686994)
625489264 XXX XXX XXX 34422018 compliance 1 Wages Documentation Qualified Mortgage (Dodd-Frank 2014): Unable to verity income due to, missing We have year end summary in file for current and previous year. Borrower has 6/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2024/XX/26: We agree borrower was at XXX. Verified via Visa. Attached Employment 2025/XX/02: Income verification provided. Exception is clear.
W-2, Paystub, LES, ETS or WVOE. (XXX XXX/Wages) less than two years of employment and was in XXX previously. Letter, 1099, and Visa Application.
625489264 XXX XXX XXX 34422019 compliance 1 General Ability To Repay Provision Income and Assets - Commission Ability to Repay (Dodd-Frank 2014): Unable to verify Commission income due to, We have year end summary in file for current and previous year. Borrower has Assignee Liability: Violations can result in regular TILA damages (actual 6/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2024/XX/26: We agree borrower was at XXX. Verified via Visa. Attached Employment 2025/XX/02: Income verification provided. Exception is clear.
missing W-2, Paystub, or WVOE. (XXX XXX/Commission) less than two years of employment and was in XXX previously. damages, statutory damages of up to $XXX costs, and attorney's fees) and Letter, 1099, and Visa Application.
enhanced damages (an amount equal to the sum of all finance charges and fees
paid by the consumer, unless the creditor demonstrates that the failure to
comply is not material). A private right of action may be brought before the end
of the three-year period beginning on the date of the occurrence of the
violation. However, when a creditor, assignee, or other holder or anyone acting
on their behalf initiates a judicial or non-judicial foreclosure, or any other
action to collect the debt, a consumer may assert a violation as a matter of
defense by recoupment or set-off without regard to a time limit. The amount of
recoupment or set-off shall equal the amount to which the consumer would be
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625489264 XXX XXX XXX 34422020 compliance 1 General Ability To Repay Provision Income and Assets - Wages Ability to Repay (Dodd-Frank 2014): Unable to verify income due to, missing W-2, We have year end summary in file for current and previous year. Borrower has Assignee Liability: Violations can result in regular TILA damages (actual 6/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2024/XX/26: We agree borrower was at XXX. Verified via Visa. Attached Employment 2025/XX/02: Income verification provided. Exception is clear.
Paystub, LES, ETS or WVOE. (XXX XXX/Wages) less than two years of employment and was in XXX previously. damages, statutory damages of up to $XXX costs, and attorney's fees) and Letter, 1099, and Visa Application.
enhanced damages (an amount equal to the sum of all finance charges and fees
paid by the consumer, unless the creditor demonstrates that the failure to
comply is not material). A private right of action may be brought before the end
of the three-year period beginning on the date of the occurrence of the
violation. However, when a creditor, assignee, or other holder or anyone acting
on their behalf initiates a judicial or non-judicial foreclosure, or any other
action to collect the debt, a consumer may assert a violation as a matter of
defense by recoupment or set-off without regard to a time limit. The amount of
recoupment or set-off shall equal the amount to which the consumer would be
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625489264 XXX XXX XXX 34422022 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor The employment history does not meet Safe Harbor QM requirements which resulted Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 6/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2024/XX/26: We agree borrower was at XXX. Verified via Visa. Attached Employment 2025/XX/02: Lender agrees. Refer to buyer.
QM does not match Due Diligence Loan Designation of Non QM. in an ATR failure. Designation to the TPR firm performing the loan level due diligence and to have Letter, 1099, and Visa Application.
the TPR firm confirm said designation. 2025/XX/08: EXCEPTION HISTORY - Exception Detail was updated on 01/XX/2025 PRIOR
2025/XX/03: Visa states dates in school and graduation / completion of master Exception Detail: Qualified Mortgage (Dodd-Frank 2014): Originator Loan
program. Designation of Safe Harbor QM does not match Due Diligence Loan Designation of
ATR Fail.
2025/XX/06: Visa states dates in school and graduation / completion of master
program. 2025/XX/09: Client agrees with income verification failure.
2025/XX/14: Client restates designation to Non-QM
625489264 XXX XXX XXX 34422024 compliance 2 Check Restated Loan Designation Match - General Ability to Repay Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did Client restates designation to Non-QM Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 6/XX/2020 MA Purchase Primary Yes B B A A 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
not match. However, the updated Loan Designation of Non QM matches the Due Designation to the TPR firm performing the loan level due diligence and to have
Diligence Loan Designation of Non QM. the TPR firm confirm said designation.
625489118 XXX XXX XXX 34422027 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement 7/XX/2020 MA Purchase Primary Yes B B B B 7/XX/2025 1/XX/2025 Yes Safe Harbor QM 2025/XX/14: Lender elects to waive with compensating factors.
625489132 XXX XXX XXX 34422035 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement 8/XX/2020 RI Purchase Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM 2025/XX/14: Lender elects to waive with compensating factors.
625489132 XXX XXX XXX 34422038 compliance 2 TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Ten Percent Fee Tolerance exceeded. Total amount of $XXX exceeds tolerance of 8/XX/2020 8/XX/2021 RI Purchase Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM 2025/XX/04: Client elected to waive
amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no $XXX plus 10% or $XXX. Insufficient, So Please provide COC/Final CD for changed
cure was provided to the borrower. (0) fee amount.
625489132 XXX XXX XXX 34422039 credit 2 Guideline Requirement: Loan to value discrepancy. Calculated loan to value percentage of XX% exceeds Guideline loan to value Calculated loan to value percentage of XX% exceeds Guideline loan to value 8/XX/2020 RI Purchase Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM 2025/XX/14: Lender elects to waive with compensating factors.
percentage of 75.00000%. percentage of 75.00000%.
625489132 XXX XXX XXX 34422040 credit 2 Guideline Requirement: Combined loan to value discrepancy. Calculated combined loan to value percentage of XX% exceeds Guideline combined Calculated combined loan to value percentage of XX% exceeds Guideline combined 8/XX/2020 RI Purchase Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM 2025/XX/14: Lender elects to waive with compensating factors.
loan to value percentage of 75.00000%. loan to value percentage of 75.00000%.
625488471 XXX XXX XXX 34422059 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement E-sign Consent Agreement is missing. 9/XX/2020 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/14: Lender elects to waive with compensating factors.
625488471 XXX XXX XXX 34422060 compliance 2 TRID Initial Closing Disclosure Timing without Waiver TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) Initial CD issued 9/XX/2020 and received by the borrower 9/XX/2020 which is less TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 9/XX/2020 9/XX/2021 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
at least three (3) business days prior to closing. (Initial/09/XX/2020) than three business days prior to closing of 9/XX/2020. liability.
625488471 XXX XXX XXX 34422062 compliance 1 Alimony Child Support Maintenance Income Qualified Mortgage (Dodd-Frank 2014): Alimony/Child Support/Maintenance income Loan is qualified using Safe Harbor QM however compliance is considering loan 9/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/13: Client restates designation to Non-QM
verification requirement not met. (XXX XXX/Alimony) designation as Non QM.
625488471 XXX XXX XXX 34422063 compliance 1 Other Income - Not to be used for qualifying Qualified Mortgage (Dodd-Frank 2014): Income used to qualify borrower(s) not Asset depletion was used to qualify the borrower. 9/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/13: Client restates designation to Non-QM
permitted for use under Appendix Q. (XXX XXX/Asset Depletion)
625488471 XXX XXX XXX 34422064 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Loan Designation discrepancy due to use of asset depletion and alimony. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 9/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/13: Client restates designation to Non-QM
QM does not match Due Diligence Loan Designation of Non QM. Designation to the TPR firm performing the loan level due diligence and to have
the TPR firm confirm said designation.
625488471 XXX XXX XXX 34422065 compliance 1 Alimony Child Support Maintenance Continuance Qualified Mortgage (Dodd-Frank 2014): Alimony/Child Support/Maintenance minimum Lender exception for using alimony income with less than three year continuance. 9/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/13: Client restates designation to Non-QM
three (3) year continuance requirement not met. (XXX XXX/Alimony)
625488471 XXX XXX XXX 34422066 compliance 2 Check Restated Loan Designation Match - General Ability to Repay Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did Client restates designation to Non-QM Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 9/XX/2020 MA Purchase Primary Yes B B A A 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
not match. However, the updated Loan Designation of Non QM matches the Due Designation to the TPR firm performing the loan level due diligence and to have
Diligence Loan Designation of Non QM. the TPR firm confirm said designation.
625488993 XXX XXX XXX 34422069 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement 9/XX/2020 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Lender elects to waive with compensating factors.
625488993 XXX XXX XXX 34422070 credit 2 Guideline Requirement: Representative FICO score discrepancy. Representative FICO score of 678 is less than Guideline representative FICO FICO score of 678 is less than Guideline FICO score of 680. 9/XX/2020 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Lender elects to waive with compensating factors.
score of 680.
625489154 XXX XXX XXX 34422075 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement E-sign Consent Agreement is missing. 10/XX/2020 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/14: Lender elects to waive with compensating factors.
625489154 XXX XXX XXX 34422076 credit 2 Missing Document: Verification of Rent (VOR) / Verification of Mortgage (VOM) Verification of Rent (VOR) is missing. 10/XX/2020 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/14: Lender elects to waive with compensating factors.
not provided
625489154 XXX XXX XXX 34422077 compliance 2 General Ability To Repay Provision Investor Qualification Method not Matching Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender 10/XX/2020 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
ATR does not match the ATR payment calculation methods under 1026.43(c)(5).
625489154 XXX XXX XXX 34422078 compliance 2 TRID Interim Closing Disclosure Timing Irregular Transactions Test TILA-RESPA Integrated Disclosure – Corrected Closing Disclosure provided on or Corrected Closing Disclosure provided on or after 10/XX/2020 contains a change TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 10/XX/2020 10/XX/2021 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
after 10/XX/2020 contains a change in APR and was not received by borrower at in APR and was not received by borrower at least three (3) business days prior liability.
least three (3) business days prior to consummation to consummation
625488592 XXX XXX XXX 34422117 credit 2 REO Documents are missing. Address: XXX, MA Insurance Verification, Tax Verification Missing Insurance and tax verification for REO XXX. 10/XX/2020 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Lender elects to waive with compensating factors.
625489688 XXX XXX XXX 34422195 compliance 1 Sole Proprietorship Income Documentation Test Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not 7/XX/2021 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2024/XX/31: 2020,2019,P&L and CPA Letter Attached. DTI is at 12.512 2025/XX/04: The 2021 balance sheet was not provided in the uploaded documents.
sufficient (Sole Proprietorship). (XXX XXX/Schedule C) Please provide for review.
2025/XX/13: Disagree,
https://www.consumerfinance.gov/rules-policy/regulations/1026/2021/XX/17/q/, 2025/XX/14: Client restates designation to Non-QM.
Section 4 says this is just required on an "S" corp or partnership.
625489688 XXX XXX XXX 34422196 compliance 2 TRID Initial Loan Estimate Timing Electronically Provided TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 7/XX/2021 7/XX/2022 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
within three (3) business days of application. Initial Loan Estimate dated liability.
06/XX/2021 was electronically provided without or prior to borrower's consent to
receive electronic disclosures. Failure to comply with the provisions of the
E-Sign Act and failure to provide good faith estimate of fees timely may result
in additional fee tolerance violations. (Initial/06/XX/2021)
625489688 XXX XXX XXX 34422197 compliance 2 ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2021 7/XX/2022 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
borrower.
625489688 XXX XXX XXX 34422198 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Data updated correctly. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 7/XX/2021 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2024/XX/31: 2020,2019,P&L and CPA Letter Attached. DTI is at 12.512 2025/XX/04: The 2021 balance sheet was not provided in the uploaded documents.
QM does not match Due Diligence Loan Designation of Non QM. Designation to the TPR firm performing the loan level due diligence and to have Please provide for review.
the TPR firm confirm said designation. 2025/XX/13: Disagree,
https://www.consumerfinance.gov/rules-policy/regulations/1026/2021/XX/17/q/, 2025/XX/14: Client restates designation to Non-QM.
Section 4 says this is just required on an "S" corp or partnership.
625489688 XXX XXX XXX 34422200 compliance 2 Check Restated Loan Designation Match - General Ability to Repay Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did Client restates designation to Non-QM. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 7/XX/2021 MA Purchase Primary Yes B B A A 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
not match. However, the updated Loan Designation of Non QM matches the Due Designation to the TPR firm performing the loan level due diligence and to have
Diligence Loan Designation of Non QM. the TPR firm confirm said designation.
625488356 XXX XXX XXX 34422240 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX 3/XX/2021 CT Refinance - Rate/Term Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/07: Client provided BPO extract with current dates and indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625489398 XXX XXX XXX 34422259 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement 3/XX/2021 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/14: Client elects to waive with compensating factors.
625489398 XXX XXX XXX 34422260 compliance 1 Income Method of Calculation Qualified Mortgage (Dodd-Frank 2014): The Method used to calculate the 3/XX/2021 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2024/XX/31: Used 2020 Tax Returns as borrower was in the same line of work for 5 2025/XX/05: Income has been corrected to the 2-year average.
qualifying monthly income is not supported by the earnings history/trend. years. Borrower became full time in 2019. 2020 reflects full year of full time
(XXX/Schedule C) income.
625489398 XXX XXX XXX 34422261 compliance 1 Sole Proprietorship Income Documentation Test Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not 3/XX/2021 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2024/XX/31: Used 2020 Tax Returns as borrower was in the same line of work for 5 2025/XX/05: EXCEPTION HISTORY - Exception Detail was updated on 01/XX/2025 PRIOR
sufficient (Sole Proprietorship). (XXX XXXSchedule C) years. Borrower became full time in 2019. 2020 reflects full year of full time Exception Detail: Qualified Mortgage (Dodd-Frank 2014): Self-employed income
income. documentation not sufficient (Sole Proprietorship). (XXX XXX/Schedule C)
2025/XX/13: Disagree, 2025/XX/05: File is missing the 2020 Balance Sheet. Please provide for review.
https://www.consumerfinance.gov/rules-policy/regulations/1026/2021/XX/17/q/,
Section 4 says this is just required on an "S" corp or partnership. 2025/XX/14: Client restates designation to Non-QM.
625489398 XXX XXX XXX 34422262 compliance 2 General Ability To Repay Provision Investor Qualification Method not Matching Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender 3/XX/2021 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
ATR does not match the ATR payment calculation methods under 1026.43(c)(5).
625489398 XXX XXX XXX 34422264 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Originator Loan Designation of Safe Harbor QM does not match Due Diligence Loan Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 3/XX/2021 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2024/XX/31: Used 2020 Tax Returns as borrower was in the same line of work for 5 2025/XX/05: Loan designation remains ATR Fail due to a DTI of 45.09% and missing
QM does not match Due Diligence Loan Designation of Non QM. Designation of ATR Fail. Designation to the TPR firm performing the loan level due diligence and to have years. Borrower became full time in 2019. 2020 reflects full year of full time the 2020 Balance Sheet.
the TPR firm confirm said designation. income.
2025/XX/14: Client restates designation to Non-QM.
2025/XX/13: XXX is primary loss is netted in borrower's rental income listed on
1003 (other income). 1003 was signed by borrower indicating their intent to use
their vacated primary as an investment property. Exception was approved to use
one year tax return to qualify
625489398 XXX XXX XXX 34422265 compliance 1 QM DTI Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and Total Debt to Income Ratio exceeds 43% and the images do not provide evidence Although this issue is subject to a 3 year SOL for affirmative claims under 3/XX/2021 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2024/XX/31: DTI is 39.798. See attached final 1008 2025/XX/05: Calculated DTI is 45.09%, which exceeds the Appendix Q maximum DTI
the images do not provide evidence loan is eligible for purchase, guarantee or loan is eligible for purchase, guarantee or insurance by the appropriate agency. TILA, AMC does not adjust grading taking into account TILA SOL for exceptions of 43.00%. DTI increased due to the borrower's income must be averaged over 2
insurance by the appropriate agency. under ATR, given the potential for enhanced damages when asserting an ability to 2025/XX/13: 379.46 is primary loss is netted in borrower's rental income listed years per Appendix Q and the 2-year verified income is $XXX. In addition, the
repay defense in response to an action to collect a debt by recoupment or on 1003 (other income). 1003 was signed by borrower indicating their intent to final 1008 did not include the monthly expenses of $XXX for the borrower's
set-off. use their vacated primary as an investment property. Exception was approved to retained departure residence. Exception remains.
use one year tax return to qualify
2025/XX/14: Client restates designation to Non-QM.
625489398 XXX XXX XXX 34422267 compliance 1 QM Employment History Qualified Mortgage (Dodd-Frank 2014): Employment history requirement not met. Borrower had a job gap between self-employment from 01/XX/2019 to 08/XX/2019 3/XX/2021 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/13: We do not see a gap. See attached showing borrower has been employed 2025/XX/14: Client restates designation to Non-QM.
(XXX XXX/14716631) which is greater than 30 days. File is missing the borrower's job gap since June of 2016
explanation letter as required by Appendix Q.
625489398 XXX XXX XXX 34422268 compliance 2 Check Restated Loan Designation Match - General Ability to Repay Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did Client restates designation to Non-QM. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 3/XX/2021 MA Purchase Primary Yes B B A A 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
not match. However, the updated Loan Designation of Non QM matches the Due Designation to the TPR firm performing the loan level due diligence and to have
Diligence Loan Designation of Non QM. the TPR firm confirm said designation.
625489411 XXX XXX XXX 34422289 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement E-Sign Consent Agreement is not provided. 5/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
625489153 XXX XXX XXX 34422291 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each 3/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 3/XX/2025 Yes 2025/XX/04: Client elected to waive
Consummation valuation to applicant three (3) business days prior to consummation.
(Type:Primary/03/XX/2021)
625489153 XXX XXX XXX 34422292 credit 2 REO Documents are missing. Address: XXX, MA Statement 3/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 3/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
625489153 XXX XXX XXX 34422293 property 2 Appraisal is required to be in name of Lender Valuation Type: Appraisal / Valuation Report Date: 03/XX/2021 3/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 3/XX/2025 Yes 2025/XX/04: Client elected to waive
625489603 XXX XXX XXX 34422295 credit 2 Guideline Requirement: Loan to value discrepancy. Calculated loan to value percentage of XX% exceeds Guideline loan to value Calculated loan to value percentage of XX% exceeds Guideline loan to value 7/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
percentage of 70.00000%. percentage of XX% with a loan amount greater than $XXX Million
625489603 XXX XXX XXX 34422296 credit 2 Guideline Requirement: Combined loan to value discrepancy. Calculated combined loan to value percentage of XX% exceeds Guideline combined Calculated combined loan to value percentage of XX% exceeds Guideline combined 7/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
loan to value percentage of 70.00000%. loan to value percentage of 70%, with a loan amount greater than $XXX million
625488452 XXX XXX XXX 34422332 credit 2 Verification(s) of employment is not within 10 business days of the Note. Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: Verbal VOE's dated 4/XX/2021 and 4/XX/2021, were not provided within 10 business 5/XX/2021 MA Refinance - Cash-out - Other Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factor
10/XX/2018 days of the Note date of 5/XX/2021
625488452 XXX XXX XXX 34422333 credit 2 Income documentation requirements not met. Verbal VOE's dated 4/XX/2021 and 4/XX/2021, were not provided within 10 business 5/XX/2021 MA Refinance - Cash-out - Other Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factor
days of the Note date of 5/XX/2021
625488790 XXX XXX XXX 34422334 credit 2 Guideline Requirement: Loan to value discrepancy. Calculated loan to value percentage of XX% exceeds Guideline loan to value Loan exceeds maximum LTV of 65%. Lender exception in file. 8/XX/2021 MA Refinance - Cash-out - Other Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
percentage of 65.00000%.
625488790 XXX XXX XXX 34422335 credit 2 Guideline Requirement: Combined loan to value discrepancy. Calculated combined loan to value percentage of XX% exceeds Guideline combined Loan exceeds maximum CLTV of 65%. Lender exception in file. 8/XX/2021 MA Refinance - Cash-out - Other Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
loan to value percentage of 65.00000%.
625488079 XXX XXX XXX 34422337 credit 2 Payment Shock exceeds credit guidelines. Payment Shock: 277.28452% 6/XX/2021 MA Refinance - Cash-out - Other Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
625488079 XXX XXX XXX 34422338 credit 2 REO Documents are missing. Address: XXX, MA, Address: XXX, MA Insurance Verification, Tax Verification 6/XX/2021 MA Refinance - Cash-out - Other Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
Insurance Verification, Tax Verification
625488079 XXX XXX XXX 34422339 credit 2 REO Documents are missing. Address: XXX, MA Insurance Verification, Tax Verification 6/XX/2021 MA Refinance - Cash-out - Other Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
625489522 XXX XXX XXX 34422346 credit 2 REO Documents are missing. 6/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
625489522 XXX XXX XXX 34422347 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement 6/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
625489522 XXX XXX XXX 34422348 credit 2 Guideline Requirement: Investor qualifying total debt ratio discrepancy. Calculated investor qualifying total debt ratio of 67.01477% exceeds Guideline Guideline Requirement: Investor qualifying total debt ratio discrepancy. Lenders 6/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
total debt ratio of 50.00000%. calculation does not include negative cash flow from the investment properties.
625489522 XXX XXX XXX 34422349 credit 2 REO Documents are missing. Address: XXX, MA, Address: XXX, MA Statement Mortgage statement not provided for property located on Empire St. Please 6/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
Statement provide for review
625489522 XXX XXX XXX 34422350 credit 2 AUS/Guideline Findings: All conditions were not met Guideline conditions were not met 6/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
625489522 XXX XXX XXX 34422351 credit 2 Asset documentation requirements not met. Asset documentation requirements not met. 2 months of statements are required. 6/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
625489522 XXX XXX XXX 34422352 credit 2 Income documentation requirements not met. Income documentation requirements not met 6/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
625488976 XXX XXX XXX 34422355 credit 2 Mismatch of data related to Occupancy. Borrower: XXX Occupancy: Investment; Declarations/Will borrower occupy: Yes Occupancy status is showing investment however declarations/will borrower occupy 6/XX/2021 RI Purchase Investment No B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factor
showing as Yes in final 1003 for co- borrower.
625488976 XXX XXX XXX 34422356 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in a FEMA Disaster area. A post-disaster 6/XX/2021 RI Purchase Investment No A A A A 7/XX/2025 1/XX/2025 Yes 2025/XX/07: Client provided BPO extract with current dates and indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage to the subject property is required. damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488976 XXX XXX XXX 34422357 credit 2 Guideline Requirement: Loan to value discrepancy. Calculated loan to value percentage of XX% exceeds Guideline loan to value Calculated LTV is exceeding the guideline limit. 6/XX/2021 RI Purchase Investment No B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factor
percentage of 75.00000%.
625488976 XXX XXX XXX 34422358 credit 2 Guideline Requirement: Combined loan to value discrepancy. Calculated combined loan to value percentage of XX% exceeds Guideline combined Calculated CLTV is exceeding the guideline limit. 6/XX/2021 RI Purchase Investment No B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factor
loan to value percentage of 75.00000%.
625488155 XXX XXX XXX 34422359 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX The subject property is located in FEMA disaster area. A post-disaster 6/XX/2021 MA Purchase Investment Yes A A A A 7/XX/2025 1/XX/2025 Yes 2025/XX/07: Client provided BPO extract with current dates and indicating no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX inspection verifying there was no damage to the subject property is required. damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488155 XXX XXX XXX 34422360 credit 2 REO Documents are missing. Address: XXX, MA, Address: XXX, GA, Address: XXX, GA, Address: XXX, GA, Address: Missing Mortgage statement for REO properties listed Below 6/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factor
XXX, GA, Address: XXX, GA, Address: XXX, GA, Address: XXX, GA Statement XXX, MA
Insurance Verification XXX, GA
Insurance Verification XXX, GA
Insurance Verification XXX, GA
Insurance Verification, Tax Verification XXX, GA:
Insurance Verification XXX, GA
Insurance Verification XXX, GA
Insurance Verification XXX, GA
625488155 XXX XXX XXX 34422361 credit 2 Verification(s) of employment is not within 10 business days of the Note. Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: Verification(s) of employment is not within 10 business days of the Note. 6/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factor
04/XX/2012
625488444 XXX XXX XXX 34422380 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement 7/XX/2021 MA Refinance - Cash-out - Other Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factor
625488444 XXX XXX XXX 34422381 credit 2 The verification of employment is required and was not found in file. Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: The file is missing the verbal verification of employment obtained within ten 7/XX/2021 MA Refinance - Cash-out - Other Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factor
02/XX/2009 business days of closing.
625488444 XXX XXX XXX 34422382 credit 2 Verification(s) of employment is not within 10 business days of the Note. Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: The file is missing the verbal verification of employment obtained within ten 7/XX/2021 MA Refinance - Cash-out - Other Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factor
02/XX/2009 business days of closing.
625488444 XXX XXX XXX 34422383 credit 2 Income documentation requirements not met. The file is missing the borrower's paystub and W-2. Please provide for review. 7/XX/2021 MA Refinance - Cash-out - Other Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factor
625488204 XXX XXX XXX 34422455 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement E-Sign Consent is missing in file. 8/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
625488204 XXX XXX XXX 34422456 credit 2 REO Documents are missing. Address: XXX, MA Statement Mortgage Statement is missing for property located at XXX[ADDRBACKSTOP], MA XXX. 8/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
625488954 XXX XXX XXX 34422457 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement E-Sign Consent Agreement is not provided. 8/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
625488954 XXX XXX XXX 34422458 credit 2 Guideline Issue:Insufficient asset documentation. Financial Institution: XXX // Account Type: Checking / Account Number: XXX Required 2 months consecutive bank statement for Santander account number 6438. 8/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
625488954 XXX XXX XXX 34422459 credit 2 AUS Findings: Available for Reserves discrepancy. Calculated Available for Reserves of $XXX is less than AUS Available for 8/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
Reserves of $XXX.
625488844 XXX XXX XXX 34422464 credit 2 REO Documents are missing. Address: XXX, MA Statement 8/XX/2021 MA Refinance - Cash-out - Other Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
625488229 XXX XXX XXX 34422485 credit 2 Mismatch of data related to Occupancy. Borrower: XXX Occupancy: Investment; Declarations/Will borrower occupy: Yes 11/XX/2021 MA Refinance - Cash-out - Other Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
625489336 XXX XXX XXX 34422498 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement E-sign Consent Agreement is missing. 11/XX/2021 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM (APOR) 2025/XX/14: Client elects to waive with compensating factors.
625489336 XXX XXX XXX 34422500 compliance 2 ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM disclosure not provided. TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2021 11/XX/2022 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM (APOR) 2025/XX/04: Client elected to waive
borrower.
625489336 XXX XXX XXX 34422501 credit 2 Guideline Requirement: Representative FICO score discrepancy. Representative FICO score of 634 is less than Guideline representative FICO FICO score of 634 is less than Guideline representative FICO score of 680. 11/XX/2021 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Safe Harbor QM (APOR) 2025/XX/14: Client elects to waive with compensating factors.
score of 680.
625488939 XXX XXX XXX 34422506 credit 2 REO Documents are missing. Address: XXX, DC HOA Verification, Insurance Verification 10/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
625488939 XXX XXX XXX 34422507 credit 2 REO Documents are missing. Address: XXX, NY HOA Verification 10/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
625488147 XXX XXX XXX 34479078 compliance 1 (Missing Doc) Incomplete loan images/file The file is missing one or more of the core documents required for a review. 11/XX/2020 MO Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2024/XX/26: Refute - Documents loaded to Box in Folder: "Exception Support: 2025/XX/04: Sufficient documentation has been provided for initial review.
Please provide a Note, Security Instrument, initial 1003, final 1003, an AUS, Incomplete Loan Images or File"
Approval or 1008, income verification, asset verification, an origination credit
report, final Title, and all issued LE's and CD's or TIL's, GFE's and HUD1's.
625488147 XXX XXX XXX 34479079 credit 1 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Most Recent Valuation Inspection Date: XX/XX/XXXX 11/XX/2020 MO Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/17: BPO extract provided with current inspection dates showing no
most recent FEMA disaster. Disaster End Date: XX/XX/XXXX damage.
Disaster Name: XXX
Disaster Declaration Date: XX/XX/XXXX
625488147 XXX XXX XXX 34479080 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each Evidence of receipt of appraisal 3 days prior to closing is not in file. 11/XX/2020 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Consummation valuation to applicant three (3) business days prior to consummation.
(Type:Primary/10/XX/2020)
625488147 XXX XXX XXX 34479082 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2020 11/XX/2021 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
CHARM Booklet, not provided to the borrower.
625488147 XXX XXX XXX 34479083 compliance 1 S-Corp Income Documentation Test Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not Missing most recent 2 years tax returns signed and dated, and balance sheets. 11/XX/2020 MO Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/13: Loan is ATR. Tax transcripts instead of signed tax returns were 2025/XX/17: Loan has been re designated at client request
sufficient (S-Corp). (XXX XXX/S-Corp) used. Document attached
625488147 XXX XXX XXX 34479084 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Loan designation discrepancy due to missing most recent 2 years tax returns Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 11/XX/2020 MO Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/13: Loan is ATR. Tax transcripts instead of signed tax returns were 2025/XX/17: Loan has been re designated at client request
QM does not match Due Diligence Loan Designation of Non QM. signed and dated, and balance sheets. Designation to the TPR firm performing the loan level due diligence and to have used. Document attached
the TPR firm confirm said designation.
625488147 XXX XXX XXX 34479086 compliance 2 TRID Final Closing Disclosure Estimated Escrow Payment Under Disclosed TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Escrow discrepancies due to Hazard insurance calculation. Due diligence TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2020 11/XX/2021 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 11/XX/2020 disclosed an escrow payment for payment stream 2 that calculation is higher based on loan data in file. defense to foreclosure. Assignee liability.
does not match the actual payment for the loan. (ProjSeq:2/2671682)
625488147 XXX XXX XXX 34479087 compliance 2 TRID Final Closing Disclosure Estimated Escrow Payment Under Disclosed TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Escrow discrepancies due to Hazard insurance calculation. Due diligence TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2020 11/XX/2021 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 11/XX/2020 disclosed an escrow payment for payment stream 3 that calculation is higher based on loan data in file. defense to foreclosure. Assignee liability.
does not match the actual payment for the loan. (ProjSeq:3/2671683)
625488147 XXX XXX XXX 34479088 compliance 2 TRID Final Closing Disclosure Estimated Escrow Payment Under Disclosed TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Escrow discrepancies due to Hazard insurance calculation. Due diligence TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2020 11/XX/2021 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 11/XX/2020 disclosed an escrow payment for payment stream 4 that calculation is higher based on loan data in file. defense to foreclosure. Assignee liability.
does not match the actual payment for the loan. (ProjSeq:4/2671684)
625488147 XXX XXX XXX 34479089 compliance 2 TRID Final Closing Disclosure Estimated Escrow Payment Under Disclosed Test TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Escrow discrepancies due to Hazard insurance calculation. Due diligence TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2020 11/XX/2021 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 11/XX/2020 disclosed an escrow payment for payment stream 1 that calculation is higher based on loan data in file. defense to foreclosure. Assignee liability.
does not match the actual payment for the loan. (ProjSeq:1/2671681)
625488147 XXX XXX XXX 34479090 compliance 2 Check Restated Loan Designation Match - General Ability to Repay Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did Loan has been re designated at client request Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 11/XX/2020 MO Purchase Primary No B B A A 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
not match. However, the updated Loan Designation of Non QM matches the Due Designation to the TPR firm performing the loan level due diligence and to have
Diligence Loan Designation of Non QM. the TPR firm confirm said designation.
625488236 XXX XXX XXX 34479092 compliance 2 TRID Final Closing Disclosure Escrowed Property Costs Year 1 Overdisclosed - TILA-RESPA Integrated Disclosure - Loan Disclosures: Escrowed Property Costs Escrowed Property Costs over Year 1 year not provided in closing disclosure. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 5/XX/2021 5/XX/2022 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
October 2018 Construction Permanent over Year 1 of XXX on Final Closing Disclosure provided on 05/XX/2021 are liability.
overdisclosed. (Final/05/XX/2021)
625488236 XXX XXX XXX 34479097 compliance 2 TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Closing disclosure Projected payment not matching with Calculated payments. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2021 5/XX/2022 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 05/XX/2021 disclosed an Estimated Total Monthly Payment for payment defense to foreclosure. Assignee liability.
stream 3 that does not match the actual total payment for the loan.
(ProjSeq:3/2646220)
625488236 XXX XXX XXX 34479098 compliance 2 TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Closing disclosure Projected payment not matching with Calculated payments. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2021 5/XX/2022 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 05/XX/2021 disclosed an Estimated Total Monthly Payment for payment defense to foreclosure. Assignee liability.
stream 4 that does not match the actual total payment for the loan.
(ProjSeq:4/2646221)
625488236 XXX XXX XXX 34479099 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Closing disclosure Projected payment not matching with Calculated payments. TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 5/XX/2021 5/XX/2022 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 05/XX/2021 with an increasing payment disclosed the due date of the last Assignee liability.
payment of interest only that does not match the actual last payment for the
loan. (Final/05/XX/2021)
625488236 XXX XXX XXX 34479100 compliance 2 TRID Initial Loan Estimate Timing Electronically Provided TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the Inital loan estimate received on 04/XX/2021 and Application date is 11/XX/2020. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 5/XX/2021 5/XX/2022 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
mail to Borrower(s) within three (3) business days of application. liability.
(Initial/04/XX/2021)
625488236 XXX XXX XXX 34479101 compliance 2 TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Ten Percent Fee Tolerance exceeded. Total amount of $XXX exceeds tolerance of 5/XX/2021 5/XX/2022 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no $XXX . no Valdi change circumstance in file.
cure was provided to the borrower. (0)
625488236 XXX XXX XXX 34479102 compliance 2 TRID Final Closing Disclosure Total Of Payments TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Final Closing Disclosure provided on 05/XX/2021 disclosed an inaccurate Total of TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2021 5/XX/2022 MO Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 05/XX/2021 disclosed an inaccurate Total of Payments on page 5 that Payments on page 5 that does not match the actual total of payments for the loan defense to foreclosure. Assignee liability.
does not match the actual total of payments for the loan (fee amounts included (fee amounts included in TOP calculation are based on Closing Disclosure dated
in TOP calculation are based on Closing Disclosure dated 05/XX/2021). The 05/XX/2021). The disclosed Total of Payments in the amount of $XXX is under
disclosed Total of Payments in the amount of $XXX is under disclosed by $XXX disclosed by $XXX compared to the calculated total of payments of $XXX
compared to the calculated total of payments of $XXX which exceeds the $XXX
threshold. (Final/05/XX/2021)
625488896 XXX XXX XXX 34479108 compliance 2 General Ability To Repay Provision Investor Qualification Method not Matching Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender Ability To Repay Provision Investor Qualification Method not Matching ATR 4/XX/2021 MN Refinance - Cash-out - Home Improvement Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
ATR does not match the ATR payment calculation methods under 1026.43(c)(5).
625488896 XXX XXX XXX 34479110 compliance 2 TRID Final Closing Disclosure AP Table Interest Only Payment TILA-RESPA Integrated Disclosure - Adjustable Payment Table: Final Closing Adjustable Payment Table: Final Closing Disclosure provided on 04/XX/2021 TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 4/XX/2021 4/XX/2022 MN Refinance - Cash-out - Home Improvement Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Disclosure provided on 04/XX/2021 incorrectly disclosed whether the loan incorrectly disclosed whether the loan contains Interest Only Payments due to liability.
contains Interest Only Payments. (Final/04/XX/2021) Construction loan terms.
625488896 XXX XXX XXX 34479111 compliance 2 TRID Final Closing Disclosure AP Table Maximum Payment TILA-RESPA Integrated Disclosure - Adjustable Payment Table: Final Closing Projected Payment and Term Structure on CD and Note is mismatched due to TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 4/XX/2021 4/XX/2022 MN Refinance - Cash-out - Home Improvement Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Disclosure provided on 04/XX/2021 disclosed a Maximum Payment amount and period construction terms on loan. liability.
that does not match the actual terms for the loan. (Final/04/XX/2021)
625488896 XXX XXX XXX 34479112 compliance 2 TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Projected Payment and Term Structure on CD and Note is mismatched due to TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 4/XX/2021 4/XX/2022 MN Refinance - Cash-out - Home Improvement Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 04/XX/2021 disclosed an Estimated Total Monthly Payment for payment construction terms on loan. defense to foreclosure. Assignee liability.
stream 2 that does not match the actual total payment for the loan.
(ProjSeq:2/2647217)
625488896 XXX XXX XXX 34479113 compliance 2 TRID Final Closing Disclosure Payment Adjusts Every Test TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Projected Payment and Term Structure on CD and Note is mismatched due to TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 4/XX/2021 4/XX/2022 MN Refinance - Cash-out - Home Improvement Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 04/XX/2021 with an increasing payment did not disclose the frequency of construction terms on loan. Assignee liability.
adjustments. (Final/04/XX/2021)
625488896 XXX XXX XXX 34479114 compliance 2 TRID Final Closing Disclosure Projected P&I Min Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Projected Payment and Term Structure on CD and Note is mismatched due to TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 4/XX/2021 4/XX/2022 MN Refinance - Cash-out - Home Improvement Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 04/XX/2021 did not disclose the periodic principal and interest construction terms on loan. defense to foreclosure. Assignee liability.
payment for payment stream 2. (ProjSeq:2/2647217)
625488896 XXX XXX XXX 34479115 compliance 2 TRID Final Closing Disclosure Projected Principal And Interest Payment Max TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Projected Payment and Term Structure on CD and Note is mismatched due to TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 4/XX/2021 4/XX/2022 MN Refinance - Cash-out - Home Improvement Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Payment Adjustable Rate provided on 04/XX/2021 disclosed a maximum periodic principal and interest construction terms on loan. defense to foreclosure. Assignee liability.
payment for payment stream 2 that does not match the actual maximum payment for
the loan. (ProjSeq:2/2647217)
625488896 XXX XXX XXX 34479116 compliance 2 TRID Interim Closing Disclosure Timing Irregular Transactions Test TILA-RESPA Integrated Disclosure – Corrected Closing Disclosure provided on or Closing Disclosure provided on 04/XX/2021 does not reflect an APR therefore when TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 4/XX/2021 4/XX/2022 MN Refinance - Cash-out - Home Improvement Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
after 04/XX/2021 contains a change in APR and was not received by borrower at the final was provided it reflects a change. Initial Closing Disclosure dated liability.
least three (3) business days prior to consummation 04/XX/2021 reflects same APR as final.
625488896 XXX XXX XXX 34479117 compliance 2 TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Ten Percent Fee Tolerance exceeded. Total amount of $XXX exceeds tolerance of 4/XX/2021 4/XX/2022 MN Refinance - Cash-out - Home Improvement Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no $XXX plus 10% or $XXX. Insufficient or no cure was provided to the borrower.
cure was provided to the borrower. (0)
625488896 XXX XXX XXX 34479118 compliance 2 TRID Final Closing Disclosure Escrowed Property Costs Year 1 Overdisclosed - TILA-RESPA Integrated Disclosure - Loan Disclosures: Escrowed Property Costs TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 4/XX/2021 4/XX/2022 MN Refinance - Cash-out - Home Improvement Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
October 2018 Construction Permanent over Year 1 of XXX on Final Closing Disclosure provided on 04/XX/2021 are liability.
overdisclosed. (Final/04/XX/2021)
625488896 XXX XXX XXX 34479120 compliance 2 TRID Final Closing Disclosure AP Table First Change Period TILA-RESPA Integrated Disclosure - Adjustable Payment Table: Final Closing Final Closing Disclosure provided on 04/XX/2021 incorrectly disclosed the First TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 4/XX/2021 4/XX/2022 MN Refinance - Cash-out - Home Improvement Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Disclosure provided on 04/XX/2021 incorrectly disclosed the First Change period Change period according to the disclosed Loan Product. liability.
according to the disclosed Loan Product. (Final/04/XX/2021)
625488896 XXX XXX XXX 34479121 compliance 2 TRID Final Closing Disclosure AP Table Subsequent Changes Test TILA-RESPA Integrated Disclosure - Adjustable Payment Table: Final Closing Final Closing Disclosure provided on 04/XX/2021 disclosed a Subsequent Changes TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 4/XX/2021 4/XX/2022 MN Refinance - Cash-out - Home Improvement Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Disclosure provided on 04/XX/2021 disclosed a Subsequent Changes period that period that does not match the actual terms for the loan. liability.
does not match the actual terms for the loan. (Final/04/XX/2021)
625488896 XXX XXX XXX 34479122 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final Closing Disclosure provided on 04/XX/2021 with an increasing payment TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 4/XX/2021 4/XX/2022 MN Refinance - Cash-out - Home Improvement Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 04/XX/2021 with an increasing payment disclosed the due date of the last disclosed the due date of the last payment of interest only that does not match Assignee liability.
payment of interest only that does not match the actual last payment for the the actual last payment for the loan.
loan. (Final/04/XX/2021)
625489559 XXX XXX XXX 34479123 compliance 2 ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each No evidence that borrower received a copy of appraisal 3 business days to 6/XX/2021 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Consummation valuation to applicant three (3) business days prior to consummation. closing.
(Type:Primary/06/XX/2021)
625489559 XXX XXX XXX 34479126 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 6/XX/2021 6/XX/2024 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
625489559 XXX XXX XXX 34479128 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final Closing Disclosure provided on 06/XX/2021 with an increasing payment TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 6/XX/2021 6/XX/2022 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 06/XX/2021 with an increasing payment disclosed the due date of the last disclosed the due date of the last payment of interest only that does not match Assignee liability.
payment of interest only that does not match the actual last payment for the the actual last payment for the loan.
loan. (Final/06/XX/2021)
625489559 XXX XXX XXX 34479129 compliance 2 TRID Final Closing Disclosure Property Costs Year 1 Overdisclosed - October 2018 TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Amount of Estimated Property Costs over Year 1 of XXX on Final Closing TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 6/XX/2021 6/XX/2022 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Construction Permanent Property Costs over Year 1 of XXX on Final Closing Disclosure provided on Disclosure provided on 06/XX/2021 are overdisclosed. liability.
06/XX/2021 are overdisclosed. (Final/06/XX/2021)
625489559 XXX XXX XXX 34479130 compliance 2 TRID Lender Credit Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure:Zero Percent Fee Tolerance exceeded for Lender Final Lender Credit of -$XXX exceeds tolerance of -$XXX. No valid COC in file. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 6/XX/2021 6/XX/2022 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Credits. Final Lender Credit of -$XXX exceeds tolerance of -$XXX. Insufficient liability.
or no cure was provided to the borrower. (9300)
625489559 XXX XXX XXX 34479131 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Flood Fee Amount of $XXX exceeds tolerance of $XXX. No valid COC in file. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 6/XX/2021 6/XX/2022 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Certification (Life Of Loan). Fee Amount of $XXX exceeds tolerance of $XXX. liability.
Insufficient or no cure was provided to the borrower. (7579)
625489559 XXX XXX XXX 34479132 compliance 2 TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Fee Amount of $XXX exceeds tolerance of $XXX. No valid COC in file. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 6/XX/2021 6/XX/2022 IL Refinance - Rate/Term Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Service Fee (Life Of Loan). Fee Amount of $XXX exceeds tolerance of $XXX. liability.
Insufficient or no cure was provided to the borrower. (7580)
625488579 XXX XXX XXX 34479133 compliance 1 QM Employment History Qualified Mortgage (Dodd-Frank 2014): Employment history requirement not met. Letter of Explanation not provided for Employment Gap. 5/XX/2021 IL Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/07: Gap was from 6/XX/20 to 8/XX/20. This is just over 30 days. No LOX 2025/XX/15: Gap in employment letter is an Appendix Q requirement. Exception
(XXX XXX/14557081) requested/Covid. remains open.
2025/XX/17: Loan has been re designated at client request
625488579 XXX XXX XXX 34479134 compliance 2 General Ability To Repay Provision Investor Qualification Method not Matching Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender Letter of Explanation not provided for Employment Gap. 5/XX/2021 IL Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
ATR does not match the ATR payment calculation methods under 1026.43(c)(5).
625488579 XXX XXX XXX 34479135 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Originator Loan Designation mismatch due to Letter of Explanation not provided Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 5/XX/2021 IL Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/07: Gap was from 6/XX/20 to 8/XX/20. This is just over 30 days. No LOX 2025/XX/15: Gap in employment letter is an Appendix Q requirement. Exception
QM does not match Due Diligence Loan Designation of Non QM. for Employment Gap. Designation to the TPR firm performing the loan level due diligence and to have requested/Covid. remains open.
the TPR firm confirm said designation.
2025/XX/17: Loan has been re designated at client request
625488579 XXX XXX XXX 34479138 compliance 2 Check Restated Loan Designation Match - General Ability to Repay Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did Loan has been re designated at client request Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 5/XX/2021 IL Purchase Primary No B B A A 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
not match. However, the updated Loan Designation of Non QM matches the Due Designation to the TPR firm performing the loan level due diligence and to have
Diligence Loan Designation of Non QM. the TPR firm confirm said designation.
625489327 XXX XXX XXX 34479139 compliance 1 Rental Income Documentation - Schedule E Method Test Qualified Mortgage (Dodd-Frank 2014): Rental income documentation requirement Lease agreement not provided. 6/XX/2021 IL Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/13: 2020 and 2019 tax returns and transcripts uploaded. Since we used 2025/XX/17: Loan has been re designated at client request
not met for XXX. Lease Agreement and/or Tax Return not provided. (XXX/Schedule the tax returns, Schedule E, for rental income, the lease agreement is not
E) needed. For 2019's tax transcripts Management accepted letter from CPA, amended
2019 return and proof of payment in lieu of 2019 transcripts.
625489327 XXX XXX XXX 34479140 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Lease agreement not provided for REO, XXX. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 6/XX/2021 IL Purchase Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/13: 2020 and 2019 tax returns and transcripts uploaded. Since we used 2025/XX/17: Loan has been re designated at client request
QM does not match Due Diligence Loan Designation of Non QM. Designation to the TPR firm performing the loan level due diligence and to have the tax returns, Schedule E, for rental income, the lease agreement is not
the TPR firm confirm said designation. needed. For 2019's tax transcripts Management accepted letter from CPA, amended
2019 return and proof of payment in lieu of 2019 transcripts.
625489327 XXX XXX XXX 34479143 compliance 2 Check Restated Loan Designation Match - General Ability to Repay Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did Loan has been re designated at client request Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 6/XX/2021 IL Purchase Primary No B B A A 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
not match. However, the updated Loan Designation of Non QM matches the Due Designation to the TPR firm performing the loan level due diligence and to have
Diligence Loan Designation of Non QM. the TPR firm confirm said designation.
625488170 XXX XXX XXX 34479151 compliance 2 TRID Lender Credit Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure:Zero Percent Fee Tolerance exceeded for Lender Lender Credit Fee was last disclosed as -$$XXX on LE but disclosed as $XXX on TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 7/XX/2021 7/XX/2022 IL Purchase Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Credits. Final Lender Credit of $XXX exceeds tolerance of -$XXX. Insufficient or Final Closing Disclosure. File does not contain a valid COC for this fee, nor liability.
no cure was provided to the borrower. (9300) evidence of cure in file. Provide a post-close CD disclosing the tolerance cure
to include $XXX, a copy of refund check, proof of delivery, and a copy of the
letter of explanation sent to the borrower disclosing the changes made.
625488583 XXX XXX XXX 34479160 credit 2 REO Documents are missing. Address: XXX, IL Insurance Verification, Tax Verification Investment property taxes and insurance are missing. 12/XX/2021 IL Construction-Permanent Primary No B B B B 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/18: Compensating Factors for waive and downgrade.
625488583 XXX XXX XXX 34479161 compliance 1 Federal Loan Originator Compensation - Individual LO Not NMLS Licensed at Time Truth in Lending Act (NMLSR Dodd- Frank 2014): Individual Loan Originator not "Assignee Liability: Civil actions that may be brought against a creditor may be 12/XX/2021 12/XX/2024 IL Construction-Permanent Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: transcripts, profit and loss, proof lender (XXX) was licensed all 2025/XX/14: Exception cleared. NMLS data updated correctly.
of Application NMLS licensed or registered at time of application. maintained against any assignee only if the violation is apparent on the face of uploaded. Proof co-borrower is self-employed can see borrower is a XXX (sch c
the disclosure or other documents assigned, except where the assignment was income) and llc search of XXX is also uploaded
involuntary. This civil liability may include $XXX in the case of an individual
transaction, or the lesser of $XXX or 1% of the creditor's net worth in the case
of a class action (effective 1/XX/14, this amount increases to the lesser of
$XXX or 1%), as well as actual damages, court costs, and attorneys' fees. For an
anti-steering violation, the creditor may also be liable in an amount equal to
the sum of all finance charges and fees paid by the consumer, unless the
creditor demonstrates the failure to comply is not material. Notwithstanding any
other provision of law, when a creditor, assignee, or other holder or anyone
acting on behalf of the creditor, assignee, or holder, initiates a judicial or
nonjudicial foreclosure of the residential mortgage loan, or any other action to
collect the debt in connection with such loan, a consumer may assert a violation
as a matter of defense by recoupment or set off without regard for the time
limit on a private action for damages.
Effective 1/XX/2014 in addition to the aforementioned, the individual Loan
Originator could be liable for statutory damages. The maximum liability is the
greater of actual damages or 3 times the loan originator's compensation or gain,
plus the cost to the consumer of the action. The Dodd-Frank Act extended the
statute of limitations on TILA violations to 3 years from the date of the
violation."
625488583 XXX XXX XXX 34479162 compliance 1 Check Loan Designation Match - ATR Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Due to missing 1040s not signed and dated. Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 12/XX/2021 IL Construction-Permanent Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: transcripts, profit and loss, proof lender (XXX) was licensed all 2025/XX/22: Transcripts provided, system cleared.
not match Due Diligence Loan Designation of ATR Fail. Designation to the TPR firm performing the loan level due diligence and to have uploaded. Proof co-borrower is self-employed can see borrower is a XXX (sch c
the TPR firm confirm said designation. income) and llc search of XXX is also uploaded
625488583 XXX XXX XXX 34479163 compliance 1 General Ability To Repay Provision Employment - Schedule C Test Ability-to-Repay (Dodd-Frank 2014): Unable to verify current Sole Proprietorship Due to following missing documents is required for this employment type: 1) Assignee Liability: Violations can result in regular TILA damages (actual 12/XX/2021 IL Construction-Permanent Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: transcripts, profit and loss, proof lender (XXX) was licensed all 2025/XX/22: Third party verification provided, system cleared.
status using reasonably reliable third-party records. (XXX XXX/Schedule C) Third Party Verification; 2) CPA Letter; 3) Audited or Third Party Prepared YTD damages, statutory damages of up to $XXX costs, and attorney's fees) and uploaded. Proof co-borrower is self-employed can see borrower is a XXX (sch c
P&L; 4) Most recent transcript or signed/dated tax return (tax year end date no enhanced damages (an amount equal to the sum of all finance charges and fees income) and llc search of XXX is also uploaded
more than 120 days prior to Note Date); 5) Other document where "Reliable Third paid by the consumer, unless the creditor demonstrates that the failure to
Party Source Employment" is checked; 6) 1099 comply is not material). A private right of action may be brought before the end
of the three-year period beginning on the date of the occurrence of the
violation. However, when a creditor, assignee, or other holder or anyone acting
on their behalf initiates a judicial or non-judicial foreclosure, or any other
action to collect the debt, a consumer may assert a violation as a matter of
defense by recoupment or set-off without regard to a time limit. The amount of
recoupment or set-off shall equal the amount to which the consumer would be
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625488583 XXX XXX XXX 34479164 compliance 1 General Ability To Repay Provision Employment - Schedule C Test Ability-to-Repay (Dodd-Frank 2014): Unable to verify current Sole Proprietorship Due to following missing documents is required for this employment type: 1) Assignee Liability: Violations can result in regular TILA damages (actual 12/XX/2021 IL Construction-Permanent Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: transcripts, profit and loss, proof lender (XXX) was licensed all 2025/XX/22: Third party verification provided, system cleared.
status using reasonably reliable third-party records. (XXX XXX/Schedule C) Third Party Verification; 2) CPA Letter; 3) Audited or Third Party Prepared YTD damages, statutory damages of up to $XXX costs, and attorney's fees) and uploaded. Proof co-borrower is self-employed can see borrower is a XXX (sch c
P&L; 4) Most recent transcript or signed/dated tax return (tax year end date no enhanced damages (an amount equal to the sum of all finance charges and fees income) and llc search of XXX is also uploaded
more than 120 days prior to Note Date); 5) Other document where "Reliable Third paid by the consumer, unless the creditor demonstrates that the failure to
Party Source Employment" is checked; 6) 1099 comply is not material). A private right of action may be brought before the end
of the three-year period beginning on the date of the occurrence of the
violation. However, when a creditor, assignee, or other holder or anyone acting
on their behalf initiates a judicial or non-judicial foreclosure, or any other
action to collect the debt, a consumer may assert a violation as a matter of
defense by recoupment or set-off without regard to a time limit. The amount of
recoupment or set-off shall equal the amount to which the consumer would be
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625488583 XXX XXX XXX 34479165 compliance 1 General Ability To Repay Provision Income and Assets - Schedule C Ability to Repay (Dodd-Frank 2014): Unable to verify Sole Proprietorship income Due to following missing documents is required for this income source: 1) Most Assignee Liability: Violations can result in regular TILA damages (actual 12/XX/2021 IL Construction-Permanent Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: transcripts, profit and loss, proof lender (XXX) was licensed all 2025/XX/22: Transcripts provided, system cleared.
using reasonably reliable third-party records. (XXX XXX/Schedule C) recent tax transcripts; 2) Most recent signed, dated 1040s; 3) Audited YTD P&L; damages, statutory damages of up to $XXX costs, and attorney's fees) and uploaded. Proof co-borrower is self-employed can see borrower is a XXX (sch c
4) 1099 enhanced damages (an amount equal to the sum of all finance charges and fees income) and llc search of XXX is also uploaded
paid by the consumer, unless the creditor demonstrates that the failure to
comply is not material). A private right of action may be brought before the end
of the three-year period beginning on the date of the occurrence of the
violation. However, when a creditor, assignee, or other holder or anyone acting
on their behalf initiates a judicial or non-judicial foreclosure, or any other
action to collect the debt, a consumer may assert a violation as a matter of
defense by recoupment or set-off without regard to a time limit. The amount of
recoupment or set-off shall equal the amount to which the consumer would be
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625488583 XXX XXX XXX 34479166 compliance 1 General Ability To Repay Provision Income and Assets - Schedule C Ability to Repay (Dodd-Frank 2014): Unable to verify Sole Proprietorship income Due to following missing documents is required for this income source: 1) Most Assignee Liability: Violations can result in regular TILA damages (actual 12/XX/2021 IL Construction-Permanent Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: transcripts, profit and loss, proof lender (XXX) was licensed all 2025/XX/22: Transcripts provided, system cleared.
using reasonably reliable third-party records. (XXX XXX/Schedule C) recent tax transcripts; 2) Most recent signed, dated 1040s; 3) Audited YTD P&L; damages, statutory damages of up to $XXX costs, and attorney's fees) and uploaded. Proof co-borrower is self-employed can see borrower is a XXX (sch c
4) 1099 enhanced damages (an amount equal to the sum of all finance charges and fees income) and llc search of XXX is also uploaded
paid by the consumer, unless the creditor demonstrates that the failure to
comply is not material). A private right of action may be brought before the end
of the three-year period beginning on the date of the occurrence of the
violation. However, when a creditor, assignee, or other holder or anyone acting
on their behalf initiates a judicial or non-judicial foreclosure, or any other
action to collect the debt, a consumer may assert a violation as a matter of
defense by recoupment or set-off without regard to a time limit. The amount of
recoupment or set-off shall equal the amount to which the consumer would be
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625488583 XXX XXX XXX 34479167 compliance 2 General Ability To Repay Provision Investor Qualification Method not Matching Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender Due to missing 1040s not signed and dated. 12/XX/2021 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
ATR does not match the ATR payment calculation methods under 1026.43(c)(5).
625488583 XXX XXX XXX 34479168 compliance 1 Income/Asset Guideline Deficiency - ATR Impact Ability to Repay (Dodd-Frank 2014): There are guideline deficiencies related to Due to missing 1040s not signed and dated. 12/XX/2021 IL Construction-Permanent Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: transcripts, profit and loss, proof lender (XXX) was licensed all 2025/XX/22: Transcripts provided, system cleared.
income and/or asset doc requirements which could result in a risk to the uploaded. Proof co-borrower is self-employed can see borrower is a XXX (sch c
borrower's ability to repay. (Exception is eligible to be regraded with income) and llc search of XXX is also uploaded
compensating factors.)
625488583 XXX XXX XXX 34479171 compliance 2 TRID Final Closing Disclosure Escrowed Property Costs Year 1 Overdisclosed - TILA-RESPA Integrated Disclosure - Loan Disclosures: Escrowed Property Costs TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 12/XX/2021 12/XX/2022 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
October 2018 Construction Permanent over Year 1 of XXX on Final Closing Disclosure provided on 12/XX/2021 are liability.
overdisclosed. (Final/12/XX/2021)
625488583 XXX XXX XXX 34479172 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Projected Payment and Term Structure on CD and Note is mismatched. As per Note TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 12/XX/2021 12/XX/2022 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 12/XX/2021 with an increasing payment disclosed the due date of the last loan term is 348 Months and CD reflects 360 months along with 1 year interest Assignee liability.
payment of interest only that does not match the actual last payment for the only payments. Additionally Mortgage Insurance Payment Starts from 2nd Year.
loan. (Final/12/XX/2021)
625488583 XXX XXX XXX 34479173 compliance 2 TRID Final Closing Disclosure Projected P&I Min Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Projected Payment and Term Structure on CD and Note is mismatched. As per Note TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 12/XX/2021 12/XX/2022 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 12/XX/2021 disclosed a periodic principal and interest payment for loan term is 348 Months and CD reflects 360 months along with 1 year interest defense to foreclosure. Assignee liability.
payment stream 3 that does not match the actual payment for the loan. only payments. Additionally Mortgage Insurance Payment Starts from 2nd Year.
(ProjSeq:3/2654942)
625488583 XXX XXX XXX 34479174 compliance 2 TRID Final Closing Disclosure Total Of Payments TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Projected Payment and Term Structure on CD and Note is mismatched. As per Note TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 12/XX/2021 12/XX/2022 IL Construction-Permanent Primary No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 12/XX/2021 disclosed an inaccurate Total of Payments on page 5 that loan term is 348 Months and CD reflects 360 months along with 1 year interest defense to foreclosure. Assignee liability.
does not match the actual total of payments for the loan (fee amounts included only payments. Additionally Mortgage Insurance Payment Starts from 2nd Year.
in TOP calculation are based on Closing Disclosure dated 01/XX/2022). The
disclosed Total of Payments in the amount of $XXX is under disclosed by $XXX
compared to the calculated total of payments of $XXX which exceeds the $XXX
threshold. (Final/12/XX/2021)
625488583 XXX XXX XXX 34479175 credit 2 Income documentation requirements not met. Due to following missing documents is required for this employment type: 1) 12/XX/2021 IL Construction-Permanent Primary No B B B B 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/18: Compensating Factors for waive and downgrade.
Third Party Verification; 2) CPA Letter; 3) Audited or Third Party Prepared YTD
P&L; 4) Most recent transcript or signed/dated tax return (tax year end date no
more than 120 days prior to Note Date); 5) Other document where "Reliable Third
Party Source Employment" is checked; 6) 1099
625488583 XXX XXX XXX 34479176 compliance 1 General Ability To Repay Provision Investor Guidelines Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more Guideline requirement not met due to 1040s is not signed and dated; Therefore 12/XX/2021 IL Construction-Permanent Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: transcripts, profit and loss, proof lender (XXX) was licensed all 2025/XX/22: Transcripts provided, system cleared.
guideline components, the loan is at ATR risk. ATR risk failed. uploaded. Proof co-borrower is self-employed can see borrower is a XXX (sch c
income) and llc search of XXX is also uploaded
625488583 XXX XXX XXX 34479178 compliance 1 Check Loan Designation Match - ATR Risk Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 12/XX/2021 IL Construction-Permanent Primary No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/22: Transcripts provided, system cleared.
not match Due Diligence Loan Designation of ATR Risk. Designation to the TPR firm performing the loan level due diligence and to have
the TPR firm confirm said designation.
625489696 XXX XXX XXX 34479179 credit 2 Available for Closing is insufficient to cover Cash From Borrower. Documented qualifying Assets for Closing of $XXX is less than Cash From Borrower Documented qualifying Assets for Closing of $XXX is less than Cash From Borrower 1/XX/2022 MI Refinance - Rate/Term Second Home No B B B B 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/18: Compensating Factors for waive and downgrade.
$XXX. $XXX.
625489696 XXX XXX XXX 34479180 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement E-sign consent is missing in loan file 1/XX/2022 MI Refinance - Rate/Term Second Home No B B B B 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/18: Compensating Factors for waive and downgrade.
625489696 XXX XXX XXX 34479181 compliance 2 Disclosed Note P&I payment does not equal calculated P&I payment Disclosed Note P&I payment does not equal calculated P&I payment. Note P&I of P&I payment. Note P&I of $XXX does not match calculated P&I of $XXX. Note P&I 1/XX/2022 MI Refinance - Rate/Term Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
$XXX does not match calculated P&I of $XXX. Note P&I was used for the APR was used for the APR calculation and compliance testing.
calculation and compliance testing.
625489696 XXX XXX XXX 34479182 compliance 1 Check Loan Designation Match - ATR Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does Originator Loan Designation of Non QM does not match Due Diligence Loan Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 1/XX/2022 MI Refinance - Rate/Term Second Home No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: Underwriter used Global Cash Flow for qualifying income. attached 2025/XX/22: Transcripts provided, system cleared.
not match Due Diligence Loan Designation of ATR Fail. Designation of ATR Fail. Designation to the TPR firm performing the loan level due diligence and to have the Global Cash Flow and UW income calc to the Sharepoint. I also attached the
the TPR firm confirm said designation. secretary of state printout as a verbal in case the reviewer was looking for
this
625489696 XXX XXX XXX 34479183 compliance 1 General Ability To Repay Provision Income and Assets - S-Corp Ability to Repay (Dodd-Frank 2014): Unable to verify S-Corp income using Unable to verify S-Corp income using reasonably reliable third-party records. Assignee Liability: Violations can result in regular TILA damages (actual 1/XX/2022 MI Refinance - Rate/Term Second Home No A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/08: Underwriter used Global Cash Flow for qualifying income. attached 2025/XX/22: Transcripts provided, system cleared.
reasonably reliable third-party records. (XXX/S-Corp) (XXX/S-Corp) damages, statutory damages of up to $XXX costs, and attorney's fees) and the Global Cash Flow and UW income calc to the Sharepoint. I also attached the
enhanced damages (an amount equal to the sum of all finance charges and fees secretary of state printout as a verbal in case the reviewer was looking for
paid by the consumer, unless the creditor demonstrates that the failure to this
comply is not material). A private right of action may be brought before the end
of the three-year period beginning on the date of the occurrence of the
violation. However, when a creditor, assignee, or other holder or anyone acting
on their behalf initiates a judicial or non-judicial foreclosure, or any other
action to collect the debt, a consumer may assert a violation as a matter of
defense by recoupment or set-off without regard to a time limit. The amount of
recoupment or set-off shall equal the amount to which the consumer would be
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625489696 XXX XXX XXX 34479184 compliance 2 General Ability To Repay Provision Investor Qualification Method not Matching Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender The Qualification Method used by the lender does not match the ATR payment 1/XX/2022 MI Refinance - Rate/Term Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
ATR does not match the ATR payment calculation methods under 1026.43(c)(5). calculation methods under 1
625489696 XXX XXX XXX 34479185 compliance 2 TRID Final Closing Disclosure AP Table Maximum Payment TILA-RESPA Integrated Disclosure - Adjustable Payment Table: Final Closing Final Closing Disclosure provided on 01/XX/2022 disclosed a Maximum Payment TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 1/XX/2022 1/XX/2023 MI Refinance - Rate/Term Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Disclosure provided on 01/XX/2022 disclosed a Maximum Payment amount and period amount and period that does not match the actual terms for the loan. liability.
that does not match the actual terms for the loan. (Final/01/XX/2022)
625489696 XXX XXX XXX 34479186 compliance 2 TRID Final Closing Disclosure AP Table Subsequent Changes Test TILA-RESPA Integrated Disclosure - Adjustable Payment Table: Final Closing Final Closing Disclosure provided on 01/XX/2022 disclosed a Subsequent Changes TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 1/XX/2022 1/XX/2023 MI Refinance - Rate/Term Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Disclosure provided on 01/XX/2022 disclosed a Subsequent Changes period that period that does not match the actual terms for the loan. liability.
does not match the actual terms for the loan. (Final/01/XX/2022)
625489696 XXX XXX XXX 34479187 compliance 2 TRID Final Closing Disclosure Balloon Payment Test TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final Closing Disclosure provided on 01/XX/2022 incorrectly disclosed whether TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 1/XX/2022 1/XX/2023 MI Refinance - Rate/Term Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 01/XX/2022 incorrectly disclosed whether the loan contains a Balloon Payment. the loan contains a Balloon Payment. (Final/01/XX/2022) defense to foreclosure. Assignee liability.
(Final/01/XX/2022)
625489696 XXX XXX XXX 34479189 compliance 2 TRID Final Closing Disclosure Payment Interest Only Until TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided Final Closing Disclosure provided on 01/XX/2022 with an increasing payment TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 1/XX/2022 1/XX/2023 MI Refinance - Rate/Term Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 01/XX/2022 with an increasing payment disclosed the due date of the last disclosed the due date of the last payment of interest only that does not match Assignee liability.
payment of interest only that does not match the actual last payment for the the actual last payment for the loan. (Final/01/XX/2022
loan. (Final/01/XX/2022)
625489696 XXX XXX XXX 34479190 compliance 2 TRID Final Closing Disclosure Payment Max Amount TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided : Final Closing Disclosure provided on 01/XX/2022 with an increasing payment TILA SOL 1 year from consummation. Unlimited as a defense to foreclosure. 1/XX/2022 1/XX/2023 MI Refinance - Rate/Term Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
on 01/XX/2022 with an increasing payment disclosed the maximum possible amount disclosed the maximum possible amount of principal and interest that does not Assignee liability.
of principal and interest that does not match the actual maximum amount for the match the actual maximum amount for the loan.
loan. (Final/01/XX/2022)
625489696 XXX XXX XXX 34479191 compliance 2 TRID Final Closing Disclosure Projected P&I Min Payment Adjustable Rate TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure Final Closing Disclosure provided on 01/XX/2022 disclosed a periodic principal TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 1/XX/2022 1/XX/2023 MI Refinance - Rate/Term Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Subsequent Payments provided on 01/XX/2022 disclosed a periodic principal and interest payment for and interest payment for payment stream 4 that does not match the actual payment defense to foreclosure. Assignee liability.
payment stream 4 that does not match the actual payment for the loan. for the loan. (ProjSeq:4/2654025)
(ProjSeq:4/2654025)
625489696 XXX XXX XXX 34479192 compliance 2 TRID Final Closing Disclosure Property Costs Year 1 Overdisclosed - October 2018 TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Loan Disclosures: Amount of Estimated Property Costs over Year 1 of XXX on Final TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 1/XX/2022 1/XX/2023 MI Refinance - Rate/Term Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Construction Permanent Property Costs over Year 1 of XXX on Final Closing Disclosure provided on Closing Disclosure provided on 01/XX/2022 are overdisclosed. liability.
01/XX/2022 are overdisclosed. (Final/01/XX/2022)
625489696 XXX XXX XXX 34479193 compliance 2 TRID Final Closing Disclosure Total Of Payments TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure Final Closing Disclosure provided on 01/XX/2022 disclosed an inaccurate Total of TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 1/XX/2022 1/XX/2023 MI Refinance - Rate/Term Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
provided on 01/XX/2022 disclosed an inaccurate Total of Payments on page 5 that Payments on page 5 that does not match the actual total of payments for the loan defense to foreclosure. Assignee liability.
does not match the actual total of payments for the loan (fee amounts included (fee amounts included in TOP calculation are based on Closing Disclosure dated
in TOP calculation are based on Closing Disclosure dated 01/XX/2022). The 01/XX/2022). The disclosed Total of Payments in the amount of $XXX is under
disclosed Total of Payments in the amount of $XXX is under disclosed by $XXX disclosed by $XXX compared to the calculated total of payments of $XXX which
compared to the calculated total of payments of $XXX which exceeds the $XXX exceeds the $XXX threshold.
threshold. (Final/01/XX/2022)
625489696 XXX XXX XXX 34479194 compliance 2 TRID Lender Credit Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure:Zero Percent Fee Tolerance exceeded for Lender no valid changed circumstance available in loan file TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 1/XX/2022 1/XX/2023 MI Refinance - Rate/Term Second Home No B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Credits. Final Lender Credit of $XXX exceeds tolerance of -$XXX. Insufficient or liability.
no cure was provided to the borrower. (9300)
625489696 XXX XXX XXX 34479196 credit 2 The verification of employment is required and was not found in file. Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: The verification of employment is required and was not found in file FOR XXX // 1/XX/2022 MI Refinance - Rate/Term Second Home No B B B B 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/18: Compensating Factors for waive and downgrade.
01/XX/2008 Employment Type: Employment / Income Type: Wages / Start Date: 01/XX/2008
625489312 XXX XXX XXX 34479238 credit 1 Missing Document: Appraisal not provided Appraisal document is missing for the subject property. 9/XX/2020 MA Refinance - Cash-out - Other Investment Yes A A A A 7/XX/2025 1/XX/2025 Yes 2024/XX/24: Appraisal Attached 2024/XX/31: Exception Remains - Provided Appraisal is not for subject property.
Required appraisal for subject property with report date prior to note date.
2025/XX/03: Appraisal for subject property attached
2025/XX/05: No new documents have been received. Missing appraisal for subject
2025/XX/06: Appraisal for subject property attached property.
2025/XX/08: Appraisal provided. Exception cleared.
625489312 XXX XXX XXX 34479239 credit 1 FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not Disaster Name: XXX 9/XX/2020 MA Refinance - Cash-out - Other Investment Yes A A A A 7/XX/2025 1/XX/2025 Yes 2025/XX/07: Client provided BPO extract with current dates and indicating no
been inspected. Disaster Declaration Date: XX/XX/XXXX damage.
Disaster End Date: XX/XX/XXXX
625489312 XXX XXX XXX 34479240 credit 2 Guideline Requirement: Loan to value discrepancy. Calculated loan to value percentage of XX% exceeds Guideline loan to value 9/XX/2020 MA Refinance - Cash-out - Other Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Lender elects to waive with compensating factors.
percentage of 60.00000%.
625489312 XXX XXX XXX 34479241 credit 2 Guideline Requirement: Combined loan to value discrepancy. Calculated combined loan to value percentage of XX% exceeds Guideline combined 9/XX/2020 MA Refinance - Cash-out - Other Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Lender elects to waive with compensating factors.
loan to value percentage of 60.00000%.
625488608 XXX XXX XXX 34479242 credit 1 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement 9/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/02: E-Sign Consent Agreement Attached 2025/XX/03: Exception cleared - E-Sign Consent Agreement received in file.
625488608 XXX XXX XXX 34479243 credit 2 REO Documents are missing. Address: XXX, FL Insurance Verification Evidence of insurance verification is not in file. 9/XX/2020 MA Purchase Primary Yes B B B B 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/02: P&S agreement for XXX attached. No MTG on XXX. Tax Payments 2025/XX/03: Exception Remains - We have received Purchase contract for the XXX,
Verified. HOI not required. Low DTI 16.835. See HUD 1 confirming borrower paid FL. Provide the signed closing statement or final closing disclosure to evidence
cash for property the property has been sold.
2025/XX/06: EXCEPTION HISTORY - Exception Detail was updated on 01/XX/2025 PRIOR
Exception Detail: Address: XXX, FL, Address: XXX, FL
EXCEPTION HISTORY - Exception Explanation was updated on 01/XX/2025 PRIOR
Exception Explanation: Insurance Verification
Insurance Verification
2025/XX/15: Client elects to waive with compensating factors.
625488608 XXX XXX XXX 34479244 compliance 1 Capital Gains Assets Qualified Mortgage (Dodd-Frank 2014): Documentation to support Capital Gains Signed tax returns including Schedule D are not in file. Copies provided are 9/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/02: See attached 2019 and 2018 Tax Transcripts 2025/XX/06: Upon further review this exception has been cleared.
income requirement not met. (XXX/Schedule D) signed at closing.
625488608 XXX XXX XXX 34479245 compliance 1 Capital Gains Tax Returns Qualified Mortgage (Dodd-Frank 2014): Three (3) years tax returns to evaluate Signed tax returns including Schedule D are not in file. Copies provided are 9/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/02: See attached 2019 and 2018 Tax Transcripts 2025/XX/06: Upon further review this exception has been cleared.
Capital Gains or Losses requirement not met. (XXX/Schedule D) signed at closing.
625488608 XXX XXX XXX 34479246 compliance 1 Commission History less than one year Qualified Mortgage (Dodd-Frank 2014): Commission income earned for less than one Lender used a more conservative calculation per lender exception in file. 9/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/02: Large reserves of XXX. We used conservative income calculation and 2025/XX/06: Co-borrower was qualified with a monthly commission income which was
(1) year not considered effective income and no valid exceptions. (XXX documented borrowers future intentions with LOX attached. only verified with a current paystub. File is missing the 2019 and 2018 W-2's or
XXX/Commission) 1099's to verify 2 years of receipt as required by Appendix Q. Exception
2025/XX/13: Removing coborrower commission income out of the file DTI is 17.8. remains.
Additionally XXX in reserves.
2025/XX/14: Client restates designation to Non-QM
625488608 XXX XXX XXX 34479247 compliance 1 Commission Justification Qualified Mortgage (Dodd-Frank 2014): Commission income earned for less than two Lender used a more conservative calculation per lender exception in file. 9/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/02: Large reserves of XXX. We used conservative income calculation and 2025/XX/06: Co-borrower was qualified with a monthly commission income which was
(2) years not justified or documented. (XXX XXX/Commission) documented borrowers future intentions with LOX attached. only verified with a current paystub. File is missing the 2019 and 2018 W-2's or
1099's to verify 2 years of receipt as required by Appendix Q. Exception
2025/XX/13: Removing coborrower commission income out of the file DTI is 17.8. remains.
Additionally XXX in reserves.
2025/XX/14: Client restates designation to Non-QM
625488608 XXX XXX XXX 34479248 compliance 1 Interest Dividend Income Qualified Mortgage (Dodd-Frank 2014): Continuation of Interest/Dividend income Lender used a more conservative calculation per lender exception in file. 9/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/02: Large reserves of XXX. We used conservative income calculation and 2025/XX/06: Upon further review this exception has been cleared.
supported with sufficient verified assets requirement not met. (XXX/Schedule B) documented borrowers future intentions with LOX attached.
625488608 XXX XXX XXX 34479249 compliance 1 K-1 Documentation Qualified Mortgage (Dodd-Frank 2014): Required K-1s or signed tax Signed tax returns including Schedule K1's are not in file. Copies provided are 9/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/02: See attached 2019 and 2018 Tax Transcripts 2025/XX/06: Upon further review this exception has been cleared.
returns/transcripts not provided for K-1 (Less than 25% Ownership) income. signed at closing.
(XXX/Schedule K-1 less than 25 Percent)
625488608 XXX XXX XXX 34479250 compliance 1 Other Income - Not to be used for qualifying Qualified Mortgage (Dodd-Frank 2014): Income used to qualify borrower(s) not Lender used a more conservative calculation per lender exception in file. 9/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/02: Large reserves of XXX. We used conservative income calculation and 2025/XX/06: Upon further review this exception has been cleared.
permitted for use under Appendix Q. (XXX/Other) documented borrowers future intentions with LOX attached.
625488608 XXX XXX XXX 34479251 compliance 1 Self-Employed Tax Return Recency Qualified Mortgage (Dodd-Frank 2014): Self Employed Tax Returns - The business File only contains the signature page for the 2020 tax return. Please provide 9/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/14: Client restates designation to Non-QM
or personal tax returns provided are not the most recent. Application Date the full 2020 personal tax return for review and upon receipt, additional
07/XX/2020, Most Recent Tax Return End Date 01/XX/2019, Tax Return Due Date conditions may apply.
05/XX/2020. (XXX/Schedule K-1 less than 25 Percent)
625488608 XXX XXX XXX 34479253 compliance 2 TRID Revised Loan Estimate Issue and Received Date > Closing Disclosure Issue TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on or after the Evidence of receipt of Loan Estimate 4 days prior to closing is not in file. TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 9/XX/2020 9/XX/2021 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
and Received Date date the Closing Disclosure was provided. (The Revised Loan Estimate was liability.
received on or after the Closing Disclosure.) (Interim/08/XX/2020)
625488608 XXX XXX XXX 34479254 compliance 1 General Ability To Repay Provision Income and Assets - K-1 Less 25% Ability to Repay (Dodd-Frank 2014): Unable to verify K-1 (Less than 25% Signed tax returns including business tax returns are not in file. Copies Assignee Liability: Violations can result in regular TILA damages (actual 9/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/02: See attached 2019 and 2018 Tax Transcripts 2025/XX/06: Upon further review this exception has been cleared.
Ownership) income using reasonably reliable third-party records. (XXX provided are signed at closing. damages, statutory damages of up to $XXX costs, and attorney's fees) and
XXX/Schedule K-1 less than 25 Percent) enhanced damages (an amount equal to the sum of all finance charges and fees
paid by the consumer, unless the creditor demonstrates that the failure to
comply is not material). A private right of action may be brought before the end
of the three-year period beginning on the date of the occurrence of the
violation. However, when a creditor, assignee, or other holder or anyone acting
on their behalf initiates a judicial or non-judicial foreclosure, or any other
action to collect the debt, a consumer may assert a violation as a matter of
defense by recoupment or set-off without regard to a time limit. The amount of
recoupment or set-off shall equal the amount to which the consumer would be
entitled as regular and/or enhanced damages for a valid claim brought in an
original action, plus the costs to the consumer of the action. If judgment is
rendered after the expiration of the three-year period, the amount of recoupment
or set-off shall not exceed three years of finance charges and fees. An action
to enforce a violation may also be brought by the appropriate state AGs.
625488608 XXX XXX XXX 34479256 compliance 1 Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Safe Harbor Originator Loan Designation of Temporary SHQM (GSE/Agency Eligible) does not Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 9/XX/2020 MA Purchase Primary Yes A A A A 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/02: See above 2025/XX/06: EXCEPTION HISTORY - Exception Detail was updated on 01/XX/2025 PRIOR
QM does not match Due Diligence Loan Designation of Non QM. match Due Diligence Loan Designation of ATR Fail. Designation to the TPR firm performing the loan level due diligence and to have Exception Detail: Qualified Mortgage (Dodd-Frank 2014): Originator Loan
the TPR firm confirm said designation. 2025/XX/13: 2020 tax returns or signature pages would not exist at closing. Designation of Safe Harbor QM does not match Due Diligence Loan Designation of
ATR Fail.
2025/XX/06: File only contains the signature page for the 2020 tax return.
Please provide the full 2020 personal tax return for review. Exception remains.
2025/XX/14: Client restates designation to Non-QM
625488608 XXX XXX XXX 34479258 compliance 2 TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total Ten Percent Fee increased without a valid change of circumstance. Cure was not 9/XX/2020 9/XX/2021 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
amount of $XXX exceeds tolerance of $XXX plus 10% or $XXX. Insufficient or no provided at closing.
cure was provided to the borrower. (0)
625488608 XXX XXX XXX 34479259 compliance 2 Self-Employed Tax Return Recency - ATR Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or File only contains the signature page for the 2020 tax return. Please provide 9/XX/2020 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
personal tax returns provided are not the most recent. Application Date the full 2020 personal tax return for review and upon receipt, additional
07/XX/2020, Most Recent Tax Return End Date 01/XX/2019, Tax Return Due Date conditions may apply.
05/XX/2020. (XXX XXX/Schedule K-1 less than 25 Percent)
625488608 XXX XXX XXX 34479260 compliance 2 Check Restated Loan Designation Match - General Ability to Repay Ability to Repay (Dodd-Frank 2014): The initial Loan Designation provided did Client restates designation to Non-QM Rating Agency requirements are to have the Creditor provide the ATR/QM Loan 9/XX/2020 MA Purchase Primary Yes B B A A 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
not match. However, the updated Loan Designation of Non QM matches the Due Designation to the TPR firm performing the loan level due diligence and to have
Diligence Loan Designation of Non QM. the TPR firm confirm said designation.
625489229 XXX XXX XXX 34479262 compliance 2 TRID Final Closing Disclosure AIR Table Maximum Interest Rate TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing Final Closing Disclosure provided on 09/XX/2020 disclosed a Maximum Interest TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 9/XX/2020 9/XX/2021 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
Disclosure provided on 09/XX/2020 disclosed a Maximum Interest Rate that does Rate that does not match the actual maximum interest rate for the loan. liability.
not match the actual maximum interest rate for the loan. (Final/09/XX/2020)
625489229 XXX XXX XXX 34479264 compliance 2 ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the ARM loan program disclosure not provided to the borrower. TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2020 9/XX/2021 MA Purchase Primary Yes B B B B 7/XX/2025 3/XX/2025 Yes Non QM 2025/XX/04: Client elected to waive
borrower.
625489229 XXX XXX XXX 34479266 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement The file was missing a copy of the E-Sign Consent Agreement. 9/XX/2020 MA Purchase Primary Yes B B B B 7/XX/2025 1/XX/2025 Yes Non QM 2025/XX/14: Lender elects to waive with compensating factors.
625487958 XXX XXX XXX 34479275 credit 2 E-sign Consent Agreement is missing. Disclosure: E-Sign Consent Agreement E-sign Consent Agreement is missing. 11/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
625487958 XXX XXX XXX 34479276 credit 2 Guideline Requirement: PITIA reserves months discrepancy. Calculated PITIA months reserves of 10.89 is less than Guideline PITIA months Calculated PITIA months reserves of 10.89 is less than Guideline PITIA months 11/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
reserves of 12.00. reserves of 12.00.
625487958 XXX XXX XXX 34479277 credit 2 The verification of employment is required and was not found in file. Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: VVOE is missing in file for primary borrower's employer as "XXX". 11/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
02/XX/2016
625487958 XXX XXX XXX 34479278 credit 2 Verification(s) of employment is not within 10 business days of the Note. Borrower: XXX // Employment Type: Employment / Income Type: Wages / Start Date: VVOE is missing in file for primary borrower's employer as "XXX". 11/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
02/XX/2016
625487958 XXX XXX XXX 34479279 credit 2 AUS/Guideline Findings: All conditions were not met 1008 indicates the loan was manually underwritten. 11/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
625487958 XXX XXX XXX 34479280 credit 2 Asset documentation requirements not met. 1008 indicates the loan was manually underwritten 11/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
625487958 XXX XXX XXX 34479281 credit 2 Income documentation requirements not met. 1008 indicates the loan was manually underwritten 11/XX/2021 MA Purchase Investment Yes B B B B 7/XX/2025 1/XX/2025 Yes 2025/XX/14: Client elects to waive with compensating factors.
625488196 XXX XXX XXX 34497500 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2006 VA Purchase Primary No B B B B 9/XX/2025
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488196 XXX XXX XXX 34518497 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 8/XX/2006 VA Purchase Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 08/XX/2006
used as disbursement date for compliance testing.
625489198 XXX XXX XXX 34497781 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 5/XX/2006 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
an application date of 05/XX/2006 which is 0 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 05/XX/2006, 05/XX/2006. Lookback testing performed up to one of the
following: TRID start date, TIL/MDIA 2011 start date, RESPA 2010 start date,
TIL/MDIA 2009 start date, LOS Application Date, Broker Application Date, or six
months prior to consummation.
625489198 XXX XXX XXX 34497783 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Til itemization did not include Tax cert fee of $XXX and document signing fee of $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 5/XX/2006 5/XX/2009 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
calculated Finance Charge of $XXX in the amount of $XXX. $XXX as prepaid finance charge for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489198 XXX XXX XXX 34520618 credit 3 Missing Document: Missing Final 1003 5/XX/2006 PA Refinance - Cash-out - Debt Consolidation Primary No C C C C 9/XX/2025
625489463 XXX XXX XXX 34497003 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 9/XX/2005 FL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 10/XX/2005
used as disbursement date for compliance testing.
625489463 XXX XXX XXX 34497004 compliance 2 Property Type Not Provided (Missing Data) Property Type. If property type is other than single family 9/XX/2005 FL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
residence, state and federal testing may be impacted.
625489463 XXX XXX XXX 34497006 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2005 9/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
CHARM Booklet, not provided to the borrower.
625489463 XXX XXX XXX 34497007 compliance 2 Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. 9/XX/2005 9/XX/2008 FL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
timing requirements.
625489463 XXX XXX XXX 34497008 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 10/XX/2005, prior to TILA ROR - 3yrs for rescindable transactions. 9/XX/2005 9/XX/2008 FL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
Date three (3) business days from transaction date of 09/XX/2005.
625489463 XXX XXX XXX 34497009 compliance 2 Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit 9/XX/2005 9/XX/2008 FL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
Model Form for a refinance by a creditor that is not considered the original courts, the continuing risk that the borrower may have an extended right to
creditor. The H-9 form was used, the H-8 form should have been used. rescind (3 additional years) if a creditor uses the incorrect Model Form
remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625489463 XXX XXX XXX 34497010 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2005 9/XX/2008 FL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
defense to foreclosure. Assignee liability.
625489463 XXX XXX XXX 34521421 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2005 9/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
application due to missing information.
625488935 XXX XXX XXX 34499119 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TIL appears to be final but not signed nor initialed by borrower. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2007 7/XX/2008 FL Purchase Primary No B B B B 9/XX/2025
defense to foreclosure. Assignee liability.
625488935 XXX XXX XXX 34499161 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 7/XX/2007 FL Purchase Primary No B B B B 9/XX/2025
625488935 XXX XXX XXX 34499162 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 7/XX/2007 FL Purchase Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 07/XX/2007
used as disbursement date for compliance testing.
625488935 XXX XXX XXX 34499163 compliance 2 Property Type Not Provided (Missing Data) Property Type. If property type is other than single family 7/XX/2007 FL Purchase Primary No B B B B 9/XX/2025
residence, state and federal testing may be impacted.
625488935 XXX XXX XXX 34499164 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2007 FL Purchase Primary No B B B B 9/XX/2025
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488935 XXX XXX XXX 34499165 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TIL in file indicated to be final, expected funding date same as disbursement TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2007 7/XX/2008 FL Purchase Primary No B B B B 9/XX/2025
and/or note date but is not signed or dated by borrower so cannot confirm that defense to foreclosure. Assignee liability.
borrower received.
625488286 XXX XXX XXX 34499493 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 7/XX/2013 VA Refinance - Rate/Term Primary No B B B B 9/XX/2025
an application date of 06/XX/2013 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 07/XX/2013, 06/XX/2013, 05/XX/2013, 04/XX/2013, 03/XX/2013, 02/XX/2013,
01/XX/2013. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625488286 XXX XXX XXX 34499495 compliance 2 SAFE Act - LO Company not licensed at time of application Unable to test LO company NMLS license due to missing information. Liability appears to be limited to originators/licensees. 7/XX/2013 VA Refinance - Rate/Term Primary No B B B B 9/XX/2025
625488286 XXX XXX XXX 34499496 compliance 2 SAFE Act - Individual LO NMLS license status not approved Unable to test Individual Loan Originator license status due to missing 7/XX/2013 VA Refinance - Rate/Term Primary No B B B B 9/XX/2025
information.
625488286 XXX XXX XXX 34499497 compliance 2 SAFE Act - Individual LO not licensed at time of application Unable to test Loan Originator license due to missing information. Liability appears to be limited to originators/licensees. 7/XX/2013 VA Refinance - Rate/Term Primary No B B B B 9/XX/2025
625488286 XXX XXX XXX 34499498 compliance 2 SAFE Act - LO Company NMLS license status not approved Unable to test LO company status due to missing information. 7/XX/2013 VA Refinance - Rate/Term Primary No B B B B 9/XX/2025
625488286 XXX XXX XXX 34499499 compliance 2 SAFE Act - Individual LO NMLS does not match NMLS Secure and Fair Enforcement for Mortgage Licensing Act: Individual Loan Liability appears to be limited to originators/licensees. 7/XX/2013 VA Refinance - Rate/Term Primary No B B B B 9/XX/2025
Originator NMLSR information on loan documents does not match NMLSR.
625488286 XXX XXX XXX 34499500 compliance 2 Safe Act NMLS - Missing Evidence of Initial Loan Application Date Secure and Fair Enforcement for Mortgage Licensing Act: Unable to determine Liability appears to be limited to originators/licensees. 7/XX/2013 VA Refinance - Rate/Term Primary No B B B B 9/XX/2025
compliance with NMLSR timing requirements due to missing evidence of initial
loan application date.
625488286 XXX XXX XXX 34499501 compliance 2 RESPA (2010) - GFE Settlement charges Good Thru Date Less than 10 Days RESPA (2010): GFE does not provide minimum ten (10) business day availability RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2013 VA Refinance - Rate/Term Primary No B B B B 9/XX/2025
for estimate of charges and terms for all other settlement charges. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488286 XXX XXX XXX 34499502 compliance 2 RESPA - Initial GFE Not Provided Within 3 Business Days of Application Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2013 VA Refinance - Rate/Term Primary No B B B B 9/XX/2025
Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488286 XXX XXX XXX 34499503 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2013 VA Refinance - Rate/Term Primary No B B B B 9/XX/2025
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625488286 XXX XXX XXX 34499504 compliance 2 RESPA Servicing Disclosure: Servicing Disclosure Statement Not Provided Within 3 Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2013 VA Refinance - Rate/Term Primary No B B B B 9/XX/2025
Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488286 XXX XXX XXX 34499505 compliance 2 TIL-MDIA - Initial TIL Not Provided within 3 Business Days of Application Unable to determine compliance with timing requirements due to missing Initial TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited 7/XX/2013 7/XX/2014 VA Refinance - Rate/Term Primary No B B B B 9/XX/2025
Loan Application Date. as a defense to foreclosure. Assignee liability.
625488068 XXX XXX XXX 34513414 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2008 FL Purchase Primary No B B B B 9/XX/2025
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489317 XXX XXX XXX 34499313 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 8/XX/2007 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
an application date of 08/XX/2007 which is 0 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 08/XX/2007, 08/XX/2007. Lookback testing performed up to one of the
following: TRID start date, TIL/MDIA 2011 start date, RESPA 2010 start date,
TIL/MDIA 2009 start date, LOS Application Date, Broker Application Date, or six
months prior to consummation.
625489317 XXX XXX XXX 34499477 credit 3 Missing Document: Missing Final 1003 8/XX/2007 PA Refinance - Cash-out - Debt Consolidation Primary No C C C C 9/XX/2025
625489066 XXX XXX XXX 34498112 credit 3 Missing Document: FHA Mortgage Insurance Certificate not provided 10/XX/2008 MI Purchase Primary No C C C C 9/XX/2025
625489066 XXX XXX XXX 34498121 credit 2 Loan has been identified as FHA/VA/USDA Mortgage Type: FHA 10/XX/2008 MI Purchase Primary No B B B B 9/XX/2025
625489066 XXX XXX XXX 34498136 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 10/XX/2008 MI Purchase Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 10/XX/2008
used as disbursement date for compliance testing.
625489066 XXX XXX XXX 34498137 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 10/XX/2008 MI Purchase Primary No B B B B 9/XX/2025
an application date of 09/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 10/XX/2008, 09/XX/2008, 09/XX/2008. Lookback testing performed up to one
of the following: TRID start date, TIL/MDIA 2011 start date, RESPA 2010 start
date, TIL/MDIA 2009 start date, LOS Application Date, Broker Application Date,
or six months prior to consummation.
625488325 XXX XXX XXX 34514215 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2005 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488325 XXX XXX XXX 34514220 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 8/XX/2005 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
625488137 XXX XXX XXX 34512940 credit 3 Missing Document: Missing Final 1003 2/XX/2005 CO Refinance - Cash-out - Other Primary No C C C C 9/XX/2025
625488137 XXX XXX XXX 34513258 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 2/XX/2005 CO Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
an application date of 01/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 02/XX/2005, 01/XX/2005. Lookback testing performed up to one of the
following: TRID start date, TIL/MDIA 2011 start date, RESPA 2010 start date,
TIL/MDIA 2009 start date, LOS Application Date, Broker Application Date, or six
months prior to consummation.
625488137 XXX XXX XXX 34513260 compliance 2 ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2005 2/XX/2006 CO Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
borrower.
625488137 XXX XXX XXX 34513261 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2005 2/XX/2006 CO Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
Loan Application Date.
625488053 XXX XXX XXX 34551180 compliance 1 (Missing Doc) Incomplete loan images/file The origination image package received is not for the subject transaction. It 12/XX/1998 GA Purchase Primary No A A A A 10/XX/2025 10/XX/2025 Yes 2025/XX/01: Replacement image package received.
appears the origination package for a different loan was co-mingled with the
servicing package for the subject loan in the original image file.
625488053 XXX XXX XXX 34635681 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 12/XX/1998 GA Purchase Primary No B B B B 10/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 12/XX/1998
used as disbursement date for compliance testing.
625488053 XXX XXX XXX 34635682 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL Itemization did not disclose the Attorney Fee $XXX, Loan Discount Fee $XXX $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 12/XX/1998 12/XX/1999 GA Purchase Primary No B B B B 10/XX/2025
calculated Finance Charge of $XXX in the amount of $XXX. and Post Closing Fee $XXX as prepaid finance charges. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489481 XXX XXX XXX 34515144 credit 3 Missing Document: Missing Final 1003 8/XX/2007 FL Refinance - Cash-out - Other Primary No C C C C 9/XX/2025
625489481 XXX XXX XXX 34515362 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 8/XX/2007 FL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
625489481 XXX XXX XXX 34515363 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 8/XX/2007 FL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
an application date of 07/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 08/XX/2007, 07/XX/2007. Lookback testing performed up to one of the
following: TRID start date, TIL/MDIA 2011 start date, RESPA 2010 start date,
TIL/MDIA 2009 start date, LOS Application Date, Broker Application Date, or six
months prior to consummation.
625489481 XXX XXX XXX 34515365 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2007 8/XX/2008 FL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
application due to missing information.
625489481 XXX XXX XXX 34522031 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2007 8/XX/2008 FL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
Loan Application Date.
625489286 XXX XXX XXX 34515937 credit 3 Missing Document: Missing Final 1003 9/XX/2004 OH Refinance - Cash-out - Debt Consolidation Primary No C C C C 9/XX/2025
625489286 XXX XXX XXX 34518146 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 9/XX/2004 OH Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
an application date of 08/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 09/XX/2004, 08/XX/2004, 07/XX/2004, 06/XX/2004, 05/XX/2004, 04/XX/2004,
03/XX/2004. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625489286 XXX XXX XXX 34518148 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2004 OH Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625489286 XXX XXX XXX 34518149 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2004 9/XX/2005 OH Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
application due to missing information.
625489286 XXX XXX XXX 34518150 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2004 9/XX/2005 OH Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Loan Application Date.
625488706 XXX XXX XXX 34515978 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 1/XX/2007 MI Refinance - Cash-out - Other Investment No B B B B 9/XX/2025
625488706 XXX XXX XXX 34515979 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 1/XX/2007 MI Refinance - Cash-out - Other Investment No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 01/XX/2007
used as disbursement date for compliance testing.
625489325 XXX XXX XXX 34541308 credit 3 Missing Document: Missing Final 1003 9/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No C C C C 9/XX/2025
625489325 XXX XXX XXX 34541753 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 9/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Security Instrument Notary Date of 09/XX/2007 used as disbursement date for
compliance testing.
625489325 XXX XXX XXX 34541754 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 9/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
an application date of 08/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 09/XX/2007, 08/XX/2007, 07/XX/2007, 06/XX/2007, 05/XX/2007, 04/XX/2007,
03/XX/2007. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625489325 XXX XXX XXX 34541757 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625489325 XXX XXX XXX 34541758 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 9/XX/2007 9/XX/2010 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
625488167 XXX XXX XXX 34527577 compliance 2 (Doc Error) Initial GFE not provided 6/XX/2007 IL Refinance - Rate/Term Primary No B B B B 9/XX/2025
625488167 XXX XXX XXX 34527668 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 6/XX/2007 IL Refinance - Rate/Term Primary No B B B B 9/XX/2025
an application date of 05/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 06/XX/2007, 05/XX/2007, 04/XX/2007, 03/XX/2007, 02/XX/2007, 01/XX/2007,
12/XX/2006. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625488167 XXX XXX XXX 34527670 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 IL Refinance - Rate/Term Primary No B B B B 9/XX/2025
application due to missing information.
625488167 XXX XXX XXX 34527671 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 IL Refinance - Rate/Term Primary No B B B B 9/XX/2025
CHARM Booklet, not provided to the borrower.
625489131 XXX XXX XXX 34516332 credit 3 Missing Document: Missing Final 1003 8/XX/2006 NJ Refinance - Cash-out - Other Primary Yes C C C C 9/XX/2025
625489131 XXX XXX XXX 34516345 compliance 2 Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit 8/XX/2006 8/XX/2009 NJ Refinance - Cash-out - Other Primary Yes B B B B 9/XX/2025
Model Form for a refinance by a creditor that is not considered the original courts, the continuing risk that the borrower may have an extended right to
creditor. The H-9 form was used, the H-8 form should have been used. rescind (3 additional years) if a creditor uses the incorrect Model Form
remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625488121 XXX XXX XXX 34521838 credit 3 Missing Document: Missing Final 1003 11/XX/2005 IN Refinance - Cash-out - Debt Consolidation Primary Yes C C C C 9/XX/2025
625488121 XXX XXX XXX 34521876 credit 3 Final Title Policy is missing. No evidence of title in file. 11/XX/2005 IN Refinance - Cash-out - Debt Consolidation Primary Yes C C C C 9/XX/2025
625488121 XXX XXX XXX 34521877 compliance 2 (Doc Error) Initial GFE not provided 11/XX/2005 IN Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 9/XX/2025
625488121 XXX XXX XXX 34521879 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 11/XX/2005 IN Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 9/XX/2025
following clauses:
625488121 XXX XXX XXX 34521880 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 11/XX/2005 IN Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 9/XX/2025
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488121 XXX XXX XXX 34521882 credit 2 Note is not on a FNMA/FHLMC form and does not contain the standard Due on Sale 11/XX/2005 IN Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 9/XX/2025
clause.
625488121 XXX XXX XXX 34521890 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 11/XX/2005 IN Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 9/XX/2025
Security Instrument Notary Date of 11/XX/2005 used as disbursement date for
compliance testing.
625488121 XXX XXX XXX 34521892 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 11/XX/2005 IN Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 9/XX/2025
an application date of 10/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 11/XX/2005, 10/XX/2005, 09/XX/2005, 08/XX/2005, 07/XX/2005, 06/XX/2005,
05/XX/2005. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625488121 XXX XXX XXX 34521894 compliance 2 Property Type Not Provided (Missing Data) Property Type. If property type is other than single family 11/XX/2005 IN Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 9/XX/2025
residence, state and federal testing may be impacted.
625488121 XXX XXX XXX 34521896 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 11/XX/2005 11/XX/2008 IN Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 9/XX/2025
625488121 XXX XXX XXX 34521897 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2005 11/XX/2008 IN Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 9/XX/2025
are estimates. defense to foreclosure. Assignee liability.
625489285 XXX XXX XXX 34515944 credit 3 Missing Document: Missing Final 1003 10/XX/2005 PA Refinance - Cash-out - Debt Consolidation Primary No C C C C 9/XX/2025
625489285 XXX XXX XXX 34516024 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 10/XX/2005 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Security Instrument Notary Date of 10/XX/2005 used as disbursement date for
compliance testing.
625489285 XXX XXX XXX 34516025 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 10/XX/2005 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
an application date of 09/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 10/XX/2005, 09/XX/2005, 08/XX/2005, 07/XX/2005, 06/XX/2005, 05/XX/2005,
04/XX/2005. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625489285 XXX XXX XXX 34516028 compliance 2 Pennsylvania First Lien Late Charge Grace Period Testing Pennsylvania Late Charge: Note grace period of 10 days is less than the state 10/XX/2005 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
minimum of 15 days.
625489285 XXX XXX XXX 34516029 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 10/XX/2005, prior to TILA ROR - 3yrs for rescindable transactions. 10/XX/2005 10/XX/2008 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Date three (3) business days from transaction date of 10/XX/2005.
625489285 XXX XXX XXX 34516030 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2005 10/XX/2008 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
are estimates. defense to foreclosure. Assignee liability.
625488006 XXX XXX XXX 34514308 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 3/XX/2005 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
625488006 XXX XXX XXX 34514309 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 3/XX/2005 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
an application date of 02/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 03/XX/2005, 02/XX/2005, 01/XX/2005, 12/XX/2004, 11/XX/2004, 10/XX/2004,
09/XX/2004. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625488006 XXX XXX XXX 34514311 compliance 2 Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Michigan Consumer Mortgage Protection Act: Borrower Bill of Rights disclosure Assignee liability is unclear. Purchasers and assignees would not appear to be 3/XX/2005 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Not Provided) not provided to borrower. liable for violations of the Act, except to the extent involved I violations
arising from servicing or collecting.
625488006 XXX XXX XXX 34514312 compliance 2 Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided Michigan Consumer Mortgage Protection Act: Consumer Caution and Home Ownership Assignee liability is unclear. Purchasers and assignees would not appear to be 3/XX/2005 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Counseling Notice not provided to borrower. liable for violations of the Act, except to the extent involved I violations
arising from servicing or collecting.
625488006 XXX XXX XXX 34514313 compliance 2 Michigan Consumer Mortgage Protection Act (Counseling Agencies List) Michigan Consumer Mortgage Protection Act: List of HUD-approved credit 3/XX/2005 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
counseling agencies not provided to borrower.
625488006 XXX XXX XXX 34514314 compliance 2 ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2005 3/XX/2006 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
borrower.
625488006 XXX XXX XXX 34514315 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2005 3/XX/2006 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
CHARM Booklet, not provided to the borrower.
625488006 XXX XXX XXX 34514320 compliance 2 (Doc Error) Initial GFE not provided 3/XX/2005 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
625488006 XXX XXX XXX 34514340 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2005 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Disclosure to borrower. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488152 XXX XXX XXX 34532048 credit 3 Missing Document: Missing Final 1003 7/XX/2002 TX Refinance - Cash-out - Debt Consolidation Primary No C C C C 9/XX/2025
625488152 XXX XXX XXX 34532126 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 7/XX/2002 TX Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Security Instrument Notary Date of 07/XX/2002 used as disbursement date for
compliance testing.
625488152 XXX XXX XXX 34532130 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 07/XX/2002, prior to TILA ROR - 3yrs for rescindable transactions. 7/XX/2002 7/XX/2005 TX Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Date three (3) business days from transaction date of 07/XX/2002.
625488152 XXX XXX XXX 34532147 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 7/XX/2002 TX Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
following clauses:
625489237 XXX XXX XXX 34514991 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 10/XX/2005 WI Purchase Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 10/XX/2005
used as disbursement date for compliance testing.
625489237 XXX XXX XXX 34514992 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 10/XX/2005 10/XX/2006 WI Purchase Primary No B B B B 9/XX/2025
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488634 XXX XXX XXX 34526217 credit 3 Missing Document: Missing Final 1003 1/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No C C C C 9/XX/2025
625488634 XXX XXX XXX 34526288 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 1/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
an application date of 12/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 01/XX/2007, 12/XX/2006, 12/XX/2006. Lookback testing performed up to one
of the following: TRID start date, TIL/MDIA 2011 start date, RESPA 2010 start
date, TIL/MDIA 2009 start date, LOS Application Date, Broker Application Date,
or six months prior to consummation.
625488634 XXX XXX XXX 34526290 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2007 1/XX/2008 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
application due to missing information.
625488634 XXX XXX XXX 34526291 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2007 1/XX/2008 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Loan Application Date.
625489202 XXX XXX XXX 34525339 compliance 3 Missing Final HUD-1 Alternate Document Used for Fees (Primary) Missing Final HUD-1: Estimated HUD1 used for any applicable Federal, State or The HUD-1 contains a hold back on Line 1303 Funds Held: Assessment Lien $XXX and Yes 11/XX/2007 IL Refinance - Cash-out - Other Primary No D D D D 9/XX/2025
Local compliance testing. cannot be considered Final.
625489202 XXX XXX XXX 34525341 compliance 2 ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 11/XX/2007 11/XX/2008 IL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
borrower.
625489202 XXX XXX XXX 34525342 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing Itemization of Amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years Yes 11/XX/2007 11/XX/2010 IL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
calculated Finance Charge of $XXX in the amount of $XXX. Financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488822 XXX XXX XXX 34545206 compliance 2 Construction Addendum/Allonge Incomplete - Combined Disclosure Type (Not Subject Construction Addendum/Allonge Incomplete Test: Construction to Perm Incomplete 4/XX/2007 AZ Refinance - Rate/Term Primary No B B B B 9/XX/2025
To High Cost) Note – Combined Disclosures - Construction Phase Addendum/Rider or Construction
Loan Agreement or other source documentation containing construction phase loan
terms not in file. Compliance testing performed based on terms of permanent
financing only, however calculated APR may not be accurate due to missing
information.
625488822 XXX XXX XXX 34545207 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 4/XX/2007 AZ Refinance - Rate/Term Primary No B B B B 9/XX/2025
an application date of 03/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 04/XX/2007, 03/XX/2007, 02/XX/2007, 02/XX/2007. Lookback testing
performed up to one of the following: TRID start date, TIL/MDIA 2011 start date,
RESPA 2010 start date, TIL/MDIA 2009 start date, LOS Application Date, Broker
Application Date, or six months prior to consummation.
625488822 XXX XXX XXX 34545209 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2007 4/XX/2008 AZ Refinance - Rate/Term Primary No B B B B 9/XX/2025
application due to missing information.
625488822 XXX XXX XXX 34545210 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2007 4/XX/2008 AZ Refinance - Rate/Term Primary No B B B B 9/XX/2025
Loan Application Date.
625488822 XXX XXX XXX 34575774 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 4/XX/2007 AZ Refinance - Rate/Term Primary No B B B B 9/XX/2025
Security Instrument Notary Date of 04/XX/2007 used as disbursement date for
compliance testing.
625487938 XXX XXX XXX 34516280 credit 3 Missing Document: Missing Final 1003 11/XX/2007 MO Refinance - Cash-out - Debt Consolidation Primary No C C C C 9/XX/2025
625487938 XXX XXX XXX 34516318 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 11/XX/2007 MO Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
an application date of 10/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 11/XX/2007, 10/XX/2007, 09/XX/2007. Lookback testing performed up to one
of the following: TRID start date, TIL/MDIA 2011 start date, RESPA 2010 start
date, TIL/MDIA 2009 start date, LOS Application Date, Broker Application Date,
or six months prior to consummation.
625488004 XXX XXX XXX 34524474 credit 3 Missing Document: Missing Final 1003 10/XX/1997 IN Refinance - Cash-out - Debt Consolidation Primary No C C C C 9/XX/2025
625488004 XXX XXX XXX 34524487 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 10/XX/1997 IN Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Security Instrument Notary Date of 10/XX/1997 used as disbursement date for
compliance testing.
625488004 XXX XXX XXX 34524489 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 10/XX/1997 IN Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
an application date of 09/XX/1997 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 10/XX/1997, 09/XX/1997, 08/XX/1997, 07/XX/1997, 06/XX/1997, 05/XX/1997,
04/XX/1997. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625488004 XXX XXX XXX 34524492 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 10/XX/1997, prior to TILA ROR - 3yrs for rescindable transactions. 10/XX/1997 10/XX/2000 IN Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Date three (3) business days from transaction date of 10/XX/1997.
625488378 XXX XXX XXX 34527684 compliance 2 (Doc Error) Initial GFE not provided 11/XX/2004 OH Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
625488378 XXX XXX XXX 34534070 compliance 2 ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2004 11/XX/2005 OH Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
borrower within three (3) days of application.
625488378 XXX XXX XXX 34534071 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2004 11/XX/2005 OH Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625488280 XXX XXX XXX 34524667 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2006 11/XX/2007 GA Purchase Primary No B B B B 9/XX/2025
defense to foreclosure. Assignee liability.
625488280 XXX XXX XXX 34524685 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 11/XX/2006 GA Purchase Primary No B B B B 9/XX/2025
625488280 XXX XXX XXX 34524687 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2006 GA Purchase Primary No B B B B 9/XX/2025
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488280 XXX XXX XXX 34524688 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TIL in file indicated to be final. Expected funding date same as disbursement TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2006 11/XX/2007 GA Purchase Primary No B B B B 9/XX/2025
and/or note date but is not dated by borrower so cannot confirm when borrower defense to foreclosure. Assignee liability.
received the TIL.
625489111 XXX XXX XXX 34516125 credit 3 Missing Document: Missing Final 1003 7/XX/2007 IL Refinance - Cash-out - Other Primary No C C C C 9/XX/2025
625489111 XXX XXX XXX 34518272 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 7/XX/2007 IL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
625489111 XXX XXX XXX 34518273 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 7/XX/2007 IL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
an application date of 07/XX/2007 which is 0 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 07/XX/2007, 07/XX/2007. Lookback testing performed up to one of the
following: TRID start date, TIL/MDIA 2011 start date, RESPA 2010 start date,
TIL/MDIA 2009 start date, LOS Application Date, Broker Application Date, or six
months prior to consummation.
625488478 XXX XXX XXX 34516346 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 7/XX/2007 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 07/XX/2007
used as disbursement date for compliance testing.
625488478 XXX XXX XXX 34516347 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 7/XX/2007 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 9/XX/2025
an application date of 06/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 07/XX/2007, 06/XX/2007, 06/XX/2007. Lookback testing performed up to one
of the following: TRID start date, TIL/MDIA 2011 start date, RESPA 2010 start
date, TIL/MDIA 2009 start date, LOS Application Date, Broker Application Date,
or six months prior to consummation.
625488478 XXX XXX XXX 34516349 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2007 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 9/XX/2025
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488478 XXX XXX XXX 34516350 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2007 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 9/XX/2025
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625488478 XXX XXX XXX 34516352 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2007 7/XX/2008 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 9/XX/2025
application due to missing information.
625488478 XXX XXX XXX 34530994 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2007 7/XX/2008 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B 9/XX/2025
CHARM Booklet, not provided to the borrower.
625488956 XXX XXX XXX 34516456 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing Itemization of Amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 7/XX/2005 7/XX/2006 WI Purchase Primary No B B B B 9/XX/2025
calculated Finance Charge of $XXX in the amount of $XXX. Financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489133 XXX XXX XXX 34495681 compliance 3 (Missing Doc) Incomplete loan images/file File contains only the security Instrument and post closing documents. UTD No D D D D 2/XX/2026 2025/XX/01: Additional image package received is just post closing documents.
2025/XX/06: Received a 256 page image file which are all post closing documents.
Unable to clear exception as no additional origination documentation was
received.
625488398 XXX XXX XXX 34533199 credit 3 Missing Document: Missing Final 1003 10/XX/2006 MA Purchase Primary Yes C C C C 9/XX/2025
625488398 XXX XXX XXX 34533246 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 10/XX/2006 MA Purchase Primary Yes B B B B 9/XX/2025
625488398 XXX XXX XXX 34533247 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 10/XX/2006 MA Purchase Primary Yes B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 10/XX/2006
used as disbursement date for compliance testing.
625488398 XXX XXX XXX 34533248 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 10/XX/2006 MA Purchase Primary Yes B B B B 9/XX/2025
an application date of 09/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 10/XX/2006, 09/XX/2006, 08/XX/2006, 07/XX/2006, 06/XX/2006, 05/XX/2006,
04/XX/2006. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625488398 XXX XXX XXX 34533249 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2006 MA Purchase Primary Yes B B B B 9/XX/2025
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488398 XXX XXX XXX 34533250 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2006 MA Purchase Primary Yes B B B B 9/XX/2025
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625488465 XXX XXX XXX 34532371 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 12/XX/2005 IA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 12/XX/2005
used as disbursement date for compliance testing.
625488465 XXX XXX XXX 34532373 compliance 2 Iowa Prepayment Penalty Iowa Prepayment Penalty: A prepayment penalty is not permitted per state law. 12/XX/2005 IA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Prepay language states prepay will not exceed maximum permitted by applicable
law.
625489333 XXX XXX XXX 34524833 compliance 2 ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2008 3/XX/2009 WA Purchase Primary No B B B B 9/XX/2025
borrower within three (3) days of application.
625489594 XXX XXX XXX 34541991 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 9/XX/2006 CA Purchase Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 09/XX/2006
used as disbursement date for compliance testing.
625489594 XXX XXX XXX 34541992 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing Unable to test Affiliated Business Disclosure due to missing information. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2006 CA Purchase Primary No B B B B 9/XX/2025
within the statute or implementing regulation, Regulation X, for these type of
violations.
625489594 XXX XXX XXX 34541993 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2006 CA Purchase Primary No B B B B 9/XX/2025
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489594 XXX XXX XXX 34541994 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2006 9/XX/2007 CA Purchase Primary No B B B B 9/XX/2025
CHARM Booklet, not provided to the borrower.
625487972 XXX XXX XXX 34524871 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2007 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Disclosure to borrower. within the statute or implementing regulation, Regulation X, for these type of
violations.
625487972 XXX XXX XXX 34524872 compliance 2 Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit 8/XX/2007 8/XX/2010 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Model Form for a refinance by a creditor that is not considered the original courts, the continuing risk that the borrower may have an extended right to
creditor. The H-9 form was used, the H-8 form should have been used. rescind (3 additional years) if a creditor uses the incorrect Model Form
remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625488719 XXX XXX XXX 34517122 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 3/XX/2007 MD Purchase Primary No B B B B 9/XX/2025
625488719 XXX XXX XXX 34517123 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 3/XX/2007 MD Purchase Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 03/XX/2007
used as disbursement date for compliance testing.
625488719 XXX XXX XXX 34517124 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 3/XX/2007 MD Purchase Primary No B B B B 9/XX/2025
an application date of 02/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 03/XX/2007, 02/XX/2007. Lookback testing performed up to one of the
following: TRID start date, TIL/MDIA 2011 start date, RESPA 2010 start date,
TIL/MDIA 2009 start date, LOS Application Date, Broker Application Date, or six
months prior to consummation.
625488719 XXX XXX XXX 34517125 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 MD Purchase Primary No B B B B 9/XX/2025
application due to missing information.
625488719 XXX XXX XXX 34517126 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 MD Purchase Primary No B B B B 9/XX/2025
Loan Application Date.
625489310 XXX XXX XXX 34517063 credit 3 Missing Document: Missing Final 1003 3/XX/2007 AL Refinance - Cash-out - Other Primary No C C C C 9/XX/2025
625489310 XXX XXX XXX 34517075 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 3/XX/2007 AL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
an application date of 02/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 03/XX/2007, 02/XX/2007, 02/XX/2007. Lookback testing performed up to one
of the following: TRID start date, TIL/MDIA 2011 start date, RESPA 2010 start
date, TIL/MDIA 2009 start date, LOS Application Date, Broker Application Date,
or six months prior to consummation.
625489310 XXX XXX XXX 34517077 compliance 2 Alabama Prepayment Penalty Alabama Prepayment Penalty: A prepayment penalty is not permitted under the 3/XX/2007 AL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
Consumer Credit Act. Prepay language states prepay will not exceed maximum
permitted by applicable law.
625489310 XXX XXX XXX 34517080 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 3/XX/2007 AL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
625489310 XXX XXX XXX 34517081 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 3/XX/2007 AL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 03/XX/2007
used as disbursement date for compliance testing.
625489310 XXX XXX XXX 34533213 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2007 AL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
Disclosure to borrower. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489525 XXX XXX XXX 34525299 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 5/XX/2007 NM Refinance - Cash-out - Debt Consolidation Investment Yes B B B B 9/XX/2025
625489525 XXX XXX XXX 34525300 compliance 2 Disparity in Occupancy - Not High Cost and Not Higher Priced The mortgage loan file contains documenting evidence the consumer intends to Declarations page of the final loan application indicates that the borrower 5/XX/2007 NM Refinance - Cash-out - Debt Consolidation Investment Yes B B B B 9/XX/2025
occupy the subject property as their primary residence. (Compliance testing intend to occupy the subject loan as a primary residence.
performed based on the Occupancy Type of Investment).
625489525 XXX XXX XXX 34525301 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 5/XX/2007 NM Refinance - Cash-out - Debt Consolidation Investment Yes B B B B 9/XX/2025
an application date of 04/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 05/XX/2007, 04/XX/2007, 04/XX/2007. Lookback testing performed up to one
of the following: TRID start date, TIL/MDIA 2011 start date, RESPA 2010 start
date, TIL/MDIA 2009 start date, LOS Application Date, Broker Application Date,
or six months prior to consummation.
625489332 XXX XXX XXX 34531158 credit 3 Incomplete Document: Note - Subject Lien is incomplete The subject note, deed of trust, and final TIL all have the lender name missing. No 6/XX/2007 CA Purchase Primary No D D D D 9/XX/2025
625489332 XXX XXX XXX 34531168 compliance 2 Incomplete Document: TIL Final is incomplete The subject note, deed of trust, and final TIL all have the lender name missing. No 6/XX/2007 6/XX/2008 CA Purchase Primary No B B B B 9/XX/2025
625489332 XXX XXX XXX 34537740 credit 3 Missing Document: Missing Final 1003 No 6/XX/2007 CA Purchase Primary No C C C C 9/XX/2025
625489332 XXX XXX XXX 34538432 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. No 6/XX/2007 CA Purchase Primary No B B B B 9/XX/2025
625489332 XXX XXX XXX 34538433 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. No 6/XX/2007 CA Purchase Primary No B B B B 9/XX/2025
Security Instrument Notary Date of 06/XX/2007 used as disbursement date for
compliance testing.
625489332 XXX XXX XXX 34538438 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA No 6/XX/2007 6/XX/2008 CA Purchase Primary No B B B B 9/XX/2025
application due to missing information.
625489332 XXX XXX XXX 34538439 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA No 6/XX/2007 6/XX/2008 CA Purchase Primary No B B B B 9/XX/2025
Loan Application Date.
625489332 XXX XXX XXX 34550097 compliance 3 Missing Final HUD-1 No Alternate Fee Source Document (Primary or Second Home) Missing Final HUD-1. No document containing fees provided. Any applicable No 6/XX/2007 CA Purchase Primary No D D D D 9/XX/2025
Federal, State or Local compliance testing is unreliable.
625489332 XXX XXX XXX 34550098 compliance 2 Missing Initial Loan Application No Fees Test No evidence of application date located in file. Compliance tests were run using No 6/XX/2007 CA Purchase Primary No B B B B 9/XX/2025
an application date of 05/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 06/XX/2007, 05/XX/2007, 05/XX/2007. Lookback testing performed up to one
of the following: TRID start date, TIL/MDIA 2011 start date, RESPA 2010 start
date, TIL/MDIA 2009 start date, LOS Application Date, Broker Application Date,
or six months prior to consummation. Due to missing HUD-1 or Closing Disclosure,
no fees were used in testing.
625488485 XXX XXX XXX 34525164 credit 3 Missing Document: Missing Final 1003 2/XX/2006 GA Refinance - Cash-out - Other UTD No C C C C 9/XX/2025
625488485 XXX XXX XXX 34525183 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 2/XX/2006 GA Refinance - Cash-out - Other UTD No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 02/XX/2006
used as disbursement date for compliance testing.
625488485 XXX XXX XXX 34525184 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 2/XX/2006 GA Refinance - Cash-out - Other UTD No B B B B 9/XX/2025
an application date of 01/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 02/XX/2006, 01/XX/2006, 12/XX/2005, 11/XX/2005, 10/XX/2005, 09/XX/2005,
08/XX/2005. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625488485 XXX XXX XXX 34525185 compliance 2 Property Type Not Provided (Missing Data) Property Type. If property type is other than single family 2/XX/2006 GA Refinance - Cash-out - Other UTD No B B B B 9/XX/2025
residence, state and federal testing may be impacted.
625488485 XXX XXX XXX 34525187 compliance 2 Right of Rescission Timing - Note Date used as Transaction Date Unable to conclusively determine date of consummation. Note date used as 2/XX/2006 GA Refinance - Cash-out - Other UTD No B B B B 9/XX/2025
transaction date for purposes of determining compliance with rescission timing
requirements
625488485 XXX XXX XXX 34525188 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 2/XX/2006 2/XX/2009 GA Refinance - Cash-out - Other UTD No B B B B 9/XX/2025
625488485 XXX XXX XXX 34525189 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 2/XX/2006 2/XX/2009 GA Refinance - Cash-out - Other UTD No B B B B 9/XX/2025
defense to foreclosure. Assignee liability.
625488485 XXX XXX XXX 34525236 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 2/XX/2006 GA Refinance - Cash-out - Other UTD No B B B B 9/XX/2025
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488485 XXX XXX XXX 34525238 compliance 2 Unable to determine occupancy, compliance results were generated using a 2/XX/2006 GA Refinance - Cash-out - Other UTD No B B B B 9/XX/2025
defaulted value of Primary.
625488485 XXX XXX XXX 34525243 compliance 2 (Doc Error) Initial GFE not provided 2/XX/2006 GA Refinance - Cash-out - Other UTD No B B B B 9/XX/2025
625489191 XXX XXX XXX 34516528 credit 3 Missing Document: Missing Final 1003 6/XX/2006 WI Refinance - Cash-out - Other Primary No C C C C 9/XX/2025
625489191 XXX XXX XXX 34516538 credit 3 Final Title Policy is missing. No evidence of title in file. 6/XX/2006 WI Refinance - Cash-out - Other Primary No C C C C 9/XX/2025
625489191 XXX XXX XXX 34516539 compliance 2 (Doc Error) Initial GFE not provided 6/XX/2006 WI Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
625489191 XXX XXX XXX 34516540 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 6/XX/2006 WI Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489191 XXX XXX XXX 34516595 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 6/XX/2006 WI Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 06/XX/2006
used as disbursement date for compliance testing.
625489191 XXX XXX XXX 34516596 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 6/XX/2006 WI Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
an application date of 05/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 06/XX/2006, 05/XX/2006, 04/XX/2006, 03/XX/2006, 02/XX/2006, 01/XX/2006,
12/XX/2005. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625489191 XXX XXX XXX 34516597 compliance 2 Property Type Not Provided (Missing Data) Property Type. If property type is other than single family 6/XX/2006 WI Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
residence, state and federal testing may be impacted.
625489191 XXX XXX XXX 34516599 compliance 2 Wisconsin Prepayment Penalty ARM Test Wisconsin Prepayment Penalty: Adjustable rate loan containing prepayment penalty 6/XX/2006 WI Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
did not provide disclosure stating that there are also loans available without
prepayment penalties.
625489191 XXX XXX XXX 34516600 compliance 2 ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2006 6/XX/2007 WI Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
borrower.
625489191 XXX XXX XXX 34516601 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2006 6/XX/2007 WI Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
CHARM Booklet, not provided to the borrower.
625489191 XXX XXX XXX 34516602 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 6/XX/2006 6/XX/2009 WI Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
625489191 XXX XXX XXX 34516603 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2006 6/XX/2009 WI Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
defense to foreclosure. Assignee liability.
625488451 XXX XXX XXX 34533635 credit 3 Missing Document: Missing Final 1003 11/XX/2004 NC Purchase Primary No C C C C 9/XX/2025
625488451 XXX XXX XXX 34533668 compliance 2 (Doc Error) Initial GFE not provided 11/XX/2004 NC Purchase Primary No B B B B 9/XX/2025
625488451 XXX XXX XXX 34533681 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 11/XX/2004 NC Purchase Primary No B B B B 9/XX/2025
Security Instrument Notary Date of 11/XX/2004 used as disbursement date for
compliance testing.
625488676 XXX XXX XXX 34533487 credit 3 Missing Document: Missing Final 1003 1/XX/2007 CA Refinance - Cash-out - Other Primary No C C C C 9/XX/2025
625488676 XXX XXX XXX 34533625 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 1/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
an application date of 01/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 02/XX/2007, 01/XX/2007. Lookback testing performed up to one of the
following: TRID start date, TIL/MDIA 2011 start date, RESPA 2010 start date,
TIL/MDIA 2009 start date, LOS Application Date, Broker Application Date, or six
months prior to consummation.
625488676 XXX XXX XXX 34533627 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 1/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625489542 XXX XXX XXX 34516638 credit 3 Missing Document: Missing Final 1003 12/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No C C C C 9/XX/2025
625489542 XXX XXX XXX 34516728 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 12/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 12/XX/2006
used as disbursement date for compliance testing.
625489542 XXX XXX XXX 34516729 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 12/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
an application date of 11/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 12/XX/2006, 11/XX/2006, 10/XX/2006. Lookback testing performed up to one
of the following: TRID start date, TIL/MDIA 2011 start date, RESPA 2010 start
date, TIL/MDIA 2009 start date, LOS Application Date, Broker Application Date,
or six months prior to consummation.
625489542 XXX XXX XXX 34516731 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2006 12/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
application due to missing information.
625489542 XXX XXX XXX 34516732 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2006 12/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Loan Application Date.
625489267 XXX XXX XXX 34524941 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 8/XX/2005 MI Purchase Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 08/XX/2005
used as disbursement date for compliance testing.
625489267 XXX XXX XXX 34524942 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 8/XX/2005 MI Purchase Primary No B B B B 9/XX/2025
an application date of 07/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 08/XX/2005, 07/XX/2005, 06/XX/2005, 05/XX/2005, 04/XX/2005, 03/XX/2005,
02/XX/2005. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625489267 XXX XXX XXX 34524943 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2005 MI Purchase Primary No B B B B 9/XX/2025
Disclosure to borrower. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489267 XXX XXX XXX 34524944 compliance 2 ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2005 8/XX/2006 MI Purchase Primary No B B B B 9/XX/2025
borrower.
625489267 XXX XXX XXX 34524945 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2005 8/XX/2006 MI Purchase Primary No B B B B 9/XX/2025
CHARM Booklet, not provided to the borrower.
625489267 XXX XXX XXX 34524953 compliance 2 (Doc Error) Initial GFE not provided 8/XX/2005 MI Purchase Primary No B B B B 9/XX/2025
625489267 XXX XXX XXX 34525032 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 8/XX/2005 MI Purchase Primary No B B B B 9/XX/2025
625488348 XXX XXX XXX 34525088 credit 3 Missing Document: Missing Final 1003 12/XX/2007 SC Refinance - Cash-out - Other Primary No C C C C 9/XX/2025
625488348 XXX XXX XXX 34525109 compliance 2 (Doc Error) Initial GFE not provided 12/XX/2007 SC Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
625488348 XXX XXX XXX 34525239 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 12/XX/2007 SC Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
625488348 XXX XXX XXX 34525240 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 12/XX/2007 SC Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
an application date of 11/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 12/XX/2007, 11/XX/2007, 10/XX/2007, 09/XX/2007, 08/XX/2007, 07/XX/2007,
06/XX/2007. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625488348 XXX XXX XXX 34525242 compliance 2 South Carolina Home Loan (Complaint Agency Disclosure Not Provided) South Carolina Home Loan: Borrower not provided with a document specifying the 12/XX/2007 12/XX/2013 SC Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
agency designated to receive complaints or inquiries about the origination and
making of the loan.
625488472 XXX XXX XXX 34543717 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2008 6/XX/2009 KS Purchase Primary No B B B B 9/XX/2025
CHARM Booklet, not provided to the borrower.
625488932 XXX XXX XXX 34517254 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 10/XX/2008 WI Purchase Primary No B B B B 9/XX/2025
an application date of 09/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 10/XX/2008, 09/XX/2008, 08/XX/2008, 07/XX/2008, 06/XX/2008, 05/XX/2008,
04/XX/2008. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625488932 XXX XXX XXX 34517255 compliance 2 ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2008 10/XX/2009 WI Purchase Primary No B B B B 9/XX/2025
borrower.
625488932 XXX XXX XXX 34517256 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2008 10/XX/2009 WI Purchase Primary No B B B B 9/XX/2025
Loan Application Date.
625489261 XXX XXX XXX 34517278 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver Yes 10/XX/2007 CA Purchase Primary No B B B B 9/XX/2025
following clauses:
625489261 XXX XXX XXX 34517282 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a Yes 10/XX/2007 10/XX/2008 CA Purchase Primary No B B B B 9/XX/2025
defense to foreclosure. Assignee liability.
625489261 XXX XXX XXX 34517304 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. Yes 10/XX/2007 CA Purchase Primary No B B B B 9/XX/2025
625489261 XXX XXX XXX 34517306 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from HUD-1 line 213 is a Seller Credit for $XXX which was not itemized and could not $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years Yes 10/XX/2007 10/XX/2008 CA Purchase Primary No B B B B 9/XX/2025
calculated Finance Charge of $XXX in the amount of $XXX. be utilized in the review. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489261 XXX XXX XXX 34517307 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a Yes 10/XX/2007 10/XX/2008 CA Purchase Primary No B B B B 9/XX/2025
defense to foreclosure. Assignee liability.
625489261 XXX XXX XXX 34581751 compliance 3 Missing Final HUD-1 Alternate Document Used for Fees (Primary) Missing Final HUD-1: Estimated HUD1 used for any applicable Federal, State or HUD-1 line 213 indicates it is an estimate so the HUD-1 cannot be considered Yes 10/XX/2007 CA Purchase Primary No D D D D 9/XX/2025
Local compliance testing. Final.
625489318 XXX XXX XXX 34534033 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TIL appears to be final but not signed nor initialed by borrower TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2006 8/XX/2007 MD Purchase Primary No B B B B 9/XX/2025
defense to foreclosure. Assignee liability.
625489318 XXX XXX XXX 34534566 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2006 MD Purchase Primary No B B B B 9/XX/2025
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489318 XXX XXX XXX 34534567 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2006 MD Purchase Primary No B B B B 9/XX/2025
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489318 XXX XXX XXX 34534568 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TIL in file indicated to be final, expected funding date same as disbursement TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2006 8/XX/2007 MD Purchase Primary No B B B B 9/XX/2025
and/or note date, but is not signed or dated by borrower so cannot confirm that defense to foreclosure. Assignee liability.
borrower received.
625489318 XXX XXX XXX 34534571 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 8/XX/2006 MD Purchase Primary No B B B B 9/XX/2025
625488971 XXX XXX XXX 34534040 credit 3 Missing Document: Missing Final 1003 9/XX/2008 FL Refinance - Cash-out - Debt Consolidation Primary No C C C C 9/XX/2025
625488971 XXX XXX XXX 34534118 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 9/XX/2008 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
following clauses:
625488971 XXX XXX XXX 34534127 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 9/XX/2008 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
an application date of 08/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 09/XX/2008, 08/XX/2008, 07/XX/2008, 06/XX/2008, 05/XX/2008, 04/XX/2008,
03/XX/2008. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625489199 XXX XXX XXX 34534153 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2005 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488284 XXX XXX XXX 34518069 credit 3 Missing Document: Missing Final 1003 1/XX/2006 AZ Refinance - Cash-out - Debt Consolidation Primary No C C C C 9/XX/2025
625488284 XXX XXX XXX 34518367 credit 3 Final Title Policy is missing. No evidence of title in file. 1/XX/2006 AZ Refinance - Cash-out - Debt Consolidation Primary No C C C C 9/XX/2025
625488284 XXX XXX XXX 34518386 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 1/XX/2006 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
625488284 XXX XXX XXX 34518388 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 1/XX/2006 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 01/XX/2006
used as disbursement date for compliance testing.
625488284 XXX XXX XXX 34518389 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 1/XX/2006 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
an application date of 12/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 01/XX/2006, 12/XX/2005, 11/XX/2005, 11/XX/2005. Lookback testing
performed up to one of the following: TRID start date, TIL/MDIA 2011 start date,
RESPA 2010 start date, TIL/MDIA 2009 start date, LOS Application Date, Broker
Application Date, or six months prior to consummation.
625488284 XXX XXX XXX 34518391 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 1/XX/2006 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488284 XXX XXX XXX 34518392 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 1/XX/2006 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625488284 XXX XXX XXX 34518393 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2006 1/XX/2007 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
application due to missing information.
625488284 XXX XXX XXX 34518394 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2006 1/XX/2007 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Loan Application Date.
625488284 XXX XXX XXX 34518395 compliance 2 (Missing Data) Unable to determine if loan is a same lender refi (Circuit 2, 5, Original Lender was not able to be determined. Unable to determine if correct 1/XX/2006 1/XX/2009 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
7, 8, 9, 10 or DC) TILA rescission form was used. (H-8 Form was used and property is in the 2 nd, 5
th, 7 th, 8 th, 9 th, 10 th, or District of Columbia)
625488238 XXX XXX XXX 34518225 credit 3 Missing Document: Missing Final 1003 7/XX/2007 AZ Purchase Primary No C C C C 9/XX/2025
625488238 XXX XXX XXX 34518736 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 7/XX/2007 AZ Purchase Primary No B B B B 9/XX/2025
an application date of 06/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 07/XX/2007, 06/XX/2007, 05/XX/2007, 04/XX/2007, 03/XX/2007, 02/XX/2007,
01/XX/2007. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625488238 XXX XXX XXX 34518738 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2007 7/XX/2008 AZ Purchase Primary No B B B B 9/XX/2025
application due to missing information.
625488238 XXX XXX XXX 34518739 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2007 7/XX/2008 AZ Purchase Primary No B B B B 9/XX/2025
Loan Application Date.
625488238 XXX XXX XXX 34518740 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 7/XX/2007 7/XX/2010 AZ Purchase Primary No B B B B 9/XX/2025
625488263 XXX XXX XXX 34535298 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Yes 4/XX/2004 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 04/XX/2004
used as disbursement date for compliance testing.
625488263 XXX XXX XXX 34541321 compliance 3 Missing Final HUD-1 Alternate Document Used for Fees (Primary) Missing Final HUD-1: HUD1, not signed or stamped used for any applicable Yes 4/XX/2004 FL Refinance - Cash-out - Debt Consolidation Primary No D D D D 9/XX/2025
Federal, State or Local compliance testing.
625488663 XXX XXX XXX 34535876 credit 3 Missing Document: Missing Final 1003 3/XX/2007 LA Purchase Primary No C C C C 9/XX/2025
625488663 XXX XXX XXX 34535916 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 3/XX/2007 LA Purchase Primary No B B B B 9/XX/2025
625488663 XXX XXX XXX 34535917 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 3/XX/2007 LA Purchase Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 03/XX/2007
used as disbursement date for compliance testing.
625488663 XXX XXX XXX 34535918 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 3/XX/2007 LA Purchase Primary No B B B B 9/XX/2025
an application date of 02/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 03/XX/2007, 02/XX/2007. Lookback testing performed up to one of the
following: TRID start date, TIL/MDIA 2011 start date, RESPA 2010 start date,
TIL/MDIA 2009 start date, LOS Application Date, Broker Application Date, or six
months prior to consummation.
625488663 XXX XXX XXX 34535920 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 LA Purchase Primary No B B B B 9/XX/2025
application due to missing information.
625488663 XXX XXX XXX 34535921 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 LA Purchase Primary No B B B B 9/XX/2025
Loan Application Date.
625488210 XXX XXX XXX 34518065 credit 3 Missing Document: Missing Final 1003 Yes 7/XX/2007 NJ Refinance - UTD UTD Yes C C C C 9/XX/2025
625488210 XXX XXX XXX 34518093 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off Yes 7/XX/2007 NJ Refinance - UTD UTD Yes B B B B 9/XX/2025
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488210 XXX XXX XXX 34518103 compliance 2 (Doc Error) Initial GFE not provided Yes 7/XX/2007 NJ Refinance - UTD UTD Yes B B B B 9/XX/2025
625488210 XXX XXX XXX 34518104 compliance 2 Unable to determine occupancy, compliance results were generated using a Yes 7/XX/2007 NJ Refinance - UTD UTD Yes B B B B 9/XX/2025
defaulted value of Primary.
625488210 XXX XXX XXX 34518106 credit 3 Final Title Policy is missing. No evidence of title in file. Yes 7/XX/2007 NJ Refinance - UTD UTD Yes C C C C 9/XX/2025
625488210 XXX XXX XXX 34518175 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Yes 7/XX/2007 NJ Refinance - UTD UTD Yes B B B B 9/XX/2025
Security Instrument Notary Date of 07/XX/2007 used as disbursement date for
compliance testing.
625488210 XXX XXX XXX 34518176 compliance 3 Missing Final HUD-1 No Alternate Fee Source Document (Primary or Second Home) Missing Final HUD-1. No document containing fees provided. Any applicable Yes 7/XX/2007 NJ Refinance - UTD UTD Yes D D D D 9/XX/2025
Federal, State or Local compliance testing is unreliable.
625488210 XXX XXX XXX 34518177 compliance 2 Missing Initial Loan Application No Fees Test No evidence of application date located in file. Compliance tests were run using Yes 7/XX/2007 NJ Refinance - UTD UTD Yes B B B B 9/XX/2025
an application date of 06/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 07/XX/2007, 06/XX/2007, 05/XX/2007, 04/XX/2007, 03/XX/2007, 02/XX/2007,
01/XX/2007. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation. Due to missing HUD-1 or Closing Disclosure, no fees were used in
testing.
625488210 XXX XXX XXX 34518179 compliance 2 Property Type Not Provided (Missing Data) Property Type. If property type is other than single family Yes 7/XX/2007 NJ Refinance - UTD UTD Yes B B B B 9/XX/2025
residence, state and federal testing may be impacted.
625488210 XXX XXX XXX 34518181 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. Yes 7/XX/2007 7/XX/2010 NJ Refinance - UTD UTD Yes B B B B 9/XX/2025
625488210 XXX XXX XXX 34518182 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a Yes 7/XX/2007 7/XX/2010 NJ Refinance - UTD UTD Yes B B B B 9/XX/2025
defense to foreclosure. Assignee liability.
625489442 XXX XXX XXX 34537583 credit 3 Missing Document: Missing Final 1003 4/XX/2007 IN Refinance - Rate/Term Primary Yes C C C C 9/XX/2025
625489442 XXX XXX XXX 34537676 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2007 4/XX/2008 IN Refinance - Rate/Term Primary Yes B B B B 9/XX/2025
CHARM Booklet, not provided to the borrower.
625488133 XXX XXX XXX 34539402 credit 3 Missing Document: Missing Final 1003 Yes 3/XX/2004 FL Refinance - UTD UTD No C C C C 9/XX/2025
625488133 XXX XXX XXX 34539406 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off Yes 3/XX/2004 FL Refinance - UTD UTD No B B B B 9/XX/2025
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488133 XXX XXX XXX 34539408 compliance 2 (Doc Error) Initial GFE not provided Yes 3/XX/2004 FL Refinance - UTD UTD No B B B B 9/XX/2025
625488133 XXX XXX XXX 34539409 compliance 2 Unable to determine occupancy, compliance results were generated using a Yes 3/XX/2004 FL Refinance - UTD UTD No B B B B 9/XX/2025
defaulted value of Primary.
625488133 XXX XXX XXX 34539416 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Yes 3/XX/2004 FL Refinance - UTD UTD No B B B B 9/XX/2025
Security Instrument Notary Date of 03/XX/2004 used as disbursement date for
compliance testing.
625488133 XXX XXX XXX 34539419 compliance 3 Missing Final HUD-1 No Alternate Fee Source Document (Primary or Second Home) Missing Final HUD-1. No document containing fees provided. Any applicable Yes 3/XX/2004 FL Refinance - UTD UTD No D D D D 9/XX/2025
Federal, State or Local compliance testing is unreliable.
625488133 XXX XXX XXX 34539420 compliance 2 Missing Initial Loan Application No Fees Test No evidence of application date located in file. Compliance tests were run using Yes 3/XX/2004 FL Refinance - UTD UTD No B B B B 9/XX/2025
an application date of 02/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 03/XX/2004, 02/XX/2004, 01/XX/2004, 12/XX/2003, 11/XX/2003, 10/XX/2003,
09/XX/2003. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation. Due to missing HUD-1 or Closing Disclosure, no fees were used in
testing.
625488133 XXX XXX XXX 34539422 compliance 2 Property Type Not Provided (Missing Data) Property Type. If property type is other than single family Yes 3/XX/2004 FL Refinance - UTD UTD No B B B B 9/XX/2025
residence, state and federal testing may be impacted.
625488133 XXX XXX XXX 34539427 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. Yes 3/XX/2004 3/XX/2007 FL Refinance - UTD UTD No B B B B 9/XX/2025
625488133 XXX XXX XXX 34539428 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a Yes 3/XX/2004 3/XX/2007 FL Refinance - UTD UTD No B B B B 9/XX/2025
defense to foreclosure. Assignee liability.
625488133 XXX XXX XXX 34539437 compliance 2 ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 3/XX/2004 3/XX/2005 FL Refinance - UTD UTD No B B B B 9/XX/2025
borrower.
625488133 XXX XXX XXX 34539438 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 3/XX/2004 3/XX/2005 FL Refinance - UTD UTD No B B B B 9/XX/2025
CHARM Booklet, not provided to the borrower.
625488328 XXX XXX XXX 34518772 credit 3 Missing Document: Missing Final 1003 5/XX/2005 CA Refinance - Cash-out - Debt Consolidation Primary No C C C C 9/XX/2025
625488328 XXX XXX XXX 34518872 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 5/XX/2005 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
an application date of 04/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 05/XX/2005, 04/XX/2005, 03/XX/2005, 02/XX/2005, 01/XX/2005, 12/XX/2004,
11/XX/2004. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625488328 XXX XXX XXX 34518874 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2005 5/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
application due to missing information.
625488328 XXX XXX XXX 34518875 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2005 5/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Loan Application Date.
625488328 XXX XXX XXX 34518876 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 05/XX/2005, prior to TILA ROR - 3yrs for rescindable transactions. 5/XX/2005 5/XX/2008 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Date three (3) business days from transaction date of 05/XX/2006.
625488328 XXX XXX XXX 34518877 compliance 2 TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Truth in Lending Act: Actual Date(s) on Notice of Right to Cancel occurs prior TILA ROR - 3yrs for rescindable transactions. 5/XX/2005 5/XX/2008 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Date to expected date(s).
625488854 XXX XXX XXX 34519588 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 8/XX/2005 FL Purchase Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 08/XX/2005
used as disbursement date for compliance testing.
625488854 XXX XXX XXX 34519590 compliance 2 ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2005 8/XX/2006 FL Purchase Primary No B B B B 9/XX/2025
borrower within three (3) days of application.
625488854 XXX XXX XXX 34519591 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2005 8/XX/2006 FL Purchase Primary No B B B B 9/XX/2025
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625488854 XXX XXX XXX 34519670 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 8/XX/2005 FL Purchase Primary No B B B B 9/XX/2025
625489179 XXX XXX XXX 34536626 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 4/XX/2007 CT Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
an application date of 03/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 04/XX/2007, 03/XX/2007. Lookback testing performed up to one of the
following: TRID start date, TIL/MDIA 2011 start date, RESPA 2010 start date,
TIL/MDIA 2009 start date, LOS Application Date, Broker Application Date, or six
months prior to consummation.
625489179 XXX XXX XXX 34536628 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2007 CT Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
Disclosure to borrower. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489179 XXX XXX XXX 34536629 compliance 2 Connecticut Prepayment Penalty Test Connecticut Prepayment Penalty: A prepayment penalty is not permissible under 4/XX/2007 CT Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
the Mortgage Lenders, Correspondent Lenders, Brokers and Loan Originators Act.
Prepay language states prepay will not exceed maximum permitted by applicable
law.
625489179 XXX XXX XXX 34536630 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2007 4/XX/2008 CT Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
application due to missing information.
625489179 XXX XXX XXX 34536631 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2007 4/XX/2008 CT Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
Loan Application Date.
625489179 XXX XXX XXX 34536634 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 4/XX/2007 CT Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
625487983 XXX XXX XXX 34536405 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 3/XX/2005 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
an application date of 02/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 03/XX/2005, 02/XX/2005, 01/XX/2005, 12/XX/2004, 11/XX/2004, 10/XX/2004,
09/XX/2004. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625487983 XXX XXX XXX 34536407 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2005 3/XX/2006 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
application due to missing information.
625487983 XXX XXX XXX 34536408 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2005 3/XX/2006 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
CHARM Booklet, not provided to the borrower.
625489636 XXX XXX XXX 34536207 credit 3 Missing Document: Missing Final 1003 5/XX/2005 FL Refinance - Cash-out - Other Primary No C C C C 9/XX/2025
625489636 XXX XXX XXX 34536228 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 5/XX/2005 FL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489636 XXX XXX XXX 34536229 compliance 2 (Doc Error) Initial GFE not provided 5/XX/2005 FL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
625489636 XXX XXX XXX 34536241 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 5/XX/2005 FL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 05/XX/2005
used as disbursement date for compliance testing.
625489636 XXX XXX XXX 34536242 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 5/XX/2005 FL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
an application date of 04/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 05/XX/2005, 04/XX/2005, 03/XX/2005, 02/XX/2005, 01/XX/2005, 12/XX/2004,
11/XX/2004. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625489636 XXX XXX XXX 34536243 compliance 2 Property Type Not Provided (Missing Data) Property Type. If property type is other than single family 5/XX/2005 FL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
residence, state and federal testing may be impacted.
625489636 XXX XXX XXX 34536245 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 5/XX/2005 5/XX/2008 FL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
625489636 XXX XXX XXX 34536246 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2005 5/XX/2008 FL Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
defense to foreclosure. Assignee liability.
625488930 XXX XXX XXX 34539950 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TIL appears to be final but not signed nor initialed by borrower TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 12/XX/2005 12/XX/2006 OK Purchase Primary No B B B B 9/XX/2025
defense to foreclosure. Assignee liability.
625488930 XXX XXX XXX 34539959 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TIL appears to be final but not signed nor initialed by borrower. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 12/XX/2005 12/XX/2006 OK Purchase Primary No B B B B 9/XX/2025
defense to foreclosure. Assignee liability.
625488930 XXX XXX XXX 34539967 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 12/XX/2005 OK Purchase Primary No B B B B 9/XX/2025
625488930 XXX XXX XXX 34539968 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2005 OK Purchase Primary No B B B B 9/XX/2025
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488930 XXX XXX XXX 34539969 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2005 OK Purchase Primary No B B B B 9/XX/2025
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488930 XXX XXX XXX 34539970 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 12/XX/2005 12/XX/2006 OK Purchase Primary No B B B B 9/XX/2025
defense to foreclosure. Assignee liability.
625488412 XXX XXX XXX 34536333 credit 3 Missing Document: Missing Final 1003 9/XX/2006 PA Purchase Primary No C C C C 9/XX/2025
625488412 XXX XXX XXX 34536415 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 9/XX/2006 PA Purchase Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 09/XX/2006
used as disbursement date for compliance testing.
625488412 XXX XXX XXX 34536417 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 9/XX/2006 PA Purchase Primary No B B B B 9/XX/2025
an application date of 09/XX/2006 which is 0 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 09/XX/2006, 09/XX/2006. Lookback testing performed up to one of the
following: TRID start date, TIL/MDIA 2011 start date, RESPA 2010 start date,
TIL/MDIA 2009 start date, LOS Application Date, Broker Application Date, or six
months prior to consummation.
625488412 XXX XXX XXX 34536418 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2006 9/XX/2007 PA Purchase Primary No B B B B 9/XX/2025
application due to missing information.
625488412 XXX XXX XXX 34536419 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2006 9/XX/2007 PA Purchase Primary No B B B B 9/XX/2025
Loan Application Date.
625489444 XXX XXX XXX 34536488 compliance 2 (Doc Error) Initial GFE not provided 7/XX/2007 AK Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
625489444 XXX XXX XXX 34537651 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 7/XX/2007 AK Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 07/XX/2007
used as disbursement date for compliance testing.
625489444 XXX XXX XXX 34537653 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 7/XX/2007 AK Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
an application date of 06/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 07/XX/2007, 06/XX/2007, 05/XX/2007, 04/XX/2007, 03/XX/2007, 02/XX/2007,
01/XX/2007. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625489444 XXX XXX XXX 34537685 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 7/XX/2007 AK Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
625488840 XXX XXX XXX 34524085 compliance 3 Missing Final HUD-1 Alternate Document Used for Fees (Primary) Missing Final HUD-1: HUD1, not signed or stamped used for any applicable Yes 3/XX/2007 AZ Refinance - Rate/Term Primary No D D D D 9/XX/2025
Federal, State or Local compliance testing.
625488840 XXX XXX XXX 34524086 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using Yes 3/XX/2007 AZ Refinance - Rate/Term Primary No B B B B 9/XX/2025
an application date of 02/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 03/XX/2007, 02/XX/2007, 01/XX/2007, 12/XX/2006, 11/XX/2006, 10/XX/2006,
09/XX/2006. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625488840 XXX XXX XXX 34524088 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions Yes 3/XX/2007 AZ Refinance - Rate/Term Primary No B B B B 9/XX/2025
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625488946 XXX XXX XXX 34536973 credit 3 Missing Document: Missing Final 1003 4/XX/2006 NY Purchase Primary No C C C C 9/XX/2025
625488946 XXX XXX XXX 34537330 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 4/XX/2006 NY Purchase Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 04/XX/2006
used as disbursement date for compliance testing.
625488946 XXX XXX XXX 34537331 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 4/XX/2006 NY Purchase Primary No B B B B 9/XX/2025
an application date of 03/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 04/XX/2006, 03/XX/2006, 02/XX/2006, 01/XX/2006, 12/XX/2005, 11/XX/2005.
Lookback testing performed up to one of the following: TRID start date, TIL/MDIA
2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date, LOS
Application Date, Broker Application Date, or six months prior to consummation.
625488946 XXX XXX XXX 34537332 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2006 NY Purchase Primary No B B B B 9/XX/2025
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625488946 XXX XXX XXX 34537333 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2006 4/XX/2007 NY Purchase Primary No B B B B 9/XX/2025
application due to missing information.
625488946 XXX XXX XXX 34537334 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2006 4/XX/2007 NY Purchase Primary No B B B B 9/XX/2025
Loan Application Date.
625488887 XXX XXX XXX 34543109 credit 3 Missing Document: Missing Final 1003 3/XX/2006 IL Refinance - Rate/Term Primary No C C C C 9/XX/2025
625488887 XXX XXX XXX 34544923 compliance 2 ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2006 3/XX/2007 IL Refinance - Rate/Term Primary No B B B B 9/XX/2025
borrower.
625488887 XXX XXX XXX 34544924 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2006 3/XX/2007 IL Refinance - Rate/Term Primary No B B B B 9/XX/2025
CHARM Booklet, not provided to the borrower.
625488056 XXX XXX XXX 34543729 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2007 WY Refinance - Cash-out - Debt Consolidation Primary No B B B B 9/XX/2025
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488678 XXX XXX XXX 34523490 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 2/XX/2007 GA Purchase Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 02/XX/2007
used as disbursement date for compliance testing.
625488678 XXX XXX XXX 34523491 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 2/XX/2007 GA Purchase Primary No B B B B 9/XX/2025
an application date of 01/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 02/XX/2007, 01/XX/2007, 12/XX/2006, 11/XX/2006. Lookback testing
performed up to one of the following: TRID start date, TIL/MDIA 2011 start date,
RESPA 2010 start date, TIL/MDIA 2009 start date, LOS Application Date, Broker
Application Date, or six months prior to consummation.
625488678 XXX XXX XXX 34523492 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2007 GA Purchase Primary No B B B B 9/XX/2025
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625488678 XXX XXX XXX 34523493 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 2/XX/2007 2/XX/2008 GA Purchase Primary No B B B B 9/XX/2025
defense to foreclosure. Assignee liability.
625488678 XXX XXX XXX 34574697 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 2/XX/2007 2/XX/2008 GA Purchase Primary No B B B B 9/XX/2025
defense to foreclosure. Assignee liability.
625488678 XXX XXX XXX 34574744 credit 3 Missing Document: Missing Final 1003 2/XX/2007 GA Purchase Primary No C C C C 9/XX/2025
625489346 XXX XXX XXX 34521909 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 7/XX/2007 MS Purchase Primary No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 07/XX/2007
used as disbursement date for compliance testing.
625489346 XXX XXX XXX 34521912 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2007 MS Purchase Primary No B B B B 9/XX/2025
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489346 XXX XXX XXX 34521913 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2007 MS Purchase Primary No B B B B 9/XX/2025
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625489346 XXX XXX XXX 34521959 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 7/XX/2007 MS Purchase Primary No B B B B 9/XX/2025
an application date of 07/XX/2007 which is 0 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 07/XX/2007, 07/XX/2007. Lookback testing performed up to one of the
following: TRID start date, TIL/MDIA 2011 start date, RESPA 2010 start date,
TIL/MDIA 2009 start date, LOS Application Date, Broker Application Date, or six
months prior to consummation.
625488312 XXX XXX XXX 34524508 credit 3 Missing Document: Missing Final 1003 3/XX/2007 MO Refinance - Cash-out - Other Primary No C C C C 9/XX/2025
625488312 XXX XXX XXX 34524521 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 3/XX/2007 MO Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
an application date of 02/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 03/XX/2007, 02/XX/2007, 02/XX/2007. Lookback testing performed up to one
of the following: TRID start date, TIL/MDIA 2011 start date, RESPA 2010 start
date, TIL/MDIA 2009 start date, LOS Application Date, Broker Application Date,
or six months prior to consummation.
625488312 XXX XXX XXX 34524523 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2007 MO Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625488312 XXX XXX XXX 34524524 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 MO Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
application due to missing information.
625488312 XXX XXX XXX 34524525 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 MO Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
Loan Application Date.
625488312 XXX XXX XXX 34524526 compliance 2 TIL APR Tolerance Irregular Transaction Truth In Lending Act: Final TIL APR of XX.XX% is underdisclosed from calculated TILA APR - subject to a 1 year SOL for affirmative claims, 3 years for 3/XX/2007 3/XX/2010 MO Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
APR of XX.XX% outside of 0.250% tolerance. rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488312 XXX XXX XXX 34524527 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from The index the Lender used at origination was not provided in the file. The $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 3/XX/2007 3/XX/2010 MO Refinance - Cash-out - Other Primary No B B B B 9/XX/2025
calculated Finance Charge of $XXX in the amount of $XXX. lowest index value available in the lookback period is 5.2591 and results in for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
higher payment streams than were disclosed on the Final TIL. liability.
625488312 XXX XXX XXX 34585011 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 3/XX/2007 MO Refinance - Cash-out - Other Primary No C C C C 9/XX/2025
625489419 XXX XXX XXX 34544411 credit 3 Missing Document: Missing Final 1003 2/XX/2002 NJ Purchase UTD No C C C C 9/XX/2025
625489419 XXX XXX XXX 34544412 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 2/XX/2002 NJ Purchase UTD No C C C C 9/XX/2025
625489419 XXX XXX XXX 34544609 compliance 2 Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. 2/XX/2002 NJ Purchase UTD No B B B B 9/XX/2025
Prepaid Interest From Date from HUD-1 or final closing disclosure of 02/XX/2002
used as disbursement date for compliance testing.
625489419 XXX XXX XXX 34544610 compliance 2 Missing Initial Loan Application Testing No evidence of application date located in file. Compliance tests were run using 2/XX/2002 NJ Purchase UTD No B B B B 9/XX/2025
an application date of 01/XX/2002 which is 1 months prior to consummation. A
lookback was performed to determine this application date using the following
dates: 02/XX/2002, 01/XX/2002, 12/XX/2001, 11/XX/2001, 10/XX/2001, 09/XX/2001,
08/XX/2001. Lookback testing performed up to one of the following: TRID start
date, TIL/MDIA 2011 start date, RESPA 2010 start date, TIL/MDIA 2009 start date,
LOS Application Date, Broker Application Date, or six months prior to
consummation.
625489419 XXX XXX XXX 34544611 compliance 2 New Jersey Prepayment Penalty New Jersey Prepayment Penalty: No prepayment penalties are permissible in the 2/XX/2002 NJ Purchase UTD No B B B B 9/XX/2025
state of New Jersey. Prepay language states prepay will not exceed maximum
permitted by applicable law.
625489419 XXX XXX XXX 34544612 compliance 2 ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2002 2/XX/2003 NJ Purchase UTD No B B B B 9/XX/2025
borrower.
625489419 XXX XXX XXX 34544613 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2002 2/XX/2003 NJ Purchase UTD No B B B B 9/XX/2025
CHARM Booklet, not provided to the borrower.
625489419 XXX XXX XXX 34544618 compliance 2 (Doc Error) Initial GFE not provided 2/XX/2002 NJ Purchase UTD No B B B B 9/XX/2025
625489419 XXX XXX XXX 34544619 compliance 2 Unable to determine occupancy, compliance results were generated using a 2/XX/2002 NJ Purchase UTD No B B B B 9/XX/2025
defaulted value of Primary.
625489299 XXX XXX XXX 35075078 compliance 1 Missing Document: Note - Subject Lien not provided 4/XX/2008 MO Refinance - Cash-out - Debt Consolidation Primary No A A A A 4/XX/2016 Yes 2016/XX/20: provided 04/XX/2016
625489299 XXX XXX XXX 35075079 compliance 1 Missing Final HUD-1 Missing Final HUD-1. Title Co. Closing Statement used for any applicable A violation of RESPA does not impair the validity of a loan or expose a true 4/XX/2008 MO Refinance - Cash-out - Debt Consolidation Primary No A A A A 5/XX/2016 Yes 2016/XX/11: Final HUD received
Federal, State or Local compliance testing. secondary market purchaser of a loan to assignee liability or rescission of the
loan. While there are no express private rights of action under either Section 4
or 5 of RESPA, originators who violate these provisions are subject to
enforcement action by a host of federal and state governmental authorities, and
face the possible imposition of civil money penalties. Further, originators who
violate Sections 4 and 5 of RESPA could be subject to claims arising under state
law, such as state deceptive acts and practices statutes.
625488086 XXX XXX XXX 35075080 compliance 1 (Doc Error) Initial GFE not provided 5/XX/2008 WA Refinance - Rate/Term Primary No A A A A 4/XX/2016 Yes 2016/XX/22: received (Doc) on 4/22
625488086 XXX XXX XXX 35075081 compliance 1 Initial TIL not provided TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2008 5/XX/2011 WA Refinance - Rate/Term Primary No A A A A 4/XX/2016 Yes 2016/XX/22: received (Doc) on 4/22
defense to foreclosure. Assignee liability.
625488086 XXX XXX XXX 35075082 compliance 1 Missing Final HUD-1 5/XX/2008 WA Refinance - Rate/Term Primary No A A A A 4/XX/2016 Yes 2016/XX/22: received (Doc) on 4/22
625488086 XXX XXX XXX 35075083 compliance 1 TILA - Final TIL Missing TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2008 5/XX/2011 WA Refinance - Rate/Term Primary No A A A A 4/XX/2016 Yes 2016/XX/22: received (Doc) on 4/22
defense to foreclosure. Assignee liability.
625488086 XXX XXX XXX 35075084 compliance 1 (Missing Doc) Incomplete loan images/file Incomplete file: File only contains Note, Mortgage and Title Policy. 5/XX/2008 WA Refinance - Rate/Term Primary No A A A A 4/XX/2016 Yes 2016/XX/22: received (Docs) for compliance testing on 4/22
625488086 XXX XXX XXX 35075085 credit 1 Missing Document: Missing all loan applications. 5/XX/2008 WA Refinance - Rate/Term Primary No A A A A 4/XX/2016 Yes 2016/XX/22: received (Doc) on 4/22
625488086 XXX XXX XXX 35075086 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 5/XX/2008 5/XX/2011 WA Refinance - Rate/Term Primary No B B B B
625489120 XXX XXX XXX 35075096 compliance 2 Initial TIL not provided TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2007 8/XX/2010 MD Refinance - Rate/Term Primary No B B B B
defense to foreclosure. Assignee liability.
625489120 XXX XXX XXX 35075097 compliance 2 (Doc Error) Initial GFE not provided 8/XX/2007 MD Refinance - Rate/Term Primary No B B B B
625489120 XXX XXX XXX 35075098 compliance 3 Missing Document: Missing 1003 Initial - Lender's Compliance testing was completed using up to a 6 month look back from the Note 8/XX/2007 MD Refinance - Rate/Term Primary No B B B B
date.
625488841 XXX XXX XXX 35075107 compliance 2 Initial TIL not provided TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2008 11/XX/2011 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625488841 XXX XXX XXX 35075108 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 11/XX/2008 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488598 XXX XXX XXX 35075179 compliance 2 TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Truth in Lending Act: Actual Date(s) on Notice of Right to Rescind occurs prior TILA ROR - 3yrs for rescindable transactions. 12/XX/2004 12/XX/2007 NV Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date to expected date(s).
625488598 XXX XXX XXX 35075180 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 12/XX/2004 12/XX/2007 NV Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625489021 XXX XXX XXX 35075206 compliance 2 Initial TIL not provided TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2006 10/XX/2009 NC Refinance - Rate/Term Primary No B B B B
defense to foreclosure. Assignee liability.
625488596 XXX XXX XXX 35075255 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2006 10/XX/2007 NC Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625488596 XXX XXX XXX 35075256 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2006 10/XX/2007 NC Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625488596 XXX XXX XXX 35075257 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2006 NC Purchase Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488726 XXX XXX XXX 35075271 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2007 MN Refinance - Rate/Term Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489659 XXX XXX XXX 35075319 compliance 1 Missing Document: Note - Subject Lien not provided 10/XX/2007 HI Purchase Primary No A A A A 4/XX/2016 Yes 2016/XX/20: provided 04/XX/2016
625489659 XXX XXX XXX 35075320 credit 1 Missing Document: Security Instrument - Subject Lien not provided 10/XX/2007 HI Purchase Primary No A A A A 4/XX/2016 Yes 2016/XX/22: Received doc 04/XX/2016
625489659 XXX XXX XXX 35075321 compliance 1 (Missing Doc) Incomplete loan images/file ? 10/XX/2007 HI Purchase Primary No A A A A 4/XX/2016 Yes 2016/XX/21: unable to run compliance due to incomplete data
2016/XX/23: file received
625489659 XXX XXX XXX 35075322 compliance 1 Missing Final HUD-1 10/XX/2007 HI Purchase Primary No A A A A 4/XX/2016 Yes 2016/XX/22: Received doc 04/XX/2016
625489659 XXX XXX XXX 35075323 compliance 1 TILA - Final TIL Missing TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2007 10/XX/2008 HI Purchase Primary No A A A A 4/XX/2016 Yes 2016/XX/22: Received doc 04/XX/2016
defense to foreclosure. Assignee liability.
625489659 XXX XXX XXX 35075324 credit 1 Title: Evidence of title is missing 10/XX/2007 HI Purchase Primary No A A A A 4/XX/2016 Yes 2016/XX/22: Received doc 04/XX/2016
625489659 XXX XXX XXX 35075325 credit 1 Missing Document: Missing all loan applications. 10/XX/2007 HI Purchase Primary No A A A A 4/XX/2016 Yes 2016/XX/22: Received doc 04/XX/2016
625489659 XXX XXX XXX 35075326 compliance 1 (Missing Data) Application Date No evidence of application date located in file. Compliance tests were run using 10/XX/2007 HI Purchase Primary No A A A A 5/XX/2016 Yes 2016/XX/10: Received doc on 4/XX/16
an application date of 9/XX/2007 which is 30 days prior to the note date.
2016/XX/10: Docs were received
2016/XX/10: docs received 4/XX/16
625489659 XXX XXX XXX 35075327 compliance 2 (Doc Error) Security Instrument Error: Notary Date was not provided 10/XX/2007 HI Purchase Primary No B B B B
625488774 XXX XXX XXX 35075365 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 6/XX/2007 FL Refinance - Rate/Term Primary No B B B B
an application date of 5/XX/2007 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625488774 XXX XXX XXX 35075366 compliance 1 Missing Final HUD-1 Missing Final HUD-1. No document containing fees provided. Any applicable A violation of RESPA does not impair the validity of a loan or expose a true 6/XX/2007 FL Refinance - Rate/Term Primary No A A A A 7/XX/2016 Yes 2016/XX/27: HUD provided
Federal, State or Local compliance testing is unreliable. secondary market purchaser of a loan to assignee liability or rescission of the
loan. While there are no express private rights of action under either Section 4
or 5 of RESPA, originators who violate these provisions are subject to
enforcement action by a host of federal and state governmental authorities, and
face the possible imposition of civil money penalties. Further, originators who
violate Sections 4 and 5 of RESPA could be subject to claims arising under state
law, such as state deceptive acts and practices statutes.
625488774 XXX XXX XXX 35075368 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. Missing documentation to determine the occupancy and purpose therefore TILA ROR - 3yrs for rescindable transactions. 6/XX/2007 6/XX/2010 FL Refinance - Rate/Term Primary No B B B B
compliance review defaulted to owner occupied/cash out refinance.
625488774 XXX XXX XXX 35075369 compliance 1 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2007 6/XX/2010 FL Refinance - Rate/Term Primary No A A A A 7/XX/2016 Yes 2016/XX/27: TIL provided
defense to foreclosure. Assignee liability.
625488774 XXX XXX XXX 35075370 compliance 2 (Doc Error) Initial GFE not provided 6/XX/2007 FL Refinance - Rate/Term Primary No B B B B
625488774 XXX XXX XXX 35075371 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 6/XX/2007 FL Refinance - Rate/Term Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488774 XXX XXX XXX 35075372 credit 3 Missing Document: Missing Final 1003 6/XX/2007 FL Refinance - Rate/Term Primary No C C C C
625488714 XXX XXX XXX 35075451 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 3/XX/2006 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
625488714 XXX XXX XXX 35075452 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 3/XX/2006 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
an application date of 2/XX/2006 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625488714 XXX XXX XXX 35075453 compliance 2 (Doc Error) Initial GFE not provided 3/XX/2006 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
625488272 XXX XXX XXX 35075456 credit 3 Missing Document: Missing Final 1003 No 8/XX/2007 TN Purchase Second Home No C C C C
625488272 XXX XXX XXX 35075457 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using No 8/XX/2007 TN Purchase Second Home No B B B B
an application date of 7/XX/2007 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625488272 XXX XXX XXX 35075458 compliance 3 Missing Final HUD-1 Missing Final HUD-1. No document containing fees provided. Any applicable A violation of RESPA does not impair the validity of a loan or expose a true No 8/XX/2007 TN Purchase Second Home No D D D D
Federal, State or Local compliance testing is unreliable. secondary market purchaser of a loan to assignee liability or rescission of the
loan. While there are no express private rights of action under either Section 4
or 5 of RESPA, originators who violate these provisions are subject to
enforcement action by a host of federal and state governmental authorities, and
face the possible imposition of civil money penalties. Further, originators who
violate Sections 4 and 5 of RESPA could be subject to claims arising under state
law, such as state deceptive acts and practices statutes.
625488272 XXX XXX XXX 35075459 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a No 8/XX/2007 8/XX/2008 TN Purchase Second Home No B B B B
defense to foreclosure. Assignee liability.
625488272 XXX XXX XXX 35075460 compliance 2 (Doc Error) Initial GFE not provided No 8/XX/2007 TN Purchase Second Home No B B B B
625488272 XXX XXX XXX 35075461 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off No 8/XX/2007 TN Purchase Second Home No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488437 XXX XXX XXX 35075498 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 12/XX/2010 OH Purchase Primary No C C C C
625488437 XXX XXX XXX 35075499 compliance 2 RESPA (2010) - GFE Settlement charges Good Thru Date Less than 10 Days RESPA (2010): GFE does not provide minimum ten (10) business day availability RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2010 OH Purchase Primary No B B B B
for estimate of charges and terms for all other settlement charges. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488437 XXX XXX XXX 35075500 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2010 OH Purchase Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488437 XXX XXX XXX 35075501 compliance 2 RESPA Disclosure - HUD Settlement Cost Booklet Missing RESPA Disclosure Rule: Creditor did not provide HUD Settlement Cost Booklet. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2010 OH Purchase Primary No B B B B
within the statute or implementing regulation, Regulation X, for these type of
violations.
625488437 XXX XXX XXX 35075502 compliance 2 Ohio Consumer Sales Practices Act (Acknowledgement of Receipt of Home Mortgage Ohio Consumer Sales Practices Act: Acknowledgement of Receipt of Home Mortgage The Consumer Sales Practices Act (CSPA) generally does not provide for assignee 12/XX/2010 OH Purchase Primary No B B B B
Loan Information Document Not Retained by Lender) Loan Information Document not retained by lender. liability. The Act provides that no claim or defense may be asserted under the
Act by the Attorney General or any consumer against a purchaser or assignee of a
mortgage loan for value for any action under the statute unless: (a) the
violation was committed by the purchaser or assignee; or (b) the assignee or
purchaser is affiliated by common control with the seller of the loan at the
time the loan was purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant
injunctions, and levy monetary fines. Additionally, the CSPA provides borrowers
with a private right of action. Therefore, it is possible that any action
commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law
as part of the private right of action, a court could reform the loan terms
which could impact purchasers. Therefore, if the seller cannot be compelled to
repurchase the loan, the assignee could face exposure.
625488437 XXX XXX XXX 35075503 compliance 2 Ohio Consumer Sales Practices Act (Closing Disclosure Not Provided) Ohio Consumer Sales Practices Act: Consumer did not receive the required Closing The Consumer Sales Practices Act (CSPA) generally does not provide for assignee 12/XX/2010 OH Purchase Primary No B B B B
Disclosure. liability. The Act provides that no claim or defense may be asserted under the
Act by the Attorney General or any consumer against a purchaser or assignee of a
mortgage loan for value for any action under the statute unless: (a) the
violation was committed by the purchaser or assignee; or (b) the assignee or
purchaser is affiliated by common control with the seller of the loan at the
time the loan was purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant
injunctions, and levy monetary fines. Additionally, the CSPA provides borrowers
with a private right of action. Therefore, it is possible that any action
commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law
as part of the private right of action, a court could reform the loan terms
which could impact purchasers. Therefore, if the seller cannot be compelled to
repurchase the loan, the assignee could face exposure.
625488437 XXX XXX XXX 35075504 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization did not disclose the following fees as prepaid finance charges: $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 12/XX/2010 12/XX/2011 OH Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. $XXX Closing Protection Letter, $XXX Flood Cert, $XXX Origination Fee, $XXX for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
Recording Service Fee, $XXX Settlement Fee, $XXX Tax Service Fee, $XXX Title liability.
Courier, $XXX Wire Fee. Itemization also included a $XXX Final Inspection Fee as
a prepaid charge.
625488244 XXX XXX XXX 35075511 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 10/XX/2006 SC Construction-Permanent Primary No B B B B
within a reasonably practicable time after using credit score.
625488244 XXX XXX XXX 35075512 compliance 2 South Carolina Home Loan (Complaint Agency Disclosure Not Provided) South Carolina Home Loan: Borrower not provided with a document specifying the Exceptions occurring more than 6 years ago may be outside the states statute of 10/XX/2006 10/XX/2012 SC Construction-Permanent Primary No B B B B
agency designated to receive complaints or inquiries about the origination and limitations. Due to the potential remedies available to a court, this exception
making of the loan. carries elevated risk to an assignee during the initial 6 years after occurrence
of the violation. After the expiration of this 6 year period, the exception
retains risk for claims raised as a defense to foreclosure, but not at the same
level as during the initial 6 years for affirmative claims.
625489093 XXX XXX XXX 35075604 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 1/XX/2008 TX Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489093 XXX XXX XXX 35075605 credit 2 Final Title Policy is missing. No evidence of title was found in file. 1/XX/2008 TX Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489506 XXX XXX XXX 35075617 compliance 2 (Doc Error) Initial GFE not provided 9/XX/2005 MD Purchase Primary No B B B B
625489506 XXX XXX XXX 35075618 compliance 2 Initial TIL not provided 9/XX/2005 9/XX/2006 MD Purchase Primary No B B B B
625488914 XXX XXX XXX 35075648 credit 3 Missing Document: FHA Mortgage Insurance Certificate not provided 4/XX/2009 NC Refinance - Rate/Term Primary No C C C C
625488914 XXX XXX XXX 35075649 credit 3 Missing Document: Missing Final 1003 4/XX/2009 NC Refinance - Rate/Term Primary No C C C C
625488914 XXX XXX XXX 35075650 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 4/XX/2009 NC Refinance - Rate/Term Primary No B B B B
an application date of 3/XX/2009 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625489676 XXX XXX XXX 35075672 credit 3 Missing Document: Missing Final 1003 Broker's only page 1 3/XX/2008 IL Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489676 XXX XXX XXX 35075673 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 3/XX/2008 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489676 XXX XXX XXX 35075674 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 3/XX/2008 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 2/XX/2008 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625488656 XXX XXX XXX 35075682 compliance 2 (Doc Error) Initial GFE not provided 6/XX/2005 CA Refinance - Cash-out - Other Primary No B B B B
625488656 XXX XXX XXX 35075683 credit 3 Missing Document: Missing Final 1003 6/XX/2005 CA Refinance - Cash-out - Other Primary No C C C C
625488656 XXX XXX XXX 35075684 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 6/XX/2005 CA Refinance - Cash-out - Other Primary No B B B B
an application date of 5/XX/2005 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625488656 XXX XXX XXX 35075685 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine cause of under disclosure due to missing itemization of $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 6/XX/2005 6/XX/2008 CA Refinance - Cash-out - Other Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. amount financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489089 XXX XXX XXX 35075759 compliance 2 SAFE Act - LO Company NMLS license status not approved Secure and Fair Enforcement for Mortgage Licensing Act: Loan Originator Oraganization is in approved status Liability appears to be limited to originators/licensees. 9/XX/2011 CA Purchase Primary No B B B B
Organization not in approved license status to conduct loan origination
activities.
625489089 XXX XXX XXX 35075760 compliance 2 SAFE Act - Individual LO NMLS license status not approved Secure and Fair Enforcement for Mortgage Licensing Act: Individual Loan LO in approved status at time of origination Liability appears to be limited to originators/licensees. 9/XX/2011 CA Purchase Primary No B B B B
Originator not in approved license status to conduct loan origination
activities.
625489089 XXX XXX XXX 35075761 compliance 2 RESPA (2010) - GFE Settlement charges Good Thru Date Less than 10 Days RESPA (2010): GFE does not provide minimum ten (10) business day availability RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2011 CA Purchase Primary No B B B B
for estimate of charges and terms for all other settlement charges. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489089 XXX XXX XXX 35075762 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2011 CA Purchase Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489089 XXX XXX XXX 35075763 compliance 2 RESPA Disclosure - HUD Settlement Cost Booklet Missing RESPA Disclosure Rule: Creditor did not provide HUD Settlement Cost Booklet. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2011 CA Purchase Primary No B B B B
within the statute or implementing regulation, Regulation X, for these type of
violations.
625488546 XXX XXX XXX 35075783 credit 3 Missing Document: Missing Final 1003 11/XX/2006 PA Purchase Primary No C C C C
625488546 XXX XXX XXX 35075784 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 11/XX/2006 PA Purchase Primary No B B B B
625488546 XXX XXX XXX 35075785 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 11/XX/2006 PA Purchase Primary No B B B B
an application date of 10/XX/2006 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625488546 XXX XXX XXX 35075786 compliance 2 (Doc Error) Initial GFE not provided 11/XX/2006 PA Purchase Primary No B B B B
625488546 XXX XXX XXX 35075787 compliance 2 Initial TIL not provided 11/XX/2006 11/XX/2007 PA Purchase Primary No B B B B
625488093 XXX XXX XXX 35075808 credit 3 Missing Document: Missing Final 1003 9/XX/2006 PA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488093 XXX XXX XXX 35075809 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 9/XX/2006 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 8/XX/2006 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625488093 XXX XXX XXX 35075810 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2006 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488046 XXX XXX XXX 35075820 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 6/XX/2008 6/XX/2011 GA Refinance - Cash-out - Other Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488046 XXX XXX XXX 35075821 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 6/XX/2008 GA Refinance - Cash-out - Other Primary No C C C C
625488046 XXX XXX XXX 35075822 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 6/XX/2008 GA Refinance - Cash-out - Other Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488046 XXX XXX XXX 35075823 compliance 2 Final TIL APR Under/Over Disclosed By Greater Than 0.125% Truth In Lending Act: Final TIL APR of XX.XX% is underdisclosed from calculated TILA APR - subject to a 1 year SOL for affirmative claims, 3 years for 6/XX/2008 6/XX/2011 GA Refinance - Cash-out - Other Primary No B B B B
APR of XX.XX% outside of 0.125% tolerance. rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489516 XXX XXX XXX 35075836 credit 3 Missing Document: FHA Mortgage Insurance Certificate not provided 8/XX/2009 MS Purchase Primary No C C C C
625489516 XXX XXX XXX 35075837 credit 3 Missing Document: Missing Final 1003 8/XX/2009 MS Purchase Primary No C C C C
625489516 XXX XXX XXX 35075838 compliance 1 Missing Document: Note - Subject Lien not provided Note provided is for property located at XXX however subject loan is for 8/XX/2009 MS Purchase Primary No A A A A 9/XX/2016 Yes 2016/XX/06: Correct note received
property located at XXX
625489125 XXX XXX XXX 35075850 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 9/XX/2007 GA Purchase Primary No B B B B
625489125 XXX XXX XXX 35075851 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2007 GA Purchase Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489711 XXX XXX XXX 35075939 credit 3 Missing Document: Missing Final 1003 1/XX/2008 FL Refinance - Cash-out - Other Primary No C C C C
625489711 XXX XXX XXX 35075940 compliance 2 (Doc Error) Initial GFE not provided 1/XX/2008 FL Refinance - Cash-out - Other Primary No B B B B
625489711 XXX XXX XXX 35075941 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 1/XX/2008 FL Refinance - Cash-out - Other Primary No C C C C
625489711 XXX XXX XXX 35075942 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 1/XX/2008 FL Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488537 XXX XXX XXX 35076063 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 4/XX/2008 IL Refinance - Rate/Term Primary No B B B B
625488537 XXX XXX XXX 35076064 compliance 2 TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit 4/XX/2008 4/XX/2011 IL Refinance - Rate/Term Primary No B B B B
(Circuit 2, 3, 5, 7, 8, 9, 10 or DC) Model Form for a refinancing by the same creditor. The H-8 form was used, the courts, the continuing risk that the borrower may have an extended right to
H-9 form should have been used. rescind (3 additional years) if a creditor uses the incorrect Model Form
remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625487939 XXX XXX XXX 35076085 compliance 2 TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit 7/XX/2005 7/XX/2008 CA Refinance - Cash-out - Other Primary No B B B B
(Circuit 2, 3, 5, 7, 8, 9, 10 or DC) Model Form for a refinancing by the same creditor. The H-8 form was used, the courts, the continuing risk that the borrower may have an extended right to
H-9 form should have been used. rescind (3 additional years) if a creditor uses the incorrect Model Form
remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625488729 XXX XXX XXX 35076088 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2005 IL Purchase Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488729 XXX XXX XXX 35076089 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2005 6/XX/2006 IL Purchase Primary No B B B B
borrower within three (3) days of application.
625488729 XXX XXX XXX 35076090 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2005 6/XX/2006 IL Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488729 XXX XXX XXX 35076091 credit 2 Final Title Policy is missing. No evidence of title was found in file. 6/XX/2005 IL Purchase Primary No B B B B
625488729 XXX XXX XXX 35076092 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine underdisclosure, missing Itemization. $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 6/XX/2005 6/XX/2006 IL Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489646 XXX XXX XXX 35076108 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 9/XX/2005 MO Purchase Primary No C C C C
625488987 XXX XXX XXX 35076112 credit 3 Missing Document: Missing Final 1003 4/XX/2005 LA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488987 XXX XXX XXX 35076113 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 4/XX/2005 LA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 3/XX/2005 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625488987 XXX XXX XXX 35076114 compliance 2 (Doc Error) Note Error: Loan does not comply with state prepayment penalty PPP expired. Prepayment charge not allowed per state of LA - max prepayment 4/XX/2005 LA Refinance - Cash-out - Debt Consolidation Primary No B B B B
requirements charge for LA loan is 5%, 4%, 3%, 2%, 1% - Note rider reflects prepayment of 5%,
5%,5%.5%,5%. Lender is XXX.
625488772 XXX XXX XXX 35076230 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using No 3/XX/2008 FL Purchase Investment No B B B B
an application date of 2/XX/2008 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625488772 XXX XXX XXX 35076231 compliance 3 Missing Final HUD-1 Missing Final HUD-1. No document containing fees provided. Any applicable A violation of RESPA does not impair the validity of a loan or expose a true No 3/XX/2008 FL Purchase Investment No D D D D
Federal, State or Local compliance testing is unreliable. secondary market purchaser of a loan to assignee liability or rescission of the
loan. While there are no express private rights of action under either Section 4
or 5 of RESPA, originators who violate these provisions are subject to
enforcement action by a host of federal and state governmental authorities, and
face the possible imposition of civil money penalties. Further, originators who
violate Sections 4 and 5 of RESPA could be subject to claims arising under state
law, such as state deceptive acts and practices statutes.
625488772 XXX XXX XXX 35076232 compliance 2 (Missing Data) Missing Information to Determine Origination Channel Unable to determine the origination channel based on the loan documents provided No 3/XX/2008 FL Purchase Investment No B B B B
for review. The compliance review was performed with using the equivalent
evaluation that would be considered for an Origination Channel of Retail.
625488772 XXX XXX XXX 35076233 credit 3 Missing Document: Missing Final 1003 No 3/XX/2008 FL Purchase Investment No C C C C
625489501 XXX XXX XXX 35076243 credit 1 Missing Document: Missing Final 1003 1/XX/2007 CA Purchase Primary No A A A A 9/XX/2016 Yes 2016/XX/02: Received Final 1003, exception cleared.
625489501 XXX XXX XXX 35076244 compliance 2 Missing Document: Missing Lender's Initial 1003 1/XX/2007 CA Purchase Primary No B B B B
625489501 XXX XXX XXX 35076245 compliance 1 Missing Document: Note - Subject Lien not provided 1/XX/2007 CA Purchase Primary No A A A A 9/XX/2016 Yes 2016/XX/02: Received Note, exception cleared.
625489501 XXX XXX XXX 35076246 credit 3 Missing Document: Security Instrument - Subject Lien not provided 1/XX/2007 CA Purchase Primary No D D D D
625489501 XXX XXX XXX 35076247 credit 1 Title: Evidence of title is missing 1/XX/2007 CA Purchase Primary No A A A A 9/XX/2016 Yes 2016/XX/02: Received Final Title, exception cleared.
625489501 XXX XXX XXX 35076248 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 1/XX/2007 CA Purchase Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489501 XXX XXX XXX 35076249 compliance 2 (Doc Error) Initial GFE not provided 1/XX/2007 CA Purchase Primary No B B B B
625489501 XXX XXX XXX 35076250 compliance 1 TILA - Final TIL Missing TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 1/XX/2007 1/XX/2008 CA Purchase Primary No A A A A 9/XX/2016 Yes 2016/XX/02: Received TIL, exception cleared.
defense to foreclosure. Assignee liability.
625489501 XXX XXX XXX 35076251 compliance 1 Missing Final HUD-1 1/XX/2007 CA Purchase Primary No A A A A 9/XX/2016 Yes 2016/XX/02: Received Final HUD-1, exception cleared.
625489501 XXX XXX XXX 35076253 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 1/XX/2007 CA Purchase Primary No B B B B
625489501 XXX XXX XXX 35076254 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 1/XX/2007 CA Purchase Primary No B B B B
an application date of 12/XX/2006 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625489501 XXX XXX XXX 35076255 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2007 1/XX/2008 CA Purchase Primary No B B B B
borrower.
625489501 XXX XXX XXX 35076256 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2007 1/XX/2008 CA Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489030 XXX XXX XXX 35076260 compliance 2 Initial TIL not provided Provided date not indicated on initial TIL. 3/XX/2007 3/XX/2008 MD Purchase Primary No B B B B
625489030 XXX XXX XXX 35076261 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 3/XX/2007 MD Purchase Primary No B B B B
625489030 XXX XXX XXX 35076262 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2007 MD Purchase Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489030 XXX XXX XXX 35076263 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2007 3/XX/2008 MD Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625489030 XXX XXX XXX 35076264 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2007 3/XX/2008 MD Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625489200 XXX XXX XXX 35076270 credit 3 Missing Document: Missing Final 1003 8/XX/2007 GA Purchase Primary No C C C C
625489200 XXX XXX XXX 35076271 compliance 2 (Doc Error) Initial GFE not provided 8/XX/2007 GA Purchase Primary No B B B B
625489200 XXX XXX XXX 35076272 compliance 2 Initial TIL not provided 8/XX/2007 8/XX/2008 GA Purchase Primary No B B B B
625489200 XXX XXX XXX 35076273 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 8/XX/2007 GA Purchase Primary No B B B B
an application date of 7/XX/2007 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625489200 XXX XXX XXX 35076274 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2007 GA Purchase Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488791 XXX XXX XXX 35076297 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 11/XX/2006 WI Refinance - Rate/Term Primary No B B B B
625488791 XXX XXX XXX 35076298 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 11/XX/2006 WI Refinance - Rate/Term Primary No B B B B
an application date of 10/XX/2006 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625488791 XXX XXX XXX 35076299 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2006 11/XX/2007 WI Refinance - Rate/Term Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488791 XXX XXX XXX 35076300 compliance 2 (Doc Error) Initial GFE not provided 11/XX/2006 WI Refinance - Rate/Term Primary No B B B B
625489206 XXX XXX XXX 35076346 credit 3 Missing Document: Missing Final 1003 7/XX/2007 MD Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489206 XXX XXX XXX 35076347 compliance 2 Initial TIL not provided The Lender's Initial Truth In Lending Disclosure was not provided in the loan 7/XX/2007 7/XX/2008 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
File.
625489206 XXX XXX XXX 35076349 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 7/XX/2007 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 6/XX/2007 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625488305 XXX XXX XXX 35076363 credit 3 Missing Document: Missing Final 1003 10/XX/2006 MS Refinance - Cash-out - Other Primary No C C C C
625488305 XXX XXX XXX 35076364 compliance 2 Missing Document: Missing Lender's Initial 1003 10/XX/2006 MS Refinance - Cash-out - Other Primary No B B B B
625488305 XXX XXX XXX 35076365 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 10/XX/2006 MS Refinance - Cash-out - Other Primary No B B B B
625488305 XXX XXX XXX 35076366 credit 2 Final Title Policy is missing. No evidence of title was found in file. 10/XX/2006 MS Refinance - Cash-out - Other Primary No B B B B
625488363 XXX XXX XXX 35076391 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 11/XX/2007 CA Refinance - Cash-out - Debt Consolidation Investment No B B B B
625489114 XXX XXX XXX 35076447 credit 3 Missing Document: FHA Case Number Assignment not provided 2/XX/2009 MA Refinance - Rate/Term Primary Yes C C C C
625489114 XXX XXX XXX 35076448 credit 3 Missing Document: FHA Mortgage Insurance Certificate not provided 2/XX/2009 MA Refinance - Rate/Term Primary Yes C C C C
625489114 XXX XXX XXX 35076449 credit 3 Missing Document: HUD/VA 92900-A not provided 2/XX/2009 MA Refinance - Rate/Term Primary Yes C C C C
625489114 XXX XXX XXX 35076450 compliance 2 Final TIL APR Under/Over Disclosed By Greater Than 0.125% Truth In Lending Act: Final TIL APR of XX.XX% is underdisclosed from calculated TILA APR - subject to a 1 year SOL for affirmative claims, 3 years for 2/XX/2009 2/XX/2013 MA Refinance - Rate/Term Primary Yes B B B B
APR of XX.XX% outside of 0.125% tolerance. rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489114 XXX XXX XXX 35076451 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 2/XX/2009 2/XX/2013 MA Refinance - Rate/Term Primary Yes B B B B
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489114 XXX XXX XXX 35076452 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 2/XX/2009 MA Refinance - Rate/Term Primary Yes B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625487961 XXX XXX XXX 35076466 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 11/XX/2005 CA Purchase Primary No B B B B
an application date of 10/XX/2005 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625487961 XXX XXX XXX 35076467 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2005 11/XX/2006 CA Purchase Primary No B B B B
borrower.
625487961 XXX XXX XXX 35076468 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2005 11/XX/2006 CA Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488455 XXX XXX XXX 35076485 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2005 9/XX/2006 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488455 XXX XXX XXX 35076486 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2005 9/XX/2006 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B
borrower within three (3) days of application.
625488073 XXX XXX XXX 35076488 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 12/XX/2006 MD Refinance - Cash-out - Other Primary No B B B B
within a reasonably practicable time after using credit score.
625488073 XXX XXX XXX 35076489 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 12/XX/2006 MD Refinance - Cash-out - Other Primary No B B B B
an application date of 11/XX/2006 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625488073 XXX XXX XXX 35076490 credit 3 Missing Document: Missing Final 1003 12/XX/2006 MD Refinance - Cash-out - Other Primary No C C C C
625488019 XXX XXX XXX 35076497 credit 3 Missing Document: Missing Final 1003 9/XX/2006 FL Refinance - Cash-out - Other Second Home No C C C C
625488019 XXX XXX XXX 35076498 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 9/XX/2006 FL Refinance - Cash-out - Other Second Home No B B B B
625488019 XXX XXX XXX 35076499 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 9/XX/2006 FL Refinance - Cash-out - Other Second Home No B B B B
an application date of 8/XX/2006 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625488019 XXX XXX XXX 35076500 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2006 FL Refinance - Cash-out - Other Second Home No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488019 XXX XXX XXX 35076501 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TIL in file indicated to be final, expected funding date same as disbursement TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2006 9/XX/2007 FL Refinance - Cash-out - Other Second Home No B B B B
and/or note date but is not signed or dated by borrower so cannot confirm that defense to foreclosure. Assignee liability.
borrower received.
625488019 XXX XXX XXX 35076502 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 9/XX/2006 FL Refinance - Cash-out - Other Second Home No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489376 XXX XXX XXX 35076515 compliance 2 (Doc Error) Initial GFE not provided 7/XX/2005 IL Refinance - Rate/Term Primary No B B B B
625489376 XXX XXX XXX 35076516 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2005 7/XX/2006 IL Refinance - Rate/Term Primary No B B B B
borrower.
625489376 XXX XXX XXX 35076517 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2005 7/XX/2006 IL Refinance - Rate/Term Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489376 XXX XXX XXX 35076518 compliance 2 TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit 7/XX/2005 7/XX/2008 IL Refinance - Rate/Term Primary No B B B B
(Circuit 2, 3, 5, 7, 8, 9, 10 or DC) Model Form for a refinancing by the same creditor. The H-8 form was used, the courts, the continuing risk that the borrower may have an extended right to
H-9 form should have been used. rescind (3 additional years) if a creditor uses the incorrect Model Form
remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625489084 XXX XXX XXX 35076519 credit 3 Missing Document: Missing Final 1003 8/XX/2007 MO Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489084 XXX XXX XXX 35076521 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 8/XX/2007 MO Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 7/XX/2007 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625489084 XXX XXX XXX 35076522 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2007 MO Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489033 XXX XXX XXX 35076598 credit 3 Missing Document: Missing Final 1003 6/XX/2005 CA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489033 XXX XXX XXX 35076599 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 6/XX/2005 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 5/XX/2005 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625489033 XXX XXX XXX 35076600 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2005 6/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
borrower within three (3) days of application.
625489033 XXX XXX XXX 35076601 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2005 6/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489433 XXX XXX XXX 35076655 credit 3 Missing Document: Missing Final 1003 7/XX/2006 WV Purchase Primary No C C C C
625489433 XXX XXX XXX 35076656 compliance 2 (Doc Error) Initial GFE not provided 7/XX/2006 WV Purchase Primary No B B B B
625489433 XXX XXX XXX 35076657 compliance 2 Initial TIL not provided 7/XX/2006 7/XX/2007 WV Purchase Primary No B B B B
625489433 XXX XXX XXX 35076658 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 7/XX/2006 WV Purchase Primary No B B B B
an application date of 6/XX/2006 which is 1 month(s) prior to consummation. A 2
month lookback was used to determine this application date.
625489284 XXX XXX XXX 35076661 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2010 NC Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489284 XXX XXX XXX 35076662 credit 2 Note is not on a FNMA/FHLMC form and may not contain standard legal language. 3/XX/2010 NC Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488441 XXX XXX XXX 35076690 credit 3 Missing Document: Missing Final 1003 2/XX/2009 SC Refinance - Rate/Term Primary No C C C C
625488441 XXX XXX XXX 35076691 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 2/XX/2009 SC Refinance - Rate/Term Primary No B B B B
an application date of 1/XX/2009 which is 1 month(s) prior to consummation. A 3
month lookback was used to determine this application date.
625488441 XXX XXX XXX 35076692 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2009 SC Refinance - Rate/Term Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488441 XXX XXX XXX 35076693 compliance 2 South Carolina Home Loan (Complaint Agency Disclosure Not Provided) South Carolina Home Loan: Borrower not provided with a document specifying the Exceptions occurring more than 6 years ago may be outside the states statute of 2/XX/2009 2/XX/2015 SC Refinance - Rate/Term Primary No B B B B
agency designated to receive complaints or inquiries about the origination and limitations. Due to the potential remedies available to a court, this exception
making of the loan. carries elevated risk to an assignee during the initial 6 years after occurrence
of the violation. After the expiration of this 6 year period, the exception
retains risk for claims raised as a defense to foreclosure, but not at the same
level as during the initial 6 years for affirmative claims.
625488441 XXX XXX XXX 35076694 compliance 2 (Doc Error) Initial GFE not provided 2/XX/2009 SC Refinance - Rate/Term Primary No B B B B
625489382 XXX XXX XXX 35076796 compliance 2 Initial TIL not provided 10/XX/2007 10/XX/2008 FL Purchase Primary No B B B B
625489382 XXX XXX XXX 35076797 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2007 FL Purchase Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488595 XXX XXX XXX 35076798 credit 3 Missing Document: Missing Final 1003 4/XX/2007 MD Refinance - Rate/Term Primary No C C C C
625488595 XXX XXX XXX 35076799 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 4/XX/2007 MD Refinance - Rate/Term Primary No B B B B
an application date of 3/XX/2007 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625489409 XXX XXX XXX 35076849 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from The itemization of amount financed did not break out origination fee; unable to $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 10/XX/2006 10/XX/2009 FL Refinance - Rate/Term Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. determine under-disclosure of $XXX. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489511 XXX XXX XXX 35076963 credit 3 Missing Document: Missing Final 1003 10/XX/2007 AR Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489511 XXX XXX XXX 35076964 credit 2 Note is not on a FNMA/FHLMC form and may not contain standard legal language. 10/XX/2007 AR Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489511 XXX XXX XXX 35076965 compliance 2 (Doc Error) Initial GFE not provided 10/XX/2007 AR Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489511 XXX XXX XXX 35076966 credit 2 Final Title Policy is missing. No evidence of title was found in file. 10/XX/2007 AR Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489511 XXX XXX XXX 35076967 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2007 10/XX/2008 AR Refinance - Cash-out - Debt Consolidation Primary No B B B B
borrower.
625489511 XXX XXX XXX 35076968 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2007 10/XX/2008 AR Refinance - Cash-out - Debt Consolidation Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489511 XXX XXX XXX 35076969 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 10/XX/2007 10/XX/2010 AR Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489511 XXX XXX XXX 35076970 compliance 1 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2007 10/XX/2010 AR Refinance - Cash-out - Debt Consolidation Primary No A A A A 11/XX/2016 Yes 2016/XX/07: Cleared with TIL provided
defense to foreclosure. Assignee liability.
625489511 XXX XXX XXX 35076971 compliance 1 Missing Final HUD-1 Missing Final HUD-1. No document containing fees provided. Any applicable A violation of RESPA does not impair the validity of a loan or expose a true 10/XX/2007 AR Refinance - Cash-out - Debt Consolidation Primary No A A A A 11/XX/2016 Yes 2016/XX/07: Cleared with HUD provided
Federal, State or Local compliance testing is unreliable. secondary market purchaser of a loan to assignee liability or rescission of the
loan. While there are no express private rights of action under either Section 4
or 5 of RESPA, originators who violate these provisions are subject to
enforcement action by a host of federal and state governmental authorities, and
face the possible imposition of civil money penalties. Further, originators who
violate Sections 4 and 5 of RESPA could be subject to claims arising under state
law, such as state deceptive acts and practices statutes.
625489511 XXX XXX XXX 35076972 compliance 2 Missing Document: Missing Lender's Initial 1003 10/XX/2007 AR Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489511 XXX XXX XXX 35076973 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 10/XX/2007 AR Refinance - Cash-out - Debt Consolidation Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489511 XXX XXX XXX 35076974 credit 3 Missing Document: Appraisal not provided 10/XX/2007 AR Refinance - Cash-out - Debt Consolidation Primary No D D D D
625489511 XXX XXX XXX 35076975 compliance 1 (Missing Data) Missing Information to Determine Origination Channel Unable to determine the origination channel based on the loan documents provided 10/XX/2007 AR Refinance - Cash-out - Debt Consolidation Primary No A A A A 11/XX/2016 Yes 2016/XX/07: Cleared with HUD provided
for review. The compliance review was performed with using the equivalent
evaluation that would be considered for an Origination Channel of Retail.
625489580 XXX XXX XXX 35077006 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2007 PA Purchase Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489580 XXX XXX XXX 35077007 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 6/XX/2007 6/XX/2008 PA Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489580 XXX XXX XXX 35077008 compliance 2 Initial TIL not provided 6/XX/2007 6/XX/2008 PA Purchase Primary No B B B B
625489036 XXX XXX XXX 35077021 credit 3 Missing Document: Service Provider Disclosure not provided 12/XX/2003 VA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489036 XXX XXX XXX 35077022 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 12/XX/2003 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 12/XX/2003 which is the consummation date. A 1 month
lookback was used to determine this application date.
625489036 XXX XXX XXX 35077023 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2003 12/XX/2004 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489220 XXX XXX XXX 35077024 credit 3 Missing Document: Missing Final 1003 7/XX/2007 MD Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489220 XXX XXX XXX 35077025 credit 3 Missing Document: Appraisal not provided 7/XX/2007 MD Refinance - Cash-out - Debt Consolidation Primary No D D D D
625489220 XXX XXX XXX 35077026 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 7/XX/2007 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489220 XXX XXX XXX 35077027 compliance 2 (Doc Error) Initial GFE not provided 7/XX/2007 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489220 XXX XXX XXX 35077028 compliance 1 Missing Final HUD-1 7/XX/2007 MD Refinance - Cash-out - Debt Consolidation Primary No A A A A 11/XX/2016 Yes 2016/XX/09: 2016/XX/07 11:20:57 by TM
Comment: Cleared with HUD provided.
625489220 XXX XXX XXX 35077029 compliance 2 TILA - Final TIL Missing TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2007 7/XX/2010 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625489220 XXX XXX XXX 35077030 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 7/XX/2007 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 6/XX/2007 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625489220 XXX XXX XXX 35077031 compliance 1 Missing Final HUD-1 Missing Final HUD-1. No document containing fees provided. Any applicable A violation of RESPA does not impair the validity of a loan or expose a true 7/XX/2007 MD Refinance - Cash-out - Debt Consolidation Primary No A A A A 11/XX/2016 Yes 2016/XX/07: Cleared with HUD provided.
Federal, State or Local compliance testing is unreliable. secondary market purchaser of a loan to assignee liability or rescission of the
loan. While there are no express private rights of action under either Section 4
or 5 of RESPA, originators who violate these provisions are subject to
enforcement action by a host of federal and state governmental authorities, and
face the possible imposition of civil money penalties. Further, originators who
violate Sections 4 and 5 of RESPA could be subject to claims arising under state
law, such as state deceptive acts and practices statutes.
625489220 XXX XXX XXX 35077032 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. Missing documentation to determine the occupancy and purpose therefore TILA ROR - 3yrs for rescindable transactions. 7/XX/2007 7/XX/2010 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
compliance review defaulted to owner occupied/cash out refinance.
625489220 XXX XXX XXX 35077033 compliance 1 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2007 7/XX/2010 MD Refinance - Cash-out - Debt Consolidation Primary No A A A A 11/XX/2016 Yes 2016/XX/07: Cleared with TIL provided
defense to foreclosure. Assignee liability.
625488372 XXX XXX XXX 35077034 compliance 3 (Doc Error) HUD Error: Disbursement date is earlier than notary/security HUD reflects a disbursement date of 12/XX/2007 however the notary date is Tested 12/XX/2007 AZ Refinance - Cash-out - Other Primary No C C C C
instrument date. 12/XX/2007.
625488372 XXX XXX XXX 35077035 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA Tested 12/XX/2007 12/XX/2008 AZ Refinance - Cash-out - Other Primary No B B B B
borrower.
625488372 XXX XXX XXX 35077036 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA Tested 12/XX/2007 12/XX/2008 AZ Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488372 XXX XXX XXX 35077037 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 12/XX/2007, prior to TILA ROR - 3yrs for rescindable transactions. Tested 12/XX/2007 12/XX/2010 AZ Refinance - Cash-out - Other Primary No B B B B
Date three (3) business days from transaction date of 12/XX/2007.
625488372 XXX XXX XXX 35077038 credit 2 Note is not on a FNMA/FHLMC form and may not contain standard legal language. Tested 12/XX/2007 AZ Refinance - Cash-out - Other Primary No B B B B
625488372 XXX XXX XXX 35077039 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using Tested 12/XX/2007 AZ Refinance - Cash-out - Other Primary No B B B B
an application date of 11/XX/2007 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625488372 XXX XXX XXX 35077040 compliance 3 (Doc Error) HUD Error: Disbursement date is earlier than final TIL signature Tested 12/XX/2007 AZ Refinance - Cash-out - Other Primary No C C C C
date.
625488041 XXX XXX XXX 35077041 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 FL Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488041 XXX XXX XXX 35077042 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2007 3/XX/2010 FL Refinance - Cash-out - Other Primary No B B B B
defense to foreclosure. Assignee liability.
625488041 XXX XXX XXX 35077043 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 FL Refinance - Cash-out - Other Primary No B B B B
borrower within three (3) days of application.
625489574 XXX XXX XXX 35077066 compliance 2 (Doc Error) Initial GFE not provided 1/XX/2008 MD Refinance - Rate/Term Primary No B B B B
625488264 XXX XXX XXX 35077088 credit 3 Missing Document: Missing Final 1003 8/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488264 XXX XXX XXX 35077089 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 8/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 7/XX/2007 which is 1 month(s) prior to consummation. A 3
month lookback was used to determine this application date.
625488264 XXX XXX XXX 35077090 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 8/XX/2007, prior to TILA ROR - 3yrs for rescindable transactions. 8/XX/2007 8/XX/2010 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 8/XX/2007.
625488264 XXX XXX XXX 35077091 compliance 2 (Doc Error) Initial GFE not provided 8/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488264 XXX XXX XXX 35077092 compliance 2 Initial TIL not provided 8/XX/2007 8/XX/2008 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488512 XXX XXX XXX 35077139 credit 2 Note is not on a FNMA/FHLMC form and may not contain standard legal language. 9/XX/2010 WA Refinance - Streamlined Primary No B B B B
625488512 XXX XXX XXX 35077140 compliance 2 RESPA (2010) - GFE Settlement charges Good Thru Date Less than 10 Days RESPA (2010): GFE does not provide minimum ten (10) business day availability RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2010 WA Refinance - Streamlined Primary No B B B B
for estimate of charges and terms for all other settlement charges. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488512 XXX XXX XXX 35077141 compliance 2 Washington Residential Mortgage Loan (Disclosure of Material Terms Not Provided) Washington HB 2770: Mortgage loan file does not contain a disclosure summary of The Act does not appear to provide for assignee liability. 9/XX/2010 WA Refinance - Streamlined Primary No B B B B
all material terms provided to borrower.
625488512 XXX XXX XXX 35077142 compliance 2 RESPA Servicing Disclosure: Servicing Disclosure Statement Not Provided Within 3 RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2010 WA Refinance - Streamlined Primary No B B B B
Business Days of Application Statement to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488972 XXX XXX XXX 35077165 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 7/XX/2007 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 6/XX/2007 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625488972 XXX XXX XXX 35077166 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2007 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488972 XXX XXX XXX 35077167 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2007 7/XX/2008 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489252 XXX XXX XXX 35077185 credit 2 Note is not on a FNMA/FHLMC form and may not contain standard legal language. 1/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489252 XXX XXX XXX 35077186 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 1/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488646 XXX XXX XXX 35077187 compliance 2 Initial TIL not provided 5/XX/2006 5/XX/2007 IL Purchase Primary No B B B B
625488646 XXX XXX XXX 35077188 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 5/XX/2006 IL Purchase Primary No B B B B
within a reasonably practicable time after using credit score.
625488646 XXX XXX XXX 35077189 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 5/XX/2006 IL Purchase Primary No B B B B
an application date of 4/XX/2006 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625488646 XXX XXX XXX 35077190 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 5/XX/2006 IL Purchase Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488646 XXX XXX XXX 35077191 credit 3 Missing Document: Appraisal not provided 5/XX/2006 IL Purchase Primary No D D D D
625488646 XXX XXX XXX 35077192 compliance 2 (Doc Error) Initial GFE not provided 5/XX/2006 IL Purchase Primary No B B B B
625489387 XXX XXX XXX 35077221 compliance 2 South Carolina Home Loan (Complaint Agency Disclosure Not Provided) South Carolina Home Loan: Borrower not provided with a document specifying the Exceptions occurring more than 6 years ago may be outside the states statute of 3/XX/2007 3/XX/2013 SC Purchase Primary No B B B B
agency designated to receive complaints or inquiries about the origination and limitations. Due to the potential remedies available to a court, this exception
making of the loan. carries elevated risk to an assignee during the initial 6 years after occurrence
of the violation. After the expiration of this 6 year period, the exception
retains risk for claims raised as a defense to foreclosure, but not at the same
level as during the initial 6 years for affirmative claims.
625489387 XXX XXX XXX 35077222 compliance 2 Initial TIL not provided 3/XX/2007 3/XX/2008 SC Purchase Primary No B B B B
625488076 XXX XXX XXX 35077259 credit 3 Missing Document: Missing Final 1003 6/XX/2007 FL Purchase Primary No C C C C
625488076 XXX XXX XXX 35077260 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 6/XX/2007 FL Purchase Primary No B B B B
625488076 XXX XXX XXX 35077261 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2007 FL Purchase Primary No B B B B
an application date of 5/XX/2007 which is 1 months prior to consummation. A 7
month lookback was used to determine this application date. The final date used
for testing was 12/XX/2006.
625488076 XXX XXX XXX 35077262 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 FL Purchase Primary No B B B B
Loan Application Date.
625488076 XXX XXX XXX 35077263 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 FL Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488076 XXX XXX XXX 35077264 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2007 FL Purchase Primary No B B B B
Disclosure to borrower. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489239 XXX XXX XXX 35077282 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 10/XX/2007 GA Purchase Primary No B B B B
625489239 XXX XXX XXX 35077283 credit 3 Missing Document: Missing Final 1003 10/XX/2007 GA Purchase Primary No C C C C
625489239 XXX XXX XXX 35077284 compliance 2 (Doc Error) Initial GFE not provided 10/XX/2007 GA Purchase Primary No B B B B
625489239 XXX XXX XXX 35077285 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2007 GA Purchase Primary No B B B B
an application date of 9/XX/2007 which is 1 months prior to consummation. A 7
month lookback was used to determine this application date. The final date used
for testing was 4/XX/2007.
625489239 XXX XXX XXX 35077286 compliance 2 Initial TIL not provided 10/XX/2007 10/XX/2008 GA Purchase Primary No B B B B
625489273 XXX XXX XXX 35077287 credit 3 Missing Document: Missing Final 1003 8/XX/2004 CO Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489273 XXX XXX XXX 35077288 compliance 1 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable 8/XX/2004 CO Refinance - Cash-out - Debt Consolidation Primary No A A A A 2/XX/2017 Yes 2017/XX/20: Received Final HUD-1, exception cleared.
Federal, State or Local compliance testing is unreliable.
625489273 XXX XXX XXX 35077289 compliance 1 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using 8/XX/2004 CO Refinance - Cash-out - Debt Consolidation Primary No A A A A 2/XX/2017 Yes 2017/XX/20: Received Final HUD-1, exception cleared.
an application date of 7/XX/2004 which is 1 months prior to consummation. A 7
month lookback was used to determine this application date. The final date used
for testing was 2/XX/2004. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625489273 XXX XXX XXX 35077290 compliance 1 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 8/XX/2004 8/XX/2007 CO Refinance - Cash-out - Debt Consolidation Primary No A A A A 2/XX/2017 Yes 2017/XX/20: Received ROR, exception cleared.
625489273 XXX XXX XXX 35077291 compliance 2 Initial TIL not provided 8/XX/2004 8/XX/2005 CO Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489273 XXX XXX XXX 35077292 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 8/XX/2004 CO Refinance - Cash-out - Debt Consolidation Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489273 XXX XXX XXX 35077293 credit 3 Missing Valuation: Missing appraisal. 8/XX/2004 CO Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489273 XXX XXX XXX 35077294 compliance 2 (Doc Error) Initial GFE not provided 8/XX/2004 CO Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489273 XXX XXX XXX 35077295 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2004 CO Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 7/XX/2004 which is 1 months prior to consummation. A 7
month lookback was used to determine this application date. The final date used
for testing was 2/XX/2004.
625487940 XXX XXX XXX 35077297 credit 3 Missing Document: Missing Final 1003 3/XX/1997 NC Refinance - Cash-out - Debt Consolidation Primary No C C C C
625487940 XXX XXX XXX 35077298 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/1997 NC Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 3/XX/1997 which is 0 months prior to consummation. A 2
month lookback was used to determine this application date. The final date used
for testing was 3/XX/1997.
625487940 XXX XXX XXX 35077299 compliance 2 (Doc Error) Initial GFE not provided 3/XX/1997 NC Refinance - Cash-out - Debt Consolidation Primary No B B B B
625487940 XXX XXX XXX 35077300 compliance 2 Initial TIL not provided 3/XX/1997 3/XX/1998 NC Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488205 XXX XXX XXX 35077341 credit 3 Missing Document: Missing Final 1003 7/XX/2004 RI Refinance - Cash-out - Other Primary No C C C C
625488205 XXX XXX XXX 35077342 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2004 RI Refinance - Cash-out - Other Primary No B B B B
an application date of 6/XX/2004 which is 1 months prior to consummation. A 2
month lookback was used to determine this application date. The final date used
for testing was 6/XX/2004.
625488459 XXX XXX XXX 35077444 credit 3 Missing Document: Missing Final 1003 4/XX/2007 PA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488459 XXX XXX XXX 35077445 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 4/XX/2007 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488459 XXX XXX XXX 35077446 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2007 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 3/XX/2007 which is 1 months prior to consummation. A 2
month lookback was used to determine this application date. The final date used
for testing was 3/XX/2007.
625488459 XXX XXX XXX 35077447 compliance 2 (Doc Error) Initial GFE not provided 4/XX/2007 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488459 XXX XXX XXX 35077448 compliance 2 Initial TIL not provided 4/XX/2007 4/XX/2008 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489550 XXX XXX XXX 35077488 credit 3 Missing Document: Missing Final 1003 9/XX/2004 NJ Refinance - Rate/Term Primary Yes C C C C
625489550 XXX XXX XXX 35077489 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 9/XX/2004 NJ Refinance - Rate/Term Primary Yes B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489550 XXX XXX XXX 35077490 compliance 2 (Doc Error) Initial GFE not provided 9/XX/2004 NJ Refinance - Rate/Term Primary Yes B B B B
625489550 XXX XXX XXX 35077491 compliance 1 Missing Final HUD-1 9/XX/2004 NJ Refinance - Rate/Term Primary Yes A A A A 2/XX/2017 Yes 2017/XX/20: Received Final HUD-1, exception cleared.
625489550 XXX XXX XXX 35077492 compliance 1 TILA - Final TIL Missing TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2004 9/XX/2007 NJ Refinance - Rate/Term Primary Yes A A A A 2/XX/2017 Yes 2017/XX/20: Received TIL, exception cleared.
defense to foreclosure. Assignee liability.
625489550 XXX XXX XXX 35077494 compliance 1 Missing Document: Missing Lender's Initial 1003 9/XX/2004 NJ Refinance - Rate/Term Primary Yes A A A A 2/XX/2017 Yes 2017/XX/20: Duplicate
625489550 XXX XXX XXX 35077495 credit 3 Missing Valuation: Missing appraisal from loan file. 9/XX/2004 NJ Refinance - Rate/Term Primary Yes C C C C
625489550 XXX XXX XXX 35077496 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2004 NJ Refinance - Rate/Term Primary Yes B B B B
an application date of 8/XX/2004 which is 1 months prior to consummation. A 7
month lookback was used to determine this application date. The final date used
for testing was 3/XX/2004.
625489550 XXX XXX XXX 35077497 compliance 3 New Jersey Home Loan (Late Charge) New Jersey Home Loan: Mortgage loan contains an impermissible late charge of Assignee Liability: Assignees and purchasers of New Jersey high cost home loans 9/XX/2004 NJ Refinance - Rate/Term Primary Yes C C C C
greater than 5.0% or a grace period less than 15 days. are subject to all affirmative claims and any defenses with respect to the loan
that the borrower could assert against the original creditor of the loan.
Section 6(c) of the Act also provides that a borrower acting only in an
individual capacity may assert against the creditor or any subsequent holder or
assignee: (1) Within six years of the closing of covered home loan, a violation
of the Act as an original action or as a defense, claim, or counterclaim; and
(2) At any time during the term of a high cost home loan a defense, claim or
counterclaim. The aforementioned may both be brought after an action to collect
on the home loan or foreclose on the collateral securing the home loan has been
initiated, the debt arising from the home loan has been accelerated, or the home
loan has become 60 days in default. Further, the Act contains a choice of law
provision permitting actions under either the New Jersey Consumer Fraud Act
("NJCFA"), which possibly allow for class actions, or the Act. The July 6, 2004
amendments clarify that a defense, claim, or counterclaim may only be brought in
an individual capacity and may not be asserted in a class action. Additionally,
the statute provides for punitive damages.
625489550 XXX XXX XXX 35077498 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 9/XX/2004 9/XX/2007 NJ Refinance - Rate/Term Primary Yes B B B B
625489550 XXX XXX XXX 35077499 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2004 9/XX/2007 NJ Refinance - Rate/Term Primary Yes B B B B
defense to foreclosure. Assignee liability.
625489550 XXX XXX XXX 35077500 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2004 9/XX/2007 NJ Refinance - Rate/Term Primary Yes B B B B
defense to foreclosure. Assignee liability.
625489617 XXX XXX XXX 35077511 credit 3 Missing Document: Missing Final 1003 5/XX/2002 AZ Purchase Primary No C C C C
625489617 XXX XXX XXX 35077512 compliance 2 (Doc Error) Initial GFE not provided 5/XX/2002 AZ Purchase Primary No B B B B
625489617 XXX XXX XXX 35077513 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2002 AZ Purchase Primary No B B B B
an application date of 4/XX/2002 which is 1 months prior to consummation. A 3
month lookback was used to determine this application date. The final date used
for testing was 4/XX/2002.
625489602 XXX XXX XXX 35077518 credit 3 Missing Document: Missing Final 1003 2/XX/2007 CT Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489602 XXX XXX XXX 35077519 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 2/XX/2007 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489602 XXX XXX XXX 35077520 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2007 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 1/XX/2007 which is 1 months prior to consummation. A 7
month lookback was used to determine this application date. The final date used
for testing was 8/XX/2006.
625489602 XXX XXX XXX 35077521 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2007 2/XX/2008 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489602 XXX XXX XXX 35077522 compliance 2 (Doc Error) Initial GFE not provided 2/XX/2007 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488730 XXX XXX XXX 35077548 credit 3 Missing Document: Missing Final 1003 3/XX/2007 NC Purchase Primary No C C C C
625488730 XXX XXX XXX 35077549 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2007 NC Purchase Primary No B B B B
an application date of 2/XX/2007 which is 1 months prior to consummation. A 7
month lookback was used to determine this application date. The final date used
for testing was 9/XX/2006.
625488730 XXX XXX XXX 35077550 compliance 2 Initial TIL not provided 3/XX/2007 3/XX/2008 NC Purchase Primary No B B B B
625488730 XXX XXX XXX 35077551 compliance 2 (Doc Error) Initial GFE not provided 3/XX/2007 NC Purchase Primary No B B B B
625488730 XXX XXX XXX 35077552 compliance 2 (Doc Error) Initial GFE not provided 3/XX/2007 NC Purchase Primary No B B B B
625488603 XXX XXX XXX 35077638 credit 3 Missing Document: Missing Final 1003 7/XX/2007 GA Purchase Primary No C C C C
625488603 XXX XXX XXX 35077639 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2007 GA Purchase Primary No B B B B
an application date of 7/XX/2007 which is 0 months prior to consummation. A 2
month lookback was used to determine this application date. The final date used
for testing was 7/XX/2007.
625488603 XXX XXX XXX 35077640 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2007 7/XX/2008 GA Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488603 XXX XXX XXX 35077641 compliance 2 (Doc Error) Initial GFE not provided 7/XX/2007 GA Purchase Primary No B B B B
625488017 XXX XXX XXX 35077647 credit 3 Missing Document: Missing Final 1003 12/XX/2005 GA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488017 XXX XXX XXX 35077648 compliance 2 (Doc Error) Initial GFE not provided 12/XX/2005 GA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488017 XXX XXX XXX 35077650 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 12/XX/2005 GA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488017 XXX XXX XXX 35077651 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 12/XX/2005 GA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 11/XX/2005 which is 1 months prior to consummation. A 7
month lookback was used to determine this application date. The final date used
for testing was 6/XX/2005.
625488361 XXX XXX XXX 35077716 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2007 2/XX/2008 WI Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488361 XXX XXX XXX 35077717 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Finance charges under disclosed by $XXX which exceeds the $XXX tolerance for $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 2/XX/2007 2/XX/2008 WI Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. purchase transactions. Unable to determine under disclosure due to missing for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
itemization of amount financed. liability.
625489268 XXX XXX XXX 35077738 credit 3 Missing Document: Missing Final 1003 5/XX/2007 OR Refinance - Cash-out - Other Primary No C C C C
625489268 XXX XXX XXX 35077739 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2007 OR Refinance - Cash-out - Other Primary No B B B B
an application date of 4/XX/2007 which is 1 months prior to consummation. A 7
month lookback was used to determine this application date. The final date used
for testing was 11/XX/2006.
625489268 XXX XXX XXX 35077740 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2007 5/XX/2008 OR Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489268 XXX XXX XXX 35077741 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 5/XX/2007 OR Refinance - Cash-out - Other Primary No B B B B
625489268 XXX XXX XXX 35077742 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 5/XX/2007 OR Refinance - Cash-out - Other Primary No B B B B
following clauses:
625488318 XXX XXX XXX 35077773 credit 3 Missing Document: Missing Final 1003 1/XX/2008 VA Refinance - Rate/Term Primary No C C C C
625488318 XXX XXX XXX 35077774 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 1/XX/2008 VA Refinance - Rate/Term Primary No B B B B
625488318 XXX XXX XXX 35077775 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 1/XX/2008 VA Refinance - Rate/Term Primary No B B B B
an application date of 12/XX/2007 which is 1 months prior to consummation. A 7
month lookback was used to determine this application date. The final date used
for testing was 7/XX/2007.
625488318 XXX XXX XXX 35077776 compliance 2 Virginia Mortgage Lender and Broker Act (Additional Compensation Not on Written Virginia Mortgage Lender and Broker Act: Mortgage broker has received The secondary market purchase of a loan does not trigger coverage of the 1/XX/2008 VA Refinance - Rate/Term Primary No B B B B
Agreement) compensation from the borrower other than that specified in the written statute.
agreement signed by the borrower.
625488682 XXX XXX XXX 35077805 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 5/XX/2007 GA Refinance - Rate/Term Primary No B B B B
625488682 XXX XXX XXX 35077806 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2007 GA Refinance - Rate/Term Primary No B B B B
an application date of 4/XX/2007 which is 1 months prior to consummation. A 7
month lookback was used to determine this application date. The final date used
for testing was 11/XX/2006.
625488682 XXX XXX XXX 35077807 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2007 5/XX/2008 GA Refinance - Rate/Term Primary No B B B B
Loan Application Date.
625488682 XXX XXX XXX 35077808 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2007 5/XX/2008 GA Refinance - Rate/Term Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488682 XXX XXX XXX 35077809 credit 3 Missing Document: Missing Final 1003 5/XX/2007 GA Refinance - Rate/Term Primary No C C C C
625488682 XXX XXX XXX 35077810 compliance 2 (Doc Error) Initial GFE not provided 5/XX/2007 GA Refinance - Rate/Term Primary No B B B B
625488682 XXX XXX XXX 35077811 compliance 2 Initial TIL not provided 5/XX/2007 5/XX/2008 GA Refinance - Rate/Term Primary No B B B B
625489041 XXX XXX XXX 35077812 compliance 2 Initial TIL not provided 10/XX/2005 10/XX/2006 RI Purchase Primary No B B B B
625489041 XXX XXX XXX 35077813 credit 3 Missing Document: Purchase Agreement / Sales Contract not provided 10/XX/2005 RI Purchase Primary No D D D D
625489041 XXX XXX XXX 35077814 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2005 10/XX/2006 RI Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625489041 XXX XXX XXX 35077815 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 10/XX/2005 RI Purchase Primary No B B B B
625489041 XXX XXX XXX 35077816 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2005 RI Purchase Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488221 XXX XXX XXX 35077903 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2003 AL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 10/XX/2003 which is 1 months prior to consummation. A 7
month lookback was used to determine this application date. The final date used
for testing was 5/XX/2003.
625488221 XXX XXX XXX 35077904 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 11/XX/2003 AL Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488690 XXX XXX XXX 35078078 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 1/XX/2008 MO Refinance - Rate/Term Primary No B B B B
625488690 XXX XXX XXX 35078079 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 1/XX/2008 MO Refinance - Rate/Term Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488690 XXX XXX XXX 35078080 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 1/XX/2008 1/XX/2011 MO Refinance - Rate/Term Primary No B B B B
defense to foreclosure. Assignee liability.
625488690 XXX XXX XXX 35078081 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 1/XX/2008 1/XX/2011 MO Refinance - Rate/Term Primary No B B B B
defense to foreclosure. Assignee liability.
625488857 XXX XXX XXX 35078096 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2006 FL Purchase Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488857 XXX XXX XXX 35078097 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 8/XX/2006 FL Purchase Primary No C C C C
625488383 XXX XXX XXX 35078099 credit 3 Missing Document: Missing Final 1003 11/XX/2008 GA Purchase Primary No C C C C
625488383 XXX XXX XXX 35078100 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2008 GA Purchase Primary No B B B B
an application date of 10/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 09/XX/2008.
625488540 XXX XXX XXX 35078102 credit 3 Missing Document: Missing Final 1003 5/XX/2008 IL Refinance - Rate/Term Primary No C C C C
625488540 XXX XXX XXX 35078103 credit 3 Missing Document: FHA Mortgage Insurance Certificate not provided 5/XX/2008 IL Refinance - Rate/Term Primary No C C C C
625488540 XXX XXX XXX 35078104 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2008 IL Refinance - Rate/Term Primary No B B B B
an application date of 04/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2008.
625489109 XXX XXX XXX 35078106 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2006 NJ Purchase Primary Yes B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489109 XXX XXX XXX 35078107 credit 3 Missing Document: FHA Mortgage Insurance Certificate not provided 2/XX/2006 NJ Purchase Primary Yes C C C C
625488180 XXX XXX XXX 35078137 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2009 VA Purchase Primary No B B B B
an application date of 06/XX/2009 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2009.
625488180 XXX XXX XXX 35078138 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2009 VA Purchase Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488180 XXX XXX XXX 35078139 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2009 VA Purchase Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488000 XXX XXX XXX 35078193 credit 3 Missing Document: Missing Final 1003 3/XX/2004 CT Refinance - Rate/Term Primary No C C C C
625488000 XXX XXX XXX 35078194 credit 3 Title: Evidence of title is missing 3/XX/2004 CT Refinance - Rate/Term Primary No C C C C
625488000 XXX XXX XXX 35078195 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 3/XX/2004 CT Refinance - Rate/Term Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488000 XXX XXX XXX 35078196 compliance 2 (Doc Error) Initial GFE not provided 3/XX/2004 CT Refinance - Rate/Term Primary No B B B B
625488000 XXX XXX XXX 35078197 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2004 CT Refinance - Rate/Term Primary No B B B B
an application date of 02/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 09/XX/2003.
625489049 XXX XXX XXX 35078198 credit 3 Missing Document: Missing Final 1003 7/XX/2008 CA Purchase Primary No C C C C
625489049 XXX XXX XXX 35078199 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2008 CA Purchase Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489049 XXX XXX XXX 35078200 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 7/XX/2008 CA Purchase Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489577 XXX XXX XXX 35078255 credit 3 Missing Document: Missing Final 1003 9/XX/2005 NY Purchase Primary No C C C C
625489577 XXX XXX XXX 35078256 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2005 NY Purchase Primary No B B B B
an application date of 08/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/2005.
625489577 XXX XXX XXX 35078257 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2005 9/XX/2006 NY Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625489577 XXX XXX XXX 35078258 compliance 2 (Doc Error) Initial GFE not provided 9/XX/2005 NY Purchase Primary No B B B B
625489577 XXX XXX XXX 35078259 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2005 9/XX/2006 NY Purchase Primary No B B B B
borrower.
625489577 XXX XXX XXX 35078260 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2005 9/XX/2006 NY Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489577 XXX XXX XXX 35078261 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2005 NY Purchase Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488624 XXX XXX XXX 35078262 credit 3 Missing Document: Missing Final 1003 5/XX/2005 NM Refinance - Cash-out - Debt Consolidation Primary Yes C C C C
625488624 XXX XXX XXX 35078263 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 5/XX/2005 NM Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
625488624 XXX XXX XXX 35078264 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2005 5/XX/2008 NM Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
defense to foreclosure. Assignee liability.
625488624 XXX XXX XXX 35078265 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2005 5/XX/2008 NM Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
defense to foreclosure. Assignee liability.
625488624 XXX XXX XXX 35078266 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2005 NM Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
an application date of 04/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2004.
625488624 XXX XXX XXX 35078267 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 05/XX/2005, prior to TILA ROR - 3yrs for rescindable transactions. 5/XX/2005 5/XX/2008 NM Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
Date three (3) business days from transaction date of 05/XX/2005.
625488391 XXX XXX XXX 35078279 credit 3 Missing Document: Missing Final 1003 10/XX/2004 MO Refinance - Rate/Term Primary No C C C C
625488391 XXX XXX XXX 35078281 compliance 1 Missing Document: Note - Subject Lien not provided 10/XX/2004 MO Refinance - Rate/Term Primary No A A A A 9/XX/2017 Yes 2017/XX/14: Cleared- Note received
625488391 XXX XXX XXX 35078282 credit 1 Missing Document: Security Instrument - Subject Lien not provided 10/XX/2004 MO Refinance - Rate/Term Primary No A A A A 9/XX/2017 Yes 2017/XX/14: Cleared- mortgage received
625488391 XXX XXX XXX 35078283 compliance 1 Missing Final HUD-1 10/XX/2004 MO Refinance - Rate/Term Primary No A A A A 9/XX/2017 Yes 2017/XX/13: HUD provided to AMC 9/12 2017/XX/13: Unable to locate HUD on MoveIT site
2017/XX/14: HUD received- Unable to run compliance testing due to missing note
625488391 XXX XXX XXX 35078284 compliance 2 (Doc Error) Initial GFE not provided 10/XX/2004 MO Refinance - Rate/Term Primary No B B B B
625488391 XXX XXX XXX 35078285 compliance 1 (Missing Doc) Incomplete loan images/file File only contains 31 pages of post closing documentation. 10/XX/2004 MO Refinance - Rate/Term Primary No A A A A 9/XX/2017 Yes 2017/XX/14: Cleared- documentation received to complete testing
625488391 XXX XXX XXX 35078286 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 10/XX/2004 MO Refinance - Rate/Term Primary No B B B B
Security Instrument Notary Date of 10/XX/2004 used as disbursement date for
compliance testing.
625488391 XXX XXX XXX 35078287 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2004 MO Refinance - Rate/Term Primary No B B B B
an application date of 09/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2004.
625488391 XXX XXX XXX 35078288 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 10/XX/2004 10/XX/2007 MO Refinance - Rate/Term Primary No B B B B
625488391 XXX XXX XXX 35078289 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2004 10/XX/2007 MO Refinance - Rate/Term Primary No B B B B
defense to foreclosure. Assignee liability.
625488391 XXX XXX XXX 35078290 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 10/XX/2004 MO Refinance - Rate/Term Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488391 XXX XXX XXX 35078291 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 10/XX/2004 MO Refinance - Rate/Term Primary No B B B B
following clauses:
625488223 XXX XXX XXX 35078296 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 4/XX/2004 4/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
defense to foreclosure. Assignee liability.
625488223 XXX XXX XXX 35078297 credit 3 Missing Document: Missing Final 1003 4/XX/2004 CA Refinance - Cash-out - Other Primary No C C C C
625488223 XXX XXX XXX 35078298 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 4/XX/2004 4/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
defense to foreclosure. Assignee liability.
625488357 XXX XXX XXX 35078313 compliance 2 Note Error: Note grace period days less than minimum per state Minimum grace period in MD is 15 days, note states 10 days. 1/XX/2007 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488357 XXX XXX XXX 35078314 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 1/XX/2007 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 12/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 07/XX/2006.
625488357 XXX XXX XXX 35078315 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 01/XX/2007, prior to TILA ROR - 3yrs for rescindable transactions. 1/XX/2007 1/XX/2010 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 01/XX/2007.
625488357 XXX XXX XXX 35078316 compliance 2 Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit 1/XX/2007 1/XX/2010 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
Model Form for a refinance by a creditor that is not considered the original courts, the continuing risk that the borrower may have an extended right to
creditor. The H-9 form was used, the H-8 form should have been used. rescind (3 additional years) if a creditor uses the incorrect Model Form
remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625488357 XXX XXX XXX 35078317 credit 3 Missing Document: Missing Final 1003 1/XX/2007 MD Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488555 XXX XXX XXX 35078366 credit 3 Missing Document: Missing Final 1003 7/XX/2006 LA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488555 XXX XXX XXX 35078367 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 7/XX/2006 LA Refinance - Cash-out - Debt Consolidation Primary No B B B B
within a reasonably practicable time after using credit score.
625488555 XXX XXX XXX 35078368 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2006 LA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 06/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2006.
625488447 XXX XXX XXX 35078390 credit 3 Missing Document: Missing Final 1003 9/XX/2001 TX Purchase Primary No C C C C
625488447 XXX XXX XXX 35078391 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2001 TX Purchase Primary No B B B B
an application date of 08/XX/2001 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2001.
625488447 XXX XXX XXX 35078392 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2001 9/XX/2002 TX Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625488447 XXX XXX XXX 35078393 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 9/XX/2001 TX Purchase Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488447 XXX XXX XXX 35078394 compliance 2 (Doc Error) Initial GFE not provided 9/XX/2001 TX Purchase Primary No B B B B
625488069 XXX XXX XXX 35078421 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2006 10/XX/2009 GA Refinance - Rate/Term Primary No B B B B
defense to foreclosure. Assignee liability.
625488069 XXX XXX XXX 35078422 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 10/XX/2006 GA Refinance - Rate/Term Primary No B B B B
625488069 XXX XXX XXX 35078423 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2006 GA Refinance - Rate/Term Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489709 XXX XXX XXX 35078431 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2007 IL Purchase Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488996 XXX XXX XXX 35078459 credit 3 Missing Document: Missing Final 1003 9/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488996 XXX XXX XXX 35078460 compliance 2 Note Error: Note late charge percentage exceeds maximum per state Late charge of 4% exceeds maximum of 2% for the state of New York. 9/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488996 XXX XXX XXX 35078461 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2006 9/XX/2009 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625488996 XXX XXX XXX 35078462 credit 3 Title: Evidence of title is missing 9/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488996 XXX XXX XXX 35078463 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2006 9/XX/2009 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625488996 XXX XXX XXX 35078464 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2006 9/XX/2009 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625488996 XXX XXX XXX 35078465 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 9/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488996 XXX XXX XXX 35078466 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 08/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2006.
625488996 XXX XXX XXX 35078467 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489272 XXX XXX XXX 35078498 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2006 5/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
borrower within three (3) days of application.
625489272 XXX XXX XXX 35078499 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2006 5/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489593 XXX XXX XXX 35078510 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2006 GA Refinance - Cash-out - Other Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625487973 XXX XXX XXX 35078524 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 6/XX/2007 NV Purchase Primary No B B B B
625487973 XXX XXX XXX 35078525 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2007 NV Purchase Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625487973 XXX XXX XXX 35078526 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2007 6/XX/2008 NV Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625487973 XXX XXX XXX 35078527 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 6/XX/2007 NV Purchase Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489141 XXX XXX XXX 35078535 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 4/XX/2007 4/XX/2010 NY Refinance - Rate/Term Primary No B B B B
defense to foreclosure. Assignee liability.
625489141 XXX XXX XXX 35078536 compliance 2 (Doc Error) Initial GFE not provided 4/XX/2007 NY Refinance - Rate/Term Primary No B B B B
625488066 XXX XXX XXX 35078542 compliance 2 (Doc Error) Initial GFE not provided 11/XX/2005 GA Purchase Second Home No B B B B
625488066 XXX XXX XXX 35078543 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 11/XX/2005 GA Purchase Second Home No B B B B
625488066 XXX XXX XXX 35078544 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2005 GA Purchase Second Home No B B B B
an application date of 10/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 05/XX/2005.
625488420 XXX XXX XXX 35078545 credit 3 Missing Document: Missing Final 1003 10/XX/2005 CA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488420 XXX XXX XXX 35078546 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2005 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 10/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 05/XX/2005.
625488420 XXX XXX XXX 35078547 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2005 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489271 XXX XXX XXX 35078548 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization did not disclose 2 wire fees of $XXX as a prepaid finance $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 3/XX/2006 3/XX/2009 IL Refinance - Rate/Term Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. charges for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489271 XXX XXX XXX 35078549 credit 3 Missing Document: Missing Final 1003 3/XX/2006 IL Refinance - Rate/Term Primary No C C C C
625489271 XXX XXX XXX 35078551 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2006 IL Refinance - Rate/Term Primary No B B B B
an application date of 02/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2006.
625489271 XXX XXX XXX 35078552 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2006 IL Refinance - Rate/Term Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489271 XXX XXX XXX 35078553 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2006 3/XX/2007 IL Refinance - Rate/Term Primary No B B B B
Loan Application Date.
625489271 XXX XXX XXX 35078554 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2006 3/XX/2007 IL Refinance - Rate/Term Primary No B B B B
Loan Application Date.
625489174 XXX XXX XXX 35078560 credit 3 Missing Document: Missing Final 1003 8/XX/2008 IL Purchase Primary No C C C C
625489174 XXX XXX XXX 35078561 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing Itemization of Amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 8/XX/2008 8/XX/2009 IL Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. Financed for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489314 XXX XXX XXX 35078575 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 6/XX/2007 FL Refinance - Rate/Term Primary No B B B B
625489314 XXX XXX XXX 35078576 compliance 2 (Doc Error) Initial GFE not provided 6/XX/2007 FL Refinance - Rate/Term Primary No B B B B
625488988 XXX XXX XXX 35078666 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2004 9/XX/2007 NH Refinance - Cash-out - Other Primary No B B B B
defense to foreclosure. Assignee liability.
625488988 XXX XXX XXX 35078667 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2004 9/XX/2007 NH Refinance - Cash-out - Other Primary No B B B B
defense to foreclosure. Assignee liability.
625488647 XXX XXX XXX 35078724 credit 3 Missing Document: Missing Final 1003 9/XX/2007 LA Refinance - Rate/Term Primary No C C C C
625488647 XXX XXX XXX 35078725 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2007 LA Refinance - Rate/Term Primary No B B B B
an application date of 08/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2007.
625488647 XXX XXX XXX 35078726 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 9/XX/2007 LA Refinance - Rate/Term Primary No B B B B
following clauses:
625488647 XXX XXX XXX 35078727 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 09/XX/2007, prior to TILA ROR - 3yrs for rescindable transactions. 9/XX/2007 9/XX/2010 LA Refinance - Rate/Term Primary No B B B B
Date three (3) business days from transaction date of 09/XX/2007.
625489142 XXX XXX XXX 35078752 credit 3 Missing Document: Missing Final 1003 5/XX/2006 MT Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489142 XXX XXX XXX 35078753 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 05/XX/2006, prior to TILA ROR - 3yrs for rescindable transactions. 5/XX/2006 5/XX/2009 MT Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 05/XX/2006.
625489142 XXX XXX XXX 35078754 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2006 5/XX/2009 MT Refinance - Cash-out - Debt Consolidation Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625488399 XXX XXX XXX 35078768 credit 3 Missing Document: Missing Final 1003 9/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488399 XXX XXX XXX 35078769 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 08/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2006.
625488399 XXX XXX XXX 35078770 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 09/XX/2006, prior to TILA ROR - 3yrs for rescindable transactions. 9/XX/2006 9/XX/2009 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 09/XX/2006.
625488399 XXX XXX XXX 35078771 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2006 9/XX/2009 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625488399 XXX XXX XXX 35078772 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 9/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625487992 XXX XXX XXX 35078809 credit 3 Missing Document: Missing Final 1003 6/XX/2004 IL Refinance - Cash-out - Debt Consolidation Primary No C C C C
625487992 XXX XXX XXX 35078810 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2004 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 05/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2004.
625489115 XXX XXX XXX 35078838 credit 3 Missing Document: Missing Final 1003 7/XX/2003 PA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489115 XXX XXX XXX 35078839 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2003 7/XX/2006 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625489115 XXX XXX XXX 35078840 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2003 7/XX/2006 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625489115 XXX XXX XXX 35078841 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2003 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 06/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2003.
625489115 XXX XXX XXX 35078842 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2003 7/XX/2006 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625489115 XXX XXX XXX 35078843 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 7/XX/2003 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
following clauses:
625489055 XXX XXX XXX 35078865 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 1/XX/2007 GA Refinance - Rate/Term Primary No B B B B
an application date of 12/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 07/XX/2006.
625489055 XXX XXX XXX 35078866 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2007 1/XX/2008 GA Refinance - Rate/Term Primary No B B B B
Loan Application Date.
625489055 XXX XXX XXX 35078867 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2007 1/XX/2008 GA Refinance - Rate/Term Primary No B B B B
Loan Application Date.
625488217 XXX XXX XXX 35078888 credit 3 Missing Document: Missing Final 1003 7/XX/2007 NV Refinance - Rate/Term Primary No C C C C
625488217 XXX XXX XXX 35078889 compliance 1 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable 7/XX/2007 NV Refinance - Rate/Term Primary No A A A A 9/XX/2017 Yes 2017/XX/01: Re-providing copies of HUD and TIL. 2017/XX/01: Final HUD provided
Federal, State or Local compliance testing is unreliable.
625488217 XXX XXX XXX 35078890 compliance 1 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using 7/XX/2007 NV Refinance - Rate/Term Primary No A A A A 9/XX/2017 Yes 2017/XX/01: HUD provided, removed redundant exception
an application date of 06/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2007. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625488217 XXX XXX XXX 35078891 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 7/XX/2007 7/XX/2010 NV Refinance - Rate/Term Primary No B B B B
625488217 XXX XXX XXX 35078892 compliance 1 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2007 7/XX/2010 NV Refinance - Rate/Term Primary No A A A A 9/XX/2017 Yes 2017/XX/01: Re-providing copies of HUD and TIL. 2017/XX/01: Final TIL provided
defense to foreclosure. Assignee liability.
625488217 XXX XXX XXX 35078893 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 7/XX/2007 NV Refinance - Rate/Term Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488217 XXX XXX XXX 35078894 compliance 2 (Doc Error) Initial GFE not provided 7/XX/2007 NV Refinance - Rate/Term Primary No B B B B
625488217 XXX XXX XXX 35078895 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2007 NV Refinance - Rate/Term Primary No B B B B
an application date of 06/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2007.
625489452 XXX XXX XXX 35078896 credit 3 Missing Document: Missing Final 1003 8/XX/2006 VA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489452 XXX XXX XXX 35078897 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2006 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488332 XXX XXX XXX 35078900 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 8/XX/2008 PA Purchase Primary No B B B B
625488724 XXX XXX XXX 35078921 credit 3 Missing Document: Missing Final 1003 7/XX/2005 FL Refinance - Cash-out - Other Primary No C C C C
625488724 XXX XXX XXX 35078922 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 7/XX/2005 FL Refinance - Cash-out - Other Primary No B B B B
625488724 XXX XXX XXX 35078923 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2005 FL Refinance - Cash-out - Other Primary No B B B B
an application date of 06/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2005.
625488724 XXX XXX XXX 35078924 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2005 7/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B
Loan Application Date.
625488724 XXX XXX XXX 35078925 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2005 7/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B
Loan Application Date.
625488143 XXX XXX XXX 35078932 credit 3 Missing Document: Missing Final 1003 6/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488143 XXX XXX XXX 35078933 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 05/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2007.
625488143 XXX XXX XXX 35078934 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488143 XXX XXX XXX 35078935 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Loan Application Date.
625488143 XXX XXX XXX 35078936 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Loan Application Date.
625488482 XXX XXX XXX 35078944 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 10/XX/2006 WA Purchase Second Home No B B B B
625488482 XXX XXX XXX 35078945 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2006 WA Purchase Second Home No B B B B
an application date of 09/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2006.
625488482 XXX XXX XXX 35078946 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2006 WA Purchase Second Home No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489180 XXX XXX XXX 35078954 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 8/XX/2006 MO Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489180 XXX XXX XXX 35078955 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2006 MO Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 07/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2006.
625489180 XXX XXX XXX 35078956 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2006 MO Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489180 XXX XXX XXX 35078957 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 8/XX/2006 MO Refinance - Cash-out - Debt Consolidation Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489180 XXX XXX XXX 35078958 compliance 2 (Doc Error) Initial GFE not provided 8/XX/2006 MO Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489642 XXX XXX XXX 35079011 credit 3 Missing Document: Missing Final 1003 8/XX/2007 IL Refinance - Rate/Term Primary No C C C C
625489642 XXX XXX XXX 35079012 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2007 IL Refinance - Rate/Term Primary No B B B B
an application date of 07/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 07/XX/2007.
625488667 XXX XXX XXX 35079015 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2004 4/XX/2005 IL Purchase Primary No B B B B
borrower within three (3) days of application.
625488667 XXX XXX XXX 35079016 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2004 4/XX/2005 IL Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488667 XXX XXX XXX 35079017 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 4/XX/2004 4/XX/2005 IL Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488273 XXX XXX XXX 35079021 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine the under disclosure due to missing the Itemization of $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 6/XX/2005 6/XX/2006 IL Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. Amount Financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489534 XXX XXX XXX 35079027 credit 3 Missing Document: Missing Final 1003 No 3/XX/2004 FL Purchase Primary No C C C C
625489534 XXX XXX XXX 35079028 compliance 2 (Doc Error) Initial GFE not provided No 3/XX/2004 FL Purchase Primary No B B B B
625489534 XXX XXX XXX 35079029 compliance 3 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable No 3/XX/2004 FL Purchase Primary No D D D D
Federal, State or Local compliance testing is unreliable.
625489534 XXX XXX XXX 35079030 compliance 2 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using No 3/XX/2004 FL Purchase Primary No B B B B
an application date of 02/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 09/XX/2003. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625487925 XXX XXX XXX 35079086 credit 3 Missing Document: Missing Final 1003 6/XX/2007 NJ Refinance - Cash-out - Debt Consolidation Investment Yes C C C C
625487925 XXX XXX XXX 35079087 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 6/XX/2007 NJ Refinance - Cash-out - Debt Consolidation Investment Yes B B B B
within a reasonably practicable time after using credit score.
625487925 XXX XXX XXX 35079088 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2007 NJ Refinance - Cash-out - Debt Consolidation Investment Yes B B B B
an application date of 05/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 12/XX/2006.
625488384 XXX XXX XXX 35079089 compliance 1 Missing Document: Note - Subject Lien not provided 11/XX/2006 IL Refinance - Cash-out - Other Primary No A A A A 9/XX/2017 Yes 2017/XX/14: Cleared- Note received
625488384 XXX XXX XXX 35079090 credit 3 Missing Document: Missing Final 1003 11/XX/2006 IL Refinance - Cash-out - Other Primary No C C C C
625488384 XXX XXX XXX 35079092 compliance 1 (Missing Doc) Incomplete loan images/file File only contains the mortgage. 11/XX/2006 IL Refinance - Cash-out - Other Primary No A A A A 9/XX/2017 Yes 2017/XX/14: Cleared- documentation received to complete testing
625488384 XXX XXX XXX 35079093 credit 3 Missing Valuation: Appraisal not porvided 11/XX/2006 IL Refinance - Cash-out - Other Primary No C C C C
625488384 XXX XXX XXX 35079094 compliance 1 Missing Final HUD-1 11/XX/2006 IL Refinance - Cash-out - Other Primary No A A A A 9/XX/2017 Yes 2017/XX/14: cleared- HUD received- Unable to run compliance due to missing note
625488384 XXX XXX XXX 35079095 compliance 1 TILA - Final TIL Missing TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2006 11/XX/2009 IL Refinance - Cash-out - Other Primary No A A A A 9/XX/2017 Yes 2017/XX/14: Cleared- TIL received
defense to foreclosure. Assignee liability.
625488384 XXX XXX XXX 35079096 credit 2 Final Title Policy is missing. No evidence of title was found in file. 11/XX/2006 IL Refinance - Cash-out - Other Primary No B B B B
625488384 XXX XXX XXX 35079097 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 11/XX/2006 IL Refinance - Cash-out - Other Primary No B B B B
Security Instrument Notary Date of 11/XX/2006 used as disbursement date for
compliance testing.
625488384 XXX XXX XXX 35079098 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2006 IL Refinance - Cash-out - Other Primary No B B B B
an application date of 10/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 05/XX/2006.
625488384 XXX XXX XXX 35079099 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 11/XX/2006 11/XX/2009 IL Refinance - Cash-out - Other Primary No B B B B
625488384 XXX XXX XXX 35079100 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 11/XX/2006 IL Refinance - Cash-out - Other Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488384 XXX XXX XXX 35079101 compliance 2 (Doc Error) Initial GFE not provided 11/XX/2006 IL Refinance - Cash-out - Other Primary No B B B B
625489328 XXX XXX XXX 35079102 credit 3 Missing Document: Missing Final 1003 8/XX/2007 OH Refinance - Cash-out - Other Primary No C C C C
625489328 XXX XXX XXX 35079103 compliance 1 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable 8/XX/2007 OH Refinance - Cash-out - Other Primary No A A A A 9/XX/2017 Yes 2017/XX/14: Cleared- HUD received
Federal, State or Local compliance testing is unreliable.
625489328 XXX XXX XXX 35079104 compliance 1 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using 8/XX/2007 OH Refinance - Cash-out - Other Primary No A A A A 9/XX/2017 Yes 2017/XX/14: HUD received
an application date of 07/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2007. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625489328 XXX XXX XXX 35079105 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 8/XX/2007 8/XX/2010 OH Refinance - Cash-out - Other Primary No B B B B
625489328 XXX XXX XXX 35079106 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2007 8/XX/2010 OH Refinance - Cash-out - Other Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625489328 XXX XXX XXX 35079107 credit 3 Title: Evidence of title is missing 8/XX/2007 OH Refinance - Cash-out - Other Primary No C C C C
625489328 XXX XXX XXX 35079108 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 8/XX/2007 OH Refinance - Cash-out - Other Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489328 XXX XXX XXX 35079109 compliance 2 (Doc Error) Initial GFE not provided 8/XX/2007 OH Refinance - Cash-out - Other Primary No B B B B
625489328 XXX XXX XXX 35079110 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 8/XX/2007 OH Refinance - Cash-out - Other Primary No B B B B
625489328 XXX XXX XXX 35079111 compliance 2 Ohio Consumer Sales Practices Act (Acknowledgement of Receipt of Home Mortgage Ohio Consumer Sales Practices Act: Acknowledgement of Receipt of Home Mortgage The Consumer Sales Practices Act (CSPA) generally does not provide for assignee 8/XX/2007 OH Refinance - Cash-out - Other Primary No B B B B
Loan Information Document Not Retained by Lender) Loan Information Document not retained by lender. liability. The Act provides that no claim or defense may be asserted under the
Act by the Attorney General or any consumer against a purchaser or assignee of a
mortgage loan for value for any action under the statute unless: (a) the
violation was committed by the purchaser or assignee; or (b) the assignee or
purchaser is affiliated by common control with the seller of the loan at the
time the loan was purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant
injunctions, and levy monetary fines. Additionally, the CSPA provides borrowers
with a private right of action. Therefore, it is possible that any action
commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law
as part of the private right of action, a court could reform the loan terms
which could impact purchasers. Therefore, if the seller cannot be compelled to
repurchase the loan, the assignee could face exposure.
625489328 XXX XXX XXX 35079112 compliance 2 Ohio Consumer Sales Practices Act (Ability to Repay not Verified) Unable to test Ability to Repay due to missing information. 8/XX/2007 OH Refinance - Cash-out - Other Primary No B B B B
625489328 XXX XXX XXX 35079113 compliance 2 Ohio Consumer Sales Practices Act (Closing Disclosure Not Provided) Ohio Consumer Sales Practices Act: Consumer did not receive the required Closing The Consumer Sales Practices Act (CSPA) generally does not provide for assignee 8/XX/2007 OH Refinance - Cash-out - Other Primary No B B B B
Disclosure. liability. The Act provides that no claim or defense may be asserted under the
Act by the Attorney General or any consumer against a purchaser or assignee of a
mortgage loan for value for any action under the statute unless: (a) the
violation was committed by the purchaser or assignee; or (b) the assignee or
purchaser is affiliated by common control with the seller of the loan at the
time the loan was purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant
injunctions, and levy monetary fines. Additionally, the CSPA provides borrowers
with a private right of action. Therefore, it is possible that any action
commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law
as part of the private right of action, a court could reform the loan terms
which could impact purchasers. Therefore, if the seller cannot be compelled to
repurchase the loan, the assignee could face exposure.
625489328 XXX XXX XXX 35079114 compliance 2 Ohio CSPA Tangible Net Benefit Test Ohio Consumer Sales Practices Act: Unable to determine if mortgage loan 8/XX/2007 OH Refinance - Cash-out - Other Primary No B B B B
refinanced has a tangible net benefit to the borrower due to missing prior loan
information.
625489328 XXX XXX XXX 35079115 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 8/XX/2007 OH Refinance - Cash-out - Other Primary No B B B B
Security Instrument Notary Date of 08/XX/2007 used as disbursement date for
compliance testing.
625489328 XXX XXX XXX 35079116 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2007 OH Refinance - Cash-out - Other Primary No B B B B
an application date of 07/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2007.
625488645 XXX XXX XXX 35079204 credit 3 Missing Document: Missing Final 1003 10/XX/2007 IL Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488645 XXX XXX XXX 35079205 compliance 1 Missing Document: Missing Lender's Initial 1003 10/XX/2007 IL Refinance - Cash-out - Debt Consolidation Primary No A A A A 9/XX/2017 Yes 2017/XX/11: Removing redundant exception
625488645 XXX XXX XXX 35079206 compliance 2 (Doc Error) Initial GFE not provided 10/XX/2007 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488645 XXX XXX XXX 35079207 credit 3 Title: Evidence of title is missing 10/XX/2007 IL Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488645 XXX XXX XXX 35079208 credit 1 Missing Valuation: Appraisal not provided 10/XX/2007 IL Refinance - Cash-out - Debt Consolidation Primary No A A A A 9/XX/2017 Yes 2017/XX/11: Removing redundant exception
625488645 XXX XXX XXX 35079209 compliance 1 Missing Final HUD-1 10/XX/2007 IL Refinance - Cash-out - Debt Consolidation Primary No A A A A 9/XX/2017 Yes 2017/XX/11: Final HUD-1 provided.
625488645 XXX XXX XXX 35079210 compliance 2 Initial TIL not provided 10/XX/2007 10/XX/2008 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488645 XXX XXX XXX 35079211 compliance 1 (Missing Doc) Incomplete loan images/file Loan file only contains the note, security instrument, and final TIL 10/XX/2007 IL Refinance - Cash-out - Debt Consolidation Primary No A A A A 9/XX/2017 Yes 2017/XX/11: Final HUD-1 provided
625488645 XXX XXX XXX 35079212 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 10/XX/2007 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 10/XX/2007 used as disbursement date for
compliance testing.
625488645 XXX XXX XXX 35079213 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2007 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 09/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2007.
625488645 XXX XXX XXX 35079214 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 10/XX/2007 10/XX/2010 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488645 XXX XXX XXX 35079215 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 10/XX/2007 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488289 XXX XXX XXX 35079282 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 1/XX/2006 AR Purchase Primary No B B B B
an application date of 12/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 07/XX/2005.
625488289 XXX XXX XXX 35079283 credit 3 Missing Document: Missing Final 1003 1/XX/2006 AR Purchase Primary No C C C C
625487997 XXX XXX XXX 35079288 credit 3 Missing Document: Missing Final 1003 2/XX/2005 OH Refinance - Cash-out - Debt Consolidation Primary No C C C C
625487997 XXX XXX XXX 35079289 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 2/XX/2005 2/XX/2008 OH Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625487997 XXX XXX XXX 35079290 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 2/XX/2005 2/XX/2008 OH Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625487997 XXX XXX XXX 35079291 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 2/XX/2005 OH Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488118 XXX XXX XXX 35079316 credit 3 Missing Document: Missing Final 1003 8/XX/2005 NY Refinance - Rate/Term Primary No C C C C
625488118 XXX XXX XXX 35079317 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2005 8/XX/2008 NY Refinance - Rate/Term Primary No B B B B
defense to foreclosure. Assignee liability.
625488118 XXX XXX XXX 35079318 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2005 8/XX/2008 NY Refinance - Rate/Term Primary No B B B B
defense to foreclosure. Assignee liability.
625488118 XXX XXX XXX 35079319 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 8/XX/2005 NY Refinance - Rate/Term Primary No B B B B
625488118 XXX XXX XXX 35079320 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 08/XX/2005, prior to TILA ROR - 3yrs for rescindable transactions. 8/XX/2005 8/XX/2008 NY Refinance - Rate/Term Primary No B B B B
Date three (3) business days from transaction date of 08/XX/2005.
625488118 XXX XXX XXX 35079321 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2005 8/XX/2008 NY Refinance - Rate/Term Primary No B B B B
defense to foreclosure. Assignee liability.
625489008 XXX XXX XXX 35079331 credit 3 Missing Document: Missing Final 1003 3/XX/2005 MA Refinance - Cash-out - Debt Consolidation Primary Yes C C C C
625489008 XXX XXX XXX 35079333 credit 3 Missing Document: Security Instrument - Subject Lien not provided 3/XX/2005 MA Refinance - Cash-out - Debt Consolidation Primary Yes D D D D
625489008 XXX XXX XXX 35079334 compliance 1 Missing Document: Note - Subject Lien not provided 3/XX/2005 MA Refinance - Cash-out - Debt Consolidation Primary Yes A A A A 9/XX/2017 Yes 2017/XX/03: Cleared- Note received
625489008 XXX XXX XXX 35079335 credit 2 Final Title Policy is missing. No evidence of title was found in file. 3/XX/2005 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
625489008 XXX XXX XXX 35079336 compliance 2 (Doc Error) Initial GFE not provided 3/XX/2005 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
625489008 XXX XXX XXX 35079337 compliance 1 (Missing Doc) Incomplete loan images/file File only contains an appraisal from origination. Note is file is dated 2001 3/XX/2005 MA Refinance - Cash-out - Debt Consolidation Primary Yes A A A A 9/XX/2017 Yes 2017/XX/03: Cleared- Documentation received
however bid tape reflects a note date in 2005.
625489008 XXX XXX XXX 35079338 compliance 1 Missing Final HUD-1 3/XX/2005 MA Refinance - Cash-out - Debt Consolidation Primary Yes A A A A 9/XX/2017 Yes 2017/XX/03: Cleared- HUD Received
625489008 XXX XXX XXX 35079339 compliance 1 TILA - Final TIL Missing TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2005 3/XX/2009 MA Refinance - Cash-out - Debt Consolidation Primary Yes A A A A 9/XX/2017 Yes 2017/XX/03: Cleared- TIL received
defense to foreclosure. Assignee liability.
625489008 XXX XXX XXX 35079340 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. Note 3/XX/2005 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
Date of 03/XX/2005 used as disbursement date for compliance testing.
625489008 XXX XXX XXX 35079341 compliance 1 (Missing Data) Last Transaction Date Last Transaction Date was not provided. Any applicable Federal, State or Local 3/XX/2005 MA Refinance - Cash-out - Debt Consolidation Primary Yes A A A A 9/XX/2017 Yes 2017/XX/05: Last transaction date documented
compliance testing is unreliable.
625489008 XXX XXX XXX 35079342 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2005 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
an application date of 02/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 09/XX/2004.
625489008 XXX XXX XXX 35079343 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 3/XX/2005 3/XX/2009 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
625489008 XXX XXX XXX 35079344 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2005 3/XX/2009 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
defense to foreclosure. Assignee liability.
625488974 XXX XXX XXX 35079396 compliance 2 (Doc Error) Initial GFE not provided 2/XX/2007 CA Purchase Primary No B B B B
625488974 XXX XXX XXX 35079397 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2007 CA Purchase Primary No B B B B
an application date of 01/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/2006.
625488974 XXX XXX XXX 35079398 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2007 2/XX/2008 CA Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488737 XXX XXX XXX 35079420 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2006 FL Purchase Primary No B B B B
an application date of 10/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 09/XX/2006.
625488737 XXX XXX XXX 35079421 credit 2 Final Title Policy is missing. No evidence of title was found in file. 11/XX/2006 FL Purchase Primary No B B B B
625489658 XXX XXX XXX 35079422 credit 3 Missing Document: Missing Final 1003 2/XX/2007 FL Purchase Investment No C C C C
625489658 XXX XXX XXX 35079423 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2007 FL Purchase Investment No B B B B
an application date of 01/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2007.
625488989 XXX XXX XXX 35079468 credit 3 Missing Valuation: Appraisal not provided 4/XX/2007 MD Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489283 XXX XXX XXX 35079474 compliance 1 Missing Document: Note - Subject Lien not provided 1/XX/1997 CA Refinance - Rate/Term Primary No A A A A 10/XX/2017 Yes 2017/XX/09: Note received
625489283 XXX XXX XXX 35079475 compliance 1 (Missing Doc) Incomplete loan images/file File incomplete due to missing note. Unable to run compliance testing. 1/XX/1997 CA Refinance - Rate/Term Primary No A A A A 10/XX/2017 Yes 2017/XX/09: Cleared- Note received
625489283 XXX XXX XXX 35079476 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/1997 1/XX/1998 CA Refinance - Rate/Term Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489283 XXX XXX XXX 35079477 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization did not disclose the closing fee of $XXX as a prepaid finance $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 1/XX/1997 1/XX/2000 CA Refinance - Rate/Term Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. charge. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489283 XXX XXX XXX 35079478 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 1/XX/1997 1/XX/2000 CA Refinance - Rate/Term Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625488032 XXX XXX XXX 35079479 credit 3 Missing Document: Missing Final 1003 9/XX/1998 UT Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488032 XXX XXX XXX 35079480 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/1998 UT Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 08/XX/1998 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/1998.
625488032 XXX XXX XXX 35079481 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/1998 9/XX/1999 UT Refinance - Cash-out - Debt Consolidation Primary No B B B B
Loan Application Date.
625488032 XXX XXX XXX 35079482 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/1998 9/XX/1999 UT Refinance - Cash-out - Debt Consolidation Primary No B B B B
Loan Application Date.
625488032 XXX XXX XXX 35079483 credit 3 Missing Valuation: Appraisal not provided 9/XX/1998 UT Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489373 XXX XXX XXX 35079484 credit 3 Missing Document: Missing Final 1003 1/XX/2007 RI Refinance - Cash-out - Debt Consolidation Primary Yes C C C C
625489373 XXX XXX XXX 35079485 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 1/XX/2007 RI Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
an application date of 12/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 07/XX/2006.
625489373 XXX XXX XXX 35079486 compliance 1 Rhode Island Ability to Repay Reliable Documentation Rhode Island High-Cost Loan: Borrower’s ability to repay not verified with """Assignee Liability: A borrower may bring a claim against an assignee or 1/XX/2007 RI Refinance - Cash-out - Debt Consolidation Primary Yes A A A A 10/XX/2017 Yes 2017/XX/13: HOI Premium invoice located in file, removed fee from high cost pts
reliable documentation. subsequent holder of a high cost home loan under two separate provisions of the and fees total. Exception no longer applies.
Act. The rights conferred on borrowers by these two provisions are independent
of each other and do not limit each other.
(1) Any person who purchases or is otherwise assigned a high cost home loan will
be subject to all affirmative claims and any defenses with respect to the loan
that the borrower could assert against the original creditor. Significantly,
this liability does not appear to be independently capped or subject to any
limitations periods. Further, class actions appear to be permitted.
(2) A borrower may also assert against any subsequent holder or assignee of a
high cost home loan any claims that the borrower could assert against the
original creditor. Any such claims must be brought only in an individual
capacity and are limited to amounts required to reduce or extinguish the
borrower’s liability under the high cost home loan plus costs, including
reasonable attorneys’ fees.
Effective June 20, 2007, HB 5485 and SB 371 revise the liability provisions to
create one single cause of action against assignees. As revised, any person who
purchases or is otherwise assigned a high cost home loan will continue to be
subject to all affirmative claims and any defenses that the borrower could
assert against the original creditor. Any such claims must be brought only in an
individual capacity and are limited to amounts required to reduce or extinguish
the borrower’s liability under the high cost home loan plus costs, including
reasonable attorneys’ fees. Any such claim may be asserted by a borrower acting
only in an individual capacity and must be asserted as follows: (a) Within five
years of the closing of a high cost home loan, if the claim is an original
action relating to a violation of the Act; and (b) With respect to any defense,
claim, counterclaim, or action to enjoin foreclosure or preserve or obtain
possession of the home that secures the loan, at any time during the term of the
high cost home loan, after an action to collect on the high cost home loan or
foreclose on the collateral securing the high cost home loan has been initiated
or the debt arising from the high cost home loan has been accelerated or the
high cost home loan has become sixty days in default."""
625489373 XXX XXX XXX 35079487 compliance 1 Rhode Island Assignee Disclosure Rhode Island High-Cost Loan: Mandatory purchaser/assignee disclosure not "Assignee Liability: A borrower may bring a claim against an assignee or 1/XX/2007 RI Refinance - Cash-out - Debt Consolidation Primary Yes A A A A 10/XX/2017 Yes 2017/XX/13: HOI Premium invoice located in file, removed fee from high cost pts
contained on document that creates debt or pledges property as collateral. subsequent holder of a high cost home loan under two separate provisions of the and fees total. Exception no longer applies.
Act. The rights conferred on borrowers by these two provisions are independent
of each other and do not limit each other.
(1) Any person who purchases or is otherwise assigned a high cost home loan will
be subject to all affirmative claims and any defenses with respect to the loan
that the borrower could assert against the original creditor. Significantly,
this liability does not appear to be independently capped or subject to any
limitations periods. Further, class actions appear to be permitted.
(2) A borrower may also assert against any subsequent holder or assignee of a
high cost home loan any claims that the borrower could assert against the
original creditor. Any such claims must be brought only in an individual
capacity and are limited to amounts required to reduce or extinguish the
borrower’s liability under the high cost home loan plus costs, including
reasonable attorneys’ fees.
Effective June 20, 2007, HB 5485 and SB 371 revise the liability provisions to
create one single cause of action against assignees. As revised, any person who
purchases or is otherwise assigned a high cost home loan will continue to be
subject to all affirmative claims and any defenses that the borrower could
assert against the original creditor. Any such claims must be brought only in an
individual capacity and are limited to amounts required to reduce or extinguish
the borrower’s liability under the high cost home loan plus costs, including
reasonable attorneys’ fees. Any such claim may be asserted by a borrower acting
only in an individual capacity and must be asserted as follows: (a) Within five
years of the closing of a high cost home loan, if the claim is an original
action relating to a violation of the Act; and (b) With respect to any defense,
claim, counterclaim, or action to enjoin foreclosure or preserve or obtain
possession of the home that secures the loan, at any time during the term of the
high cost home loan, after an action to collect on the high cost home loan or
foreclose on the collateral securing the high cost home loan has been initiated
or the debt arising from the high cost home loan has been accelerated or the
high cost home loan has become sixty days in default."
625489373 XXX XXX XXX 35079488 compliance 1 Rhode Island Financed Fees Rhode Island High-Cost Loan: Fees financed in excess of the greater of five "Assignee Liability: A borrower may bring a claim against an assignee or 1/XX/2007 RI Refinance - Cash-out - Debt Consolidation Primary Yes A A A A 10/XX/2017 Yes 2017/XX/13: HOI Premium invoice located in file, removed fee from high cost pts
percent (5%) or $XXX. subsequent holder of a high cost home loan under two separate provisions of the and fees total. Exception no longer applies.
Act. The rights conferred on borrowers by these two provisions are independent
of each other and do not limit each other.
(1) Any person who purchases or is otherwise assigned a high cost home loan will
be subject to all affirmative claims and any defenses with respect to the loan
that the borrower could assert against the original creditor. Significantly,
this liability does not appear to be independently capped or subject to any
limitations periods. Further, class actions appear to be permitted.
(2) A borrower may also assert against any subsequent holder or assignee of a
high cost home loan any claims that the borrower could assert against the
original creditor. Any such claims must be brought only in an individual
capacity and are limited to amounts required to reduce or extinguish the
borrower’s liability under the high cost home loan plus costs, including
reasonable attorneys’ fees.
Effective June 20, 2007, HB 5485 and SB 371 revise the liability provisions to
create one single cause of action against assignees. As revised, any person who
purchases or is otherwise assigned a high cost home loan will continue to be
subject to all affirmative claims and any defenses that the borrower could
assert against the original creditor. Any such claims must be brought only in an
individual capacity and are limited to amounts required to reduce or extinguish
the borrower’s liability under the high cost home loan plus costs, including
reasonable attorneys’ fees. Any such claim may be asserted by a borrower acting
only in an individual capacity and must be asserted as follows: (a) Within five
years of the closing of a high cost home loan, if the claim is an original
action relating to a violation of the Act; and (b) With respect to any defense,
claim, counterclaim, or action to enjoin foreclosure or preserve or obtain
possession of the home that secures the loan, at any time during the term of the
high cost home loan, after an action to collect on the high cost home loan or
foreclose on the collateral securing the high cost home loan has been initiated
or the debt arising from the high cost home loan has been accelerated or the
high cost home loan has become sixty days in default."
625489373 XXX XXX XXX 35079489 compliance 1 Rhode Island Home Loan Protection Act Counseling Received Rhode Island High-Cost Loan: No evidence of certification from a HUD-approved "Assignee Liability: A borrower may bring a claim against an assignee or 1/XX/2007 RI Refinance - Cash-out - Debt Consolidation Primary Yes A A A A 10/XX/2017 Yes 2017/XX/13: HOI Premium invoice located in file, removed fee from high cost pts
third party counselor that borrower has received counseling on the advisability subsequent holder of a high cost home loan under two separate provisions of the and fees total. Exception no longer applies.
of the loan transaction. Act. The rights conferred on borrowers by these two provisions are independent
of each other and do not limit each other.
(1) Any person who purchases or is otherwise assigned a high cost home loan will
be subject to all affirmative claims and any defenses with respect to the loan
that the borrower could assert against the original creditor. Significantly,
this liability does not appear to be independently capped or subject to any
limitations periods. Further, class actions appear to be permitted.
(2) A borrower may also assert against any subsequent holder or assignee of a
high cost home loan any claims that the borrower could assert against the
original creditor. Any such claims must be brought only in an individual
capacity and are limited to amounts required to reduce or extinguish the
borrower’s liability under the high cost home loan plus costs, including
reasonable attorneys’ fees.
Effective June 20, 2007, HB 5485 and SB 371 revise the liability provisions to
create one single cause of action against assignees. As revised, any person who
purchases or is otherwise assigned a high cost home loan will continue to be
subject to all affirmative claims and any defenses that the borrower could
assert against the original creditor. Any such claims must be brought only in an
individual capacity and are limited to amounts required to reduce or extinguish
the borrower’s liability under the high cost home loan plus costs, including
reasonable attorneys’ fees. Any such claim may be asserted by a borrower acting
only in an individual capacity and must be asserted as follows: (a) Within five
years of the closing of a high cost home loan, if the claim is an original
action relating to a violation of the Act; and (b) With respect to any defense,
claim, counterclaim, or action to enjoin foreclosure or preserve or obtain
possession of the home that secures the loan, at any time during the term of the
high cost home loan, after an action to collect on the high cost home loan or
foreclose on the collateral securing the high cost home loan has been initiated
or the debt arising from the high cost home loan has been accelerated or the
high cost home loan has become sixty days in default."
625489373 XXX XXX XXX 35079490 compliance 1 Rhode Island Home Loan Protection Act Disclosure Rhode Island High-Cost Loan: Borrower was not provided with the Consumer Caution "Assignee Liability: A borrower may bring a claim against an assignee or 1/XX/2007 RI Refinance - Cash-out - Debt Consolidation Primary Yes A A A A 10/XX/2017 Yes 2017/XX/13: HOI Premium invoice located in file, removed fee from high cost pts
and Home Ownership Counseling Notice and Certification. subsequent holder of a high cost home loan under two separate provisions of the and fees total. Exception no longer applies.
Act. The rights conferred on borrowers by these two provisions are independent
of each other and do not limit each other.
(1) Any person who purchases or is otherwise assigned a high cost home loan will
be subject to all affirmative claims and any defenses with respect to the loan
that the borrower could assert against the original creditor. Significantly,
this liability does not appear to be independently capped or subject to any
limitations periods. Further, class actions appear to be permitted.
(2) A borrower may also assert against any subsequent holder or assignee of a
high cost home loan any claims that the borrower could assert against the
original creditor. Any such claims must be brought only in an individual
capacity and are limited to amounts required to reduce or extinguish the
borrower’s liability under the high cost home loan plus costs, including
reasonable attorneys’ fees.
Effective June 20, 2007, HB 5485 and SB 371 revise the liability provisions to
create one single cause of action against assignees. As revised, any person who
purchases or is otherwise assigned a high cost home loan will continue to be
subject to all affirmative claims and any defenses that the borrower could
assert against the original creditor. Any such claims must be brought only in an
individual capacity and are limited to amounts required to reduce or extinguish
the borrower’s liability under the high cost home loan plus costs, including
reasonable attorneys’ fees. Any such claim may be asserted by a borrower acting
only in an individual capacity and must be asserted as follows: (a) Within five
years of the closing of a high cost home loan, if the claim is an original
action relating to a violation of the Act; and (b) With respect to any defense,
claim, counterclaim, or action to enjoin foreclosure or preserve or obtain
possession of the home that secures the loan, at any time during the term of the
high cost home loan, after an action to collect on the high cost home loan or
foreclose on the collateral securing the high cost home loan has been initiated
or the debt arising from the high cost home loan has been accelerated or the
high cost home loan has become sixty days in default."
625489373 XXX XXX XXX 35079491 compliance 1 (State High Cost Provision) Rhode Island Late Charge Rhode Island High-Cost Loan: Loan contains an impermissible late charge. High cost home loan not to exceed 3% late payment fee. Late charge per note 6%. "Assignee Liability: A borrower may bring a claim against an assignee or 1/XX/2007 RI Refinance - Cash-out - Debt Consolidation Primary Yes A A A A 10/XX/2017 Yes 2017/XX/13: HOI Premium invoice located in file, removed fee from high cost pts
subsequent holder of a high cost home loan under two separate provisions of the and fees total. Exception no longer applies.
Act. The rights conferred on borrowers by these two provisions are independent
of each other and do not limit each other.
(1) Any person who purchases or is otherwise assigned a high cost home loan will
be subject to all affirmative claims and any defenses with respect to the loan
that the borrower could assert against the original creditor. Significantly,
this liability does not appear to be independently capped or subject to any
limitations periods. Further, class actions appear to be permitted.
(2) A borrower may also assert against any subsequent holder or assignee of a
high cost home loan any claims that the borrower could assert against the
original creditor. Any such claims must be brought only in an individual
capacity and are limited to amounts required to reduce or extinguish the
borrower’s liability under the high cost home loan plus costs, including
reasonable attorneys’ fees.
Effective June 20, 2007, HB 5485 and SB 371 revise the liability provisions to
create one single cause of action against assignees. As revised, any person who
purchases or is otherwise assigned a high cost home loan will continue to be
subject to all affirmative claims and any defenses that the borrower could
assert against the original creditor. Any such claims must be brought only in an
individual capacity and are limited to amounts required to reduce or extinguish
the borrower’s liability under the high cost home loan plus costs, including
reasonable attorneys’ fees. Any such claim may be asserted by a borrower acting
only in an individual capacity and must be asserted as follows: (a) Within five
years of the closing of a high cost home loan, if the claim is an original
action relating to a violation of the Act; and (b) With respect to any defense,
claim, counterclaim, or action to enjoin foreclosure or preserve or obtain
possession of the home that secures the loan, at any time during the term of the
high cost home loan, after an action to collect on the high cost home loan or
foreclose on the collateral securing the high cost home loan has been initiated
or the debt arising from the high cost home loan has been accelerated or the
high cost home loan has become sixty days in default."
625489373 XXX XXX XXX 35079492 compliance 1 (State High Cost) Rhode Island High-Cost Loan (Points and Fees) Rhode Island Home Loan Protection Act: Points and Fees on subject loan of "Assignee Liability: A borrower may bring a claim against an assignee or 1/XX/2007 RI Refinance - Cash-out - Debt Consolidation Primary Yes A A A A 10/XX/2017 Yes 2017/XX/13: Disagree - Home Owner's Insurance iao $XXX paid to a 3rd party 2017/XX/13: HOI Premium invoice located in file, removed fee from high cost pts
5.10397% is in excess of the allowable maximum of 5.00000% of the Total Loan subsequent holder of a high cost home loan under two separate provisions of the should not have been included in the State HC fee calculations. and fees total. Exception no longer applies.
Amount. Points and Fees total $XXX on a Total Loan Amount of $XXX vs. an Act. The rights conferred on borrowers by these two provisions are independent
allowable total of $XXX (an overage of $XXX or .10397%). Non-Compliant High Cost of each other and do not limit each other.
Loan. (1) Any person who purchases or is otherwise assigned a high cost home loan will
be subject to all affirmative claims and any defenses with respect to the loan
that the borrower could assert against the original creditor. Significantly,
this liability does not appear to be independently capped or subject to any
limitations periods. Further, class actions appear to be permitted.
(2) A borrower may also assert against any subsequent holder or assignee of a
high cost home loan any claims that the borrower could assert against the
original creditor. Any such claims must be brought only in an individual
capacity and are limited to amounts required to reduce or extinguish the
borrower’s liability under the high cost home loan plus costs, including
reasonable attorneys’ fees.
Effective June 20, 2007, HB 5485 and SB 371 revise the liability provisions to
create one single cause of action against assignees. As revised, any person who
purchases or is otherwise assigned a high cost home loan will continue to be
subject to all affirmative claims and any defenses that the borrower could
assert against the original creditor. Any such claims must be brought only in an
individual capacity and are limited to amounts required to reduce or extinguish
the borrower’s liability under the high cost home loan plus costs, including
reasonable attorneys’ fees. Any such claim may be asserted by a borrower acting
only in an individual capacity and must be asserted as follows: (a) Within five
years of the closing of a high cost home loan, if the claim is an original
action relating to a violation of the Act; and (b) With respect to any defense,
claim, counterclaim, or action to enjoin foreclosure or preserve or obtain
possession of the home that secures the loan, at any time during the term of the
high cost home loan, after an action to collect on the high cost home loan or
foreclose on the collateral securing the high cost home loan has been initiated
or the debt arising from the high cost home loan has been accelerated or the
high cost home loan has become sixty days in default."
625489373 XXX XXX XXX 35079493 compliance 2 Note Error: Note late charge percentage exceeds maximum per state Maximum late charge for RI is 3% - note states 6%. 1/XX/2007 RI Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
625489373 XXX XXX XXX 35079494 credit 3 Missing Valuation: 1/XX/2007 RI Refinance - Cash-out - Debt Consolidation Primary Yes C C C C
625488343 XXX XXX XXX 35079511 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2005 KY Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488723 XXX XXX XXX 35079555 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2006 7/XX/2009 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625488723 XXX XXX XXX 35079556 credit 3 Missing Document: Missing Final 1003 7/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488723 XXX XXX XXX 35079557 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 06/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2006.
625488915 XXX XXX XXX 35079601 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 1/XX/2010 NC Refinance - Rate/Term Primary No B B B B
an application date of 12/XX/2009 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 07/XX/2009.
625488915 XXX XXX XXX 35079602 compliance 2 TIL-MDIA - Initial TIL Not Provided within 3 Business Days of Application Unable to determine compliance with timing requirements due to missing Initial TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited 1/XX/2010 1/XX/2011 NC Refinance - Rate/Term Primary No B B B B
Loan Application Date. as a defense to foreclosure. Assignee liability.
625488915 XXX XXX XXX 35079603 credit 3 Missing Document: FHA Mortgage Insurance Certificate not provided 1/XX/2010 NC Refinance - Rate/Term Primary No C C C C
625488863 XXX XXX XXX 35079616 compliance 2 (Doc Error) Initial GFE not provided 11/XX/2004 IL Purchase Primary No B B B B
625488863 XXX XXX XXX 35079617 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2004 11/XX/2005 IL Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625489427 XXX XXX XXX 35079633 credit 3 Missing Document: Missing Final 1003 5/XX/2008 MD Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489427 XXX XXX XXX 35079634 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 5/XX/2008 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489427 XXX XXX XXX 35079635 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2008 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 04/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2007.
625489684 XXX XXX XXX 35079636 credit 3 Missing Document: Missing Final 1003 6/XX/2008 MI Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489684 XXX XXX XXX 35079637 compliance 2 Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Michigan Consumer Mortgage Protection Act: Borrower Bill of Rights disclosure Assignee liability is unclear. Purchasers and assignees would not appear to be 6/XX/2008 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B
Not Provided) not provided to borrower. liable for violations of the Act, except to the extent involved I violations
arising from servicing or collecting.
625489684 XXX XXX XXX 35079638 compliance 2 Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided Michigan Consumer Mortgage Protection Act: Consumer Caution and Home Ownership Assignee liability is unclear. Purchasers and assignees would not appear to be 6/XX/2008 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B
Counseling Notice not provided to borrower. liable for violations of the Act, except to the extent involved I violations
arising from servicing or collecting.
625489684 XXX XXX XXX 35079639 compliance 2 Michigan Consumer Mortgage Protection Act (Counseling Agencies List) Michigan Consumer Mortgage Protection Act: List of HUD-approved credit 6/XX/2008 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B
counseling agencies not provided to borrower.
625489488 XXX XXX XXX 35079654 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 1/XX/2006 MS Purchase Primary No B B B B
an application date of 12/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/2005.
625489488 XXX XXX XXX 35079655 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2006 1/XX/2007 MS Purchase Primary No B B B B
borrower.
625489488 XXX XXX XXX 35079656 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2006 1/XX/2007 MS Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489488 XXX XXX XXX 35079657 credit 3 Missing Document: Missing Final 1003 1/XX/2006 MS Purchase Primary No C C C C
625489637 XXX XXX XXX 35079682 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2002 MI Refinance - Rate/Term Primary No B B B B
an application date of 03/XX/2002 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2001.
625489204 XXX XXX XXX 35079709 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 6/XX/2006 MO Purchase Primary No B B B B
625489204 XXX XXX XXX 35079710 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2006 MO Purchase Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489204 XXX XXX XXX 35079711 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2006 6/XX/2007 MO Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625489204 XXX XXX XXX 35079712 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2006 6/XX/2007 MO Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625488576 XXX XXX XXX 35079739 credit 3 Missing Document: Missing Final 1003 7/XX/2003 WA Refinance - Cash-out - Other Primary No C C C C
625488576 XXX XXX XXX 35079740 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2003 WA Refinance - Cash-out - Other Primary No B B B B
an application date of 06/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2003.
625488576 XXX XXX XXX 35079741 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2003 WA Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488576 XXX XXX XXX 35079742 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from The Lender's TIL reflects MI dropping off after 83 months, however, the audited $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 7/XX/2003 7/XX/2006 WA Refinance - Cash-out - Other Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. TIL indicates MI should drop off after 84 months. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488157 XXX XXX XXX 35079745 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 4/XX/2005 4/XX/2006 FL Construction-Permanent Primary No B B B B
defense to foreclosure. Assignee liability.
625488157 XXX XXX XXX 35079746 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 4/XX/2005 4/XX/2006 FL Construction-Permanent Primary No B B B B
defense to foreclosure. Assignee liability.
625488157 XXX XXX XXX 35079747 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2005 4/XX/2006 FL Construction-Permanent Primary No B B B B
borrower within three (3) days of application.
625488157 XXX XXX XXX 35079748 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2005 4/XX/2006 FL Construction-Permanent Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488300 XXX XXX XXX 35079808 credit 3 Missing Document: FHA Mortgage Insurance Certificate not provided 8/XX/2003 IN Purchase Primary No C C C C
625489061 XXX XXX XXX 35079840 credit 3 Missing Document: Missing Final 1003 7/XX/2007 AL Purchase Primary No C C C C
625489061 XXX XXX XXX 35079841 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2007 AL Purchase Primary No B B B B
an application date of 07/XX/2007 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 07/XX/2007.
625489647 XXX XXX XXX 35079871 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2007 NY Refinance - Cash-out - Other Primary No B B B B
an application date of 05/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2007.
625489647 XXX XXX XXX 35079872 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2007 NY Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488321 XXX XXX XXX 35079873 compliance 3 Missing Final HUD-1: HUD-1 Not Signed or Stamped Used For Fee Testing Missing Final HUD-1: HUD-1 Not Signed or Stamped used for any applicable Truth in Lending Act (HOEPA): APR of XX.XX% does not exceed a threshold of Yes 7/XX/2007 CA Refinance - Rate/Term Primary No D D D D
Federal, State or Local compliance testing. 12.88000% based on the US Treasury for comparable maturities of 4.88000% plus
jurisdiction allowable margin of 8.00000%.
625488321 XXX XXX XXX 35079874 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 7/XX/2007 7/XX/2008 CA Refinance - Rate/Term Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488321 XXX XXX XXX 35079875 credit 3 Missing Document: Missing Final 1003 Yes 7/XX/2007 CA Refinance - Rate/Term Primary No C C C C
625488321 XXX XXX XXX 35079876 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using Yes 7/XX/2007 CA Refinance - Rate/Term Primary No B B B B
an application date of 06/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2007.
625488321 XXX XXX XXX 35079877 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions Yes 7/XX/2007 CA Refinance - Rate/Term Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488321 XXX XXX XXX 35079878 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 7/XX/2007 7/XX/2008 CA Refinance - Rate/Term Primary No B B B B
Loan Application Date.
625488669 XXX XXX XXX 35079891 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 12/XX/2007 KY Purchase Primary Yes B B B B
an application date of 11/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2007.
625488669 XXX XXX XXX 35079892 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 12/XX/2007 KY Purchase Primary Yes C C C C
625488931 XXX XXX XXX 35079896 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 12/XX/2006 12/XX/2007 NJ Purchase Primary Yes B B B B
defense to foreclosure. Assignee liability.
625488931 XXX XXX XXX 35079897 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 12/XX/2006 NJ Purchase Primary Yes B B B B
625488351 XXX XXX XXX 35079917 credit 3 Missing Document: Missing Final 1003 9/XX/2007 NC Purchase Primary No C C C C
625488351 XXX XXX XXX 35079918 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2007 9/XX/2008 NC Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625488351 XXX XXX XXX 35079919 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 9/XX/2007 NC Purchase Primary No B B B B
625488440 XXX XXX XXX 35079921 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 12/XX/2005 OK Purchase Primary No B B B B
625488440 XXX XXX XXX 35079922 compliance 2 Final TIL APR Under/Over Disclosed By Greater Than 0.125% Truth In Lending Act: Final TIL APR of XX.XX% is underdisclosed from calculated Unable to determine under disclosure due to missing itemization of amount TILA APR - subject to a 1 year SOL for affirmative claims, 3 years for 12/XX/2005 12/XX/2006 OK Purchase Primary No B B B B
APR of XX.XX% outside of 0.125% tolerance. financed. rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488440 XXX XXX XXX 35079923 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 12/XX/2005 12/XX/2006 OK Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488715 XXX XXX XXX 35079940 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2007 FL Refinance - Cash-out - Other Primary No B B B B
an application date of 01/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/2006.
625488584 XXX XXX XXX 35080055 credit 3 Missing Document: Missing Final 1003 6/XX/2007 MD Refinance - Rate/Term Primary No C C C C
625488584 XXX XXX XXX 35080056 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2007 MD Refinance - Rate/Term Primary No B B B B
an application date of 05/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 05/XX/2007.
625488584 XXX XXX XXX 35080057 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 MD Refinance - Rate/Term Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488584 XXX XXX XXX 35080058 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2007 6/XX/2010 MD Refinance - Rate/Term Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625488584 XXX XXX XXX 35080059 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 MD Refinance - Rate/Term Primary No B B B B
Loan Application Date.
625488296 XXX XXX XXX 35080067 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 4/XX/2007 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488027 XXX XXX XXX 35080076 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 8/XX/2007 NC Purchase Primary No B B B B
625488027 XXX XXX XXX 35080077 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2007 8/XX/2008 NC Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625488027 XXX XXX XXX 35080078 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2007 8/XX/2008 NC Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625488978 XXX XXX XXX 35080095 credit 3 Missing Document: Missing Final 1003 3/XX/2005 KS Refinance - Cash-out - Other Primary No C C C C
625488978 XXX XXX XXX 35080096 compliance 2 TILA HELOC - HELOC Brochure Missing Truth in Lending Act (HELOC): HELOC Brochure not provided to borrower. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2005 3/XX/2008 KS Refinance - Cash-out - Other Primary No B B B B
defense to foreclosure. Assignee liability.
625488978 XXX XXX XXX 35080097 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2005 KS Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488978 XXX XXX XXX 35080098 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 3/XX/2005 KS Refinance - Cash-out - Other Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488978 XXX XXX XXX 35080099 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 3/XX/2005 KS Refinance - Cash-out - Other Primary No B B B B
Security Instrument Notary Date of 03/XX/2005 used as disbursement date for
compliance testing.
625488978 XXX XXX XXX 35080100 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2005 KS Refinance - Cash-out - Other Primary No B B B B
an application date of 02/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 09/XX/2004.
625488978 XXX XXX XXX 35080101 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 03/XX/2005, prior to TILA ROR - 3yrs for rescindable transactions. 3/XX/2005 3/XX/2008 KS Refinance - Cash-out - Other Primary No B B B B
Date three (3) business days from transaction date of 03/XX/2005.
625488950 XXX XXX XXX 35080151 compliance 1 (Missing Doc) Incomplete loan images/file File is missing all origination documents. 10/XX/1998 SC Refinance - Cash-out - Other Primary No A A A A 10/XX/2017 Yes 2017/XX/12: Received complete loan package. Exception cleared.
625488950 XXX XXX XXX 35080152 credit 3 Missing Document: Missing Final 1003 10/XX/1998 SC Refinance - Cash-out - Other Primary No C C C C
625488950 XXX XXX XXX 35080153 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/1998 SC Refinance - Cash-out - Other Primary No B B B B
an application date of 09/XX/1998 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/1998.
625488950 XXX XXX XXX 35080154 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/1998 10/XX/1999 SC Refinance - Cash-out - Other Primary No B B B B
borrower.
625488950 XXX XXX XXX 35080155 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/1998 10/XX/1999 SC Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488950 XXX XXX XXX 35080156 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Lender did not include the $XXX attorney fee as a prepaid finance charge. $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 10/XX/1998 10/XX/2001 SC Refinance - Cash-out - Other Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488950 XXX XXX XXX 35080157 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 10/XX/1998 10/XX/2001 SC Refinance - Cash-out - Other Primary No B B B B
625488950 XXX XXX XXX 35080158 compliance 2 (Doc Error) Initial GFE not provided 10/XX/1998 SC Refinance - Cash-out - Other Primary No B B B B
625489059 XXX XXX XXX 35080173 compliance 2 Initial TIL not provided 7/XX/2001 7/XX/2002 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489184 XXX XXX XXX 35080213 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2007 5/XX/2010 FL Refinance - Cash-out - Other Primary No B B B B
defense to foreclosure. Assignee liability.
625489184 XXX XXX XXX 35080214 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2007 FL Refinance - Cash-out - Other Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489184 XXX XXX XXX 35080215 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 5/XX/2007 FL Refinance - Cash-out - Other Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489184 XXX XXX XXX 35080216 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2007 5/XX/2010 FL Refinance - Cash-out - Other Primary No B B B B
defense to foreclosure. Assignee liability.
625488443 XXX XXX XXX 35080217 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 7/XX/2007 RI Refinance - Cash-out - Other Primary No B B B B
625488443 XXX XXX XXX 35080218 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2007 RI Refinance - Cash-out - Other Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488443 XXX XXX XXX 35080219 compliance 3 Rhode Island Home Loan (Prohibited Acts and Practices Regarding High-Cost Home Rhode Island Home Loan: Prohibited Acts and Practices Regarding High-Cost Home A court, as injunctive relieve to an aggrieved consumer, may issue an order or 7/XX/2007 RI Refinance - Cash-out - Other Primary No C C C C
Loans Disclosure Not Provided) Loans disclosure not provided. injunction barring any judicial or non-judicial foreclosure or other lender
action under the mortgage or deed of trust securing any home mortgage loan which
violates this chapter (RI Stat 34-25.2-8)
625488443 XXX XXX XXX 35080221 compliance 3 Rhode Island Home Loan (Prohibited Acts and Practices Regarding Home Loans Rhode Island Home Loan: Prohibited Acts and Practices Regarding Home Loans A court, as injunctive relieve to an aggrieved consumer, may issue an order or 7/XX/2007 RI Refinance - Cash-out - Other Primary No C C C C
Disclosure Not Provided) disclosure not provided. injunction barring any judicial or non-judicial foreclosure or other lender
action under the mortgage or deed of trust securing any home mortgage loan which
violates this chapter (RI Stat 34-25.2-8)
625488443 XXX XXX XXX 35080222 compliance 3 Rhode Island Home Loan (Tangible Net Benefit Disclosure Not Provided) Rhode Island Home Loan: Tangible Net Benefit Disclosure not provided to borrower A court, as injunctive relieve to an aggrieved consumer, may issue an order or 7/XX/2007 RI Refinance - Cash-out - Other Primary No C C C C
for refinance within 60 months. injunction barring any judicial or non-judicial foreclosure or other lender
action under the mortgage or deed of trust securing any home mortgage loan which
violates this chapter (RI Stat 34-25.2-8)
625488443 XXX XXX XXX 35080223 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2007 7/XX/2010 RI Refinance - Cash-out - Other Primary No B B B B
defense to foreclosure. Assignee liability.
625488443 XXX XXX XXX 35080224 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2007 7/XX/2010 RI Refinance - Cash-out - Other Primary No B B B B
defense to foreclosure. Assignee liability.
625488443 XXX XXX XXX 35080225 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine the reason for under-disclosure. There was no itemization of $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 7/XX/2007 7/XX/2010 RI Refinance - Cash-out - Other Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. amount financed provided with the documentation. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488089 XXX XXX XXX 35080251 credit 3 Missing Document: Missing Final 1003 3/XX/2006 FL Purchase Primary No C C C C
625488089 XXX XXX XXX 35080252 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2006 3/XX/2007 FL Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488089 XXX XXX XXX 35080253 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2006 FL Purchase Primary No B B B B
an application date of 02/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2006.
625488089 XXX XXX XXX 35080254 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2006 3/XX/2007 FL Purchase Primary No B B B B
Loan Application Date.
625488207 XXX XXX XXX 35080271 credit 3 Missing Document: Missing Final 1003 6/XX/1999 FL Purchase Second Home No C C C C
625489678 XXX XXX XXX 35080278 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2007 MD Refinance - Rate/Term Primary No B B B B
an application date of 10/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 05/XX/2007.
625489678 XXX XXX XXX 35080279 credit 3 Missing Document: Missing Final 1003 11/XX/2007 MD Refinance - Rate/Term Primary No C C C C
625489641 XXX XXX XXX 35080280 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 12/XX/2006 TX Purchase Primary No B B B B
an application date of 11/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2006.
625489552 XXX XXX XXX 35080311 credit 3 Missing Document: Missing Final 1003 11/XX/2003 IN Purchase Primary No C C C C
625489552 XXX XXX XXX 35080312 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2003 11/XX/2004 IN Purchase Primary No B B B B
borrower.
625489552 XXX XXX XXX 35080313 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2003 11/XX/2004 IN Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489552 XXX XXX XXX 35080314 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2003 11/XX/2004 IN Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625489552 XXX XXX XXX 35080315 credit 1 Title: Evidence of title is missing 11/XX/2003 IN Purchase Primary No A A A A 11/XX/2017 Yes 2017/XX/29: Final title policy provided, exception has been cleared.
625489552 XXX XXX XXX 35080316 compliance 2 (Doc Error) Initial GFE not provided 11/XX/2003 IN Purchase Primary No B B B B
625489552 XXX XXX XXX 35080317 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 11/XX/2003 IN Purchase Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489552 XXX XXX XXX 35080318 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2003 IN Purchase Primary No B B B B
an application date of 10/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 05/XX/2003.
625488860 XXX XXX XXX 35080351 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 12/XX/2010 CT Refinance - Rate/Term Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488860 XXX XXX XXX 35080352 compliance 2 (Doc Error) Initial GFE not provided 12/XX/2010 CT Refinance - Rate/Term Primary No B B B B
625488860 XXX XXX XXX 35080353 compliance 2 RESPA - Initial Escrow Account Statement Missing RESPA: Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2010 CT Refinance - Rate/Term Primary No B B B B
within the statute or implementing regulation, Regulation X, for these type of
violations.
625488860 XXX XXX XXX 35080354 compliance 2 RESPA Servicing Disclosure: Servicing Disclosure Statement Missing RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2010 CT Refinance - Rate/Term Primary No B B B B
Statement. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488860 XXX XXX XXX 35080355 compliance 2 RESPA - Initial GFE Missing RESPA: Initial GFE not provided to Borrower(s). RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2010 CT Refinance - Rate/Term Primary No B B B B
within the statute or implementing regulation, Regulation X, for these type of
violations.
625488860 XXX XXX XXX 35080356 compliance 2 TIL-MDIA - Initial TIL Missing Truth in Lending Act (Early TIL Disclosure): Initial TIL was not provided to the TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited 12/XX/2010 12/XX/2011 CT Refinance - Rate/Term Primary No B B B B
borrower. as a defense to foreclosure. Assignee liability.
625488860 XXX XXX XXX 35080357 compliance 2 Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. 12/XX/2010 12/XX/2013 CT Refinance - Rate/Term Primary No B B B B
timing requirements.
625488860 XXX XXX XXX 35080358 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 12/XX/2010 12/XX/2013 CT Refinance - Rate/Term Primary No B B B B
defense to foreclosure. Assignee liability.
625488428 XXX XXX XXX 35080366 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 04/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2005.
625488799 XXX XXX XXX 35080401 credit 1 Final Title Policy is missing. No evidence of title was found in file. 7/XX/2007 NJ Purchase Primary Yes A A A A 11/XX/2017 Yes 2017/XX/29: Final title policy provided, exception has been cleared.
625488799 XXX XXX XXX 35080402 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2007 NJ Purchase Primary Yes B B B B
an application date of 06/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2007.
625488799 XXX XXX XXX 35080403 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2007 NJ Purchase Primary Yes B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488515 XXX XXX XXX 35080411 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2004 CA Refinance - Cash-out - Other Investment No B B B B
an application date of 09/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2004.
625488225 XXX XXX XXX 35080455 compliance 2 (Doc Error) Initial GFE not provided 4/XX/2009 CA Refinance - Rate/Term Primary No B B B B
625488225 XXX XXX XXX 35080456 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 4/XX/2009 CA Refinance - Rate/Term Primary No B B B B
625488225 XXX XXX XXX 35080457 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2009 CA Refinance - Rate/Term Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488367 XXX XXX XXX 35080479 compliance 2 (Doc Error) Initial GFE not provided 8/XX/2006 NJ Refinance - Cash-out - Other Primary Yes B B B B
625488741 XXX XXX XXX 35080556 credit 3 Missing Document: Missing Final 1003 12/XX/2005 CA Refinance - Cash-out - Other Investment No C C C C
625488741 XXX XXX XXX 35080557 compliance 1 Missing Document: Missing Lender's Initial 1003 12/XX/2005 CA Refinance - Cash-out - Other Investment No A A A A 12/XX/2017 Yes 2017/XX/08: initial 1003 received
625488741 XXX XXX XXX 35080558 credit 3 Missing Document: Security Instrument - Subject Lien not provided 12/XX/2005 CA Refinance - Cash-out - Other Investment No D D D D
625488741 XXX XXX XXX 35080559 compliance 1 Missing Document: Note - Subject Lien not provided 12/XX/2005 CA Refinance - Cash-out - Other Investment No A A A A 12/XX/2017 Yes 2017/XX/08: note received
625488741 XXX XXX XXX 35080560 compliance 1 Missing Final HUD-1 12/XX/2005 CA Refinance - Cash-out - Other Investment No A A A A 12/XX/2017 Yes 2017/XX/08: HUD received
625488741 XXX XXX XXX 35080561 compliance 1 TILA - Final TIL Missing TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 12/XX/2005 12/XX/2006 CA Refinance - Cash-out - Other Investment No A A A A 12/XX/2017 Yes 2017/XX/08: TIL received
defense to foreclosure. Assignee liability.
625488741 XXX XXX XXX 35080562 compliance 1 (Missing Doc) Incomplete loan images/file File only contains post closing documentation. Unable to test. 12/XX/2005 CA Refinance - Cash-out - Other Investment No A A A A 12/XX/2017 Yes 2017/XX/08: trailing documentation received
625488741 XXX XXX XXX 35080563 compliance 2 FACTA Disclosure Missing Unable to determine FACTA Credit Score Disclosure was provided due to missing There is no Assignee Liability. 12/XX/2005 CA Refinance - Cash-out - Other Investment No B B B B
information.
625488741 XXX XXX XXX 35080564 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 12/XX/2005 CA Refinance - Cash-out - Other Investment No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488741 XXX XXX XXX 35080565 compliance 2 (Doc Error) Initial GFE not provided 12/XX/2005 CA Refinance - Cash-out - Other Investment No B B B B
625489090 XXX XXX XXX 35080623 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2006 NC Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 07/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2006.
625489090 XXX XXX XXX 35080624 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2006 NC Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488933 XXX XXX XXX 35080660 compliance 2 RESPA (2010) - 10% Tolerance Without Cure RESPA (2010): 10% tolerance violation without evidence of sufficient cure RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2010 WV Purchase Primary No B B B B
provided. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488933 XXX XXX XXX 35080661 compliance 2 RESPA (2010) - GFE Settlement charges Good Thru Date Less than 10 Days RESPA (2010): GFE does not provide minimum ten (10) business day availability RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2010 WV Purchase Primary No B B B B
for estimate of charges and terms for all other settlement charges. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488933 XXX XXX XXX 35080662 compliance 2 RESPA Disclosure - HUD Settlement Cost Booklet Missing RESPA Disclosure Rule: Creditor did not provide HUD Settlement Cost Booklet. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2010 WV Purchase Primary No B B B B
within the statute or implementing regulation, Regulation X, for these type of
violations.
625488933 XXX XXX XXX 35080663 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 8/XX/2010 8/XX/2011 WV Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488933 XXX XXX XXX 35080664 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2010 8/XX/2011 WV Purchase Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625489477 XXX XXX XXX 35080680 compliance 2 RESPA (2010) - GFE Settlement charges Good Thru Date Less than 10 Days RESPA (2010): GFE does not provide minimum ten (10) business day availability RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2011 MD Refinance - Cash-out - Other Primary No B B B B
for estimate of charges and terms for all other settlement charges. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489477 XXX XXX XXX 35080681 compliance 2 Maryland Counseling Disclosure Not In File Maryland HB1399 - No evidence of counseling disclosure per Maryland HB 1399. HB 1399 does not contain express provisions for assignee liability. 8/XX/2011 MD Refinance - Cash-out - Other Primary No B B B B
625489477 XXX XXX XXX 35080682 compliance 2 Maryland Mortgage Lending Regulations (Tangible Net Benefit Worksheet Not Maryland Mortgage Lending Regulations: Net Tangible Benefit Worksheet not Assignee liability is unclear. 8/XX/2011 MD Refinance - Cash-out - Other Primary No B B B B
Provided) provided to borrower.
625489477 XXX XXX XXX 35080683 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - Maximum In First 5 Years Change Date Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" date on the TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2011 8/XX/2014 MD Refinance - Cash-out - Other Primary No B B B B
Inaccurate (ARM loan) Final TIL does not match the date on which the first regular periodic payment defense to foreclosure. Assignee liability.
will be due and the earliest date on which that rate may apply.
625489477 XXX XXX XXX 35080684 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - Maximum In First 5 Years Interest Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" interest rate TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2011 8/XX/2014 MD Refinance - Cash-out - Other Primary No B B B B
Rate Inaccurate on the Final TIL does not match the maximum interest rate that may apply during defense to foreclosure. Assignee liability.
the first five (5) years of the loan.
625489477 XXX XXX XXX 35080685 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - Maximum In First 5 Years P&I Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" P&I payment on TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2011 8/XX/2014 MD Refinance - Cash-out - Other Primary No B B B B
Inaccurate the Final TIL does not match the maximum principal and interest payment on the defense to foreclosure. Assignee liability.
loan during the first five (5) years of the loan.
625489477 XXX XXX XXX 35080686 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - Maximum In First 5 Years Total Truth in Lending Act (MDIA 2011): The "Maximum First Five Years" total payment TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2011 8/XX/2014 MD Refinance - Cash-out - Other Primary No B B B B
Payment (PITI) Inaccurate amount (PITI) on the Final TIL does not match the maximum total payment on the defense to foreclosure. Assignee liability.
loan during the first five (5) years for the loan.
625489477 XXX XXX XXX 35080687 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - Maximum Ever Change Date Inaccurate Truth in Lending Act (MDIA 2011): The "Maximum Ever" date on the Final TIL does TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2011 8/XX/2014 MD Refinance - Cash-out - Other Primary No B B B B
not match the earliest date on which the maximum rate may apply. defense to foreclosure. Assignee liability.
625489477 XXX XXX XXX 35080688 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2011 8/XX/2012 MD Refinance - Cash-out - Other Primary No B B B B
borrower.
625489477 XXX XXX XXX 35080689 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2011 8/XX/2012 MD Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489477 XXX XXX XXX 35080690 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 8/XX/2011 8/XX/2014 MD Refinance - Cash-out - Other Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489477 XXX XXX XXX 35080691 compliance 2 RESPA - Initial Escrow Account Statement Missing Unable to determine if the initial escrow account statement is compliant based RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2011 MD Refinance - Cash-out - Other Primary No B B B B
on missing information. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488606 XXX XXX XXX 35080745 credit 3 Missing Document: Missing Final 1003 No 5/XX/2000 OH Purchase UTD No C C C C
625488606 XXX XXX XXX 35080746 credit 1 Title: Evidence of title is missing No 5/XX/2000 OH Purchase UTD No A A A A 11/XX/2017 Yes 2017/XX/29: Final title policy provided, exception has been cleared.
625488606 XXX XXX XXX 35080747 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off No 5/XX/2000 OH Purchase UTD No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488606 XXX XXX XXX 35080748 compliance 2 (Doc Error) Initial GFE not provided No 5/XX/2000 OH Purchase UTD No B B B B
625488606 XXX XXX XXX 35080749 compliance 2 Unable to determine occupancy, compliance results were generated using a No 5/XX/2000 OH Purchase UTD No B B B B
defaulted value of Primary.
625488606 XXX XXX XXX 35080750 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. No 5/XX/2000 OH Purchase UTD No B B B B
Security Instrument Notary Date of 05/XX/2000 used as disbursement date for
compliance testing.
625488606 XXX XXX XXX 35080751 compliance 3 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable No 5/XX/2000 OH Purchase UTD No D D D D
Federal, State or Local compliance testing is unreliable.
625488606 XXX XXX XXX 35080752 compliance 2 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using No 5/XX/2000 OH Purchase UTD No B B B B
an application date of 04/XX/2000 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/1999. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625488606 XXX XXX XXX 35080753 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA No 5/XX/2000 5/XX/2001 OH Purchase UTD No B B B B
borrower.
625488606 XXX XXX XXX 35080754 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA No 5/XX/2000 5/XX/2001 OH Purchase UTD No B B B B
CHARM Booklet, not provided to the borrower.
625488606 XXX XXX XXX 35080755 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a No 5/XX/2000 5/XX/2001 OH Purchase UTD No B B B B
defense to foreclosure. Assignee liability.
625488572 XXX XXX XXX 35080789 credit 3 Missing Document: Missing Final 1003 11/XX/2006 NY Refinance - Cash-out - Other Primary No C C C C
625488572 XXX XXX XXX 35080790 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 11/XX/2006 NY Refinance - Cash-out - Other Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488572 XXX XXX XXX 35080791 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 11/XX/2006 NY Refinance - Cash-out - Other Primary No B B B B
625488572 XXX XXX XXX 35080792 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2006 NY Refinance - Cash-out - Other Primary No B B B B
an application date of 10/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 05/XX/2006.
625488572 XXX XXX XXX 35080793 compliance 2 New York Late Charge Percent Testing Note late charge exceeds maximum per state. Late charge not permitted. 2% late charge maximum per state (NY) - Note states 11/XX/2006 NY Refinance - Cash-out - Other Primary No B B B B
5%.
625488572 XXX XXX XXX 35080794 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 11/XX/2006 11/XX/2009 NY Refinance - Cash-out - Other Primary No B B B B
625489338 XXX XXX XXX 35080817 credit 3 Missing Document: Missing Final 1003 1/XX/2007 VT Refinance - Cash-out - Other Primary No C C C C
625489338 XXX XXX XXX 35080818 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 1/XX/2007 1/XX/2010 VT Refinance - Cash-out - Other Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625489338 XXX XXX XXX 35080819 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 1/XX/2007 VT Refinance - Cash-out - Other Primary No B B B B
Security Instrument Notary Date of 01/XX/2007 used as disbursement date for
compliance testing.
625489338 XXX XXX XXX 35080820 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 01/XX/2007, prior to TILA ROR - 3yrs for rescindable transactions. 1/XX/2007 1/XX/2010 VT Refinance - Cash-out - Other Primary No B B B B
Date three (3) business days from transaction date of 01/XX/2007.
625488985 XXX XXX XXX 35080864 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2006 11/XX/2007 CA Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625488985 XXX XXX XXX 35080865 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 11/XX/2006 CA Purchase Primary No B B B B
625488985 XXX XXX XXX 35080866 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2006 11/XX/2007 CA Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625488119 XXX XXX XXX 35080873 credit 3 Missing Document: Missing Final 1003 5/XX/2007 MA Refinance - Rate/Term Second Home Yes C C C C
625488119 XXX XXX XXX 35080874 compliance 2 (Doc Error) Initial GFE not provided 5/XX/2007 MA Refinance - Rate/Term Second Home Yes B B B B
625488119 XXX XXX XXX 35080875 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure The FACTA was sent out on 05/XX/2007. 5/XX/2007 MA Refinance - Rate/Term Second Home Yes B B B B
within a reasonably practicable time after using credit score.
625488119 XXX XXX XXX 35080876 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2007 MA Refinance - Rate/Term Second Home Yes B B B B
an application date of 04/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2007.
625488119 XXX XXX XXX 35080877 compliance 2 Massachusetts Home Loan - Borrower's Interest Tangible Net Benefit Worksheet Not Massachusetts Home Loan: No evidence in loan file of document or worksheet The regulations do not clarify the enforcement provisions of Mass. Gen. L. c. 5/XX/2007 5/XX/2010 MA Refinance - Rate/Term Second Home Yes B B B B 2018/XX/06: If we have records to show loan in borrower's interest, ok 2018/XX/06: Final 1003 reflects consolidating a 1st & 2nd mortgage with payments
in File indicating how the lender determined that the home loan is in the borrower's 183. Accordingly, the consequences of a compliance failure remain unclear. In of $XXX and $XXX into a new 1st and 2nd with payments of $XXX and $XXX, however
interest. particular, it is probable that a violation of the "borrower's interest" comparing the information on the 1003 to the preliminary title and the credit
standard can be raised as a defense to, or otherwise impede, foreclosure. Also, report it appears that the payments listed on the 1003 for the Present expenses
it is possible that a violation of the "borrower's interest" standard would on the subject property are not the correct mortgages. The actual existing 1st
constitute a violation of the Massachusetts unfair and deceptive acts and and 2nd lien payments are $XXX and $XXX however unable to determine if the 1st
practices statute. lien $XXX payment is P&I only or if that amount includes monthly escrows. If
this is a P&I payment only, then monthly savings are $XXX, but if this amount is
the escrowed payment then we cannot determine what, if any, payment reduction
there is without additional documentation showing the P&I payment.
Original credit report shows no reduction in loan term, and unable to determine
if refinancing out of an IO, ARM, or balloon loan or if refinance is reducing
the interest rate which would also be considered a benefit.
There is a Statement of Borrower's Benefits listing a number of possible
benefits, however none of the options have been checked to indicate that they
apply and the borrower signature/date is blank.
Unclear if a TNB existed based on documentation available.
Rescindable transaction so 3 year SOL expired on this 05/XX/2010.
625488779 XXX XXX XXX 35080963 credit 3 Missing Document: Missing Final 1003 No 2/XX/2008 FL Purchase Primary No C C C C
625488779 XXX XXX XXX 35080964 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing Itemization of Amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years No 2/XX/2008 2/XX/2009 FL Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. Financed for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488779 XXX XXX XXX 35080965 compliance 3 Missing Final HUD-1: HUD-1 Not Signed or Stamped Used For Fee Testing Missing Final HUD-1: HUD-1 Not Signed or Stamped used for any applicable No 2/XX/2008 FL Purchase Primary No D D D D
Federal, State or Local compliance testing.
625488904 XXX XXX XXX 35080967 credit 3 Missing Document: Missing Final 1003 4/XX/2008 PA Refinance - Cash-out - Other Primary No C C C C
625488904 XXX XXX XXX 35080968 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 4/XX/2008 PA Refinance - Cash-out - Other Primary No B B B B
following clauses:
625488904 XXX XXX XXX 35080969 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure Audit verified information per FACTA form in file. 4/XX/2008 PA Refinance - Cash-out - Other Primary No B B B B
within a reasonably practicable time after using credit score.
625488904 XXX XXX XXX 35080970 compliance 2 TILA HELOC - HELOC Brochure Not Provided Timely Unable to determine compliance with timing requirements due to missing Initial TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 4/XX/2008 4/XX/2011 PA Refinance - Cash-out - Other Primary No B B B B
Loan Application Date. defense to foreclosure. Assignee liability.
625488904 XXX XXX XXX 35080971 compliance 2 TILA HELOC - Important Terms Disclosure Not Provided Timely Unable to determine compliance with timing requirements due to missing Initial TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 4/XX/2008 4/XX/2011 PA Refinance - Cash-out - Other Primary No B B B B
Loan Application Date. defense to foreclosure. Assignee liability.
625488904 XXX XXX XXX 35080972 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 4/XX/2008 PA Refinance - Cash-out - Other Primary No B B B B
Security Instrument Notary Date of 04/XX/2008 used as disbursement date for
compliance testing.
625488904 XXX XXX XXX 35080973 compliance 2 TILA - Incorrect Right To Cancel Form Used - G-5 Used on Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit 4/XX/2008 4/XX/2011 PA Refinance - Cash-out - Other Primary No B B B B
Model Form for a refinancing by the same creditor. The G-5 form was used, the courts, the continuing risk that the borrower may have an extended right to
G-7 frm should have been used. rescind (3 additional years) if a creditor uses the incorrect Model Form
remains.
625488904 XXX XXX XXX 35080974 compliance 2 TILA HELOC - Billing Rights Disclosure Not Provided Timely Truth in Lending Act (HELOC): "Billing Rights" disclosure not provided to TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 4/XX/2008 4/XX/2011 PA Refinance - Cash-out - Other Primary No B B B B
borrower at time of account opening. defense to foreclosure. Assignee liability.
625488904 XXX XXX XXX 35080975 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2008 PA Refinance - Cash-out - Other Primary No B B B B
an application date of 03/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2007.
625488904 XXX XXX XXX 35080976 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 04/XX/2008, prior to TILA ROR - 3yrs for rescindable transactions. 4/XX/2008 4/XX/2011 PA Refinance - Cash-out - Other Primary No B B B B
Date three (3) business days from transaction date of 04/XX/2008.
625488151 XXX XXX XXX 35080982 credit 3 Missing Document: Missing Final 1003 2/XX/2002 TX Refinance - Rate/Term Primary No C C C C
625488151 XXX XXX XXX 35080983 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2002 TX Refinance - Rate/Term Primary No B B B B
an application date of 01/XX/2002 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/2001.
625488151 XXX XXX XXX 35080984 compliance 2 Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. 2/XX/2002 2/XX/2005 TX Refinance - Rate/Term Primary No B B B B
timing requirements.
625488151 XXX XXX XXX 35080985 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 2/XX/2002 2/XX/2005 TX Refinance - Rate/Term Primary No B B B B
defense to foreclosure. Assignee liability.
625488349 XXX XXX XXX 35080986 credit 3 Missing Document: Missing Final 1003 9/XX/2006 TN Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488349 XXX XXX XXX 35080987 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2006 9/XX/2009 TN Refinance - Cash-out - Debt Consolidation Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625488349 XXX XXX XXX 35080988 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2006 TN Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 08/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2006.
625488376 XXX XXX XXX 35081012 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2006 NC Purchase Primary No B B B B
an application date of 04/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2005.
625488376 XXX XXX XXX 35081013 compliance 2 North Carolina First Lien Late Charge Percent Testing Note late charge exceeds maximum per state. 5% late charge exceeds 4% maximum per state (NC) 5/XX/2006 NC Purchase Primary No B B B B
625488376 XXX XXX XXX 35081014 compliance 2 (Doc Error) Initial GFE not provided 5/XX/2006 NC Purchase Primary No B B B B
625489616 XXX XXX XXX 35081033 credit 3 Missing Document: Missing Final 1003 2/XX/2008 GA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489616 XXX XXX XXX 35081034 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 2/XX/2008 GA Refinance - Cash-out - Debt Consolidation Primary No B B B B
following clauses:
625489616 XXX XXX XXX 35081035 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 2/XX/2008 GA Refinance - Cash-out - Debt Consolidation Primary No B B B B
within a reasonably practicable time after using credit score.
625489616 XXX XXX XXX 35081036 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2008 GA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489616 XXX XXX XXX 35081037 compliance 2 Right of Rescission Timing - Note Date used as Transaction Date Unable to conclusively determine date of consummation. Note date used as 2/XX/2008 GA Refinance - Cash-out - Debt Consolidation Primary No B B B B
transaction date for purposes of determining compliance with rescission timing
requirements
625489616 XXX XXX XXX 35081038 compliance 2 Georgia Home Loan (Arbitration Clause) Georgia Home Loan: Mortgage loan contains an unfair or oppressive arbitration Assignee Liability: Purchasers and assignees of high cost home loans are subject 2/XX/2008 3/XX/2013 GA Refinance - Cash-out - Debt Consolidation Primary No B B B B 2018/XX/06: Does arbitration clause void whole mortgage? If it can be severed, 2018/XX/06: Whole mortgage is not void but arbitration clause is deemed
clause. to all affirmative claims and any defenses the borrower could assert against the ok. unconscionable and void. SOL for GAFLA home loan violations outside of blackout
original creditor or home improvement contractor where a home loan was made, period is 5 years from first payment date.
arranged or assigned by the home improvement contractor. However, the foregoing
does not apply to loans other than high cost home loans unless applicable law
requires a certificate of occupancy, inspection or completion to be obtained and
said certificate is not obtained. The statute provides for damages which may
include: (i) actual damages; (ii) statutory damages equal to the recovery of
twice the interest paid and forfeiture of interest for any violation relating to
the financing of insurance or recommendation of default, loan flipping or any of
the high cost prohibited terms and practices; (iii) punitive damages; (iv) costs
and attorneys' fees; (v) injunctive, declaratory and other equitable relief;
(vi) rescission for violations of the flipping, insurance, and encouragement of
default provisions as well as the high cost home loan provisions; (vii)
administrative penalties; and (viii) criminal penalties.
625488047 XXX XXX XXX 35081042 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2004 IN Refinance - Cash-out - Other Primary No B B B B
an application date of 08/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2004.
625488047 XXX XXX XXX 35081043 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2004 IN Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488549 XXX XXX XXX 35081047 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2003 NY Refinance - Cash-out - Other Primary No B B B B
an application date of 09/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2003.
625488549 XXX XXX XXX 35081048 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization did not disclose a commitment fee of $XXX a flood cert fee of $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 10/XX/2003 10/XX/2006 NY Refinance - Cash-out - Other Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. $XXX or a disbursement fee of $XXX and underdisclosed the settlement fee by $XXX for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
as prepaid finance charges liability.
625488549 XXX XXX XXX 35081049 compliance 2 (Doc Error) Initial GFE not provided 10/XX/2003 NY Refinance - Cash-out - Other Primary No B B B B
625489222 XXX XXX XXX 35081104 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2006 GA Purchase Primary No B B B B
an application date of 07/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 07/XX/2006.
625489222 XXX XXX XXX 35081105 compliance 2 ARM Disclosure Compliant TIL variable rate disclosure: ARM loan program disclosure does not match terms TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2006 8/XX/2007 GA Purchase Primary No B B B B
of loan.
625489222 XXX XXX XXX 35081106 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2006 8/XX/2007 GA Purchase Primary No B B B B
Loan Application Date.
625489222 XXX XXX XXX 35081107 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2006 8/XX/2007 GA Purchase Primary No B B B B
Loan Application Date.
625489222 XXX XXX XXX 35081108 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization did not disclose an aattorney fee of $XXX or a post closing fee $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 8/XX/2006 8/XX/2007 GA Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. of $XXX as prepaid finance charges for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489201 XXX XXX XXX 35081129 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2008 DE Refinance - Cash-out - Other Primary No B B B B
an application date of 03/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2007.
625489201 XXX XXX XXX 35081130 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2008 DE Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625487978 XXX XXX XXX 35081166 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2007 DE Refinance - Cash-out - Other Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625487978 XXX XXX XXX 35081167 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 03/XX/2007, prior to TILA ROR - 3yrs for rescindable transactions. 3/XX/2007 3/XX/2010 DE Refinance - Cash-out - Other Primary No B B B B
Date three (3) business days from transaction date of 03/XX/2007.
625488112 XXX XXX XXX 35081176 credit 3 Missing Document: Missing Final 1003 5/XX/2004 AZ Purchase Primary No C C C C
625488112 XXX XXX XXX 35081177 credit 1 Final Title Policy is missing. No evidence of title was found in file. 5/XX/2004 AZ Purchase Primary No A A A A 3/XX/2018 Yes 2018/XX/02: Upon further review, exception has been cleared.
625489679 XXX XXX XXX 35081245 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2003 12/XX/2004 OR Refinance - Cash-out - Other Primary No B B B B
borrower within three (3) days of application.
625489679 XXX XXX XXX 35081246 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2003 12/XX/2004 OR Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489557 XXX XXX XXX 35081260 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2006 TN Refinance - Cash-out - Other Primary No B B B B
an application date of 04/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2005.
625489557 XXX XXX XXX 35081261 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2006 5/XX/2007 TN Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488795 XXX XXX XXX 35081296 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2006 TX Purchase Primary No B B B B
an application date of 04/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2006.
625488600 XXX XXX XXX 35081336 credit 3 Missing Document: FHA Case Number Assignment not provided 10/XX/2007 NY Refinance - Cash-out - Other Primary No C C C C
625488600 XXX XXX XXX 35081337 credit 3 Missing Document: FHA Mortgage Insurance Certificate not provided 10/XX/2007 NY Refinance - Cash-out - Other Primary No C C C C
625488600 XXX XXX XXX 35081338 compliance 2 FHA Case Number Assignment Date Missing FHA Case # Assignment Date missing. Creditor application date used as FHA case # 10/XX/2007 NY Refinance - Cash-out - Other Primary No B B B B
assignment date for purposes of any applicable compliance testing.
625488130 XXX XXX XXX 35081350 credit 3 Missing Document: Missing Final 1003 9/XX/2007 CT Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488130 XXX XXX XXX 35081351 compliance 2 Right of Rescission Timing - Note Date used as Transaction Date Unable to conclusively determine date of consummation. Note date used as 9/XX/2007 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B
transaction date for purposes of determining compliance with rescission timing
requirements
625487945 XXX XXX XXX 35081364 credit 3 Missing Document: Missing Final 1003 3/XX/2007 OH Purchase UTD No C C C C
625487945 XXX XXX XXX 35081365 compliance 2 Initial TIL not provided 3/XX/2007 3/XX/2008 OH Purchase UTD No B B B B
625487945 XXX XXX XXX 35081366 compliance 1 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 3/XX/2007 OH Purchase UTD No A A A A 3/XX/2018 Yes 2018/XX/19: Final HUD provided.
Security Instrument Notary Date of 03/XX/2007 used as disbursement date for
compliance testing.
625487945 XXX XXX XXX 35081367 compliance 1 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable 3/XX/2007 OH Purchase UTD No A A A A 3/XX/2018 Yes 2018/XX/19: Final HUD provided.
Federal, State or Local compliance testing is unreliable.
625487945 XXX XXX XXX 35081368 compliance 1 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using 3/XX/2007 OH Purchase UTD No A A A A 3/XX/2018 Yes 2018/XX/19: Final HUD provided.
an application date of 02/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 09/XX/2006. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625487945 XXX XXX XXX 35081369 compliance 2 Property Type Not Provided (Missing Data) Property Type. If property type is other than single family 3/XX/2007 OH Purchase UTD No B B B B
residence, state and federal testing may be impacted.
625487945 XXX XXX XXX 35081370 compliance 2 Ohio Consumer Sales Practices Act (Ability to Repay not Verified) Ohio Consumer Sales Practices Act: Borrower’s ability to repay not verified with 3/XX/2007 OH Purchase UTD No B B B B
reliable documentation.
625487945 XXX XXX XXX 35081371 compliance 2 Ohio Consumer Sales Practices Act (Acknowledgement of Receipt of Home Mortgage Ohio Consumer Sales Practices Act: Acknowledgement of Receipt of Home Mortgage The Consumer Sales Practices Act (CSPA) generally does not provide for assignee 3/XX/2007 OH Purchase UTD No B B B B
Loan Information Document Not Retained by Lender) Loan Information Document not retained by lender. liability. The Act provides that no claim or defense may be asserted under the
Act by the Attorney General or any consumer against a purchaser or assignee of a
mortgage loan for value for any action under the statute unless: (a) the
violation was committed by the purchaser or assignee; or (b) the assignee or
purchaser is affiliated by common control with the seller of the loan at the
time the loan was purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant
injunctions, and levy monetary fines. Additionally, the CSPA provides borrowers
with a private right of action. Therefore, it is possible that any action
commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law
as part of the private right of action, a court could reform the loan terms
which could impact purchasers. Therefore, if the seller cannot be compelled to
repurchase the loan, the assignee could face exposure.
625487945 XXX XXX XXX 35081372 compliance 2 Ohio Consumer Sales Practices Act (Closing Disclosure Not Provided) Ohio Consumer Sales Practices Act: Consumer did not receive the required Closing The Consumer Sales Practices Act (CSPA) generally does not provide for assignee 3/XX/2007 OH Purchase UTD No B B B B
Disclosure. liability. The Act provides that no claim or defense may be asserted under the
Act by the Attorney General or any consumer against a purchaser or assignee of a
mortgage loan for value for any action under the statute unless: (a) the
violation was committed by the purchaser or assignee; or (b) the assignee or
purchaser is affiliated by common control with the seller of the loan at the
time the loan was purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant
injunctions, and levy monetary fines. Additionally, the CSPA provides borrowers
with a private right of action. Therefore, it is possible that any action
commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law
as part of the private right of action, a court could reform the loan terms
which could impact purchasers. Therefore, if the seller cannot be compelled to
repurchase the loan, the assignee could face exposure.
625487945 XXX XXX XXX 35081373 compliance 1 Ohio CSPA Tangible Net Benefit Test Ohio Consumer Sales Practices Act: Unable to determine if mortgage loan 3/XX/2007 OH Purchase UTD No A A A A 3/XX/2018 Yes 2018/XX/19: Final HUD provided shows purchase.
refinanced has a tangible net benefit to the borrower due to missing prior loan
information.
625487945 XXX XXX XXX 35081374 compliance 1 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 3/XX/2007 3/XX/2008 OH Purchase UTD No A A A A 3/XX/2018 Yes 2018/XX/19: Final HUD provided shows purchase.
625487945 XXX XXX XXX 35081375 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2007 3/XX/2008 OH Purchase UTD No B B B B
defense to foreclosure. Assignee liability.
625487945 XXX XXX XXX 35081376 compliance 2 (Doc Error) Initial GFE not provided 3/XX/2007 OH Purchase UTD No B B B B
625487945 XXX XXX XXX 35081377 compliance 2 Unable to determine occupancy, compliance results were generated using a 3/XX/2007 OH Purchase UTD No B B B B
defaulted value of Primary.
625487945 XXX XXX XXX 35081378 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2007 OH Purchase UTD No B B B B
an application date of 02/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 09/XX/2006.
625489221 XXX XXX XXX 35081379 credit 3 Missing Document: Missing Final 1003 7/XX/2006 CA Refinance - Cash-out - Other Primary No C C C C
625489221 XXX XXX XXX 35081380 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2006 CA Refinance - Cash-out - Other Primary No B B B B
an application date of 06/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2006.
625489221 XXX XXX XXX 35081381 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 7/XX/2006 CA Refinance - Cash-out - Other Primary No B B B B
within a reasonably practicable time after using credit score.
625488254 XXX XXX XXX 35081400 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. Final HUD-1 does not reflect disbursement date. 3/XX/2008 WA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 03/XX/2008 used as disbursement date for
compliance testing.
625488254 XXX XXX XXX 35081401 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2008 WA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488254 XXX XXX XXX 35081402 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 03/XX/2008, prior to No disbursement date has been provided. TILA ROR - 3yrs for rescindable transactions. 3/XX/2008 3/XX/2011 WA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 03/XX/2008.
625488254 XXX XXX XXX 35081403 compliance 2 TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Truth in Lending Act: Actual Date(s) on Notice of Right to Cancel occurs prior TILA ROR - 3yrs for rescindable transactions. 3/XX/2008 3/XX/2011 WA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date to expected date(s).
625488254 XXX XXX XXX 35081404 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 3/XX/2008 WA Refinance - Cash-out - Debt Consolidation Primary No B B B B
following clauses:
625489145 XXX XXX XXX 35081427 compliance 2 (Doc Error) Initial GFE not provided 9/XX/2004 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
625489145 XXX XXX XXX 35081428 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2004 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
an application date of 08/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2004.
625489145 XXX XXX XXX 35081429 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2004 9/XX/2005 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
borrower.
625489145 XXX XXX XXX 35081430 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2004 9/XX/2005 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
CHARM Booklet, not provided to the borrower.
625489145 XXX XXX XXX 35081431 compliance 2 Right of Rescission Timing - Note Date used as Transaction Date Unable to conclusively determine date of consummation. Note date used as 9/XX/2004 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
transaction date for purposes of determining compliance with rescission timing
requirements
625489145 XXX XXX XXX 35081432 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine cause of underdisclosure of $XXX due to missing Itemization $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 9/XX/2004 9/XX/2007 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
calculated Finance Charge of $XXX in the amount of $XXX. of amount financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489145 XXX XXX XXX 35081433 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 9/XX/2004 9/XX/2007 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
625488754 XXX XXX XXX 35081460 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2006 MD Refinance - Cash-out - Other Primary No B B B B
an application date of 06/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2006.
625488754 XXX XXX XXX 35081461 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2006 MD Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488680 XXX XXX XXX 35081491 credit 3 Missing Document: Missing Final 1003 11/XX/2006 CA Refinance - UTD Primary No C C C C
625488680 XXX XXX XXX 35081492 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 11/XX/2006 CA Refinance - UTD Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488680 XXX XXX XXX 35081493 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 11/XX/2006 CA Refinance - UTD Primary No B B B B
625488680 XXX XXX XXX 35081494 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 11/XX/2006 CA Refinance - UTD Primary No B B B B
Security Instrument Notary Date of 11/XX/2006 used as disbursement date for
compliance testing.
625488680 XXX XXX XXX 35081495 compliance 1 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable 11/XX/2006 CA Refinance - UTD Primary No A A A A 3/XX/2018 Yes 2018/XX/20: Received FinalHUD-1
Federal, State or Local compliance testing is unreliable.
625488680 XXX XXX XXX 35081496 compliance 1 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using 11/XX/2006 CA Refinance - UTD Primary No A A A A 3/XX/2018 Yes 2018/XX/20: Received FinalHUD-1
an application date of 10/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 05/XX/2006. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625488680 XXX XXX XXX 35081497 compliance 1 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 11/XX/2006 11/XX/2009 CA Refinance - UTD Primary No A A A A 3/XX/2018 Yes 2018/XX/20: Received Notice of Right to Cancel
625488680 XXX XXX XXX 35081498 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2006 11/XX/2009 CA Refinance - UTD Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625488680 XXX XXX XXX 35081499 compliance 2 (Doc Error) Initial GFE not provided 11/XX/2006 CA Refinance - UTD Primary No B B B B
625488680 XXX XXX XXX 35081500 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2006 CA Refinance - UTD Primary No B B B B
an application date of 10/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 05/XX/2006.
625488680 XXX XXX XXX 35081501 compliance 2 (Missing Data) Unable to determine if loan is a same lender refi Original Lender was not able to be determined. Unable to determine if correct 11/XX/2006 11/XX/2009 CA Refinance - UTD Primary No B B B B
TILA rescission form was used.
625488680 XXX XXX XXX 35081502 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 11/XX/2006, prior to TILA ROR - 3yrs for rescindable transactions. 11/XX/2006 11/XX/2009 CA Refinance - UTD Primary No B B B B
Date three (3) business days from transaction date of 11/XX/2006.
625488680 XXX XXX XXX 35081503 compliance 2 Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance Truth in Lending Act: Unable to determine if Notice of Right to Cancel was TILA ROR Form - Because this issue is not uniformly settled among the circuit 11/XX/2006 11/XX/2009 CA Refinance - UTD Primary No B B B B
executed on the proper Model Form. The H-9 form was used instead of the H-8 courts, the continuing risk that the borrower may have an extended right to
form, however, the loan file does not contain evidence that the refinance was by rescind (3 additional years) if a creditor uses the incorrect Model Form
the original creditor. remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625489397 XXX XXX XXX 35081540 compliance 2 (Doc Error) Initial GFE not provided 8/XX/2012 FL Refinance - Rate/Term Primary No B B B B
625489397 XXX XXX XXX 35081541 compliance 2 RESPA (2010) - Loan Amount on Final HUD-1 Inaccurate RESPA (2010): Loan Amount on Final HUD-1 does not match Note. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2012 FL Refinance - Rate/Term Primary No B B B B
within the statute or implementing regulation, Regulation X, for these type of
violations.
625489397 XXX XXX XXX 35081542 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2012 FL Refinance - Rate/Term Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489397 XXX XXX XXX 35081543 compliance 2 RESPA Servicing Disclosure: Servicing Disclosure Statement Missing RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2012 FL Refinance - Rate/Term Primary No B B B B
Statement. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489397 XXX XXX XXX 35081544 compliance 2 RESPA - Initial GFE Missing RESPA: Initial GFE not provided to Borrower(s). RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2012 FL Refinance - Rate/Term Primary No B B B B
within the statute or implementing regulation, Regulation X, for these type of
violations.
625489397 XXX XXX XXX 35081545 compliance 2 TIL-MDIA - Initial TIL Missing Truth in Lending Act (Early TIL Disclosure): Initial TIL was not provided to the TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited 8/XX/2012 8/XX/2013 FL Refinance - Rate/Term Primary No B B B B
borrower. as a defense to foreclosure. Assignee liability.
625489397 XXX XXX XXX 35081546 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine the fee under disclosure due to missing the itemization of $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 8/XX/2012 8/XX/2015 FL Refinance - Rate/Term Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. amount financed.Lender credit on page 1 of HUD in the amount of $XXX could not for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
be applied due to missing itemization of credit. liability.
625489397 XXX XXX XXX 35081547 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 8/XX/2012 FL Refinance - Rate/Term Primary No B B B B
625489388 XXX XXX XXX 35081566 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 9/XX/2006 GA Purchase Primary No B B B B
625489388 XXX XXX XXX 35081567 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2006 GA Purchase Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489388 XXX XXX XXX 35081568 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2006 9/XX/2007 GA Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625489388 XXX XXX XXX 35081569 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2006 9/XX/2007 GA Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625489321 XXX XXX XXX 35081627 credit 3 Missing Document: Missing Final 1003 10/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489321 XXX XXX XXX 35081628 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 10/XX/2006 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2006.
625489321 XXX XXX XXX 35081629 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2006 10/XX/2007 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
Loan Application Date.
625489321 XXX XXX XXX 35081630 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2006 10/XX/2007 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
Loan Application Date.
625488827 XXX XXX XXX 35081653 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2004 FL Purchase Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489123 XXX XXX XXX 35081657 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2006 FL Refinance - Rate/Term Primary No B B B B
an application date of 03/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2006.
625489123 XXX XXX XXX 35081658 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 4/XX/2006 FL Refinance - Rate/Term Primary No B B B B
625489448 XXX XXX XXX 35081677 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 4/XX/2006 TX Refinance - Rate/Term Primary No B B B B
625489448 XXX XXX XXX 35081678 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2006 TX Refinance - Rate/Term Primary No B B B B
an application date of 03/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2005.
625489448 XXX XXX XXX 35081679 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2006 TX Refinance - Rate/Term Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489448 XXX XXX XXX 35081680 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 4/XX/2006 4/XX/2009 TX Refinance - Rate/Term Primary No B B B B
625489108 XXX XXX XXX 35081703 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization did not disclose a title pick-up fee of $XXX as a prepaid $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 1/XX/2006 1/XX/2009 NY Refinance - Rate/Term Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. finance charge. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489108 XXX XXX XXX 35081704 credit 3 Missing Document: Missing Final 1003 1/XX/2006 NY Refinance - Rate/Term Primary No C C C C
625489108 XXX XXX XXX 35081705 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 1/XX/2006 NY Refinance - Rate/Term Primary No B B B B
an application date of 12/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/2005.
625489108 XXX XXX XXX 35081706 compliance 2 (Doc Error) Initial GFE not provided 1/XX/2006 NY Refinance - Rate/Term Primary No B B B B
625489578 XXX XXX XXX 35081742 credit 3 Missing Document: Missing Final 1003 10/XX/2003 NJ Purchase Primary No C C C C
625489578 XXX XXX XXX 35081743 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2003 NJ Purchase Primary No B B B B
an application date of 09/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 09/XX/2003.
625489578 XXX XXX XXX 35081744 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2003 NJ Purchase Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489578 XXX XXX XXX 35081745 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2003 10/XX/2004 NJ Purchase Primary No B B B B
Loan Application Date.
625489578 XXX XXX XXX 35081746 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2003 10/XX/2004 NJ Purchase Primary No B B B B
Loan Application Date.
625489578 XXX XXX XXX 35081747 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization did not disclose a courier fee of $XXX a wire fee of $XXX an $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 10/XX/2003 10/XX/2004 NJ Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. attorney fee of $XXX and a notice of settlement fee of $XXX as prepaid finance for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
charges. However, the itemization did reflect a $XXX broker application fee and liability.
a $XXX satisfaction fee not included on the final HUD. All causing an under
disclosure of $XXX.
625488213 XXX XXX XXX 35081750 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2004 1/XX/2005 PA Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488213 XXX XXX XXX 35081751 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 1/XX/2004 PA Purchase Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488213 XXX XXX XXX 35081752 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2004 1/XX/2005 PA Purchase Primary No B B B B
borrower within three (3) days of application.
625488213 XXX XXX XXX 35081753 credit 3 Missing Document: Missing Final 1003 1/XX/2004 PA Purchase Primary No C C C C
625488101 XXX XXX XXX 35081782 credit 3 Missing Document: Missing Final 1003 8/XX/2003 MA Refinance - Rate/Term Primary No C C C C
625488101 XXX XXX XXX 35081783 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2003 MA Refinance - Rate/Term Primary No B B B B
an application date of 07/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2003.
625488101 XXX XXX XXX 35081784 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2003 MA Refinance - Rate/Term Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625487919 XXX XXX XXX 35081792 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 7/XX/2006 NC Refinance - Cash-out - Other Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625487919 XXX XXX XXX 35081793 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 7/XX/2006 NC Refinance - Cash-out - Other Primary No B B B B
625487919 XXX XXX XXX 35081794 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2006 NC Refinance - Cash-out - Other Primary No B B B B
an application date of 06/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2006.
625487919 XXX XXX XXX 35081795 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2006 NC Refinance - Cash-out - Other Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625487919 XXX XXX XXX 35081796 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2006 NC Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625487919 XXX XXX XXX 35081797 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 7/XX/2006 7/XX/2009 NC Refinance - Cash-out - Other Primary No B B B B
625487919 XXX XXX XXX 35081798 credit 3 Missing Document: Missing Final 1003 7/XX/2006 NC Refinance - Cash-out - Other Primary No C C C C
625487919 XXX XXX XXX 35081799 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 7/XX/2006 NC Refinance - Cash-out - Other Primary No B B B B
Security Instrument Notary Date of 07/XX/2006 used as disbursement date for
compliance testing.
625487919 XXX XXX XXX 35081800 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2006 7/XX/2009 NC Refinance - Cash-out - Other Primary No B B B B
defense to foreclosure. Assignee liability.
625487919 XXX XXX XXX 35081801 credit 2 Final Title Policy is missing. No evidence of title was found in file. 7/XX/2006 NC Refinance - Cash-out - Other Primary No B B B B
625489461 XXX XXX XXX 35081901 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 5/XX/2007 CA Purchase Primary No B B B B
625489700 XXX XXX XXX 35081935 credit 3 Missing Document: Missing Final 1003 No 9/XX/2006 CA Purchase Primary No C C C C
625489700 XXX XXX XXX 35081936 compliance 3 Missing Final HUD-1: Estimated HUD-1 Used For Fee Testing Missing Final HUD-1: Estimated HUD-1 used for any applicable Federal, State or No 9/XX/2006 CA Purchase Primary No D D D D
Local compliance testing.
625489700 XXX XXX XXX 35081937 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using No 9/XX/2006 CA Purchase Primary No B B B B
an application date of 08/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/2006.
625489700 XXX XXX XXX 35081938 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA No 9/XX/2006 9/XX/2007 CA Purchase Primary No B B B B
borrower.
625489700 XXX XXX XXX 35081939 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA No 9/XX/2006 9/XX/2007 CA Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489700 XXX XXX XXX 35081940 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a No 9/XX/2006 9/XX/2007 CA Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625488150 XXX XXX XXX 35081981 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 6/XX/2003 IN Refinance - Rate/Term Primary No C C C C
625488150 XXX XXX XXX 35081982 credit 3 Missing Document: Missing Final 1003 6/XX/2003 IN Refinance - Rate/Term Primary No C C C C
625488150 XXX XXX XXX 35081983 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2003 IN Refinance - Rate/Term Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488150 XXX XXX XXX 35081984 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2003 6/XX/2006 IN Refinance - Rate/Term Primary No B B B B
defense to foreclosure. Assignee liability.
625489673 XXX XXX XXX 35082000 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2007 CA Refinance - Rate/Term Primary No B B B B
an application date of 04/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2006.
625488281 XXX XXX XXX 35082042 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 6/XX/2006 OK Purchase Primary No B B B B
625488281 XXX XXX XXX 35082043 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2006 6/XX/2007 OK Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625488808 XXX XXX XXX 35082081 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 2/XX/2004 PA Purchase Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488808 XXX XXX XXX 35082082 compliance 2 (Doc Error) Initial GFE not provided 2/XX/2004 PA Purchase Primary No B B B B
625488808 XXX XXX XXX 35082083 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2004 PA Purchase Primary No B B B B
an application date of 01/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/2003.
625488808 XXX XXX XXX 35082084 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 2/XX/2004 2/XX/2005 PA Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625488808 XXX XXX XXX 35082085 credit 3 Missing Document: Missing Final 1003 2/XX/2004 PA Purchase Primary No C C C C
625488808 XXX XXX XXX 35082086 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 2/XX/2004 PA Purchase Primary No C C C C
625488338 XXX XXX XXX 35082172 credit 3 Missing Document: Missing Final 1003 2/XX/2007 MN Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488338 XXX XXX XXX 35082173 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2007 MN Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 01/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2007.
625488338 XXX XXX XXX 35082174 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2007 2/XX/2008 MN Refinance - Cash-out - Debt Consolidation Primary No B B B B
Loan Application Date.
625488338 XXX XXX XXX 35082175 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2007 2/XX/2008 MN Refinance - Cash-out - Debt Consolidation Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488413 XXX XXX XXX 35082176 credit 3 Missing Document: Missing Final 1003 7/XX/2007 PA Refinance - Cash-out - Other Primary No C C C C
625488413 XXX XXX XXX 35082177 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2007 PA Refinance - Cash-out - Other Primary No B B B B
an application date of 06/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2007.
625489092 XXX XXX XXX 35082192 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 8/XX/2007 NY Purchase Primary No B B B B
625489092 XXX XXX XXX 35082193 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2007 NY Purchase Primary No B B B B
an application date of 07/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2007.
625489092 XXX XXX XXX 35082194 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2007 NY Purchase Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489092 XXX XXX XXX 35082195 compliance 2 New York Late Charge Percent Testing Note late charge exceeds maximum per state. 5% late charge exceeds 2% maximum per state (NY) 8/XX/2007 NY Purchase Primary No B B B B
625489092 XXX XXX XXX 35082196 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from The lender did not include the broker application fee of $XXX in the finance $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 8/XX/2007 8/XX/2008 NY Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. charge calculation. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489092 XXX XXX XXX 35082197 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 8/XX/2007 NY Purchase Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488885 XXX XXX XXX 35082234 compliance 2 (Doc Error) Initial GFE not provided 2/XX/1999 NY Purchase Primary No B B B B
625488226 XXX XXX XXX 35082273 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2006 9/XX/2007 AL Construction-Permanent Primary No B B B B
borrower.
625488226 XXX XXX XXX 35082274 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2006 9/XX/2007 AL Construction-Permanent Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488310 XXX XXX XXX 35082281 credit 3 Missing Document: Missing Final 1003 2/XX/2008 WI Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488310 XXX XXX XXX 35082282 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2008 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 01/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2008.
625488310 XXX XXX XXX 35082283 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2008 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488310 XXX XXX XXX 35082284 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2008 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489016 XXX XXX XXX 35082460 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2007 IL Refinance - Rate/Term Primary No B B B B
an application date of 03/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2007.
625489016 XXX XXX XXX 35082461 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2007 IL Refinance - Rate/Term Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489530 XXX XXX XXX 35082484 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 6/XX/2005 CA Refinance - Rate/Term Primary No B B B B
625489530 XXX XXX XXX 35082485 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2005 CA Refinance - Rate/Term Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489293 XXX XXX XXX 35082525 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 4/XX/2007 DC Refinance - Cash-out - Other Primary No B B B B
within a reasonably practicable time after using credit score.
625489293 XXX XXX XXX 35082526 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2007 DC Refinance - Cash-out - Other Primary No B B B B
an application date of 03/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2006.
625489293 XXX XXX XXX 35082527 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2007 DC Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489293 XXX XXX XXX 35082528 compliance 2 TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Truth in Lending Act: Actual Date(s) on Notice of Right to Cancel occurs prior TILA ROR - 3yrs for rescindable transactions. 4/XX/2007 4/XX/2010 DC Refinance - Cash-out - Other Primary No B B B B
Date to expected date(s).
625488235 XXX XXX XXX 35082529 credit 3 Missing Document: Missing Final 1003 5/XX/2006 AZ Refinance - Cash-out - Other Primary No C C C C
625488235 XXX XXX XXX 35082530 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 5/XX/2006 AZ Refinance - Cash-out - Other Primary No B B B B
within a reasonably practicable time after using credit score.
625488235 XXX XXX XXX 35082531 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2006 AZ Refinance - Cash-out - Other Primary No B B B B
an application date of 04/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2006.
625488235 XXX XXX XXX 35082532 compliance 2 CHARM Booklet Disclosure Prior to Closing Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2006 5/XX/2007 AZ Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower at least three (3) days prior to
consummation for a loan that did not start as an ARM.
625488235 XXX XXX XXX 35082533 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2006 5/XX/2007 AZ Refinance - Cash-out - Other Primary No B B B B
borrower.
625488235 XXX XXX XXX 35082534 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Closing instructions indicate the Index used was 3.56%. The lowest Index $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 5/XX/2006 5/XX/2009 AZ Refinance - Cash-out - Other Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. available within the look-back period is 3.79%. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488364 XXX XXX XXX 35082593 compliance 2 RESPA (2010) - 0% Tolerance (Line 1203) Without Cure RESPA (2010): 0% tolerance violation for 1203 fee without evidence of sufficient RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2011 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
cure provided. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488364 XXX XXX XXX 35082594 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2011 3/XX/2012 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
borrower within three (3) days of application.
625488364 XXX XXX XXX 35082595 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2011 3/XX/2012 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488364 XXX XXX XXX 35082596 compliance 2 TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit 3/XX/2011 3/XX/2014 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
(Circuit 2, 5, 7, 8, 9, 10 or DC) Model Form for a refinancing by the same creditor. The H-8 form was used, the courts, the continuing risk that the borrower may have an extended right to
H-9 form should have been used. rescind (3 additional years) if a creditor uses the incorrect Model Form
remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625487969 XXX XXX XXX 35082633 compliance 2 ARM Disclosure Status Unable to determine if loan file contains ARM Disclosure due to missing TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2005 11/XX/2006 IL Purchase Primary No B B B B
information.
625487969 XXX XXX XXX 35082634 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2005 11/XX/2006 IL Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625487969 XXX XXX XXX 35082635 credit 3 Missing Document: Missing Final 1003 11/XX/2005 IL Purchase Primary No C C C C
625487969 XXX XXX XXX 35082636 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2005 IL Purchase Primary No B B B B
an application date of 10/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2005.
625487969 XXX XXX XXX 35082637 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2005 IL Purchase Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489063 XXX XXX XXX 35082643 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2004 NY Purchase Primary No B B B B
an application date of 06/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2004.
625489063 XXX XXX XXX 35082644 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2004 7/XX/2005 NY Purchase Primary No B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625489063 XXX XXX XXX 35082645 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2004 7/XX/2005 NY Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488675 XXX XXX XXX 35082650 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2005 KS Refinance - Rate/Term Primary No B B B B
an application date of 06/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2005.
625488675 XXX XXX XXX 35082651 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2005 KS Refinance - Rate/Term Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488675 XXX XXX XXX 35082652 credit 3 Missing Document: Missing Final 1003 7/XX/2005 KS Refinance - Rate/Term Primary No C C C C
625488910 XXX XXX XXX 35082665 compliance 2 (Doc Error) Initial GFE not provided 10/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488910 XXX XXX XXX 35082666 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 10/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488034 XXX XXX XXX 35082676 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2007 8/XX/2008 PA Purchase Second Home No B B B B
defense to foreclosure. Assignee liability.
625488034 XXX XXX XXX 35082677 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2007 8/XX/2008 PA Purchase Second Home No B B B B
defense to foreclosure. Assignee liability.
625488034 XXX XXX XXX 35082678 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 8/XX/2007 PA Purchase Second Home No B B B B
625488034 XXX XXX XXX 35082679 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2007 PA Purchase Second Home No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488081 XXX XXX XXX 35082705 credit 3 Missing Document: Missing Final 1003 No 10/XX/2002 NJ Purchase UTD No C C C C
625488081 XXX XXX XXX 35082706 compliance 1 Missing Document: Missing Lender's Initial 1003 No 10/XX/2002 NJ Purchase UTD No A A A A 5/XX/2018 Yes 2018/XX/10: duplicate exception
625488081 XXX XXX XXX 35082707 compliance 1 Missing Document: Note - Subject Lien not provided No 10/XX/2002 NJ Purchase UTD No A A A A 5/XX/2018 Yes 2018/XX/10: Note provided
625488081 XXX XXX XXX 35082708 compliance 1 Missing Final HUD-1 No 10/XX/2002 NJ Purchase UTD No A A A A 5/XX/2018 Yes 2018/XX/10: duplicate exception
625488081 XXX XXX XXX 35082709 compliance 1 TILA - Final TIL Missing TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a No 10/XX/2002 10/XX/2003 NJ Purchase UTD No A A A A 5/XX/2018 Yes 2018/XX/10: Final TIL provided
defense to foreclosure. Assignee liability.
625488081 XXX XXX XXX 35082710 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off No 10/XX/2002 NJ Purchase UTD No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488081 XXX XXX XXX 35082711 compliance 1 (Missing Doc) Incomplete loan images/file File contains the Security Instrument, prelimnary and final Title, purchase No 10/XX/2002 NJ Purchase UTD No A A A A 5/XX/2018 Yes 2018/XX/10: Note provided
agreement, credit report and GFE.
625488081 XXX XXX XXX 35082712 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. No 10/XX/2002 NJ Purchase UTD No B B B B
Security Instrument Notary Date of 10/XX/2002 used as disbursement date for
compliance testing.
625488081 XXX XXX XXX 35082713 compliance 3 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable No 10/XX/2002 NJ Purchase UTD No D D D D
Federal, State or Local compliance testing is unreliable.
625488081 XXX XXX XXX 35082714 compliance 2 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using No 10/XX/2002 NJ Purchase UTD No B B B B
an application date of 09/XX/2002 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2002. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625488081 XXX XXX XXX 35082715 compliance 2 Unable to determine occupancy, compliance results were generated using a No 10/XX/2002 NJ Purchase UTD No B B B B
defaulted value of Primary.
625489190 XXX XXX XXX 35082718 credit 1 Final Title Policy is missing. No evidence of title in file. 6/XX/2003 MA Refinance - Rate/Term Primary No A A A A 4/XX/2018 Yes 2018/XX/27: [GS Comment 4/XX/2018]: Final Title Policy Located 2018/XX/30: Final policy provided.
625489190 XXX XXX XXX 35082719 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 6/XX/2003 6/XX/2007 MA Refinance - Rate/Term Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489190 XXX XXX XXX 35082720 credit 3 Missing Document: Missing Final 1003 6/XX/2003 MA Refinance - Rate/Term Primary No C C C C
625489190 XXX XXX XXX 35082721 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2003 MA Refinance - Rate/Term Primary No B B B B
an application date of 06/XX/2003 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2003.
625488881 XXX XXX XXX 35082734 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2007 OR Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488881 XXX XXX XXX 35082735 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 12/XX/2007, prior to TILA ROR - 3yrs for rescindable transactions. 11/XX/2007 11/XX/2010 OR Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 12/XX/2007.
625487930 XXX XXX XXX 35082827 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2003 12/XX/2004 DE Refinance - Cash-out - Other Primary No B B B B
borrower.
625487930 XXX XXX XXX 35082828 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2003 12/XX/2004 DE Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower.
625487930 XXX XXX XXX 35082829 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Closing instructions indicate the Index used was 1.140%. The lowest Index $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 12/XX/2003 12/XX/2006 DE Refinance - Cash-out - Other Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. available within the look-back period is 1.2163%. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625487955 XXX XXX XXX 35082861 credit 3 Missing Document: Missing Final 1003 5/XX/2003 TX Purchase Primary No C C C C
625487955 XXX XXX XXX 35082862 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2003 TX Purchase Primary No B B B B
an application date of 04/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2003.
625487955 XXX XXX XXX 35082863 compliance 2 ARM Disclosure Compliant TIL variable rate disclosure: ARM loan program disclosure does not match terms TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2003 5/XX/2004 TX Purchase Primary No B B B B
of loan.
625487955 XXX XXX XXX 35082864 compliance 2 ARM Disclosure Status Unable to determine if loan file contains ARM Disclosure due to missing TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2003 5/XX/2004 TX Purchase Primary No B B B B
information.
625488501 XXX XXX XXX 35083021 credit 3 Missing Document: Missing Final 1003 No 2/XX/1999 GA Purchase Primary No C C C C
625488501 XXX XXX XXX 35083022 compliance 2 Initial TIL not provided No 2/XX/1999 2/XX/2000 GA Purchase Primary No B B B B
625488501 XXX XXX XXX 35083023 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. Note No 2/XX/1999 GA Purchase Primary No B B B B
Date of 02/XX/1999 used as disbursement date for compliance testing.
625488501 XXX XXX XXX 35083024 compliance 3 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable No 2/XX/1999 GA Purchase Primary No D D D D
Federal, State or Local compliance testing is unreliable.
625488501 XXX XXX XXX 35083025 compliance 2 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using No 2/XX/1999 GA Purchase Primary No B B B B
an application date of 01/XX/1999 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/1998. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625488501 XXX XXX XXX 35083026 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA No 2/XX/1999 2/XX/2000 GA Purchase Primary No B B B B
borrower.
625488501 XXX XXX XXX 35083027 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA No 2/XX/1999 2/XX/2000 GA Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488501 XXX XXX XXX 35083028 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a No 2/XX/1999 2/XX/2000 GA Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625488501 XXX XXX XXX 35083029 compliance 2 (Doc Error) Initial GFE not provided No 2/XX/1999 GA Purchase Primary No B B B B
625488599 XXX XXX XXX 35083032 compliance 2 (Doc Error) Initial GFE not provided 11/XX/2006 GA Refinance - Cash-out - Other Primary No B B B B
625488599 XXX XXX XXX 35083033 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 11/XX/2006, prior to TILA ROR - 3yrs for rescindable transactions. 11/XX/2006 11/XX/2009 GA Refinance - Cash-out - Other Primary No B B B B
Date three (3) business days from transaction date of 11/XX/2006.
625488599 XXX XXX XXX 35083034 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2006 GA Refinance - Cash-out - Other Primary No B B B B
an application date of 10/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 05/XX/2006.
625488099 XXX XXX XXX 35083090 credit 3 Missing Document: Missing Final 1003 11/XX/2001 CO Purchase Primary No C C C C
625488099 XXX XXX XXX 35083091 compliance 2 (Doc Error) Initial GFE not provided 11/XX/2001 CO Purchase Primary No B B B B
625488099 XXX XXX XXX 35083092 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2001 11/XX/2002 CO Purchase Primary No B B B B
borrower.
625488099 XXX XXX XXX 35083093 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2001 11/XX/2002 CO Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488099 XXX XXX XXX 35083094 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2001 11/XX/2002 CO Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625488681 XXX XXX XXX 35083104 credit 3 Missing Document: Missing Final 1003 7/XX/2007 VA Refinance - Cash-out - Other Primary No C C C C
625488681 XXX XXX XXX 35083105 compliance 2 (Doc Error) Initial GFE not provided 7/XX/2007 VA Refinance - Cash-out - Other Primary No B B B B
625488681 XXX XXX XXX 35083106 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2007 VA Refinance - Cash-out - Other Primary No B B B B
an application date of 06/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2007.
625488681 XXX XXX XXX 35083107 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2007 7/XX/2008 VA Refinance - Cash-out - Other Primary No B B B B
borrower.
625488681 XXX XXX XXX 35083108 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2007 7/XX/2008 VA Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488681 XXX XXX XXX 35083109 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 7/XX/2007 7/XX/2010 VA Refinance - Cash-out - Other Primary No B B B B
625488681 XXX XXX XXX 35083110 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 7/XX/2007 VA Refinance - Cash-out - Other Primary No B B B B
Security Instrument Notary Date of 07/XX/2007 used as disbursement date for
compliance testing.
625488681 XXX XXX XXX 35083111 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2007 7/XX/2010 VA Refinance - Cash-out - Other Primary No B B B B
defense to foreclosure. Assignee liability.
625488638 XXX XXX XXX 35083127 credit 3 Missing Document: Missing Final 1003 3/XX/2004 IL Refinance - Cash-out - Other Primary No C C C C
625488275 XXX XXX XXX 35083163 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2007 NJ Refinance - Cash-out - Other Primary Yes B B B B
an application date of 06/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2007.
625489082 XXX XXX XXX 35083165 compliance 2 (Doc Error) Initial GFE not provided 1/XX/2004 MS Refinance - Rate/Term Primary No B B B B
625489082 XXX XXX XXX 35083166 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2004 1/XX/2005 MS Refinance - Rate/Term Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489082 XXX XXX XXX 35083167 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 1/XX/2004 1/XX/2007 MS Refinance - Rate/Term Primary No B B B B
625489082 XXX XXX XXX 35083168 credit 1 Final Title Policy is missing. No evidence of title in file. 1/XX/2004 MS Refinance - Rate/Term Primary No A A A A 5/XX/2018 Yes 2018/XX/31: Final title provided.
625489082 XXX XXX XXX 35083169 credit 3 Missing Document: HUD/VA 92900-A not provided 1/XX/2004 MS Refinance - Rate/Term Primary No C C C C
625489082 XXX XXX XXX 35083170 credit 3 Missing Valuation: Appraisal not provided 1/XX/2004 MS Refinance - Rate/Term Primary No C C C C
625489359 XXX XXX XXX 35083183 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2006 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 01/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2006.
625489359 XXX XXX XXX 35083184 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2006 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489359 XXX XXX XXX 35083185 credit 3 Missing Document: Missing Final 1003 2/XX/2006 MD Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489359 XXX XXX XXX 35083186 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2006 2/XX/2007 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
Loan Application Date.
625489359 XXX XXX XXX 35083187 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2006 2/XX/2007 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
Loan Application Date.
625488407 XXX XXX XXX 35083189 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2007 1/XX/2008 IL Refinance - Rate/Term Primary No B B B B
borrower within three (3) days of application.
625488407 XXX XXX XXX 35083190 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2007 1/XX/2008 IL Refinance - Rate/Term Primary No B B B B
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625489596 XXX XXX XXX 35083376 credit 3 Missing Document: Missing Final 1003 9/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489596 XXX XXX XXX 35083377 compliance 2 Initial TIL not provided 9/XX/2006 9/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489596 XXX XXX XXX 35083378 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 9/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489596 XXX XXX XXX 35083379 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 9/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 09/XX/2006 used as disbursement date for
compliance testing.
625489596 XXX XXX XXX 35083380 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 09/XX/2006, prior to TILA ROR - 3yrs for rescindable transactions. 9/XX/2006 9/XX/2009 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 09/XX/2006.
625489692 XXX XXX XXX 35083435 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 3/XX/2007 VA Refinance - Cash-out - Other Primary No B B B B
625489692 XXX XXX XXX 35083436 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2007 VA Refinance - Cash-out - Other Primary No B B B B
an application date of 02/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2006.
625487971 XXX XXX XXX 35083460 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2005 NY Purchase Primary No B B B B
an application date of 05/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 12/XX/2004.
625487971 XXX XXX XXX 35083461 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2005 NY Purchase Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625487971 XXX XXX XXX 35083462 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2005 NY Purchase Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625487971 XXX XXX XXX 35083463 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2005 6/XX/2006 NY Purchase Primary No B B B B
Loan Application Date.
625487971 XXX XXX XXX 35083464 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2005 6/XX/2006 NY Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488022 XXX XXX XXX 35083469 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 9/XX/2003 NC Purchase Primary No B B B B
following clauses:
625488022 XXX XXX XXX 35083470 credit 3 Missing Document: Missing Final 1003 9/XX/2003 NC Purchase Primary No C C C C
625488707 XXX XXX XXX 35083482 credit 3 Missing Document: Missing Final 1003 9/XX/2005 FL Purchase Primary No C C C C
625488707 XXX XXX XXX 35083483 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2005 FL Purchase Primary No B B B B
an application date of 08/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 05/XX/2005.
625488051 XXX XXX XXX 35083554 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 12/XX/2005 12/XX/2008 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488631 XXX XXX XXX 35083586 credit 3 Missing Document: Missing Final 1003 12/XX/2002 MI Refinance - Rate/Term Primary No C C C C
625488631 XXX XXX XXX 35083587 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 12/XX/2002 MI Refinance - Rate/Term Primary No B B B B
following clauses:
625488631 XXX XXX XXX 35083588 compliance 2 (Doc Error) Initial GFE not provided 12/XX/2002 MI Refinance - Rate/Term Primary No B B B B
625488631 XXX XXX XXX 35083589 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 12/XX/2002 MI Refinance - Rate/Term Primary No B B B B
Security Instrument Notary Date of 12/XX/2002 used as disbursement date for
compliance testing.
625488631 XXX XXX XXX 35083590 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 12/XX/2002 12/XX/2005 MI Refinance - Rate/Term Primary No B B B B
625488631 XXX XXX XXX 35083591 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 12/XX/2002 12/XX/2005 MI Refinance - Rate/Term Primary No B B B B
defense to foreclosure. Assignee liability.
625488631 XXX XXX XXX 35083592 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 12/XX/2002 MI Refinance - Rate/Term Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488631 XXX XXX XXX 35083593 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 12/XX/2002 MI Refinance - Rate/Term Primary No B B B B
an application date of 11/XX/2002 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2002.
625489469 XXX XXX XXX 35083616 credit 3 Missing Document: Missing Final 1003 4/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489469 XXX XXX XXX 35083617 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 03/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2005.
625489469 XXX XXX XXX 35083618 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 04/XX/2006, prior to TILA ROR - 3yrs for rescindable transactions. 4/XX/2006 4/XX/2009 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 04/XX/2006.
625489469 XXX XXX XXX 35083619 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 4/XX/2006 4/XX/2009 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625489469 XXX XXX XXX 35083620 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 4/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 04/XX/2006 used as disbursement date for
compliance testing.
625488365 XXX XXX XXX 35083685 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 06/XX/2006, prior to TILA ROR - 3yrs for rescindable transactions. 6/XX/2006 6/XX/2009 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 06/XX/2006.
625488365 XXX XXX XXX 35083686 credit 3 Missing Document: Missing Final 1003 6/XX/2006 CT Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488365 XXX XXX XXX 35083687 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 6/XX/2006 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B
following clauses:
625488365 XXX XXX XXX 35083688 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 6/XX/2006 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 06/XX/2006 used as disbursement date for
compliance testing.
625488365 XXX XXX XXX 35083689 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2006 6/XX/2009 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625488365 XXX XXX XXX 35083690 credit 3 Missing Valuation: Appraisal not provided 6/XX/2006 CT Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489527 XXX XXX XXX 35083696 compliance 2 (Doc Error) Initial GFE not provided 7/XX/2002 MO Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489527 XXX XXX XXX 35083697 credit 3 Missing Document: Missing Final 1003 7/XX/2002 MO Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489527 XXX XXX XXX 35083698 compliance 1 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 7/XX/2002 MO Refinance - Cash-out - Debt Consolidation Primary No A A A A 5/XX/2018 Yes 2018/XX/10: Received final HUD-1
Security Instrument Notary Date of 07/XX/2002 used as disbursement date for
compliance testing.
625489527 XXX XXX XXX 35083699 compliance 1 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable 7/XX/2002 MO Refinance - Cash-out - Debt Consolidation Primary No A A A A 5/XX/2018 Yes 2018/XX/10: Received final HUD-1
Federal, State or Local compliance testing is unreliable.
625489527 XXX XXX XXX 35083700 compliance 1 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using 7/XX/2002 MO Refinance - Cash-out - Debt Consolidation Primary No A A A A 5/XX/2018 Yes 2018/XX/10: Received final HUD-1
an application date of 06/XX/2002 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2002. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625489527 XXX XXX XXX 35083701 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 7/XX/2002 7/XX/2005 MO Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489527 XXX XXX XXX 35083702 compliance 1 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2002 7/XX/2005 MO Refinance - Cash-out - Debt Consolidation Primary No A A A A 5/XX/2018 Yes 2018/XX/10: Received final TIL
defense to foreclosure. Assignee liability.
625489527 XXX XXX XXX 35083703 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2002 MO Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 06/XX/2002 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2002.
625489527 XXX XXX XXX 35083704 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2002 7/XX/2005 MO Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625489181 XXX XXX XXX 35083754 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2004 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 09/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/2004.
625489181 XXX XXX XXX 35083755 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2004 10/XX/2005 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625489181 XXX XXX XXX 35083756 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2004 10/XX/2005 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489350 XXX XXX XXX 35083778 credit 3 Missing Document: FHA Mortgage Insurance Certificate not provided 6/XX/2008 MS Purchase Primary No C C C C
625489256 XXX XXX XXX 35083814 compliance 2 (Doc Error) Initial GFE not provided 3/XX/1999 OH Purchase Primary No B B B B
625489256 XXX XXX XXX 35083815 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization did not disclose a flood certification fee of $XXX settlement $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 3/XX/1999 3/XX/2000 OH Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. fee of $XXX or title courier fee of $XXX as prepaid finance charges. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489549 XXX XXX XXX 35083979 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 1/XX/2005 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 01/XX/2005 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2005.
625489549 XXX XXX XXX 35083980 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 1/XX/2005 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489549 XXX XXX XXX 35083981 compliance 2 TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Truth in Lending Act: Actual Date(s) on Notice of Right to Cancel occurs prior TILA ROR - 3yrs for rescindable transactions. 1/XX/2005 1/XX/2008 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date to expected date(s).
625489549 XXX XXX XXX 35083982 compliance 2 Initial TIL not provided 1/XX/2005 1/XX/2006 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489549 XXX XXX XXX 35083983 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 1/XX/2005 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 01/XX/2005 used as disbursement date for
compliance testing.
625489549 XXX XXX XXX 35083984 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 01/XX/2005, prior to TILA ROR - 3yrs for rescindable transactions. 1/XX/2005 1/XX/2008 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 01/XX/2005.
625489077 XXX XXX XXX 35083992 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2005 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 07/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2005.
625489417 XXX XXX XXX 35084063 credit 3 Missing Document: Missing Final 1003 3/XX/2001 ID Refinance - Rate/Term UTD No C C C C
625489417 XXX XXX XXX 35084065 compliance 2 Note Error: Note late charge percentage exceeds maximum per state 10% late charge exceeds 5% maximum per state (ID) 3/XX/2001 ID Refinance - Rate/Term UTD No B B B B
625489417 XXX XXX XXX 35084066 compliance 2 (Doc Error) Initial GFE not provided 3/XX/2001 ID Refinance - Rate/Term UTD No B B B B
625489417 XXX XXX XXX 35084067 compliance 2 Unable to determine occupancy, compliance results were generated using a 3/XX/2001 ID Refinance - Rate/Term UTD No B B B B
defaulted value of Primary.
625489417 XXX XXX XXX 35084068 credit 1 Final Title Policy is missing. No evidence of title in file. 3/XX/2001 ID Refinance - Rate/Term UTD No A A A A 6/XX/2018 Yes 2018/XX/19: Final policy provided, exception cleared.
625489417 XXX XXX XXX 35084069 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. Note 3/XX/2001 ID Refinance - Rate/Term UTD No B B B B
Date of 03/XX/2001 used as disbursement date for compliance testing.
625489417 XXX XXX XXX 35084070 compliance 2 Right of Rescission Timing - Note Date used as Transaction Date Unable to conclusively determine date of consummation. Note date used as 3/XX/2001 ID Refinance - Rate/Term UTD No B B B B
transaction date for purposes of determining compliance with rescission timing
requirements
625489417 XXX XXX XXX 35084071 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 3/XX/2001 3/XX/2004 ID Refinance - Rate/Term UTD No B B B B
625489417 XXX XXX XXX 35084072 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2001 3/XX/2004 ID Refinance - Rate/Term UTD No B B B B
defense to foreclosure. Assignee liability.
625489417 XXX XXX XXX 35084073 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2001 ID Refinance - Rate/Term UTD No B B B B
an application date of 02/XX/2001 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 09/XX/2000.
625489417 XXX XXX XXX 35084074 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 3/XX/2001 ID Refinance - Rate/Term UTD No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488891 XXX XXX XXX 35084122 credit 3 Missing Document: Missing Final 1003 1/XX/2005 VA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488891 XXX XXX XXX 35084123 compliance 2 Initial TIL not provided 1/XX/2005 1/XX/2006 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488891 XXX XXX XXX 35084124 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 1/XX/2005 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488891 XXX XXX XXX 35084125 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 1/XX/2005 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 01/XX/2005 used as disbursement date for
compliance testing.
625488891 XXX XXX XXX 35084126 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 01/XX/2005, prior to TILA ROR - 3yrs for rescindable transactions. 1/XX/2005 1/XX/2008 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 01/XX/2005.
625488891 XXX XXX XXX 35084127 compliance 2 Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit 1/XX/2005 1/XX/2008 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Model Form for a refinance by a creditor that is not considered the original courts, the continuing risk that the borrower may have an extended right to
creditor. The H-9 form was used, the H-8 form should have been used. rescind (3 additional years) if a creditor uses the incorrect Model Form
remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625488891 XXX XXX XXX 35084128 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 1/XX/2005 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 12/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 12/XX/2004.
625489060 XXX XXX XXX 35084135 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 3/XX/2005 3/XX/2008 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489454 XXX XXX XXX 35084136 credit 3 Missing Document: Missing Final 1003 11/XX/2007 NY Refinance - Cash-out - Other Primary No C C C C
625489454 XXX XXX XXX 35084137 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 11/XX/2007 NY Refinance - Cash-out - Other Primary No B B B B
Security Instrument Notary Date of 11/XX/2007 used as disbursement date for
compliance testing.
625489454 XXX XXX XXX 35084138 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2007 NY Refinance - Cash-out - Other Primary No B B B B
an application date of 10/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 05/XX/2007.
625489454 XXX XXX XXX 35084139 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 11/XX/2007, prior to TILA ROR - 3yrs for rescindable transactions. 11/XX/2007 11/XX/2010 NY Refinance - Cash-out - Other Primary No B B B B
Date three (3) business days from transaction date of 11/XX/2007.
625489669 XXX XXX XXX 35084140 credit 2 Note is not on a FNMA/FHLMC form and does not contain the standard Due on Sale 9/XX/2006 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B
clause.
625489669 XXX XXX XXX 35084141 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 9/XX/2006 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B
following clauses:
625489669 XXX XXX XXX 35084142 credit 3 Missing Document: Missing Final 1003 9/XX/2006 MI Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489669 XXX XXX XXX 35084143 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 9/XX/2006 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 09/XX/2006 used as disbursement date for
compliance testing.
625489669 XXX XXX XXX 35084144 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 09/XX/2006, prior to TILA ROR - 3yrs for rescindable transactions. 9/XX/2006 9/XX/2009 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 09/XX/2006.
625489669 XXX XXX XXX 35084145 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2006 9/XX/2009 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625489298 XXX XXX XXX 35084288 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 7/XX/2005 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489298 XXX XXX XXX 35084289 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. Note 7/XX/2005 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date of 07/XX/2005 used as disbursement date for compliance testing.
625489298 XXX XXX XXX 35084290 compliance 2 Right of Rescission Timing - Note Date used as Transaction Date Unable to conclusively determine date of consummation. Note date used as 7/XX/2005 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
transaction date for purposes of determining compliance with rescission timing
requirements
625489298 XXX XXX XXX 35084291 compliance 2 Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. 7/XX/2005 7/XX/2008 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
timing requirements.
625489298 XXX XXX XXX 35084292 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 07/XX/2005, prior to TILA ROR - 3yrs for rescindable transactions. 7/XX/2005 7/XX/2008 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 07/XX/2005.
625489298 XXX XXX XXX 35084293 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2005 7/XX/2008 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625489298 XXX XXX XXX 35084294 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2005 7/XX/2008 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625489298 XXX XXX XXX 35084295 credit 3 Missing Document: Missing Final 1003 7/XX/2005 VA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489298 XXX XXX XXX 35084296 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2005 7/XX/2008 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625489081 XXX XXX XXX 35084303 compliance 2 (Doc Error) Initial GFE not provided 9/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B
625489081 XXX XXX XXX 35084304 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2006 9/XX/2009 FL Refinance - Cash-out - Other Primary No B B B B
defense to foreclosure. Assignee liability.
625489081 XXX XXX XXX 35084305 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B
an application date of 08/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2006.
625489188 XXX XXX XXX 35084324 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2006 IL Refinance - Rate/Term Primary No B B B B
an application date of 05/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 05/XX/2006.
625489188 XXX XXX XXX 35084325 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2006 IL Refinance - Rate/Term Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489188 XXX XXX XXX 35084326 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine the reason for the under disclosure due to missing the $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 6/XX/2006 6/XX/2009 IL Refinance - Rate/Term Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. itemization of amount financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489247 XXX XXX XXX 35084376 credit 3 Missing Document: Missing Final 1003 5/XX/2006 NY Purchase Primary No C C C C
625489247 XXX XXX XXX 35084377 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2006 NY Purchase Primary No B B B B
an application date of 04/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2005.
625489266 XXX XXX XXX 35084450 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488371 XXX XXX XXX 35084486 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 12/XX/2006 MS Refinance - Cash-out - Other Primary No B B B B
an application date of 11/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2006.
625488371 XXX XXX XXX 35084487 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2006 MS Refinance - Cash-out - Other Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488371 XXX XXX XXX 35084488 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2006 MS Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488897 XXX XXX XXX 35084529 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 8/XX/2007 VA Refinance - Cash-out - Other Primary No B B B B
within a reasonably practicable time after using credit score.
625488653 XXX XXX XXX 35084565 compliance 1 (Missing Doc) Incomplete loan images/file Loan file does not contain any origination documentation. 6/XX/2007 CA Refinance - Cash-out - Other Primary No A A A A 5/XX/2018 Yes 2018/XX/23: Received Loan Images - exception cleared
625488653 XXX XXX XXX 35084566 credit 3 Missing Document: Missing Final 1003 6/XX/2007 CA Refinance - Cash-out - Other Primary No C C C C
625488653 XXX XXX XXX 35084567 compliance 2 (Doc Error) Initial GFE not provided 6/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
625488653 XXX XXX XXX 35084568 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 6/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488653 XXX XXX XXX 35084569 compliance 1 Unable to determine occupancy, compliance results were generated using a 6/XX/2007 CA Refinance - Cash-out - Other Primary No A A A A 6/XX/2018 Yes 2018/XX/11: Occupancy determined from HUD provided.
defaulted value of Primary.
625488653 XXX XXX XXX 35084570 compliance 1 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 6/XX/2007 CA Refinance - Cash-out - Other Primary No A A A A 6/XX/2018 Yes 2018/XX/11: Document provided as trailing doc.
Security Instrument Notary Date of 06/XX/2007 used as disbursement date for
compliance testing.
625488653 XXX XXX XXX 35084571 compliance 1 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable 6/XX/2007 CA Refinance - Cash-out - Other Primary No A A A A 6/XX/2018 Yes 2018/XX/11: Document provided as trailing doc.
Federal, State or Local compliance testing is unreliable.
625488653 XXX XXX XXX 35084572 compliance 1 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using 6/XX/2007 CA Refinance - Cash-out - Other Primary No A A A A 6/XX/2018 Yes 2018/XX/11: Document provided as trailing doc.
an application date of 05/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 12/XX/2006. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625488653 XXX XXX XXX 35084573 compliance 2 Property Type Not Provided (Missing Data) Property Type. If property type is other than single family 6/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
residence, state and federal testing may be impacted.
625488653 XXX XXX XXX 35084574 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 CA Refinance - Cash-out - Other Primary No B B B B
borrower.
625488653 XXX XXX XXX 35084575 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 CA Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488653 XXX XXX XXX 35084576 compliance 1 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 6/XX/2007 6/XX/2010 CA Refinance - Cash-out - Other Primary No A A A A 6/XX/2018 Yes 2018/XX/11: Document provided as trailing doc.
625488653 XXX XXX XXX 35084577 compliance 1 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2007 6/XX/2010 CA Refinance - Cash-out - Other Primary No A A A A 6/XX/2018 Yes 2018/XX/11: Document provided as trailing doc.
defense to foreclosure. Assignee liability.
625488653 XXX XXX XXX 35084578 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
an application date of 05/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 12/XX/2006.
625488653 XXX XXX XXX 35084579 compliance 2 (Missing Data) Unable to determine if loan is a same lender refi Original Lender was not able to be determined. Unable to determine if correct 6/XX/2007 6/XX/2010 CA Refinance - Cash-out - Other Primary No B B B B
TILA rescission form was used.
625488198 XXX XXX XXX 35084716 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 9/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
within a reasonably practicable time after using credit score.
625488198 XXX XXX XXX 35084717 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Underdisclosure is due to $XXX Settlement Fee and $XXX Courier Fee not included $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 9/XX/2007 9/XX/2010 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. in prepaid finance charges on Itemization. Additional $.53 seems to be payment for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
stream related. liability.
625488096 XXX XXX XXX 35084780 credit 3 Missing Document: Missing Final 1003 8/XX/2007 FL Refinance - Cash-out - Home Improvement Primary No C C C C
625488096 XXX XXX XXX 35084781 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2007 FL Refinance - Cash-out - Home Improvement Primary No B B B B
an application date of 07/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 07/XX/2007.
625489045 XXX XXX XXX 35084797 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2008 FL Purchase Primary No B B B B
an application date of 03/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2008.
625489045 XXX XXX XXX 35084798 credit 3 Missing Document: Missing Final 1003 4/XX/2008 FL Purchase Primary No C C C C
625489313 XXX XXX XXX 35084840 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 10/XX/2005 10/XX/2006 OH Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489313 XXX XXX XXX 35084841 credit 3 Missing Document: Missing Final 1003 10/XX/2005 OH Purchase Primary No C C C C
625489313 XXX XXX XXX 35084842 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2005 OH Purchase Primary No B B B B
an application date of 09/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2005.
625489313 XXX XXX XXX 35084843 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2005 10/XX/2006 OH Purchase Primary No B B B B
Loan Application Date.
625489313 XXX XXX XXX 35084844 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2005 10/XX/2006 OH Purchase Primary No B B B B
Loan Application Date.
625488912 XXX XXX XXX 35084870 credit 3 Missing Document: Missing Final 1003 7/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488912 XXX XXX XXX 35084871 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2006 7/XX/2009 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625489085 XXX XXX XXX 35084957 credit 3 Missing Document: Missing Final 1003 10/XX/2006 NM Refinance - Cash-out - Debt Consolidation Primary Yes C C C C
625489085 XXX XXX XXX 35084958 compliance 2 (Doc Error) Initial GFE not provided 10/XX/2006 NM Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
625489085 XXX XXX XXX 35084959 credit 2 Note is not on a FNMA/FHLMC form and does not contain the standard Due on Sale 10/XX/2006 NM Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
clause.
625489085 XXX XXX XXX 35084960 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 10/XX/2006 NM Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
625489085 XXX XXX XXX 35084961 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2006 NM Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
an application date of 09/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2006.
625489085 XXX XXX XXX 35084962 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2006 10/XX/2007 NM Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
borrower.
625489085 XXX XXX XXX 35084963 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2006 10/XX/2007 NM Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
CHARM Booklet, not provided to the borrower.
625489085 XXX XXX XXX 35084964 compliance 2 Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. 10/XX/2006 10/XX/2009 NM Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
timing requirements.
625489085 XXX XXX XXX 35084965 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2006 10/XX/2009 NM Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
defense to foreclosure. Assignee liability.
625488246 XXX XXX XXX 35084998 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2008 1/XX/2009 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
borrower.
625488246 XXX XXX XXX 35084999 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2008 1/XX/2009 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488316 XXX XXX XXX 35085107 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 6/XX/2007 WA Construction-Permanent Primary No B B B B
625488316 XXX XXX XXX 35085108 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 6/XX/2007 WA Construction-Permanent Primary No C C C C
625488302 XXX XXX XXX 35085133 compliance 2 Initial TIL not provided 12/XX/2005 12/XX/2006 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488302 XXX XXX XXX 35085134 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 12/XX/2005 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 11/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2005.
625488302 XXX XXX XXX 35085135 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 12/XX/2005 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489588 XXX XXX XXX 35085176 compliance 2 Initial TIL not provided 9/XX/2003 9/XX/2004 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489588 XXX XXX XXX 35085177 credit 3 Missing Document: Missing Final 1003 9/XX/2003 CT Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489588 XXX XXX XXX 35085178 compliance 2 (Doc Error) Initial GFE not provided 9/XX/2003 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489588 XXX XXX XXX 35085180 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 9/XX/2003 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 09/XX/2003 used as disbursement date for
compliance testing.
625489588 XXX XXX XXX 35085181 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2003 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 08/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2003.
625489588 XXX XXX XXX 35085182 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 9/XX/2003 9/XX/2006 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489588 XXX XXX XXX 35085183 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2003 9/XX/2006 CT Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625489588 XXX XXX XXX 35085184 credit 3 Missing Valuation: Appraisal not provided 9/XX/2003 CT Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489072 XXX XXX XXX 35085185 credit 3 Missing Document: Missing Final 1003 9/XX/2003 OH Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489072 XXX XXX XXX 35085186 compliance 2 (Doc Error) Initial GFE not provided 9/XX/2003 OH Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489072 XXX XXX XXX 35085187 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 9/XX/2003 OH Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 09/XX/2003 used as disbursement date for
compliance testing.
625489072 XXX XXX XXX 35085188 compliance 1 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable 9/XX/2003 OH Refinance - Cash-out - Debt Consolidation Primary No A A A A 6/XX/2018 Yes 2018/XX/15: Final HUD provided, exception cleared.
Federal, State or Local compliance testing is unreliable.
625489072 XXX XXX XXX 35085189 compliance 1 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using 9/XX/2003 OH Refinance - Cash-out - Debt Consolidation Primary No A A A A 6/XX/2018 Yes 2018/XX/15: Final HUD provided, exception cleared.
an application date of 08/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2003. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625489072 XXX XXX XXX 35085190 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 9/XX/2003 9/XX/2006 OH Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489072 XXX XXX XXX 35085191 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2003 9/XX/2006 OH Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625489072 XXX XXX XXX 35085192 compliance 2 Initial TIL not provided 9/XX/2003 9/XX/2004 OH Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489072 XXX XXX XXX 35085193 credit 3 Missing Valuation: Appraisal not provided 9/XX/2003 OH Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489072 XXX XXX XXX 35085194 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2003 OH Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 08/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2003.
625487991 XXX XXX XXX 35085195 credit 3 Missing Document: Missing Final 1003 10/XX/2004 OK Refinance - Cash-out - Debt Consolidation Primary No C C C C
625487991 XXX XXX XXX 35085196 compliance 2 (Doc Error) Initial GFE not provided 10/XX/2004 OK Refinance - Cash-out - Debt Consolidation Primary No B B B B
625487991 XXX XXX XXX 35085197 credit 1 Final Title Policy is missing. No evidence of title in file. 10/XX/2004 OK Refinance - Cash-out - Debt Consolidation Primary No A A A A 6/XX/2018 Yes 2018/XX/19: Final policy provided, exception cleared.
625487991 XXX XXX XXX 35085198 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. Note 10/XX/2004 OK Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date of 10/XX/2004 used as disbursement date for compliance testing.
625487991 XXX XXX XXX 35085199 compliance 1 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable 10/XX/2004 OK Refinance - Cash-out - Debt Consolidation Primary No A A A A 6/XX/2018 Yes 2018/XX/15: Final HUD provided, exception cleared.
Federal, State or Local compliance testing is unreliable.
625487991 XXX XXX XXX 35085200 compliance 1 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using 10/XX/2004 OK Refinance - Cash-out - Debt Consolidation Primary No A A A A 6/XX/2018 Yes 2018/XX/15: Final HUD provided, exception cleared.
an application date of 09/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2004. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625487991 XXX XXX XXX 35085201 compliance 1 Right of Rescission Timing - Note Date used as Transaction Date Unable to conclusively determine date of consummation. Note date used as 10/XX/2004 OK Refinance - Cash-out - Debt Consolidation Primary No A A A A 6/XX/2018 Yes 2018/XX/19: Received Security Intrument with notary date page, exception cleared
transaction date for purposes of determining compliance with rescission timing
requirements
625487991 XXX XXX XXX 35085202 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 10/XX/2004 10/XX/2007 OK Refinance - Cash-out - Debt Consolidation Primary No B B B B
625487991 XXX XXX XXX 35085203 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2004 10/XX/2007 OK Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625487991 XXX XXX XXX 35085204 credit 3 Missing Valuation: Appraisal not provided 10/XX/2004 OK Refinance - Cash-out - Debt Consolidation Primary No C C C C
625487991 XXX XXX XXX 35085205 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2004 OK Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 09/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2004.
625488491 XXX XXX XXX 35085211 credit 3 Missing Document: Security Instrument - Subject Lien not provided 2/XX/2007 IN Purchase Primary Yes D D D D
625488491 XXX XXX XXX 35085212 compliance 2 (Doc Error) Initial GFE not provided 2/XX/2007 IN Purchase Primary Yes B B B B
625488491 XXX XXX XXX 35085213 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2007 IN Purchase Primary Yes B B B B
an application date of 01/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2007.
625488491 XXX XXX XXX 35085214 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2007 2/XX/2008 IN Purchase Primary Yes B B B B
borrower.
625488491 XXX XXX XXX 35085215 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2007 2/XX/2008 IN Purchase Primary Yes B B B B
CHARM Booklet, not provided to the borrower.
625488491 XXX XXX XXX 35085216 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 2/XX/2007 2/XX/2008 IN Purchase Primary Yes B B B B
defense to foreclosure. Assignee liability.
625488491 XXX XXX XXX 35085217 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 2/XX/2007 IN Purchase Primary Yes B B B B
625488491 XXX XXX XXX 35085218 credit 3 Missing Valuation: Appraisal not provided. 2/XX/2007 IN Purchase Primary Yes C C C C
625489006 XXX XXX XXX 35085229 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2007 CA Refinance - Rate/Term Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489006 XXX XXX XXX 35085230 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 4/XX/2007 CA Refinance - Rate/Term Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489078 XXX XXX XXX 35085247 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2006 FL Refinance - Rate/Term Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489078 XXX XXX XXX 35085248 compliance 2 Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. 8/XX/2006 8/XX/2009 FL Refinance - Rate/Term Primary No B B B B
timing requirements.
625489078 XXX XXX XXX 35085249 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 08/XX/2006, prior to TILA ROR - 3yrs for rescindable transactions. 8/XX/2006 8/XX/2009 FL Refinance - Rate/Term Primary No B B B B
Date three (3) business days from transaction date of 09/XX/2006.
625489078 XXX XXX XXX 35085250 compliance 2 TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Truth in Lending Act: Actual Date(s) on Notice of Right to Cancel occurs prior TILA ROR - 3yrs for rescindable transactions. 8/XX/2006 8/XX/2009 FL Refinance - Rate/Term Primary No B B B B
Date to expected date(s).
625489078 XXX XXX XXX 35085251 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2006 8/XX/2009 FL Refinance - Rate/Term Primary No B B B B
defense to foreclosure. Assignee liability.
625489078 XXX XXX XXX 35085252 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2006 8/XX/2009 FL Refinance - Rate/Term Primary No B B B B
defense to foreclosure. Assignee liability.
625489078 XXX XXX XXX 35085253 credit 3 Final Title Policy is missing. No evidence of title in file. 8/XX/2006 FL Refinance - Rate/Term Primary No C C C C
625489124 XXX XXX XXX 35085279 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 06/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2006.
625489124 XXX XXX XXX 35085280 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489124 XXX XXX XXX 35085281 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2006 7/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Loan Application Date.
625489124 XXX XXX XXX 35085282 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2006 7/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Loan Application Date.
625489124 XXX XXX XXX 35085283 compliance 2 TIL APR Tolerance Irregular Transaction Truth In Lending Act: Final TIL APR of XX.XX% is underdisclosed from calculated TILA APR - subject to a 1 year SOL for affirmative claims, 3 years for 7/XX/2006 7/XX/2009 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
APR of XX.XX% outside of 0.125% tolerance. rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489124 XXX XXX XXX 35085284 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Closing instructions indicate the Index used was 3.790%. The closest Index $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 7/XX/2006 7/XX/2009 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. available in our look-back period is 4.11%. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489124 XXX XXX XXX 35085285 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 7/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488710 XXX XXX XXX 35085294 credit 3 Missing Document: Missing Final 1003 11/XX/2006 CA Refinance - Cash-out - Home Improvement Primary No C C C C
625488710 XXX XXX XXX 35085295 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2006 11/XX/2007 CA Refinance - Cash-out - Home Improvement Primary No B B B B
borrower.
625488710 XXX XXX XXX 35085296 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2006 CA Refinance - Cash-out - Home Improvement Primary No B B B B
an application date of 10/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2006.
625488710 XXX XXX XXX 35085297 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2006 CA Refinance - Cash-out - Home Improvement Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488710 XXX XXX XXX 35085298 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2006 11/XX/2007 CA Refinance - Cash-out - Home Improvement Primary No B B B B
Loan Application Date.
625488759 XXX XXX XXX 35085300 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 2/XX/2005 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
within a reasonably practicable time after using credit score.
625488759 XXX XXX XXX 35085301 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2005 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 01/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/2004.
625488759 XXX XXX XXX 35085302 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2005 2/XX/2006 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625488759 XXX XXX XXX 35085303 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2005 2/XX/2006 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488759 XXX XXX XXX 35085304 compliance 2 (Doc Error) Initial GFE not provided 2/XX/2005 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488160 XXX XXX XXX 35085316 compliance 2 (Missing Data) Unable to determine if loan is a same lender refi Original Lender was not able to be determined. Unable to determine if correct 4/XX/2007 4/XX/2011 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
TILA rescission form was used.
625488160 XXX XXX XXX 35085317 compliance 2 Payoff Statement Missing Missing Payoff Statement: Unable to determine if a prepayment penalty was 4/XX/2007 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
included in the pay-off which may impact high cost findings.
625488160 XXX XXX XXX 35085319 compliance 2 Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance Truth in Lending Act: Unable to determine if Notice of Right to Cancel was TILA ROR Form - Because this issue is not uniformly settled among the circuit 4/XX/2007 4/XX/2011 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
executed on the proper Model Form. The H-9 form was used instead of the H-8 courts, the continuing risk that the borrower may have an extended right to
form, however, the loan file does not contain evidence that the refinance was by rescind (3 additional years) if a creditor uses the incorrect Model Form
the original creditor. remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625488160 XXX XXX XXX 35085320 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine reason for under disclosure due to TIL Itemization missing $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 4/XX/2007 4/XX/2011 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
calculated Finance Charge of $XXX in the amount of $XXX. breakdown of prepaid finance charge. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489546 XXX XXX XXX 35085382 credit 3 Missing Document: Missing Final 1003 6/XX/2005 CA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489546 XXX XXX XXX 35085383 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2005 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 05/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 12/XX/2004.
625489546 XXX XXX XXX 35085384 compliance 2 Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. 6/XX/2005 6/XX/2008 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
timing requirements.
625489546 XXX XXX XXX 35085385 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2005 6/XX/2008 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625489546 XXX XXX XXX 35085386 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2005 6/XX/2008 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625489546 XXX XXX XXX 35085387 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2005 6/XX/2008 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625488360 XXX XXX XXX 35085395 credit 3 Missing Document: Missing Final 1003 12/XX/2007 CA Refinance - Cash-out - Other Primary No C C C C
625488360 XXX XXX XXX 35085396 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 12/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
625488360 XXX XXX XXX 35085397 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 12/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
an application date of 11/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2007.
625488360 XXX XXX XXX 35085398 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 12/XX/2007 12/XX/2010 CA Refinance - Cash-out - Other Primary No B B B B
625488360 XXX XXX XXX 35085399 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 12/XX/2007 12/XX/2010 CA Refinance - Cash-out - Other Primary No B B B B
defense to foreclosure. Assignee liability.
625489148 XXX XXX XXX 35085400 credit 3 Missing Document: Missing Final 1003 2/XX/2008 CT Purchase Primary No C C C C
625489148 XXX XXX XXX 35085401 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 2/XX/2008 CT Purchase Primary No B B B B
within a reasonably practicable time after using credit score.
625489148 XXX XXX XXX 35085402 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2008 CT Purchase Primary No B B B B
an application date of 02/XX/2008 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2008.
625488011 XXX XXX XXX 35085403 credit 3 Missing Document: Missing Final 1003 7/XX/2007 MD Purchase Primary No C C C C
625488011 XXX XXX XXX 35085404 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 7/XX/2007 MD Purchase Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488011 XXX XXX XXX 35085405 compliance 2 (Doc Error) Initial GFE not provided 7/XX/2007 MD Purchase Primary No B B B B
625488011 XXX XXX XXX 35085406 compliance 1 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 7/XX/2007 MD Purchase Primary No A A A A 11/XX/2018 Yes 2018/XX/21: Received Final HUD
Security Instrument Notary Date of 07/XX/2007 used as disbursement date for
compliance testing.
625488011 XXX XXX XXX 35085407 compliance 1 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable 7/XX/2007 MD Purchase Primary No A A A A 11/XX/2018 Yes 2018/XX/21: Received Final HUD
Federal, State or Local compliance testing is unreliable.
625488011 XXX XXX XXX 35085408 compliance 1 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using 7/XX/2007 MD Purchase Primary No A A A A 11/XX/2018 Yes 2018/XX/21: Received Final HUD
an application date of 06/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2007. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625488011 XXX XXX XXX 35085409 compliance 2 Maryland Late Charge Grace Period Testing Note grace period less than minimum per state. 10 day grace period less than 15 day minimum per state (MD) 7/XX/2007 MD Purchase Primary No B B B B
625488011 XXX XXX XXX 35085410 compliance 2 Maryland Late Charge Percent and Amount Testing Note late charge exceeds maximum per state. 6% late charge exceeds 5% maximum per state (MD) 7/XX/2007 MD Purchase Primary No B B B B
625488011 XXX XXX XXX 35085411 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2007 7/XX/2008 MD Purchase Primary No B B B B
borrower.
625488011 XXX XXX XXX 35085412 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2007 7/XX/2008 MD Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488011 XXX XXX XXX 35085413 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2007 7/XX/2008 MD Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625488011 XXX XXX XXX 35085415 credit 3 Missing Valuation: Appraisal not provided. 7/XX/2007 MD Purchase Primary No C C C C
625488011 XXX XXX XXX 35085416 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2007 MD Purchase Primary No B B B B
an application date of 06/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2007.
625488877 XXX XXX XXX 35085428 compliance 2 (Missing Data) Last Rate Set Date Last Date Rate Set and Initial Rate Lock Date not provded. Worst Case Scenario 10/XX/2012 NJ Refinance - Rate/Term Primary Yes B B B B
between Creditor Application Date and Transaction Date used to determine rate
used for testing.
625488877 XXX XXX XXX 35085429 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2012 NJ Refinance - Rate/Term Primary Yes B B B B
an application date of 09/XX/2012 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2012.
625488877 XXX XXX XXX 35085430 compliance 2 (Missing Data) Unable to determine if loan is a same lender refi Original Lender was not able to be determined. Unable to determine if correct 10/XX/2012 10/XX/2015 NJ Refinance - Rate/Term Primary Yes B B B B
TILA rescission form was used.
625488877 XXX XXX XXX 35085431 compliance 2 Payoff Statement Missing Missing Payoff Statement: Unable to determine if a prepayment penalty was 10/XX/2012 NJ Refinance - Rate/Term Primary Yes B B B B
included in the pay-off which may impact high cost findings.
625488877 XXX XXX XXX 35085436 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2012 NJ Refinance - Rate/Term Primary Yes B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488877 XXX XXX XXX 35085437 compliance 2 RESPA - Initial Escrow Account Statement Missing RESPA: Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2012 NJ Refinance - Rate/Term Primary Yes B B B B
within the statute or implementing regulation, Regulation X, for these type of
violations.
625488877 XXX XXX XXX 35085438 compliance 2 RESPA Servicing Disclosure: Servicing Disclosure Statement Missing RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2012 NJ Refinance - Rate/Term Primary Yes B B B B
Statement. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488877 XXX XXX XXX 35085439 compliance 2 RESPA - Initial GFE Missing RESPA: Initial GFE not provided to Borrower(s). RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2012 NJ Refinance - Rate/Term Primary Yes B B B B
within the statute or implementing regulation, Regulation X, for these type of
violations.
625488877 XXX XXX XXX 35085440 compliance 2 Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. 10/XX/2012 10/XX/2015 NJ Refinance - Rate/Term Primary Yes B B B B
timing requirements.
625488877 XXX XXX XXX 35085441 compliance 2 (Doc Error) Initial GFE not provided 10/XX/2012 NJ Refinance - Rate/Term Primary Yes B B B B
625488877 XXX XXX XXX 35085442 compliance 2 TIL-MDIA - Initial TIL Not Provided within 3 Business Days of Application Unable to determine compliance with timing requirements due to missing Initial TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited 10/XX/2012 10/XX/2013 NJ Refinance - Rate/Term Primary Yes B B B B
Loan Application Date. as a defense to foreclosure. Assignee liability.
625488877 XXX XXX XXX 35085443 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2012 10/XX/2015 NJ Refinance - Rate/Term Primary Yes B B B B
defense to foreclosure. Assignee liability.
625488877 XXX XXX XXX 35085444 credit 3 Missing Valuation: Appraisal not provided. 10/XX/2012 NJ Refinance - Rate/Term Primary Yes C C C C
625489690 XXX XXX XXX 35085453 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2004 IL Refinance - Rate/Term Primary No B B B B
an application date of 04/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2004.
625489690 XXX XXX XXX 35085454 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2004 5/XX/2005 IL Refinance - Rate/Term Primary No B B B B
Loan Application Date.
625489690 XXX XXX XXX 35085455 credit 3 Missing Document: Missing Final 1003 5/XX/2004 IL Refinance - Rate/Term Primary No C C C C
625489690 XXX XXX XXX 35085456 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2004 5/XX/2005 IL Refinance - Rate/Term Primary No B B B B
Loan Application Date.
625488664 XXX XXX XXX 35085581 credit 3 Missing Document: Missing Final 1003 1/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488664 XXX XXX XXX 35085582 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 1/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
within a reasonably practicable time after using credit score.
625488664 XXX XXX XXX 35085583 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 1/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 12/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 07/XX/2005.
625488664 XXX XXX XXX 35085584 compliance 2 (Doc Error) Initial GFE not provided 1/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489375 XXX XXX XXX 35085641 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 03/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2006.
625489375 XXX XXX XXX 35085642 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489375 XXX XXX XXX 35085643 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489375 XXX XXX XXX 35085644 compliance 2 CHARM Booklet Disclosure Prior to Closing Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2007 4/XX/2008 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
CHARM Booklet, not provided to the borrower at least three (3) days prior to
consummation for a loan that did not start as an ARM.
625489610 XXX XXX XXX 35085666 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 2/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
within a reasonably practicable time after using credit score.
625489610 XXX XXX XXX 35085667 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489610 XXX XXX XXX 35085668 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2006 2/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
borrower within three (3) days of application.
625489610 XXX XXX XXX 35085669 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2006 2/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625489610 XXX XXX XXX 35085670 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Under disclosure is due to the lender utilizing an index value of 3.512% per the $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 2/XX/2006 2/XX/2009 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. approval, however the lowest index value available in the lookback period is for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
3.67417%. liability.
625488116 XXX XXX XXX 35085698 compliance 2 (Doc Error) Initial GFE not provided 8/XX/2003 FL Refinance - Cash-out - Other Primary No B B B B
625488116 XXX XXX XXX 35085700 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2003 FL Refinance - Cash-out - Other Primary No B B B B
an application date of 07/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2003.
625488374 XXX XXX XXX 35085712 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 5/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B
within a reasonably practicable time after using credit score.
625488374 XXX XXX XXX 35085713 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B
an application date of 04/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2005.
625488374 XXX XXX XXX 35085714 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2006 5/XX/2007 FL Refinance - Cash-out - Other Primary No B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625488374 XXX XXX XXX 35085715 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2006 5/XX/2007 FL Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488884 XXX XXX XXX 35085716 credit 3 Missing Document: Missing Final 1003 12/XX/2006 HI Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488884 XXX XXX XXX 35085717 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 12/XX/2006 HI Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 12/XX/2006 used as disbursement date for
compliance testing.
625488884 XXX XXX XXX 35085718 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2006 12/XX/2007 HI Refinance - Cash-out - Debt Consolidation Primary No B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625488884 XXX XXX XXX 35085719 compliance 2 Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. 12/XX/2006 12/XX/2009 HI Refinance - Cash-out - Debt Consolidation Primary No B B B B
timing requirements.
625488884 XXX XXX XXX 35085720 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from The TIL payment streams disclosed do not match the actual terms of the note. The $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 12/XX/2006 12/XX/2009 HI Refinance - Cash-out - Debt Consolidation Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. TIL indicates the loan was disclosed as a fixed rate, however the note terms for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
reflect that it actually was an ARM loan liability.
625488884 XXX XXX XXX 35085721 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 12/XX/2006, prior to TILA ROR - 3yrs for rescindable transactions. 12/XX/2006 12/XX/2009 HI Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 12/XX/2006.
625488884 XXX XXX XXX 35085722 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 12/XX/2006 12/XX/2009 HI Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625488884 XXX XXX XXX 35085723 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 12/XX/2006 12/XX/2009 HI Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625488884 XXX XXX XXX 35085724 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 12/XX/2006 HI Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 12/XX/2006 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 12/XX/2006.
625488016 XXX XXX XXX 35085770 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 12/XX/2004 LA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488016 XXX XXX XXX 35085772 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 12/XX/2004 LA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 12/XX/2004 used as disbursement date for
compliance testing.
625488016 XXX XXX XXX 35085773 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2004 12/XX/2005 LA Refinance - Cash-out - Debt Consolidation Primary No B B B B
borrower.
625488016 XXX XXX XXX 35085774 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2004 12/XX/2005 LA Refinance - Cash-out - Debt Consolidation Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488016 XXX XXX XXX 35085775 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 12/XX/2004, prior to TILA ROR - 3yrs for rescindable transactions. 12/XX/2004 12/XX/2007 LA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 12/XX/2004.
625488016 XXX XXX XXX 35085776 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 12/XX/2004 12/XX/2007 LA Refinance - Cash-out - Debt Consolidation Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625489113 XXX XXX XXX 35085780 credit 3 Missing Document: Missing Final 1003 7/XX/2003 MN Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489232 XXX XXX XXX 35085788 credit 3 Missing Document: Missing Final 1003 10/XX/2005 KS Refinance - Cash-out - Other Primary No C C C C
625489232 XXX XXX XXX 35085789 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2005 KS Refinance - Cash-out - Other Primary No B B B B
an application date of 09/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2005.
625489232 XXX XXX XXX 35085790 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2005 10/XX/2008 KS Refinance - Cash-out - Other Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625489003 XXX XXX XXX 35085791 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2004 CA Refinance - Cash-out - Home Improvement Primary No B B B B
an application date of 08/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/2004.
625489003 XXX XXX XXX 35085792 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2004 9/XX/2005 CA Refinance - Cash-out - Home Improvement Primary No B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625489003 XXX XXX XXX 35085793 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2004 9/XX/2005 CA Refinance - Cash-out - Home Improvement Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489003 XXX XXX XXX 35085794 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Under disclosure is due to the lender utilizing an index value of 1.910% per the $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 9/XX/2004 9/XX/2007 CA Refinance - Cash-out - Home Improvement Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. approval, however the lowest index value available in the lookback period is for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
1.21167%, in addition the Final TIL Finance Charge is under-disclosed due to liability.
incorrect payment stream between Final TIL and actual TIL calculation.
625489003 XXX XXX XXX 35085795 compliance 2 TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Truth in Lending Act: Actual Date(s) on Notice of Right to Cancel occurs prior TILA ROR - 3yrs for rescindable transactions. 9/XX/2004 9/XX/2007 CA Refinance - Cash-out - Home Improvement Primary No B B B B
Date to expected date(s).
625488797 XXX XXX XXX 35085806 credit 3 Missing Document: Missing Final 1003 5/XX/2007 MA Refinance - Cash-out - Other Primary Yes C C C C
625488797 XXX XXX XXX 35085807 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 5/XX/2007 MA Refinance - Cash-out - Other Primary Yes B B B B
625488797 XXX XXX XXX 35085808 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2007 MA Refinance - Cash-out - Other Primary Yes B B B B
an application date of 04/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2007.
625488797 XXX XXX XXX 35085809 compliance 2 (Missing Data) Unable to determine if loan is a same lender refi Original Lender was not able to be determined. Unable to determine if correct 5/XX/2007 5/XX/2011 MA Refinance - Cash-out - Other Primary Yes B B B B
TILA rescission form was used.
625488797 XXX XXX XXX 35085811 compliance 3 Massachusetts Borrower's Interest Tangible Net Benefit Test Massachusetts Home Loan: Unable to determine if mortgage loan was refinanced The regulations do not clarify the enforcement provisions of Mass. Gen. L. c. 5/XX/2007 MA Refinance - Cash-out - Other Primary Yes C C C C 2018/XX/28: Non Material - There is no express assignee liability for failure to 2018/XX/28: This exception is regarding whether a TNB actually existed, not
within 60 months without providing a tangible net benefit to the borrower due to 183. Accordingly, the consequences of a compliance failure remain unclear. In have the Massachusetts NTB form in the file. whether or not the worksheet is present. The worksheet is actually in the file,
missing prior loan information. particular, it is probable that a violation of the "borrower's interest" however the only TNB identified is cash out in excees of the points and fees
standard can be raised as a defense to, or otherwise impede, foreclosure. Also, charged - the HUD-1 shows cash out of $XXX and the fees charged exceeded this
it is possible that a violation of the "borrower's interest" standard would amount so that benefit does not appear to exist. It does not appear that there
constitute a violation of the Massachusetts unfair and deceptive acts and was a reduction in payment, loan term, or interest rate either. Need additional
practices statute. documentation to support loan passes TNB testing in order to clear exception.
625488797 XXX XXX XXX 35085812 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2007 5/XX/2008 MA Refinance - Cash-out - Other Primary Yes B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625488797 XXX XXX XXX 35085813 compliance 2 CHARM Booklet Disclosure Prior to Closing Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2007 5/XX/2008 MA Refinance - Cash-out - Other Primary Yes B B B B
CHARM Booklet, not provided to the borrower at least three (3) days prior to
consummation for a loan that did not start as an ARM.
625488727 XXX XXX XXX 35085819 credit 3 Missing Document: Missing Final 1003 No 6/XX/2007 NV Purchase Primary No C C C C
625488727 XXX XXX XXX 35085820 compliance 3 Missing Final HUD-1: HUD-1 Not Signed or Stamped Used For Fee Testing Missing Final HUD-1: HUD-1 Not Signed or Stamped used for any applicable No 6/XX/2007 NV Purchase Primary No D D D D 2018/XX/21: Received duplicate copy of the unsigned HUD previously provided.
Federal, State or Local compliance testing. Unable to clear exception.
625488727 XXX XXX XXX 35085821 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using No 6/XX/2007 NV Purchase Primary No B B B B
an application date of 05/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 12/XX/2006.
625488727 XXX XXX XXX 35085822 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions No 6/XX/2007 NV Purchase Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488720 XXX XXX XXX 35086030 credit 3 Missing Document: Missing Final 1003 1/XX/2006 FL Refinance - Cash-out - Other Primary No C C C C
625488720 XXX XXX XXX 35086031 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 1/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B
following clauses:
625488720 XXX XXX XXX 35086033 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 1/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B
an application date of 12/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 07/XX/2005.
625488720 XXX XXX XXX 35086034 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2006 1/XX/2007 FL Refinance - Cash-out - Other Primary No B B B B
borrower.
625488720 XXX XXX XXX 35086035 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2006 1/XX/2007 FL Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488720 XXX XXX XXX 35086036 compliance 2 Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. 1/XX/2006 1/XX/2009 FL Refinance - Cash-out - Other Primary No B B B B
timing requirements.
625488720 XXX XXX XXX 35086037 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 1/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B
Security Instrument Notary Date of 01/XX/2006 used as disbursement date for
compliance testing.
625488720 XXX XXX XXX 35086038 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 01/XX/2006, prior to TILA ROR - 3yrs for rescindable transactions. 1/XX/2006 1/XX/2009 FL Refinance - Cash-out - Other Primary No B B B B
Date three (3) business days from transaction date of 01/XX/2006.
625488531 XXX XXX XXX 35086048 credit 3 Missing Document: Missing Final 1003 9/XX/2007 PA Refinance - Cash-out - Other Primary No C C C C
625488531 XXX XXX XXX 35086049 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 9/XX/2007 PA Refinance - Cash-out - Other Primary No B B B B
625488531 XXX XXX XXX 35086050 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2007 PA Refinance - Cash-out - Other Primary No B B B B
an application date of 08/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2007.
625488531 XXX XXX XXX 35086051 compliance 2 Pennsylvania First Lien Late Charge Grace Period Testing Note grace period less than minimum per state. 10 day grace period is less than 15 day minimum per state (PA). 9/XX/2007 PA Refinance - Cash-out - Other Primary No B B B B
625488531 XXX XXX XXX 35086052 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 09/XX/2007, prior to TILA ROR - 3yrs for rescindable transactions. 9/XX/2007 9/XX/2010 PA Refinance - Cash-out - Other Primary No B B B B
Date three (3) business days from transaction date of 09/XX/2007.
625489715 XXX XXX XXX 35086161 credit 3 Missing Document: Missing Final 1003 4/XX/2004 IN Refinance - Cash-out - Debt Consolidation Primary No C C C C 2018/XX/21: Received a copy of the note which was in the original image file, no
new documentation provided and no note related exceptions on this loan. No
changes made.
625489715 XXX XXX XXX 35086163 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2004 IN Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 03/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2003.
625489715 XXX XXX XXX 35086164 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 04/XX/2004, prior to TILA ROR - 3yrs for rescindable transactions. 4/XX/2004 4/XX/2007 IN Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 04/XX/2004.
625489715 XXX XXX XXX 35086165 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 4/XX/2004 IN Refinance - Cash-out - Debt Consolidation Primary No B B B B
following clauses:
625489715 XXX XXX XXX 35086166 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 4/XX/2004 IN Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 04/XX/2004 used as disbursement date for
compliance testing.
625489693 XXX XXX XXX 35086167 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2006 TN Purchase Primary No B B B B
an application date of 02/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2006.
625489513 XXX XXX XXX 35086171 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2000 11/XX/2001 MD Refinance - Cash-out - Other Primary No B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625489386 XXX XXX XXX 35086179 credit 3 Missing Document: Missing Final 1003 9/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489386 XXX XXX XXX 35086180 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 9/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489386 XXX XXX XXX 35086181 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 08/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2006.
625488227 XXX XXX XXX 35086205 credit 3 Missing Document: Missing Final 1003 3/XX/2008 FL Refinance - Cash-out - Other Primary No C C C C
625488227 XXX XXX XXX 35086206 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2008 FL Refinance - Cash-out - Other Primary No B B B B
an application date of 02/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2008.
625488227 XXX XXX XXX 35086207 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2008 FL Refinance - Cash-out - Other Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488227 XXX XXX XXX 35086208 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2008 FL Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488201 XXX XXX XXX 35086222 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
an application date of 05/XX/2007 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 05/XX/2007.
625488201 XXX XXX XXX 35086223 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488201 XXX XXX XXX 35086224 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 5/XX/2007 5/XX/2010 CA Refinance - Cash-out - Other Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488097 XXX XXX XXX 35086232 credit 3 Missing Document: Missing Final 1003 2/XX/2005 IL Purchase Primary No C C C C
625488097 XXX XXX XXX 35086233 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2005 IL Purchase Primary No B B B B
an application date of 01/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2005.
625488097 XXX XXX XXX 35086234 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2005 2/XX/2006 IL Purchase Primary No B B B B
Loan Application Date.
625488097 XXX XXX XXX 35086235 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2005 2/XX/2006 IL Purchase Primary No B B B B
Loan Application Date.
625488810 XXX XXX XXX 35086357 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 8/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
within a reasonably practicable time after using credit score.
625488810 XXX XXX XXX 35086358 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 07/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2006.
625488810 XXX XXX XXX 35086359 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488810 XXX XXX XXX 35086360 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2006 8/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Loan Application Date.
625488810 XXX XXX XXX 35086361 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2006 8/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Loan Application Date.
625488810 XXX XXX XXX 35086362 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from The loan approval indicates the Index used was 3.94%. The closest Index $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 8/XX/2006 8/XX/2009 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. available in the look-back period is 4.11%. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488342 XXX XXX XXX 35086422 credit 3 Missing Document: FHA Case Number Assignment not provided 11/XX/1996 NJ Purchase Primary No C C C C
625488342 XXX XXX XXX 35086423 credit 3 Amendatory Clause is missing. Disclosure: FHA - Amendatory Clause (Government Documents) 11/XX/1996 NJ Purchase Primary No C C C C
625488342 XXX XXX XXX 35086424 credit 3 Real Estate Certification is missing. Disclosure: FHA - Real Estate Certification (Government Documents) 11/XX/1996 NJ Purchase Primary No C C C C
625488342 XXX XXX XXX 35086425 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from The Lender's TIL reflects MI expiring after 12 years, however the FHA MI premium $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 11/XX/1996 11/XX/1997 NJ Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. terms were for the life of the loan. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488252 XXX XXX XXX 35086468 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2007 VA Refinance - Rate/Term Primary No B B B B
an application date of 10/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 05/XX/2007.
625488792 XXX XXX XXX 35086516 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2008 NY Purchase Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488202 XXX XXX XXX 35086517 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2004 IL Refinance - Cash-out - Other Primary No B B B B
an application date of 06/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2004.
625489011 XXX XXX XXX 35086518 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2005 CA Purchase Primary No B B B B
an application date of 04/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2005.
625489011 XXX XXX XXX 35086519 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2005 CA Purchase Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489011 XXX XXX XXX 35086520 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2005 5/XX/2006 CA Purchase Primary No B B B B
Loan Application Date.
625489011 XXX XXX XXX 35086521 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2005 5/XX/2006 CA Purchase Primary No B B B B
Loan Application Date.
625489011 XXX XXX XXX 35086522 credit 3 Missing Document: Missing Final 1003 5/XX/2005 CA Purchase Primary No C C C C
625488177 XXX XXX XXX 35086613 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 05/XX/2007 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 05/XX/2007.
625488177 XXX XXX XXX 35086614 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488177 XXX XXX XXX 35086615 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2007 5/XX/2008 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625488177 XXX XXX XXX 35086616 credit 3 Missing Document: Missing Final 1003 5/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488024 XXX XXX XXX 35086682 compliance 2 TIL-MDIA 3-day Waiting Period - Corrected TIL for APR Inaccuracy Received Less Truth in Lending Act (Early TIL Disclosure): Corrected TIL for APR inaccuracy TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee 1/XX/2010 1/XX/2011 DE Purchase Primary No B B B B
than 3 Business Days from Consummation was not received by the borrower at least three (3) business days prior to liability.
closing.
625488024 XXX XXX XXX 35086683 compliance 2 Final TIL APR Under/Over Disclosed By Greater Than 0.125% Truth In Lending Act: Final TIL APR of XX.XX% is underdisclosed from calculated Unable to determine under disclosure due to missing Itemization of Amount TILA APR - subject to a 1 year SOL for affirmative claims, 3 years for 1/XX/2010 1/XX/2011 DE Purchase Primary No B B B B
APR of XX.XX% outside of 0.125% tolerance. Financed. The HUD reflects a seller credit of $XXX however it is not itemized rescindable transactions. Unlimited as a defense to foreclosure. Assignee
and has not been applied. liability.
625488024 XXX XXX XXX 35086684 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing Itemization of Amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 1/XX/2010 1/XX/2011 DE Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. Financed. The HUD reflects a seller credit of $XXX however it is not itemized for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
and has not been applied. liability.
625488991 XXX XXX XXX 35086700 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2007 5/XX/2008 RI Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
Loan Application Date.
625488991 XXX XXX XXX 35086701 credit 3 Missing Document: Missing Final 1003 5/XX/2007 RI Refinance - Cash-out - Debt Consolidation Primary Yes C C C C
625488991 XXX XXX XXX 35086702 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 5/XX/2007 5/XX/2008 RI Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
Loan Application Date.
625488991 XXX XXX XXX 35086703 compliance 2 Missing Document: Missing Lender's Initial 1003 No evidence of application date located in file. Compliance tests were run using 5/XX/2007 RI Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
an application date of 04/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2006.
625488473 XXX XXX XXX 35086704 credit 3 Missing Document: Missing Final 1003 7/XX/2004 PA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488473 XXX XXX XXX 35086706 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 7/XX/2004 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 07/XX/2004 used as disbursement date for
compliance testing.
625488473 XXX XXX XXX 35086707 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2004 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488473 XXX XXX XXX 35086708 compliance 2 Pennsylvania First Lien Late Charge Grace Period Testing Note grace period less than minimum per state. 10 day grace period less than 15 day minimum per state (PA) 7/XX/2004 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488473 XXX XXX XXX 35086709 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 07/XX/2004, prior to TILA ROR - 3yrs for rescindable transactions. 7/XX/2004 7/XX/2007 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 07/XX/2004.
625488473 XXX XXX XXX 35086710 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing amortization schedule. $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 7/XX/2004 7/XX/2007 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488473 XXX XXX XXX 35086711 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2004 7/XX/2007 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625488435 XXX XXX XXX 35086717 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 1/XX/2008 CA Refinance - Cash-out - Home Improvement Primary No B B B B
within a reasonably practicable time after using credit score.
625488435 XXX XXX XXX 35086718 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 1/XX/2008 CA Refinance - Cash-out - Home Improvement Primary No B B B B
an application date of 01/XX/2008 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2008.
625488435 XXX XXX XXX 35086719 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2008 1/XX/2009 CA Refinance - Cash-out - Home Improvement Primary No B B B B
Loan Application Date.
625488435 XXX XXX XXX 35086720 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2008 1/XX/2009 CA Refinance - Cash-out - Home Improvement Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488876 XXX XXX XXX 35086729 credit 3 Missing Document: Missing Final 1003 12/XX/2005 TX Purchase Primary No C C C C 2018/XX/21: Received another copy of the final HUD and partial appraisal,
however both documents were available in the original image file and no
exceptions apply related to them. No changes made.
625488876 XXX XXX XXX 35086730 credit 3 Missing Document: Security Instrument - Subject Lien not provided 12/XX/2005 TX Purchase Primary No D D D D
625488876 XXX XXX XXX 35086731 compliance 2 (Doc Error) Initial GFE not provided 12/XX/2005 TX Purchase Primary No B B B B
625488876 XXX XXX XXX 35086732 credit 3 Final Title Policy is missing. No evidence of title in file. 12/XX/2005 TX Purchase Primary No C C C C
625488876 XXX XXX XXX 35086733 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2005 12/XX/2006 TX Purchase Primary No B B B B
borrower.
625488876 XXX XXX XXX 35086734 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2005 12/XX/2006 TX Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488876 XXX XXX XXX 35086735 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 12/XX/2005 TX Purchase Primary No B B B B
an application date of 11/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2005.
625489505 XXX XXX XXX 35086786 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 9/XX/2006 9/XX/2007 NC Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489653 XXX XXX XXX 35086828 compliance 2 (Doc Error) Initial GFE not provided 12/XX/2003 NJ Purchase Primary Yes B B B B
625489653 XXX XXX XXX 35086829 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing TIL itemization $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 12/XX/2003 12/XX/2004 NJ Purchase Primary Yes B B B B
calculated Finance Charge of $XXX in the amount of $XXX. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488557 XXX XXX XXX 35086847 credit 3 Missing Document: Missing Final 1003 4/XX/2004 NJ Refinance - Cash-out - Other Primary Yes C C C C
625488557 XXX XXX XXX 35086848 compliance 2 (Doc Error) Initial GFE not provided 4/XX/2004 NJ Refinance - Cash-out - Other Primary Yes B B B B
625488557 XXX XXX XXX 35086850 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2004 NJ Refinance - Cash-out - Other Primary Yes B B B B
an application date of 03/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625488557 XXX XXX XXX 35086851 compliance 2 Payoff Statement Missing Missing Payoff Statement: Unable to determine if a prepayment penalty was 4/XX/2004 NJ Refinance - Cash-out - Other Primary Yes B B B B
included in the pay-off which may impact high cost findings.
625488557 XXX XXX XXX 35086852 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 4/XX/2004 4/XX/2007 NJ Refinance - Cash-out - Other Primary Yes B B B B
625488550 XXX XXX XXX 35086889 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 10/XX/2007 FL Refinance - Rate/Term Primary No B B B B
625489213 XXX XXX XXX 35086948 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2007 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 02/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625489213 XXX XXX XXX 35086949 compliance 2 Maryland Prepayment Penalty Test Maryland Prepayment Penalty: Prepayment penalty not permissible by state law; PPP Expired. Prepayment charge not allowed per state (MD)-max prepayment charge 3/XX/2007 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
however Note or Prepay Addendum provides specific language that prepay will not for MD loan is 2 months interest > 1/3 OPB-note states 6 months interest.
exceed maximum permitted by applicable law. Lender is XXX.
625489213 XXX XXX XXX 35086950 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
application due to missing information.
625489213 XXX XXX XXX 35086951 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
Loan Application Date.
625489568 XXX XXX XXX 35086983 credit 3 Missing Document: FHA Case Number Assignment not provided 3/XX/2003 GA Purchase Primary No C C C C
625489568 XXX XXX XXX 35086984 compliance 2 (Doc Error) Initial GFE not provided 3/XX/2003 GA Purchase Primary No B B B B
625489568 XXX XXX XXX 35086985 compliance 2 FHA Case Number Assignment Date Missing FHA Case # Assignment Date missing. Creditor application date used as FHA case # 3/XX/2003 GA Purchase Primary No B B B B
assignment date for purposes of any applicable compliance testing.
625489568 XXX XXX XXX 35086986 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2003 GA Purchase Primary No B B B B
an application date of 02/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625489568 XXX XXX XXX 35086987 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2003 3/XX/2004 GA Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625488563 XXX XXX XXX 35087015 credit 3 Missing Document: Missing Final 1003 No 2/XX/2007 FL Purchase Primary No C C C C
625488563 XXX XXX XXX 35087016 credit 3 Missing Valuation: Appraisal not provided No 2/XX/2007 FL Purchase Primary No C C C C
625488563 XXX XXX XXX 35087017 compliance 2 (Doc Error) Initial GFE not provided No 2/XX/2007 FL Purchase Primary No B B B B
625488563 XXX XXX XXX 35087019 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. No 2/XX/2007 FL Purchase Primary No B B B B
Security Instrument Notary Date of 02/XX/2007 used as disbursement date for
compliance testing.
625488563 XXX XXX XXX 35087020 compliance 3 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable No 2/XX/2007 FL Purchase Primary No D D D D
Federal, State or Local compliance testing is unreliable.
625488563 XXX XXX XXX 35087021 compliance 2 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using No 2/XX/2007 FL Purchase Primary No B B B B
an application date of 01/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. Due to missing HUD-1
or Closing Disclosure, no fees were used in testing.
625488563 XXX XXX XXX 35087022 compliance 2 ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA No 2/XX/2007 2/XX/2008 FL Purchase Primary No B B B B
borrower.
625488563 XXX XXX XXX 35087023 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA No 2/XX/2007 2/XX/2008 FL Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488563 XXX XXX XXX 35087024 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a No 2/XX/2007 2/XX/2008 FL Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625488352 XXX XXX XXX 35087125 credit 3 Missing Document: Missing Final 1003 3/XX/2008 CA Refinance - Rate/Term Primary No C C C C
625488352 XXX XXX XXX 35087126 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2008 CA Refinance - Rate/Term Primary No B B B B
an application date of 02/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625488352 XXX XXX XXX 35087127 compliance 2 (Missing Data) Unable to determine if loan is a same lender refi Original Lender was not able to be determined. Unable to determine if correct 3/XX/2008 3/XX/2011 CA Refinance - Rate/Term Primary No B B B B 2019/XX/25: Outside TILA SOL
TILA rescission form was used.
625488352 XXX XXX XXX 35087128 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2008 CA Refinance - Rate/Term Primary No B B B B
Disclosure to borrower. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488352 XXX XXX XXX 35087129 compliance 2 Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. 3/XX/2008 3/XX/2011 CA Refinance - Rate/Term Primary No B B B B
timing requirements.
625488352 XXX XXX XXX 35087130 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2008 3/XX/2011 CA Refinance - Rate/Term Primary No B B B B
defense to foreclosure. Assignee liability.
625488456 XXX XXX XXX 35087134 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 3/XX/2005 FL Purchase Second Home No B B B B
625488456 XXX XXX XXX 35087135 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 3/XX/2005 3/XX/2006 FL Purchase Second Home No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. financed. Under disclosure is due to a payment stream issue. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488687 XXX XXX XXX 35087150 credit 3 Missing Document: Missing Final 1003 9/XX/1998 KY Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488687 XXX XXX XXX 35087151 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/1998 KY Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 08/XX/1998 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625488380 XXX XXX XXX 35087205 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 3/XX/2005 NJ Purchase Primary Yes C C C C
625488380 XXX XXX XXX 35087206 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2005 3/XX/2006 NJ Purchase Primary Yes B B B B
defense to foreclosure. Assignee liability.
625489102 XXX XXX XXX 35087255 credit 3 Missing Document: Missing Final 1003 9/XX/2005 NJ Refinance - Cash-out - Other Primary Yes C C C C
625489102 XXX XXX XXX 35087256 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 9/XX/2005 NJ Refinance - Cash-out - Other Primary Yes B B B B
following clauses:
625489102 XXX XXX XXX 35087257 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 9/XX/2005 NJ Refinance - Cash-out - Other Primary Yes B B B B
within a reasonably practicable time after using credit score.
625489102 XXX XXX XXX 35087258 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2005 NJ Refinance - Cash-out - Other Primary Yes B B B B
an application date of 08/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625489102 XXX XXX XXX 35087259 compliance 3 New Jersey Home Loan (Late Charge) New Jersey Home Loan: Mortgage loan contains an impermissible late charge of 6% late charge exceeds 5% maximum per state (NJ). 10 day grace period less than Assignee Liability: Assignees and purchasers of New Jersey high cost home loans 9/XX/2005 NJ Refinance - Cash-out - Other Primary Yes C C C C
greater than 5.0% or a grace period less than 15 days. 15 day minimum per state (NJ) are subject to all affirmative claims and any defenses with respect to the loan
that the borrower could assert against the original creditor of the loan.
Section 6(c) of the Act also provides that a borrower acting only in an
individual capacity may assert against the creditor or any subsequent holder or
assignee: (1) Within six years of the closing of covered home loan, a violation
of the Act as an original action or as a defense, claim, or counterclaim; and
(2) At any time during the term of a high cost home loan a defense, claim or
counterclaim. The aforementioned may both be brought after an action to collect
on the home loan or foreclose on the collateral securing the home loan has been
initiated, the debt arising from the home loan has been accelerated, or the home
loan has become 60 days in default. Further, the Act contains a choice of law
provision permitting actions under either the New Jersey Consumer Fraud Act
("NJCFA"), which possibly allow for class actions, or the Act. The July 6, 2004
amendments clarify that a defense, claim, or counterclaim may only be brought in
an individual capacity and may not be asserted in a class action. Additionally,
the statute provides for punitive damages.
625489102 XXX XXX XXX 35087260 compliance 2 New Jersey Prepayment Penalty New Jersey Prepayment Penalty: No prepayment penalties are permissible in the 9/XX/2005 NJ Refinance - Cash-out - Other Primary Yes B B B B
state of New Jersey; however Note or Prepay Addendum provides specific language
that prepay will not exceed maximum permitted by applicable law.
625489102 XXX XXX XXX 35087261 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2005 9/XX/2006 NJ Refinance - Cash-out - Other Primary Yes B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625489102 XXX XXX XXX 35087262 compliance 2 CHARM Booklet Disclosure Prior to Closing Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2005 9/XX/2006 NJ Refinance - Cash-out - Other Primary Yes B B B B
CHARM Booklet, not provided to the borrower at least three (3) days prior to
consummation for a loan that did not start as an ARM.
625489102 XXX XXX XXX 35087263 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Index used by lender (2.78%) is below the minimum index available in the look $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 9/XX/2005 9/XX/2008 NJ Refinance - Cash-out - Other Primary Yes B B B B
calculated Finance Charge of $XXX in the amount of $XXX. back period (2.97%) for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489102 XXX XXX XXX 35087264 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 9/XX/2005 9/XX/2008 NJ Refinance - Cash-out - Other Primary Yes B B B B
625489556 XXX XXX XXX 35087265 credit 3 Missing Document: Missing Final 1003 8/XX/2005 CA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489556 XXX XXX XXX 35087266 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 8/XX/2005 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
within a reasonably practicable time after using credit score.
625489556 XXX XXX XXX 35087267 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2005 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 07/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625489556 XXX XXX XXX 35087268 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2005 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625489556 XXX XXX XXX 35087269 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2005 8/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625489556 XXX XXX XXX 35087270 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Under disclosure is due to the lender utilizing an index value of 2.61% per the $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 8/XX/2005 8/XX/2008 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. approval, however the lowest index value available in the look back period is for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
2.89%. liability.
625489556 XXX XXX XXX 35087271 compliance 2 CHARM Booklet Disclosure Status Unable to determine if loan file contains CHARM Booklet due to missing TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2005 8/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
information.
625488333 XXX XXX XXX 35087278 credit 3 Missing Document: Missing Final 1003 6/XX/2004 KY Refinance - Cash-out - Debt Consolidation Primary Yes C C C C
625488333 XXX XXX XXX 35087279 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 6/XX/2004 KY Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488333 XXX XXX XXX 35087280 compliance 2 (Doc Error) Initial GFE not provided 6/XX/2004 KY Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
625488333 XXX XXX XXX 35087281 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 6/XX/2004 KY Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
Security Instrument Notary Date of 06/XX/2004 used as disbursement date for
compliance testing.
625488333 XXX XXX XXX 35087282 compliance 1 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable 6/XX/2004 KY Refinance - Cash-out - Debt Consolidation Primary Yes A A A A 9/XX/2019 Yes 2019/XX/30: Exception cleared.
Federal, State or Local compliance testing is unreliable.
625488333 XXX XXX XXX 35087283 compliance 1 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using 6/XX/2004 KY Refinance - Cash-out - Debt Consolidation Primary Yes A A A A 9/XX/2019 Yes 2019/XX/30: Exception cleared.
an application date of 05/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. Due to missing HUD-1
or Closing Disclosure, no fees were used in testing.
625488333 XXX XXX XXX 35087284 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 6/XX/2004 6/XX/2007 KY Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
625488333 XXX XXX XXX 35087285 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2004 6/XX/2007 KY Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
defense to foreclosure. Assignee liability.
625488333 XXX XXX XXX 35087286 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2004 KY Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
an application date of 05/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625489058 XXX XXX XXX 35087370 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2002 OH Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 6/XX/2002 which is 1 months prior to consummation. A 7
month lookback was used to determine this application date. The final date used
for testing was 1/XX/2002.
625488403 XXX XXX XXX 35087476 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 3/XX/2005 PA Purchase Primary No B B B B
625488115 XXX XXX XXX 35087481 compliance 1 (Missing Doc) Incomplete loan images/file Image file not provided. 5/XX/2009 PA Purchase Primary No A A A A 5/XX/2019 Yes 2019/XX/21: TD provided
625488115 XXX XXX XXX 35087482 credit 3 Missing Document: FHA Mortgage Insurance Certificate not provided 5/XX/2009 PA Purchase Primary No C C C C
625489103 XXX XXX XXX 35087483 compliance 1 ILAPLD - Missing Certificate of Compliance/Exemption IL Cook County (SB 1167) - Certificate of Compliance or Exemption not attached Although assignees do not appear to be exposed to liability arising from a 2/XX/2009 IL Purchase Primary No A A A A 4/XX/2019 Yes 2019/XX/15: Upon further review, exception has been cleared.
to mortgage for recording. violation of SB 1167, there is some ambiguity related to the possibility of a
courts determination and the potential reputational risk associated with
predatory lending.
625488817 XXX XXX XXX 35087509 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2003 3/XX/2006 IL Refinance - Rate/Term Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625488817 XXX XXX XXX 35087510 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2003 IL Refinance - Rate/Term Primary No B B B B
an application date of 02/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2003.
625489040 XXX XXX XXX 35087533 credit 3 Missing Document: FHA Case Number Assignment not provided 9/XX/2009 NJ Refinance - Rate/Term Primary Yes C C C C
625489040 XXX XXX XXX 35087534 compliance 2 FHA Case Number Assignment Date Missing FHA Case # Assignment Date missing. Creditor application date used as FHA case # 9/XX/2009 NJ Refinance - Rate/Term Primary Yes B B B B
assignment date for purposes of any applicable compliance testing.
625488571 XXX XXX XXX 35087565 credit 3 Missing Document: FHA Case Number Assignment not provided 12/XX/2008 WA Refinance - Rate/Term Primary No C C C C
625488571 XXX XXX XXX 35087566 credit 3 Missing Document: HUD/VA 92900-A not provided 12/XX/2008 WA Refinance - Rate/Term Primary No C C C C
625488571 XXX XXX XXX 35087567 compliance 2 FHA Case Number Assignment Date Missing FHA Case # Assignment Date missing. Creditor application date used as FHA case # 12/XX/2008 WA Refinance - Rate/Term Primary No B B B B
assignment date for purposes of any applicable compliance testing.
625488571 XXX XXX XXX 35087568 compliance 2 Washington Residential Mortgage Loan (Disclosure of Material Terms Not Provided) Washington HB 2770: Mortgage loan file does not contain a disclosure summary of The Act does not appear to provide for assignee liability. 12/XX/2008 WA Refinance - Rate/Term Primary No B B B B
all material terms provided to borrower.
625488571 XXX XXX XXX 35087569 compliance 2 Right of Rescission Timing - Receipt Date Missing Missing RTC Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. 12/XX/2008 12/XX/2011 WA Refinance - Rate/Term Primary No B B B B
timing requirements.
625488571 XXX XXX XXX 35087570 compliance 1 Missing Final HUD-1: Estimated HUD-1 Used For Fee Testing Missing Final HUD-1: Estimated HUD-1 used for any applicable Federal, State or 12/XX/2008 WA Refinance - Rate/Term Primary No A A A A 5/XX/2019 Yes 2019/XX/22: Received Final HUD
Local compliance testing.
625488329 XXX XXX XXX 35087574 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 6/XX/2009 6/XX/2012 NJ Refinance - Rate/Term Primary Yes B B B B
625488329 XXX XXX XXX 35087575 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2009 NJ Refinance - Rate/Term Primary Yes B B B B
an application date of 05/XX/2009 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 12/XX/2008.
625488329 XXX XXX XXX 35087576 compliance 2 Payoff Statement Missing Missing Payoff Statement: Unable to determine if a prepayment penalty was 6/XX/2009 NJ Refinance - Rate/Term Primary Yes B B B B
included in the pay-off which may impact high cost findings.
625488329 XXX XXX XXX 35087577 credit 3 Missing Valuation: Appraisal not provided 6/XX/2009 NJ Refinance - Rate/Term Primary Yes C C C C
625488237 XXX XXX XXX 35087582 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2008 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 08/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2008.
625488100 XXX XXX XXX 35087681 credit 3 Missing Valuation: Appraisal not provided 12/XX/2004 PA Refinance - Cash-out - Other Primary No C C C C
625488633 XXX XXX XXX 35087747 credit 3 Missing Document: FHA Mortgage Insurance Certificate not provided 7/XX/2009 FL Refinance - Rate/Term Primary No C C C C
625488633 XXX XXX XXX 35087748 compliance 2 TIL APR Tolerance Irregular Transaction Truth In Lending Act: Final TIL APR of XX.XX% is underdisclosed from calculated The lender used an index of 0.51% which is not available in the lookback period. TILA APR - subject to a 1 year SOL for affirmative claims, 3 years for 7/XX/2009 7/XX/2012 FL Refinance - Rate/Term Primary No B B B B
APR of XX.XX% outside of 0.125% tolerance. The lowest index of 0.46% results in a higher payment for the final paystream rescindable transactions. Unlimited as a defense to foreclosure. Assignee
than the TIL disclosed.. liability.
625488633 XXX XXX XXX 35087749 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from The lender used an index of 0.51% which is not available in the lookback period. $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 7/XX/2009 7/XX/2012 FL Refinance - Rate/Term Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. The lowest index of 0.46% results in a higher payment for the final paystream for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
than the TIL disclosed.. liability.
625488477 XXX XXX XXX 35087750 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 1/XX/2008 1/XX/2011 FL Refinance - Cash-out - Other Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625488477 XXX XXX XXX 35087751 credit 3 Missing Valuation: Appraisal not provided 1/XX/2008 FL Refinance - Cash-out - Other Primary No C C C C
625488408 XXX XXX XXX 35087754 credit 3 Final Title Policy is missing. No evidence of title in file. 4/XX/2008 UT Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488408 XXX XXX XXX 35087755 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2008 UT Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 03/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2007.
625488408 XXX XXX XXX 35087756 credit 3 Missing Document: Appraisal not provided 4/XX/2008 UT Refinance - Cash-out - Debt Consolidation Primary No D D D D
625488499 XXX XXX XXX 35087822 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2007 MN Refinance - Rate/Term Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488548 XXX XXX XXX 35087915 credit 3 Missing Document: Missing Final 1003 10/XX/2007 MD Refinance - UTD Primary No C C C C
625488548 XXX XXX XXX 35087916 compliance 2 (Doc Error) Initial GFE not provided 10/XX/2007 MD Refinance - UTD Primary No B B B B
625488548 XXX XXX XXX 35087917 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 10/XX/2007 MD Refinance - UTD Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488548 XXX XXX XXX 35087918 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 10/XX/2007 MD Refinance - UTD Primary No C C C C
625488548 XXX XXX XXX 35087920 compliance 1 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable 10/XX/2007 MD Refinance - UTD Primary No A A A A 12/XX/2018 Yes 2018/XX/19: Received final HUD clearing issue
Federal, State or Local compliance testing is unreliable.
625488548 XXX XXX XXX 35087921 compliance 1 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using 10/XX/2007 MD Refinance - UTD Primary No A A A A 12/XX/2018 Yes 2018/XX/19: Received final HUD clearing issue
an application date of 09/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2007. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625488548 XXX XXX XXX 35087922 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 10/XX/2007 10/XX/2010 MD Refinance - UTD Primary No B B B B
625488548 XXX XXX XXX 35087923 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2007 10/XX/2010 MD Refinance - UTD Primary No B B B B
defense to foreclosure. Assignee liability.
625488548 XXX XXX XXX 35087924 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2007 MD Refinance - UTD Primary No B B B B
an application date of 09/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2007.
625488231 XXX XXX XXX 35087950 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 7/XX/2005 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488231 XXX XXX XXX 35087951 compliance 2 TILA HELOC - Billing Rights Disclosure Not Provided Timely Truth in Lending Act (HELOC): "Billing Rights" disclosure not provided to TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2005 7/XX/2008 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
borrower at time of account opening. defense to foreclosure. Assignee liability.
625488231 XXX XXX XXX 35087952 compliance 2 Truth in Lending Act (HELOC): Fee amounts for testing were sourced from one or Truth in Lending Act (HELOC): Fees disclosed on Final HUD1 exceed those 7/XX/2005 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
more fee documents in file containing higher amounts than that reflected on disclosed in HELOC Agreement. Fees from Itemization used in any federal, state,
HELOC Agreement. and local high cost testing
625488375 XXX XXX XXX 35088006 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2004 MI Refinance - Cash-out - Other Primary No B B B B
an application date of 09/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 04/XX/2004.
625488375 XXX XXX XXX 35088007 compliance 2 Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Unable to determine compliance with timing requirements due to missing Initial Assignee liability is unclear. Purchasers and assignees would not appear to be 10/XX/2004 MI Refinance - Cash-out - Other Primary No B B B B
Not Provided Timely) Loan Application Date. liable for violations of the Act, except to the extent involved I violations
arising from servicing or collecting.
625488375 XXX XXX XXX 35088008 compliance 2 Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided Unable to determine compliance with timing requirements due to missing Initial Assignee liability is unclear. Purchasers and assignees would not appear to be 10/XX/2004 MI Refinance - Cash-out - Other Primary No B B B B
Timely Loan Application Date. liable for violations of the Act, except to the extent involved I violations
arising from servicing or collecting.
625488375 XXX XXX XXX 35088009 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2004 10/XX/2005 MI Refinance - Cash-out - Other Primary No B B B B
Loan Application Date.
625488375 XXX XXX XXX 35088010 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2004 10/XX/2005 MI Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488375 XXX XXX XXX 35088011 compliance 2 Michigan Consumer Mortgage Protection Act (Counseling Agencies List Timing) Michigan Consumer Mortgage Protection Act: List of HUD-approved credit 10/XX/2004 MI Refinance - Cash-out - Other Primary No B B B B
counseling agencies not provided to borrower at the time of application.
625489296 XXX XXX XXX 35088075 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 3/XX/2008 FL Refinance - Rate/Term Primary No C C C C
625489296 XXX XXX XXX 35088076 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2008 FL Refinance - Rate/Term Primary No B B B B
Disclosure to borrower. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489719 XXX XXX XXX 35088107 credit 3 Missing Document: Credit Report not provided 10/XX/2007 CA Refinance - Rate/Term Primary No D D D D
625489719 XXX XXX XXX 35088108 credit 3 Final Title Policy is missing. No evidence of title in file. 10/XX/2007 CA Refinance - Rate/Term Primary No C C C C
625489719 XXX XXX XXX 35088109 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2007 CA Refinance - Rate/Term Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625487933 XXX XXX XXX 35088120 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2007 AZ Purchase Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489374 XXX XXX XXX 35088139 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2006 GA Purchase Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489374 XXX XXX XXX 35088140 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2006 9/XX/2007 GA Purchase Primary No B B B B
borrower.
625489374 XXX XXX XXX 35088141 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2006 9/XX/2007 GA Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489167 XXX XXX XXX 35088157 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 4/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489167 XXX XXX XXX 35088158 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489167 XXX XXX XXX 35088159 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625487943 XXX XXX XXX 35088167 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 5/XX/2006 5/XX/2009 NC Refinance - Rate/Term Primary No B B B B
625487943 XXX XXX XXX 35088168 credit 3 Missing Document: Missing Final 1003 5/XX/2006 NC Refinance - Rate/Term Primary No C C C C
625487943 XXX XXX XXX 35088169 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2006 NC Refinance - Rate/Term Primary No B B B B
an application date of 04/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 12/XX/2005.
625487943 XXX XXX XXX 35088170 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2006 NC Refinance - Rate/Term Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625487924 XXX XXX XXX 35088212 compliance 2 Payoff Statement Missing Missing Payoff Statement: Unable to determine if a prepayment penalty was 9/XX/2004 MA Refinance - Cash-out - Home Improvement Primary No B B B B
included in the pay-off which may impact high cost findings.
625488083 XXX XXX XXX 35088222 credit 3 Missing Document: Missing Final 1003 3/XX/2004 VA Refinance - Rate/Term Primary No C C C C
625488083 XXX XXX XXX 35088223 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2004 VA Refinance - Rate/Term Primary No B B B B
an application date of 02/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2004.
625488083 XXX XXX XXX 35088224 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2004 VA Refinance - Rate/Term Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488083 XXX XXX XXX 35088225 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2004 3/XX/2007 VA Refinance - Rate/Term Primary No B B B B
defense to foreclosure. Assignee liability.
625488084 XXX XXX XXX 35088252 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2006 MD Purchase Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488084 XXX XXX XXX 35088253 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 3/XX/2006 MD Purchase Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488084 XXX XXX XXX 35088254 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2006 3/XX/2007 MD Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625488709 XXX XXX XXX 35088255 compliance 2 TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit 3/XX/2003 3/XX/2006 NY Refinance - Rate/Term Primary No B B B B
(Circuit 2, 5, 7, 8, 9, 10 or DC) Model Form for a refinancing by the same creditor. The H-8 form was used, the courts, the continuing risk that the borrower may have an extended right to
H-9 form should have been used. rescind (3 additional years) if a creditor uses the incorrect Model Form
remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625488132 XXX XXX XXX 35088285 credit 3 Missing Document: Missing Final 1003 8/XX/2003 MI Refinance - Rate/Term Investment No C C C C
625488132 XXX XXX XXX 35088286 compliance 2 (Doc Error) Initial GFE not provided 8/XX/2003 MI Refinance - Rate/Term Investment No B B B B
625488132 XXX XXX XXX 35088287 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2003 MI Refinance - Rate/Term Investment No B B B B
an application date of 07/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2003.
625488698 XXX XXX XXX 35088304 credit 3 Missing Document: Missing Final 1003 4/XX/2010 FL Refinance - UTD Primary No C C C C
625488698 XXX XXX XXX 35088305 credit 3 Missing Document: FHA Case Number Assignment not provided 4/XX/2010 FL Refinance - UTD Primary No C C C C
625488698 XXX XXX XXX 35088306 credit 3 Missing Document: FHA Mortgage Insurance Certificate not provided 4/XX/2010 FL Refinance - UTD Primary No C C C C
625488698 XXX XXX XXX 35088307 credit 3 Missing Document: HUD/VA 92900-A not provided 4/XX/2010 FL Refinance - UTD Primary No C C C C
625488698 XXX XXX XXX 35088308 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 4/XX/2010 FL Refinance - UTD Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488698 XXX XXX XXX 35088309 compliance 2 (Doc Error) Initial GFE not provided 4/XX/2010 FL Refinance - UTD Primary No B B B B
625488698 XXX XXX XXX 35088310 compliance 1 Missing details of FHA UFMIP (ie. financed vs cash portions). Testing is 4/XX/2010 FL Refinance - UTD Primary No A A A A 12/XX/2018 Yes 2018/XX/05: Final HUD Provided clearing issue
incomplete.
625488698 XXX XXX XXX 35088311 credit 3 Final Title Policy is missing. No evidence of title in file. 4/XX/2010 FL Refinance - UTD Primary No C C C C
625488698 XXX XXX XXX 35088312 compliance 2 (Missing Data) Last Rate Set Date Last Date Rate Set and Initial Rate Lock Date not provded. Worst Case Scenario 4/XX/2010 FL Refinance - UTD Primary No B B B B
between Creditor Application Date and Transaction Date used to determine rate
used for testing.
625488698 XXX XXX XXX 35088314 compliance 2 FHA Case Number Assignment Date Missing FHA Case # Assignment Date missing. Creditor application date used as FHA case # 4/XX/2010 FL Refinance - UTD Primary No B B B B
assignment date for purposes of any applicable compliance testing.
625488698 XXX XXX XXX 35088315 compliance 1 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable 4/XX/2010 FL Refinance - UTD Primary No A A A A 12/XX/2018 Yes 2018/XX/05: Final HUD received clearing issue
Federal, State or Local compliance testing is unreliable.
625488698 XXX XXX XXX 35088316 compliance 1 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using 4/XX/2010 FL Refinance - UTD Primary No A A A A 12/XX/2018 Yes 2018/XX/05: Final HUD received clearing issue
an application date of 03/XX/2010 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2010. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625488698 XXX XXX XXX 35088317 compliance 1 RESPA (2010) – Written Service Provider List Missing Unable to determine if the borrower received a list of service providers due to RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2010 FL Refinance - UTD Primary No A A A A 12/XX/2018 Yes 2018/XX/05: Final HUD received clearing issue
missing information. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488698 XXX XXX XXX 35088318 compliance 2 RESPA Servicing Disclosure: Servicing Disclosure Statement Missing RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2010 FL Refinance - UTD Primary No B B B B
Statement. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488698 XXX XXX XXX 35088319 compliance 2 RESPA - Initial GFE Missing RESPA: Initial GFE not provided to Borrower(s). RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2010 FL Refinance - UTD Primary No B B B B
within the statute or implementing regulation, Regulation X, for these type of
violations.
625488698 XXX XXX XXX 35088320 compliance 2 TIL-MDIA - Initial TIL Missing Truth in Lending Act (Early TIL Disclosure): Initial TIL was not provided to the TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited 4/XX/2010 4/XX/2011 FL Refinance - UTD Primary No B B B B
borrower. as a defense to foreclosure. Assignee liability.
625488698 XXX XXX XXX 35088321 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 4/XX/2010 4/XX/2013 FL Refinance - UTD Primary No B B B B
625488698 XXX XXX XXX 35088322 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 4/XX/2010 4/XX/2013 FL Refinance - UTD Primary No B B B B
defense to foreclosure. Assignee liability.
625488698 XXX XXX XXX 35088323 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2010 FL Refinance - UTD Primary No B B B B
an application date of 03/XX/2010 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2010.
625488698 XXX XXX XXX 35088324 compliance 2 RESPA - Initial Escrow Account Statement Missing RESPA: Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2010 FL Refinance - UTD Primary No B B B B
within the statute or implementing regulation, Regulation X, for these type of
violations.
625489558 XXX XXX XXX 35088341 credit 3 Missing Document: Missing Final 1003 No 7/XX/1999 TX Purchase Primary No C C C C
625489558 XXX XXX XXX 35088343 compliance 3 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable No 7/XX/1999 TX Purchase Primary No D D D D
Federal, State or Local compliance testing is unreliable.
625489558 XXX XXX XXX 35088344 compliance 2 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using No 7/XX/1999 TX Purchase Primary No B B B B
an application date of 06/XX/1999 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/1999. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625489558 XXX XXX XXX 35088345 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a No 7/XX/1999 7/XX/2000 TX Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625489558 XXX XXX XXX 35088347 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off No 7/XX/1999 TX Purchase Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489558 XXX XXX XXX 35088348 compliance 2 (Doc Error) Initial GFE not provided No 7/XX/1999 TX Purchase Primary No B B B B
625487937 XXX XXX XXX 35088349 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 7/XX/2007 WI Refinance - Rate/Term Primary No B B B B
within a reasonably practicable time after using credit score.
625487937 XXX XXX XXX 35088350 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2007 WI Refinance - Rate/Term Primary No B B B B
an application date of 07/XX/2007 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 07/XX/2007.
625487937 XXX XXX XXX 35088351 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2007 7/XX/2008 WI Refinance - Rate/Term Primary No B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625487937 XXX XXX XXX 35088352 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2007 7/XX/2008 WI Refinance - Rate/Term Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488466 XXX XXX XXX 35088384 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 3/XX/2007 RI Purchase Primary Yes B B B B
625488466 XXX XXX XXX 35088385 compliance 3 Rhode Island Home Loan (Invoices for Third Party Fees Not in File - Unable to Rhode Island Home Loan: No documentation in loan file to confirm third party A court, as injunctive relieve to an aggrieved consumer, may issue an order or 3/XX/2007 RI Purchase Primary Yes C C C C
Determined if Bona Fide) fees listed on the HUD-1. injunction barring any judicial or non-judicial foreclosure or other lender
action under the mortgage or deed of trust securing any home mortgage loan which
violates this chapter (RI Stat 34-25.2-8)
625488466 XXX XXX XXX 35088386 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 RI Purchase Primary Yes B B B B
borrower.
625488466 XXX XXX XXX 35088387 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 RI Purchase Primary Yes B B B B
CHARM Booklet, not provided to the borrower.
625488466 XXX XXX XXX 35088388 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2007 3/XX/2008 RI Purchase Primary Yes B B B B
defense to foreclosure. Assignee liability.
625488466 XXX XXX XXX 35088389 compliance 2 (Doc Error) Initial GFE not provided 3/XX/2007 RI Purchase Primary Yes B B B B
625488466 XXX XXX XXX 35088390 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2007 RI Purchase Primary Yes B B B B
Disclosure to borrower. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488566 XXX XXX XXX 35088391 credit 3 Missing Document: Missing Final 1003 No 9/XX/2005 NY Purchase Primary No C C C C
625488566 XXX XXX XXX 35088392 compliance 2 (Doc Error) Initial GFE not provided No 9/XX/2005 NY Purchase Primary No B B B B
625488566 XXX XXX XXX 35088394 compliance 3 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable No 9/XX/2005 NY Purchase Primary No D D D D
Federal, State or Local compliance testing is unreliable.
625488566 XXX XXX XXX 35088395 compliance 2 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using No 9/XX/2005 NY Purchase Primary No B B B B
an application date of 08/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2005. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625488566 XXX XXX XXX 35088396 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a No 9/XX/2005 9/XX/2006 NY Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625489547 XXX XXX XXX 35088412 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2007 NJ Refinance - Rate/Term Primary Yes B B B B
an application date of 06/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2007.
625489547 XXX XXX XXX 35088413 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2007 NJ Refinance - Rate/Term Primary Yes B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489547 XXX XXX XXX 35088414 compliance 2 (Doc Error) Initial GFE not provided 7/XX/2007 NJ Refinance - Rate/Term Primary Yes B B B B
625488394 XXX XXX XXX 35088439 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 8/XX/2006 IN Refinance - Cash-out - Debt Consolidation Primary Yes C C C C
625488394 XXX XXX XXX 35088440 compliance 2 ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2006 8/XX/2007 IN Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
borrower within three (3) days of application.
625488287 XXX XXX XXX 35088679 credit 3 Missing Document: Missing Final 1003 7/XX/2006 WI Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488287 XXX XXX XXX 35088680 compliance 2 Note Error: Note grace period days less than minimum per state Grace period not allowed per state (WI) – min grace period for WI is 15 days - 7/XX/2006 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
note states 10 days
625488287 XXX XXX XXX 35088681 compliance 2 Note Error: Note late charge percentage exceeds maximum per state Late charge not allowed per state (WI) - max late charge for WI is 5% - note 7/XX/2006 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
states 6%
625488287 XXX XXX XXX 35088682 compliance 2 (Doc Error) Initial GFE not provided 7/XX/2006 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488287 XXX XXX XXX 35088683 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 7/XX/2006 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488287 XXX XXX XXX 35088684 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2006 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 06/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2006.
625488287 XXX XXX XXX 35088685 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2006 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489076 XXX XXX XXX 35088703 compliance 2 (Missing Data) Unable to determine if loan is a same lender refi Original Lender was not able to be determined. Unable to determine if correct 12/XX/2007 12/XX/2010 GA Refinance - Rate/Term Primary No B B B B
TILA rescission form was used.
625489718 XXX XXX XXX 35088705 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 12/XX/2007 NJ Purchase Primary Yes B B B B
an application date of 12/XX/2007 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 12/XX/2007.
625489718 XXX XXX XXX 35088706 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2007 NJ Purchase Primary Yes B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489718 XXX XXX XXX 35088707 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 12/XX/2007 NJ Purchase Primary Yes C C C C
625489591 XXX XXX XXX 35088792 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2007 IL Refinance - Rate/Term Primary No B B B B
an application date of 11/XX/2007 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2007.
625488295 XXX XXX XXX 35088929 credit 3 Missing Document: Missing Final 1003 8/XX/2007 CA Refinance - Cash-out - Other Investment No C C C C
625488295 XXX XXX XXX 35088930 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2007 CA Refinance - Cash-out - Other Investment No B B B B
an application date of 07/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 07/XX/2007.
625488319 XXX XXX XXX 35088998 credit 3 Final Title Policy is missing. No evidence of title in file. 4/XX/2006 NC Refinance - Cash-out - Other Primary No C C C C
625488319 XXX XXX XXX 35088999 credit 3 Initial Rate Lock rate date is not documented in file. 4/XX/2006 NC Refinance - Cash-out - Other Primary No C C C C
625488319 XXX XXX XXX 35089000 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 4/XX/2006 NC Refinance - Cash-out - Other Primary No B B B B
within a reasonably practicable time after using credit score.
625488319 XXX XXX XXX 35089001 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2006 NC Refinance - Cash-out - Other Primary No B B B B
an application date of 03/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2005.
625488319 XXX XXX XXX 35089002 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 04/XX/2006, prior to TILA ROR - 3yrs for rescindable transactions. 4/XX/2006 4/XX/2009 NC Refinance - Cash-out - Other Primary No B B B B
Date three (3) business days from transaction date of 04/XX/2006.
625488319 XXX XXX XXX 35089003 compliance 2 (Missing Data) Unable to determine if loan is a same lender refi Original Lender was not able to be determined. Unable to determine if correct 4/XX/2006 4/XX/2009 NC Refinance - Cash-out - Other Primary No B B B B
TILA rescission form was used.
625488319 XXX XXX XXX 35089004 compliance 2 Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance Truth in Lending Act: Unable to determine if Notice of Right to Cancel was TILA ROR Form - Because this issue is not uniformly settled among the circuit 4/XX/2006 4/XX/2009 NC Refinance - Cash-out - Other Primary No B B B B
executed on the proper Model Form. The H-9 form was used instead of the H-8 courts, the continuing risk that the borrower may have an extended right to
form, however, the loan file does not contain evidence that the refinance was by rescind (3 additional years) if a creditor uses the incorrect Model Form
the original creditor. remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625488662 XXX XXX XXX 35089418 credit 3 Missing Document: Missing Final 1003 Yes 4/XX/2004 NY Refinance - UTD Primary No C C C C
625488662 XXX XXX XXX 35089419 credit 3 Missing Document: Security Instrument - Subject Lien not provided Yes 4/XX/2004 NY Refinance - UTD Primary No D D D D
625488662 XXX XXX XXX 35089420 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a Yes 4/XX/2004 4/XX/2007 NY Refinance - UTD Primary No B B B B
defense to foreclosure. Assignee liability.
625488662 XXX XXX XXX 35089421 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off Yes 4/XX/2004 NY Refinance - UTD Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488662 XXX XXX XXX 35089422 compliance 2 (Doc Error) Initial GFE not provided Yes 4/XX/2004 NY Refinance - UTD Primary No B B B B
625488662 XXX XXX XXX 35089423 credit 3 Final Title Policy is missing. No evidence of title in file. Yes 4/XX/2004 NY Refinance - UTD Primary No C C C C
625488662 XXX XXX XXX 35089424 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. Yes 4/XX/2004 NY Refinance - UTD Primary No B B B B
Security Instrument Notary Date of 04/XX/2004 used as disbursement date for
compliance testing.
625488662 XXX XXX XXX 35089425 compliance 3 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable Yes 4/XX/2004 NY Refinance - UTD Primary No D D D D
Federal, State or Local compliance testing is unreliable.
625488662 XXX XXX XXX 35089426 compliance 2 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using Yes 4/XX/2004 NY Refinance - UTD Primary No B B B B
an application date of 03/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. Due to missing HUD-1
or Closing Disclosure, no fees were used in testing.
625488662 XXX XXX XXX 35089427 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. Yes 4/XX/2004 4/XX/2007 NY Refinance - UTD Primary No B B B B
625488662 XXX XXX XXX 35089428 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver Yes 4/XX/2004 NY Refinance - UTD Primary No B B B B
following clauses:
625487911 XXX XXX XXX 35089478 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2006 MO Refinance - Rate/Term Primary No B B B B
an application date of 04/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625487911 XXX XXX XXX 35089479 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2006 MO Refinance - Rate/Term Primary No B B B B
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625487911 XXX XXX XXX 35089480 compliance 2 TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Truth in Lending Act: Actual Date(s) on Notice of Right to Cancel occurs prior TILA ROR - 3yrs for rescindable transactions. 5/XX/2006 5/XX/2009 MO Refinance - Rate/Term Primary No B B B B
Date to expected date(s).
625488567 XXX XXX XXX 35089545 credit 3 Missing Document: Missing Final 1003 Yes 5/XX/2008 CA Refinance - UTD Primary No C C C C
625488567 XXX XXX XXX 35089547 compliance 2 (Doc Error) Initial GFE not provided Yes 5/XX/2008 CA Refinance - UTD Primary No B B B B
625488567 XXX XXX XXX 35089548 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off Yes 5/XX/2008 CA Refinance - UTD Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488567 XXX XXX XXX 35089549 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. Yes 5/XX/2008 CA Refinance - UTD Primary No B B B B
Security Instrument Notary Date of 05/XX/2008 used as disbursement date for
compliance testing.
625488567 XXX XXX XXX 35089550 compliance 3 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable Yes 5/XX/2008 CA Refinance - UTD Primary No D D D D
Federal, State or Local compliance testing is unreliable.
625488567 XXX XXX XXX 35089551 compliance 2 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using Yes 5/XX/2008 CA Refinance - UTD Primary No B B B B
an application date of 04/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date. Due to missing HUD-1
or Closing Disclosure, no fees were used in testing.
625488567 XXX XXX XXX 35089552 compliance 2 Property Type Not Provided (Missing Data) Property Type. If property type is other than single family Yes 5/XX/2008 CA Refinance - UTD Primary No B B B B
residence, state and federal testing may be impacted.
625488567 XXX XXX XXX 35089553 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. Yes 5/XX/2008 5/XX/2011 CA Refinance - UTD Primary No B B B B
625488567 XXX XXX XXX 35089554 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a Yes 5/XX/2008 5/XX/2011 CA Refinance - UTD Primary No B B B B
defense to foreclosure. Assignee liability.
625489226 XXX XXX XXX 35089624 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 4/XX/2008 OH Purchase Primary No C C C C
625489226 XXX XXX XXX 35089625 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 4/XX/2008 OH Purchase Primary No B B B B
625489226 XXX XXX XXX 35089626 compliance 2 Ohio Consumer Sales Practices Act (Acknowledgement of Receipt of Home Mortgage Ohio Consumer Sales Practices Act: Acknowledgement of Receipt of Home Mortgage The Consumer Sales Practices Act (CSPA) generally does not provide for assignee 4/XX/2008 OH Purchase Primary No B B B B
Loan Information Document Not Retained by Lender) Loan Information Document not retained by lender. liability. The Act provides that no claim or defense may be asserted under the
Act by the Attorney General or any consumer against a purchaser or assignee of a
mortgage loan for value for any action under the statute unless: (a) the
violation was committed by the purchaser or assignee; or (b) the assignee or
purchaser is affiliated by common control with the seller of the loan at the
time the loan was purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant
injunctions, and levy monetary fines. Additionally, the CSPA provides borrowers
with a private right of action. Therefore, it is possible that any action
commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law
as part of the private right of action, a court could reform the loan terms
which could impact purchasers. Therefore, if the seller cannot be compelled to
repurchase the loan, the assignee could face exposure.
625489226 XXX XXX XXX 35089627 compliance 2 Ohio Consumer Sales Practices Act (Closing Disclosure Not Provided) Ohio Consumer Sales Practices Act: Consumer did not receive the required Closing The Consumer Sales Practices Act (CSPA) generally does not provide for assignee 4/XX/2008 OH Purchase Primary No B B B B
Disclosure. liability. The Act provides that no claim or defense may be asserted under the
Act by the Attorney General or any consumer against a purchaser or assignee of a
mortgage loan for value for any action under the statute unless: (a) the
violation was committed by the purchaser or assignee; or (b) the assignee or
purchaser is affiliated by common control with the seller of the loan at the
time the loan was purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant
injunctions, and levy monetary fines. Additionally, the CSPA provides borrowers
with a private right of action. Therefore, it is possible that any action
commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law
as part of the private right of action, a court could reform the loan terms
which could impact purchasers. Therefore, if the seller cannot be compelled to
repurchase the loan, the assignee could face exposure.
625489226 XXX XXX XXX 35089628 compliance 2 Ohio Consumer Sales Practices Act (Default Rate Increase) Ohio Consumer Sales Practices Act: Mortgage loan contains an impermissible The Consumer Sales Practices Act (CSPA) generally does not provide for assignee 4/XX/2008 OH Purchase Primary No B B B B
demand feature. liability. The Act provides that no claim or defense may be asserted under the
Act by the Attorney General or any consumer against a purchaser or assignee of a
mortgage loan for value for any action under the statute unless: (a) the
violation was committed by the purchaser or assignee; or (b) the assignee or
purchaser is affiliated by common control with the seller of the loan at the
time the loan was purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant
injunctions, and levy monetary fines. Additionally, the CSPA provides borrowers
with a private right of action. Therefore, it is possible that any action
commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law
as part of the private right of action, a court could reform the loan terms
which could impact purchasers. Therefore, if the seller cannot be compelled to
repurchase the loan, the assignee could face exposure.
625489622 XXX XXX XXX 35089644 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2006 TN Refinance - Cash-out - Other Primary No B B B B
an application date of 07/XX/2006 which is 0 months prior to consummation. A
lookback was performed to determine this application date.
625488979 XXX XXX XXX 35089742 credit 3 Missing Document: Missing Final 1003 2/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488979 XXX XXX XXX 35089743 compliance 2 ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2006 2/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
borrower within three (3) days of application.
625488979 XXX XXX XXX 35089744 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Under disclosure is due to the lender utilizing an index value of 3.240% per the $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 2/XX/2006 2/XX/2009 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. approval, however the lowest index value available in the look back period is for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
3.46000% liability.
625488979 XXX XXX XXX 35089745 credit 3 Missing Valuation: Appraisal not provided. 2/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489634 XXX XXX XXX 35089841 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2006 CA Refinance - Cash-out - Other Primary No B B B B
an application date of 11/XX/2006 which is 0 months prior to consummation. A
lookback was performed to determine this application date.
625489634 XXX XXX XXX 35089842 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2006 CA Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625489634 XXX XXX XXX 35089843 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2006 11/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625489634 XXX XXX XXX 35089844 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 11/XX/2006 11/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489634 XXX XXX XXX 35089845 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Under disclosure is due to the lender utilizing an index value of 4.997% per the $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 11/XX/2006 11/XX/2009 CA Refinance - Cash-out - Other Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. approval, however the lowest index value available in the lookback period is for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
5.08083%. liability.
625488623 XXX XXX XXX 35089853 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 2/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488623 XXX XXX XXX 35089854 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488623 XXX XXX XXX 35089855 compliance 2 ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2007 2/XX/2008 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
borrower within three (3) days of application.
625488623 XXX XXX XXX 35089856 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2007 2/XX/2008 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488623 XXX XXX XXX 35089857 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from The Approval indicates the Index used was 4.65%. The only Index available within $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 2/XX/2007 2/XX/2010 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. the look-back period is 4.73%. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488623 XXX XXX XXX 35089858 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 01/XX/2007, prior to TILA ROR - 3yrs for rescindable transactions. 2/XX/2007 2/XX/2010 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 02/XX/2007.
625488623 XXX XXX XXX 35089859 compliance 2 Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit 2/XX/2007 2/XX/2010 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Model Form for a refinance by a creditor that is not considered the original courts, the continuing risk that the borrower may have an extended right to
creditor. The H-9 form was used, the H-8 form should have been used. rescind (3 additional years) if a creditor uses the incorrect Model Form
remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625488623 XXX XXX XXX 35089860 credit 2 Note is not on a FNMA/FHLMC form and does not contain the standard Due on Sale 2/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
clause.
625488868 XXX XXX XXX 35089871 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 2/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
within a reasonably practicable time after using credit score.
625488868 XXX XXX XXX 35089872 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
an application date of 02/XX/2007 which is 0 months prior to consummation. A
lookback was performed to determine this application date.
625488868 XXX XXX XXX 35089873 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488868 XXX XXX XXX 35089874 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625488868 XXX XXX XXX 35089875 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2007 2/XX/2008 CA Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488868 XXX XXX XXX 35089876 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Index used by lender 4.69% is below the minimum index available in the look back $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 2/XX/2007 2/XX/2010 CA Refinance - Cash-out - Other Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. period 4.75% for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489445 XXX XXX XXX 35089880 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
an application date of 03/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625489445 XXX XXX XXX 35089881 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625489445 XXX XXX XXX 35089882 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2007 4/XX/2008 CA Refinance - Cash-out - Other Primary No B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625489445 XXX XXX XXX 35089883 compliance 2 TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Truth in Lending Act: Actual Date(s) on Notice of Right to Cancel occurs prior TILA ROR - 3yrs for rescindable transactions. 4/XX/2007 4/XX/2010 CA Refinance - Cash-out - Other Primary No B B B B
Date to expected date(s).
625489445 XXX XXX XXX 35089884 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine reason for under disclosure due to missing itermization of $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 4/XX/2007 4/XX/2010 CA Refinance - Cash-out - Other Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. prepaid finance charges. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489445 XXX XXX XXX 35089885 credit 3 Missing Document: Missing Final 1003 4/XX/2007 CA Refinance - Cash-out - Other Primary No C C C C
625488064 XXX XXX XXX 35089897 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2007 FL Refinance - Cash-out - Other Primary No B B B B
an application date of 04/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625488433 XXX XXX XXX 35089916 credit 3 Missing Document: Missing Final 1003 6/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488433 XXX XXX XXX 35089917 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 6/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
following clauses:
625488433 XXX XXX XXX 35089918 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 05/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625488433 XXX XXX XXX 35089919 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488433 XXX XXX XXX 35089920 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625488135 XXX XXX XXX 35089961 compliance 2 (Missing Data) Last Rate Set Date Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario 7/XX/2011 AL Purchase Primary No B B B B
between Creditor Application Date and Transaction Date used to determine rate
used for testing.
625488135 XXX XXX XXX 35089962 compliance 2 RESPA (2010) - GFE Settlement charges Good Thru Date Less than 10 Days RESPA (2010): GFE does not provide minimum ten (10) business day availability RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2011 AL Purchase Primary No B B B B
for estimate of charges and terms for all other settlement charges. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488135 XXX XXX XXX 35089963 compliance 2 RESPA (2010) - Loan Amount on Final GFE Inaccurate RESPA (2010): Loan Amount on Final GFE does not match Note. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2011 AL Purchase Primary No B B B B
within the statute or implementing regulation, Regulation X, for these type of
violations.
625488135 XXX XXX XXX 35089964 compliance 2 RESPA (2010) - Initial Payment on GFE Inaccurate RESPA (2010): Initial payment on GFE does not match actual payment on loan. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2011 AL Purchase Primary No B B B B
within the statute or implementing regulation, Regulation X, for these type of
violations.
625488135 XXX XXX XXX 35089965 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2011 AL Purchase Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488135 XXX XXX XXX 35089966 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 7/XX/2011 7/XX/2012 AL Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489007 XXX XXX XXX 35090131 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488386 XXX XXX XXX 35090167 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2007 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 11/XX/2007 which is 0 months prior to consummation. A
lookback was performed to determine this application date.
625488386 XXX XXX XXX 35090168 compliance 2 (Missing Data) Unable to determine if loan is a same lender refi Original Lender was not able to be determined. Unable to determine if correct 11/XX/2007 11/XX/2010 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B 2020/XX/10: Regraded to EV2-B due to outside of 3 year SOL and no NY or CT
TILA rescission form was used. high-cost.
625488386 XXX XXX XXX 35090169 compliance 2 Wisconsin Prepayment Penalty Wisconsin Prepayment Penalty: First lien loan contains an impermissible PPP Expired. Prepayment charge not allowed per state (WI) - prepayment charge 11/XX/2007 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
prepayment penalty of greater than 60 days interest on 80% of the original not allowed for greater than 60 days interest. Note states 3%, 2%. Lender is XXX
amount of the loan.
625488386 XXX XXX XXX 35090170 compliance 2 Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance Truth in Lending Act: Unable to determine if Notice of Right to Cancel was TILA ROR Form - Because this issue is not uniformly settled among the circuit 11/XX/2007 11/XX/2010 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
executed on the proper Model Form. The H-9 form was used instead of the H-8 courts, the continuing risk that the borrower may have an extended right to
form, however, the loan file does not contain evidence that the refinance was by rescind (3 additional years) if a creditor uses the incorrect Model Form
the original creditor. remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625488386 XXX XXX XXX 35090171 credit 3 Missing Valuation: Appraisal not provided 11/XX/2007 WI Refinance - Cash-out - Debt Consolidation Primary No C C C C
625487954 XXX XXX XXX 35090180 credit 3 Missing Document: Missing Final 1003 9/XX/2006 PA Refinance - Rate/Term Primary No C C C C
625487954 XXX XXX XXX 35090181 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 9/XX/2006 PA Refinance - Rate/Term Primary No B B B B
625487954 XXX XXX XXX 35090182 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 9/XX/2006 PA Refinance - Rate/Term Primary No B B B B
Security Instrument Notary Date of 09/XX/2006 used as disbursement date for
compliance testing.
625487954 XXX XXX XXX 35090183 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 09/XX/2006, prior to TILA ROR - 3yrs for rescindable transactions. 9/XX/2006 9/XX/2009 PA Refinance - Rate/Term Primary No B B B B
Date three (3) business days from transaction date of 09/XX/2006.
625487954 XXX XXX XXX 35090185 compliance 2 TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - The Third Circuit has prior rulings that the borrower may have 9/XX/2006 9/XX/2009 PA Refinance - Rate/Term Primary No B B B B
(Third Circuit) Model Form for a refinancing by the same creditor. The H-8 form was used, the an extended right to rescind (3 additional years) if a creditor uses the
H-9 form should have been used. incorrect Model Form. Creditors are required to use Model Form H-8 only for
refinances involving a new creditor and Model Form H-9 for refinances involving
the same creditor.
625489214 XXX XXX XXX 35090225 credit 3 Missing Document: Missing Final 1003 Yes 9/XX/2005 FL Refinance - UTD Primary No C C C C
625489214 XXX XXX XXX 35090226 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off Yes 9/XX/2005 FL Refinance - UTD Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489214 XXX XXX XXX 35090227 compliance 2 (Doc Error) Initial GFE not provided Yes 9/XX/2005 FL Refinance - UTD Primary No B B B B
625489214 XXX XXX XXX 35090228 credit 3 Final Title Policy is missing. No evidence of title in file. Yes 9/XX/2005 FL Refinance - UTD Primary No C C C C
625489214 XXX XXX XXX 35090229 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. Yes 9/XX/2005 FL Refinance - UTD Primary No B B B B
Security Instrument Notary Date of 09/XX/2005 used as disbursement date for
compliance testing.
625489214 XXX XXX XXX 35090230 compliance 3 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable Yes 9/XX/2005 FL Refinance - UTD Primary No D D D D
Federal, State or Local compliance testing is unreliable.
625489214 XXX XXX XXX 35090231 compliance 2 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using Yes 9/XX/2005 FL Refinance - UTD Primary No B B B B
an application date of 08/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. Due to missing HUD-1
or Closing Disclosure, no fees were used in testing.
625489214 XXX XXX XXX 35090232 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. Yes 9/XX/2005 9/XX/2008 FL Refinance - UTD Primary No B B B B
625489214 XXX XXX XXX 35090233 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TIL appears to be final but not signed nor initialed by borrower. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a Yes 9/XX/2005 9/XX/2008 FL Refinance - UTD Primary No B B B B
defense to foreclosure. Assignee liability.
625489214 XXX XXX XXX 35090234 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a Yes 9/XX/2005 9/XX/2008 FL Refinance - UTD Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625488111 XXX XXX XXX 35090385 credit 3 Missing Document: Missing Final 1003 9/XX/2003 NJ Refinance - Cash-out - Other Primary No C C C C
625488111 XXX XXX XXX 35090386 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2003 NJ Refinance - Cash-out - Other Primary No B B B B
an application date of 08/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625488111 XXX XXX XXX 35090387 compliance 2 New Jersey Prepayment Penalty New Jersey Prepayment Penalty: No prepayment penalties are permissible in the PPP Expired. Prepayment charge not allowed per state (NJ) - max prepayment 9/XX/2003 NJ Refinance - Cash-out - Other Primary No B B B B
state of New Jersey. charge for NJ loan is 0% - note states 2%, 2%, 2%. Lender is XXX.
625488111 XXX XXX XXX 35090388 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2003 9/XX/2004 NJ Refinance - Cash-out - Other Primary No B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625488111 XXX XXX XXX 35090389 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2003 9/XX/2004 NJ Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489098 XXX XXX XXX 35090413 credit 3 Missing Document: Missing Final 1003 6/XX/2005 CA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489098 XXX XXX XXX 35090414 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2005 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 06/XX/2005 which is 0 months prior to consummation. A
lookback was performed to determine this application date.
625489098 XXX XXX XXX 35090415 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2005 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625489098 XXX XXX XXX 35090416 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Under disclosure is due to the lender utilizing an index value of 2.52% per the $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 6/XX/2005 6/XX/2008 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. loan approval, however the lowest index value available in the lookback period for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
is 2.70%. liability.
625488804 XXX XXX XXX 35090423 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 7/XX/2005 CA Refinance - Cash-out - Other Primary No B B B B
625488804 XXX XXX XXX 35090424 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2005 CA Refinance - Cash-out - Other Primary No B B B B
an application date of 06/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625488804 XXX XXX XXX 35090425 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2005 CA Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625488804 XXX XXX XXX 35090426 compliance 2 TIL APR Tolerance Irregular Transaction Truth In Lending Act: Final TIL APR of XX.XX% is underdisclosed from calculated Under disclosure is due to the lender utilizing an index value of 2.332% per the TILA APR - subject to a 1 year SOL for affirmative claims, 3 years for 7/XX/2005 7/XX/2008 CA Refinance - Cash-out - Other Primary No B B B B
APR of XX.XX% outside of 0.125% tolerance. approval, however the lowest index value available in the lookback period is rescindable transactions. Unlimited as a defense to foreclosure. Assignee
2.65833%. liability.
625488804 XXX XXX XXX 35090427 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Under disclosure is due to the lender utilizing an index value of 2.332% per the $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 7/XX/2005 7/XX/2008 CA Refinance - Cash-out - Other Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. approval, however the lowest index value available in the lookback period is for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
2.65833%. liability.
625488804 XXX XXX XXX 35090428 credit 3 Missing Document: Missing Final 1003 7/XX/2005 CA Refinance - Cash-out - Other Primary No C C C C
625488616 XXX XXX XXX 35090466 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 12/XX/2005 CA Purchase Primary No B B B B
an application date of 11/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625488616 XXX XXX XXX 35090467 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2005 CA Purchase Primary No B B B B
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625488616 XXX XXX XXX 35090468 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2005 12/XX/2006 CA Purchase Primary No B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625488616 XXX XXX XXX 35090469 compliance 2 California Prepayment Penalty ARM Test California Prepayment Penalty: Interest rate increase may be invalid due to 12/XX/2005 CA Purchase Primary No B B B B
borrower not being permitted to prepay the loan without penalty within 90 days
of notification of any increase in the interest rate, depending on the lender's
license type.
625488616 XXX XXX XXX 35090470 credit 3 Missing Document: Missing Final 1003 12/XX/2005 CA Purchase Primary No C C C C
625488616 XXX XXX XXX 35090471 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Under disclosure is due to the lender utilizing an index value of 2.97% per the $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 12/XX/2005 12/XX/2006 CA Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. approval, however the lowest index value available in the lookback period is for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
3.14%. liability.
625489420 XXX XXX XXX 35090505 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 07/XX/2006 which is 0 months prior to consummation. A
lookback was performed to determine this application date.
625489420 XXX XXX XXX 35090506 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2006 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625489420 XXX XXX XXX 35090507 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2006 7/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625489420 XXX XXX XXX 35090508 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2006 7/XX/2007 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489420 XXX XXX XXX 35090509 compliance 2 TIL APR Tolerance Irregular Transaction Truth In Lending Act: Final TIL APR of XX.XX% is underdisclosed from calculated Under disclosure is due to the lender utilizing an index value of 3.79% per the TILA APR - subject to a 1 year SOL for affirmative claims, 3 years for 7/XX/2006 7/XX/2009 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
APR of XX.XX% outside of 0.125% tolerance. loan approval, however the lowest index value available in the lookback period rescindable transactions. Unlimited as a defense to foreclosure. Assignee
is 4.11%. liability.
625489420 XXX XXX XXX 35090510 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Under disclosure is due to the lender utilizing an index value of 3.79% per the $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 7/XX/2006 7/XX/2009 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. loan approval, however the lowest index value available in the lookback period for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
is 4.11%. liability.
625489570 XXX XXX XXX 35090549 compliance 2 (Missing Data) Unable to determine if loan is a same lender refi Original Lender was not able to be determined. Unable to determine if correct 12/XX/2006 12/XX/2009 CA Refinance - Cash-out - Other Primary No B B B B 2020/XX/10: Regraded to EV2-B due to outside of 3 year SOL and no NY or CT
TILA rescission form was used. high-cost.
625489570 XXX XXX XXX 35090550 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2006 CA Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489570 XXX XXX XXX 35090551 compliance 2 ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2006 12/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
borrower within three (3) days of application.
625489570 XXX XXX XXX 35090552 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2006 12/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488880 XXX XXX XXX 35090565 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 2/XX/2007 CA Refinance - Cash-out - Home Improvement Primary No B B B B
within a reasonably practicable time after using credit score.
625488880 XXX XXX XXX 35090566 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2007 CA Refinance - Cash-out - Home Improvement Primary No B B B B
an application date of 01/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625488880 XXX XXX XXX 35090567 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2007 CA Refinance - Cash-out - Home Improvement Primary No B B B B
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625489170 XXX XXX XXX 35090574 credit 3 Missing Document: Missing Final 1003 3/XX/2007 AZ Refinance - Cash-out - Other Primary No C C C C
625489170 XXX XXX XXX 35090575 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 3/XX/2007 AZ Refinance - Cash-out - Other Primary No B B B B
within a reasonably practicable time after using credit score.
625489170 XXX XXX XXX 35090576 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2007 AZ Refinance - Cash-out - Other Primary No B B B B
an application date of 02/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625489170 XXX XXX XXX 35090577 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2007 AZ Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625489170 XXX XXX XXX 35090578 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 3/XX/2007 3/XX/2008 AZ Refinance - Cash-out - Other Primary No B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625489169 XXX XXX XXX 35090579 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2007 FL Refinance - Cash-out - Other Primary No B B B B
an application date of 03/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625489169 XXX XXX XXX 35090580 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2007 4/XX/2008 FL Refinance - Cash-out - Other Primary No B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625488718 XXX XXX XXX 35090581 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2007 5/XX/2010 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625488718 XXX XXX XXX 35090582 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 5/XX/2007 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B
within a reasonably practicable time after using credit score.
625488718 XXX XXX XXX 35090583 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2007 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488718 XXX XXX XXX 35090584 compliance 2 Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. 5/XX/2007 5/XX/2010 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B
timing requirements.
625488718 XXX XXX XXX 35090585 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2007 5/XX/2010 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625488182 XXX XXX XXX 35090592 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
an application date of 04/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625488182 XXX XXX XXX 35090593 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488182 XXX XXX XXX 35090594 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2007 CA Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625488182 XXX XXX XXX 35090595 credit 3 Missing Valuation: Appraisal not provided. 5/XX/2007 CA Refinance - Cash-out - Other Primary No C C C C
625488409 XXX XXX XXX 35090608 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2007 CA Refinance - Rate/Term Primary No B B B B
an application date of 05/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625488409 XXX XXX XXX 35090609 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2007 CA Refinance - Rate/Term Primary No B B B B
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625488409 XXX XXX XXX 35090610 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 CA Refinance - Rate/Term Primary No B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625488409 XXX XXX XXX 35090611 compliance 2 CHARM Booklet Disclosure Prior to Closing Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 6/XX/2007 6/XX/2008 CA Refinance - Rate/Term Primary No B B B B
CHARM Booklet, not provided to the borrower at least three (3) days prior to
consummation for a loan that did not start as an ARM.
625489523 XXX XXX XXX 35090857 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 11/XX/2007 TX Purchase Primary No B B B B
625489523 XXX XXX XXX 35090858 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TIL appears to be final but not signed nor initialed by borrower. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2007 11/XX/2008 TX Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625489523 XXX XXX XXX 35090859 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TIL in file indicated to be final, expected funding date same as disbursement TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2007 11/XX/2008 TX Purchase Primary No B B B B
and/or note date but is not signed or dated by borrower so cannot confirm that defense to foreclosure. Assignee liability.
borrower received.
625489372 XXX XXX XXX 35090874 credit 3 Missing Document: Missing Final 1003 3/XX/2007 PA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489372 XXX XXX XXX 35090875 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2007 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 02/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 09/XX/2006.
625489372 XXX XXX XXX 35090876 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2007 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489372 XXX XXX XXX 35090877 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 3/XX/2007 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625489372 XXX XXX XXX 35090878 compliance 2 Pennsylvania Prepayment Penalty Banking Code Pennsylvania Prepayment Penalty: Prepayment penalty not permissible on a loan 3/XX/2007 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B 2019/XX/23: Updated from: Pennsylvania Prepayment Penalty: Prepayment penalty
made by a Pennsylvania-chartered bank or bank and trust company; however Note or not permissible on a loan made by a Pennsylvania-chartered bank or bank and
Prepay Addendum provides specific language that prepay will not exceed maximum trust company.
permitted by applicable law.
625489372 XXX XXX XXX 35090879 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 03/XX/2007, prior to TILA ROR - 3yrs for rescindable transactions. 3/XX/2007 3/XX/2010 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 03/XX/2007.
625489372 XXX XXX XXX 35090880 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 3/XX/2007 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 03/XX/2007 used as disbursement date for
compliance testing.
625488490 XXX XXX XXX 35090889 credit 3 Missing Document: Missing Final 1003 1/XX/2006 MD Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488490 XXX XXX XXX 35090890 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 1/XX/2006 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 01/XX/2006 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2006.
625489468 XXX XXX XXX 35090891 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 1/XX/2006 PA Purchase Primary No B B B B
an application date of 12/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 12/XX/2005.
625489468 XXX XXX XXX 35090892 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 1/XX/2006 PA Purchase Primary No B B B B
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625489468 XXX XXX XXX 35090893 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2006 1/XX/2007 PA Purchase Primary No B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625489468 XXX XXX XXX 35090894 compliance 2 CHARM Booklet Disclosure Prior to Closing Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2006 1/XX/2007 PA Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower at least three (3) days prior to
consummation for a loan that did not start as an ARM.
625488938 XXX XXX XXX 35091031 compliance 2 FACTA Disclosure Not Provided Prior to Closing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure There is no Assignee Liability. 12/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B
within a reasonably practicable time after using credit score.
625488938 XXX XXX XXX 35091032 credit 3 FEMA Disaster Issue: The most recent valuation inspection is dated prior to the Disaster Date: XX/XX/XXXX 12/XX/2006 FL Refinance - Cash-out - Other Primary No C C C C
most recent FEMA disaster. Inspection Date:
625489497 XXX XXX XXX 35091050 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 7/XX/2005 NJ Refinance - Cash-out - Other Primary Yes B B B B
625489497 XXX XXX XXX 35091051 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 7/XX/2005 7/XX/2008 NJ Refinance - Cash-out - Other Primary Yes B B B B
625489497 XXX XXX XXX 35091052 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2005 7/XX/2008 NJ Refinance - Cash-out - Other Primary Yes B B B B
defense to foreclosure. Assignee liability.
625489497 XXX XXX XXX 35091053 compliance 2 (Doc Error) Initial GFE not provided 7/XX/2005 NJ Refinance - Cash-out - Other Primary Yes B B B B
625489422 XXX XXX XXX 35091063 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 2/XX/2007 GA Refinance - Cash-out - Other Primary No B B B B
an application date of 1/XX/2007 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625488044 XXX XXX XXX 35091075 credit 1 Missing Document: Missing Final 1003 9/XX/2011 MN Refinance - Rate/Term Primary No A A A A 6/XX/2019 Yes 2019/XX/28: Cleared with documentation received for new trade
625488044 XXX XXX XXX 35091076 compliance 1 Missing Document: Missing Lender's Initial 1003 9/XX/2011 MN Refinance - Rate/Term Primary No A A A A 6/XX/2019 Yes 2019/XX/28: Cleared with documentation received for new trade
625488044 XXX XXX XXX 35091078 credit 1 Title: Evidence of title is missing File does not contain either Preliminary or Final Title. 9/XX/2011 MN Refinance - Rate/Term Primary No A A A A 6/XX/2019 Yes 2019/XX/28: Cleared with documentation received for new trade
625488044 XXX XXX XXX 35091079 compliance 1 Due to lack of appraised value, compliance tests requiring an LTV were run off 9/XX/2011 MN Refinance - Rate/Term Primary No A A A A 6/XX/2019 Yes 2019/XX/28: Cleared with documentation received for new trade
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488044 XXX XXX XXX 35091080 compliance 1 Missing Final HUD-1 9/XX/2011 MN Refinance - Rate/Term Primary No A A A A 6/XX/2019 Yes 2019/XX/28: Cleared with documentation received for new trade
625488044 XXX XXX XXX 35091081 compliance 1 TILA - Final TIL Missing TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2011 9/XX/2014 MN Refinance - Rate/Term Primary No A A A A 6/XX/2019 Yes 2019/XX/28: Cleared with documentation received for new trade
defense to foreclosure. Assignee liability.
625488044 XXX XXX XXX 35091082 compliance 1 (Doc Error) Initial GFE not provided 9/XX/2011 MN Refinance - Rate/Term Primary No A A A A 6/XX/2019 Yes 2019/XX/28: Cleared with documentation received for new trade
625488044 XXX XXX XXX 35091083 compliance 1 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 9/XX/2011 MN Refinance - Rate/Term Primary No A A A A 6/XX/2019 Yes 2019/XX/28: Cleared with documentation received for new trade
625488044 XXX XXX XXX 35091084 compliance 1 Missing Final HUD-1 Missing Final HUD-1. No document containing fees provided. Any applicable A violation of RESPA does not impair the validity of a loan or expose a true 9/XX/2011 MN Refinance - Rate/Term Primary No A A A A 6/XX/2019 Yes 2019/XX/28: Cleared with documentation received for new trade
Federal, State or Local compliance testing is unreliable. secondary market purchaser of a loan to assignee liability or rescission of the
loan. While there are no express private rights of action under either Section 4
or 5 of RESPA, originators who violate these provisions are subject to
enforcement action by a host of federal and state governmental authorities, and
face the possible imposition of civil money penalties. Further, originators who
violate Sections 4 and 5 of RESPA could be subject to claims arising under state
law, such as state deceptive acts and practices statutes.
625488044 XXX XXX XXX 35091085 compliance 1 SAFE Act - NMLS Info Not in File Secure and Fair Enforcement for Mortgage Licensing Act: NMLSR information not Liability appears to be limited to originators/licensees. 9/XX/2011 MN Refinance - Rate/Term Primary No A A A A 6/XX/2019 Yes 2019/XX/28: Cleared with documentation received for new trade
present on loan application.
625488044 XXX XXX XXX 35091086 compliance 2 SAFE Act - Individual LO not licensed at time of application Unable to test Loan Originator license due to missing information. Liability appears to be limited to originators/licensees. 9/XX/2011 MN Refinance - Rate/Term Primary No B B B B
625488044 XXX XXX XXX 35091087 compliance 2 SAFE Act - Individual LO NMLS does not match NMLS Secure and Fair Enforcement for Mortgage Licensing Act: Individual Loan Liability appears to be limited to originators/licensees. 9/XX/2011 MN Refinance - Rate/Term Primary No B B B B
Originator NMLSR information on loan documents does not match NMLSR.
625488044 XXX XXX XXX 35091088 compliance 2 SAFE Act - Individual LO NMLS license status not approved Unable to test Individual Loan Originator license status due to missing Liability appears to be limited to originators/licensees. 9/XX/2011 MN Refinance - Rate/Term Primary No B B B B
information.
625488044 XXX XXX XXX 35091089 compliance 1 RESPA (2010) - Initial Escrow Account Statement Missing RESPA (2010): Initial escrow account statement was not provided to the borrower. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2011 MN Refinance - Rate/Term Primary No A A A A 6/XX/2019 Yes 2019/XX/28: Cleared with documentation received for new trade
within the statute or implementing regulation, Regulation X, for these type of
violations.
625488044 XXX XXX XXX 35091090 compliance 1 RESPA Servicing Disclosure: Servicing Disclosure Statement Missing RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2011 MN Refinance - Rate/Term Primary No A A A A 6/XX/2019 Yes 2019/XX/28: Cleared with documentation received for new trade
Statement. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488044 XXX XXX XXX 35091091 compliance 2 Minnesota Residential Mortgage Originator and Servicer Licensing Act (Counseling Minnesota Residential Mortgage Originator and Servicer Licensing Act: Refinance Assignee liability is unclear. Purchasers and assignees of Minnesota mortgage 9/XX/2011 MN Refinance - Rate/Term Primary No B B B B
Requirement) of a "special mortgage" without evidence that borrower received counseling on loans would not appear to be liable for violations of the Act. However,
advisability of transaction by an authorized independent loan counselor. effective 8/XX/07, although there does not appear to be any explicit assignee
liability, because a new private right of action permits a court to award
statutory damages equal to the amount of all lender fees included in the amount
of the principal of the residential mortgage loan, there is the potential that
secondary market participants may be adversely affected.
625488044 XXX XXX XXX 35091092 compliance 1 Minnesota Tangible Net Benefit Test Minnesota Residential Mortgage Originator and Servicer Licensing Act: Unable to 9/XX/2011 MN Refinance - Rate/Term Primary No A A A A 6/XX/2019 Yes 2019/XX/27: Cleared with documentation received for new trade
determine if mortgage loan provides a tangible net benefit to the borrower due
to missing prior loan information.
625488044 XXX XXX XXX 35091093 compliance 1 TIL-MDIA - Initial TIL Missing Truth in Lending Act (Early TIL Disclosure): Initial TIL was not provided to the TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited 9/XX/2011 9/XX/2012 MN Refinance - Rate/Term Primary No A A A A 6/XX/2019 Yes 2019/XX/28: Cleared with documentation received for new trade
borrower. as a defense to foreclosure. Assignee liability.
625488044 XXX XXX XXX 35091094 compliance 1 2011 TIL-MDIA - ‘No guarantee to Refinance’ Statement Missing Truth in Lending Act (MDIA 2011): Final TIL does not contain required ‘No TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2011 9/XX/2014 MN Refinance - Rate/Term Primary No A A A A 6/XX/2019 Yes 2019/XX/27: Cleared with documentation received for new trade
guarantee to Refinance’ statement. defense to foreclosure. Assignee liability.
625488044 XXX XXX XXX 35091095 compliance 2 RESPA Servicing Disclosure: Servicing Disclosure Statement Missing Unable to determine Servicing Disclosure Statement was provided due to missing RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 9/XX/2011 MN Refinance - Rate/Term Primary No B B B B
information. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488044 XXX XXX XXX 35091096 compliance 2 2011 TIL-MDIA - Introductory Escrow Payment Inaccurate Truth in Lending Act (MDIA 2011): The amount of taxes and insurance, including TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2011 9/XX/2014 MN Refinance - Rate/Term Primary No B B B B
any mortgage insurance, on the Final TIL does not match the amount of taxes and defense to foreclosure. Assignee liability.
insurance, including any mortgage insurance, for the loan.
625488044 XXX XXX XXX 35091097 compliance 2 2011 TIL-MDIA Rate-Payment Summary Table - Introductory Total Payment (PITI) Truth in Lending Act (MDIA 2011): Total payment amount (PITI) on the Final TIL TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 9/XX/2011 9/XX/2014 MN Refinance - Rate/Term Primary No B B B B
Inaccurate does not match the total payment amount for the loan. defense to foreclosure. Assignee liability.
625488140 XXX XXX XXX 35091137 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2008 GA Purchase Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489520 XXX XXX XXX 35091175 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/1998 3/XX/2001 CT Refinance - Rate/Term Primary No B B B B
defense to foreclosure. Assignee liability.
625489520 XXX XXX XXX 35091176 compliance 2 (Doc Error) Initial GFE not provided 3/XX/1998 CT Refinance - Rate/Term Primary No B B B B
625488763 XXX XXX XXX 35091224 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2008 WA Refinance - Rate/Term Primary No B B B B
an application date of 03/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2008.
625488763 XXX XXX XXX 35091225 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2008 4/XX/2009 WA Refinance - Rate/Term Primary No B B B B
Loan Application Date.
625488763 XXX XXX XXX 35091226 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2008 4/XX/2009 WA Refinance - Rate/Term Primary No B B B B
Loan Application Date.
625487962 XXX XXX XXX 35091270 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2006 PA Purchase Primary No B B B B
an application date of 10/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2006.
625487962 XXX XXX XXX 35091272 compliance 2 Other Compliance Exception (Manual Add) Final TIL Finance Charge Under Disclosed $XXX. 11/XX/2006 PA Purchase Primary No B B B B
625487962 XXX XXX XXX 35091273 compliance 2 Other Compliance Exception (Manual Add) Final TIL APR Under/Over Disclosed By Greater Than 0.125%. Variance .693% 11/XX/2006 PA Purchase Primary No B B B B
625488131 XXX XXX XXX 35091280 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2006 NC Purchase Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488131 XXX XXX XXX 35091281 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2006 2/XX/2007 NC Purchase Primary No B B B B
borrower within three (3) days of application.
625488131 XXX XXX XXX 35091282 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TIL appears to be final but not signed nor initialed by borrower TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 2/XX/2006 2/XX/2007 NC Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625488131 XXX XXX XXX 35091283 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2006 2/XX/2007 NC Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625488346 XXX XXX XXX 35091292 compliance 2 (Doc Error) Initial GFE not provided 6/XX/2006 CA Purchase Primary No B B B B
625489355 XXX XXX XXX 35091301 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 12/XX/2006 MA Purchase Primary Yes B B B B
an application date of 11/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2006.
625489355 XXX XXX XXX 35091302 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2006 MA Purchase Primary Yes B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488890 XXX XXX XXX 35091325 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2007 WA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 01/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2007.
625489399 XXX XXX XXX 35091375 compliance 2 (Doc Error) Initial GFE not provided 1/XX/2007 FL Refinance - Cash-out - Other Primary No B B B B
625489399 XXX XXX XXX 35091376 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 1/XX/2007 FL Refinance - Cash-out - Other Primary No B B B B
625489399 XXX XXX XXX 35091377 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 1/XX/2007 FL Refinance - Cash-out - Other Primary No B B B B
an application date of 12/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 07/XX/2006.
625489399 XXX XXX XXX 35091378 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2007 1/XX/2008 FL Refinance - Cash-out - Other Primary No B B B B
borrower.
625489399 XXX XXX XXX 35091379 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2007 1/XX/2008 FL Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489140 XXX XXX XXX 35091441 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 1/XX/2005 1/XX/2008 FL Refinance - Cash-out - Other Primary No B B B B
defense to foreclosure. Assignee liability.
625489140 XXX XXX XXX 35091442 compliance 2 (Missing Data) Unable to determine if loan is a same lender refi Original Lender was not able to be determined. Unable to determine if correct 1/XX/2005 1/XX/2008 FL Refinance - Cash-out - Other Primary No B B B B
TILA rescission form was used.
625489140 XXX XXX XXX 35091443 compliance 2 Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. 1/XX/2005 1/XX/2008 FL Refinance - Cash-out - Other Primary No B B B B
timing requirements.
625488148 XXX XXX XXX 35091557 compliance 2 RESPA Servicing Disclosure: Servicing Disclosure Statement Missing RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2013 IL Refinance - Rate/Term Primary No B B B B
Statement. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488148 XXX XXX XXX 35091558 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to apply the $XXX lender credit on line 204 of the HUD due to missing the $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 2/XX/2013 2/XX/2016 IL Refinance - Rate/Term Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. credit itemization. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488148 XXX XXX XXX 35091559 compliance 2 SAFE Act - NMLS Info Not in File Secure and Fair Enforcement for Mortgage Licensing Act: NMLSR information not Liability appears to be limited to originators/licensees. 2/XX/2013 IL Refinance - Rate/Term Primary No B B B B
present on loan application.
625488148 XXX XXX XXX 35091560 compliance 2 RESPA (2010) - 0% Tolerance (Line 1203) Without Cure RESPA (2010): 0% tolerance violation for 1203 fee without evidence of sufficient RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2013 IL Refinance - Rate/Term Primary No B B B B
cure provided. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488148 XXX XXX XXX 35091561 compliance 2 RESPA (2010) - Existence of Escrow Account on Final GFE Inaccurate RESPA (2010): Existence of escrow account disclosed on Final GFE does not match RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2013 IL Refinance - Rate/Term Primary No B B B B
actual terms. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488148 XXX XXX XXX 35091562 compliance 2 RESPA (2010) - Loan Amount on Final GFE Inaccurate RESPA (2010): Loan Amount on Final GFE does not match Note. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2013 IL Refinance - Rate/Term Primary No B B B B
within the statute or implementing regulation, Regulation X, for these type of
violations.
625488148 XXX XXX XXX 35091563 compliance 2 RESPA (2010) - Initial Payment on GFE Inaccurate RESPA (2010): Initial payment on GFE does not match actual payment on loan. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2013 IL Refinance - Rate/Term Primary No B B B B
within the statute or implementing regulation, Regulation X, for these type of
violations.
625488148 XXX XXX XXX 35091564 compliance 2 TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit 2/XX/2013 2/XX/2016 IL Refinance - Rate/Term Primary No B B B B
(Circuit 2, 5, 7, 8, 9, 10 or DC) Model Form for a refinancing by the same creditor. The H-8 form was used, the courts, the continuing risk that the borrower may have an extended right to
H-9 form should have been used. rescind (3 additional years) if a creditor uses the incorrect Model Form
remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625489067 XXX XXX XXX 35091577 credit 3 Missing Document: Missing Final 1003 1/XX/2006 MD Refinance - Cash-out - Other Primary No C C C C
625489067 XXX XXX XXX 35091578 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 1/XX/2006 MD Refinance - Cash-out - Other Primary No B B B B
Security Instrument Notary Date of 01/XX/2006 used as disbursement date for
compliance testing.
625489067 XXX XXX XXX 35091579 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 1/XX/2006 MD Refinance - Cash-out - Other Primary No B B B B
an application date of 12/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 07/XX/2005.
625489067 XXX XXX XXX 35091580 compliance 2 Maryland Late Charge Grace Period Testing Note grace period less than minimum per state. Grace period of 7 days is less than minimum per state (MD) of 15 days. 1/XX/2006 MD Refinance - Cash-out - Other Primary No B B B B
625489067 XXX XXX XXX 35091581 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 1/XX/2006 1/XX/2009 MD Refinance - Cash-out - Other Primary No B B B B
625487979 XXX XXX XXX 35091582 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 7/XX/2007 NJ Purchase Second Home Yes B B B B
625487979 XXX XXX XXX 35091583 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2007 NJ Purchase Second Home Yes B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625487979 XXX XXX XXX 35091584 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2007 7/XX/2008 NJ Purchase Second Home Yes B B B B
defense to foreclosure. Assignee liability.
625487979 XXX XXX XXX 35091585 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 7/XX/2007 7/XX/2008 NJ Purchase Second Home Yes B B B B
defense to foreclosure. Assignee liability.
625488967 XXX XXX XXX 35091608 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2008 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 01/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2008.
625488553 XXX XXX XXX 35091698 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 10/XX/2003 HI Refinance - Cash-out - Other Primary No B B B B
Security Instrument Notary Date of 10/XX/2003 used as disbursement date for
compliance testing.
625488553 XXX XXX XXX 35091699 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 10/XX/2003 10/XX/2006 HI Refinance - Cash-out - Other Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488553 XXX XXX XXX 35091700 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 10/XX/2003, prior to TILA ROR - 3yrs for rescindable transactions. 10/XX/2003 10/XX/2006 HI Refinance - Cash-out - Other Primary No B B B B
Date three (3) business days from transaction date of 10/XX/2003.
625488553 XXX XXX XXX 35091701 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 10/XX/2003 10/XX/2006 HI Refinance - Cash-out - Other Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625488553 XXX XXX XXX 35091702 credit 3 Missing Document: Missing Final 1003 10/XX/2003 HI Refinance - Cash-out - Other Primary No C C C C
625489485 XXX XXX XXX 35091704 credit 3 Missing Document: Missing Final 1003 8/XX/2004 NJ Refinance - Cash-out - Debt Consolidation Primary Yes C C C C
625489485 XXX XXX XXX 35091705 compliance 2 Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. 8/XX/2004 8/XX/2007 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
timing requirements.
625489485 XXX XXX XXX 35091706 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2004 8/XX/2007 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
defense to foreclosure. Assignee liability.
625489485 XXX XXX XXX 35091707 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2004 8/XX/2007 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
defense to foreclosure. Assignee liability.
625489485 XXX XXX XXX 35091708 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 8/XX/2004 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
Security Instrument Notary Date of 08/XX/2004 used as disbursement date for
compliance testing.
625489485 XXX XXX XXX 35091709 compliance 2 Payoff Statement Missing Missing Payoff Statement: Unable to determine if a prepayment penalty was 8/XX/2004 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
included in the pay-off which may impact high cost findings.
625489485 XXX XXX XXX 35091710 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 08/XX/2004, prior to TILA ROR - 3yrs for rescindable transactions. 8/XX/2004 8/XX/2007 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
Date three (3) business days from transaction date of 08/XX/2004.
625489485 XXX XXX XXX 35091711 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2004 8/XX/2007 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
are estimates. defense to foreclosure. Assignee liability.
625488209 XXX XXX XXX 35091755 compliance 2 Initial GFE not disclosed to the borrower within 3 days. 2/XX/2005 MA Refinance - Rate/Term Primary Yes B B B B
625488209 XXX XXX XXX 35091756 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Commitment letter indicates the Index used was 1.773%. The lowest Index $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 2/XX/2005 2/XX/2009 MA Refinance - Rate/Term Primary Yes B B B B
calculated Finance Charge of $XXX in the amount of $XXX. available within the look-back period is 1.8867%. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488209 XXX XXX XXX 35091757 compliance 2 Initial TIL not provided TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 2/XX/2005 2/XX/2009 MA Refinance - Rate/Term Primary Yes B B B B
defense to foreclosure. Assignee liability.
625488209 XXX XXX XXX 35091758 credit 3 Missing Document: Missing Final 1003 2/XX/2005 MA Refinance - Rate/Term Primary Yes C C C C
625488209 XXX XXX XXX 35091759 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 2/XX/2005 MA Refinance - Rate/Term Primary Yes B B B B
an application date of 1/XX/2005 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625488209 XXX XXX XXX 35091760 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2005 MA Refinance - Rate/Term Primary Yes B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489383 XXX XXX XXX 35091762 credit 3 Missing Document: Missing Final 1003 6/XX/2006 IL Purchase Primary No C C C C
625489383 XXX XXX XXX 35091763 compliance 2 Initial Loan Application Status Test No evidence of application date located in file. Compliance tests were run using 6/XX/2006 IL Purchase Primary No B B B B
an application date of 5/XX/2006 which is 1 month(s) prior to consummation. A 7
month lookback was used to determine this application date.
625488861 XXX XXX XXX 35091864 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 12/XX/2010 CA Refinance - Rate/Term Primary No B B B B
625488509 XXX XXX XXX 35091918 credit 3 Missing Document: Missing Final 1003 6/XX/2007 NY Refinance - Cash-out - Other Primary No C C C C
625488509 XXX XXX XXX 35091919 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2007 NY Refinance - Cash-out - Other Primary No B B B B
an application date of 05/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 05/XX/2007.
625488509 XXX XXX XXX 35091920 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 6/XX/2007 6/XX/2010 NY Refinance - Cash-out - Other Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. financed.Under disclosure appears to be fee related for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488049 XXX XXX XXX 35091990 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 11/XX/2007 NY Purchase Primary No C C C C
625488049 XXX XXX XXX 35091991 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2007 NY Purchase Primary No B B B B
an application date of 10/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 05/XX/2007.
625488049 XXX XXX XXX 35091992 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 11/XX/2007 NY Purchase Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488049 XXX XXX XXX 35091993 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing Itemization of Amount $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 11/XX/2007 11/XX/2008 NY Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. Financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488074 XXX XXX XXX 35092002 credit 3 Missing Document: Missing Final 1003 Yes 1/XX/2010 MS Refinance - Rate/Term Primary No C C C C
625488074 XXX XXX XXX 35092003 compliance 2 TIL-MDIA 7-day Waiting Period - Initial TIL Less than 7 days from Consummation Truth in Lending Act (Early TIL Disclosure): Initial TIL was not delivered to TILA - 1yr affirmative, Unlimited as a defense to foreclosure. Assignee Yes 1/XX/2010 1/XX/2011 MS Refinance - Rate/Term Primary No B B B B
the borrower at least seven (7) business days prior to note date. liability.
625488074 XXX XXX XXX 35092004 compliance 2 Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. Yes 1/XX/2010 1/XX/2013 MS Refinance - Rate/Term Primary No B B B B
timing requirements.
625488074 XXX XXX XXX 35092005 credit 3 Missing Document: Credit Report not provided Yes 1/XX/2010 MS Refinance - Rate/Term Primary No D D D D
625488074 XXX XXX XXX 35092006 compliance 2 (Doc Error) Initial GFE not provided Yes 1/XX/2010 MS Refinance - Rate/Term Primary No B B B B
625488074 XXX XXX XXX 35092007 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties Close at Home Loan. Final TIL not signed however, Acknowledgment of Receipt in TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a Yes 1/XX/2010 1/XX/2013 MS Refinance - Rate/Term Primary No B B B B
file signed by borrower defense to foreclosure. Assignee liability.
625488074 XXX XXX XXX 35092008 credit 3 Missing Document: Appraisal not provided Valuation Type: Stated / Valuation Report Date: 07/XX/2009 Yes 1/XX/2010 MS Refinance - Rate/Term Primary No D D D D
625488074 XXX XXX XXX 35092009 compliance 3 Missing Final HUD-1: HUD-1 Not Signed or Stamped Used For Fee Testing Missing Final HUD-1: HUD-1 Not Signed or Stamped used for any applicable Close at Home Loan. Final HUD-1 not signed by borrower however, Acknowledgment Yes 1/XX/2010 MS Refinance - Rate/Term Primary No D D D D
Federal, State or Local compliance testing. of Receipt is in file signed by borrower. This unsigned HUD was used for
compliance testing.
625488074 XXX XXX XXX 35092010 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using Yes 1/XX/2010 MS Refinance - Rate/Term Primary No B B B B
an application date of 12/XX/2009 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 07/XX/2009.
625488074 XXX XXX XXX 35092011 compliance 2 TIL-MDIA - Initial TIL Not Provided within 3 Business Days of Application Unable to determine compliance with timing requirements due to missing Initial TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited Yes 1/XX/2010 1/XX/2011 MS Refinance - Rate/Term Primary No B B B B
Loan Application Date. as a defense to foreclosure. Assignee liability.
625488074 XXX XXX XXX 35092012 compliance 2 TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit Yes 1/XX/2010 1/XX/2013 MS Refinance - Rate/Term Primary No B B B B
(Circuit 2, 5, 7, 8, 9, 10 or DC) Model Form for a refinancing by the same creditor. The H-8 form was used, the courts, the continuing risk that the borrower may have an extended right to
H-9 form should have been used. rescind (3 additional years) if a creditor uses the incorrect Model Form
remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625488813 XXX XXX XXX 35092038 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2007 MD Refinance - Rate/Term Primary No B B B B
an application date of 03/XX/2007 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2007.
625489158 XXX XXX XXX 35092081 credit 3 Missing Document: Missing Final 1003 12/XX/2004 MI Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489158 XXX XXX XXX 35092082 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 12/XX/2004 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 11/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2004.
625489158 XXX XXX XXX 35092083 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2004 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489158 XXX XXX XXX 35092084 compliance 2 Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Unable to determine compliance with timing requirements due to missing Initial Assignee liability is unclear. Purchasers and assignees would not appear to be 12/XX/2004 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B
Not Provided Timely) Loan Application Date. liable for violations of the Act, except to the extent involved I violations
arising from servicing or collecting.
625489158 XXX XXX XXX 35092085 compliance 2 Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided Unable to determine compliance with timing requirements due to missing Initial Assignee liability is unclear. Purchasers and assignees would not appear to be 12/XX/2004 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B
Timely Loan Application Date. liable for violations of the Act, except to the extent involved I violations
arising from servicing or collecting.
625489158 XXX XXX XXX 35092086 compliance 2 Michigan Consumer Mortgage Protection Act (Counseling Agencies List) Michigan Consumer Mortgage Protection Act: List of HUD-approved credit 12/XX/2004 MI Refinance - Cash-out - Debt Consolidation Primary No B B B B
counseling agencies not provided to borrower.
625488387 XXX XXX XXX 35092095 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2007 OH Refinance - Rate/Term Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488387 XXX XXX XXX 35092096 compliance 2 Ohio Consumer Sales Practices Act (Acknowledgement of Receipt of Home Mortgage Ohio Consumer Sales Practices Act: Acknowledgement of Receipt of Home Mortgage The Consumer Sales Practices Act (CSPA) generally does not provide for assignee 2/XX/2007 OH Refinance - Rate/Term Primary No B B B B
Loan Information Document Not Retained by Lender) Loan Information Document not retained by lender. liability. The Act provides that no claim or defense may be asserted under the
Act by the Attorney General or any consumer against a purchaser or assignee of a
mortgage loan for value for any action under the statute unless: (a) the
violation was committed by the purchaser or assignee; or (b) the assignee or
purchaser is affiliated by common control with the seller of the loan at the
time the loan was purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant
injunctions, and levy monetary fines. Additionally, the CSPA provides borrowers
with a private right of action. Therefore, it is possible that any action
commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law
as part of the private right of action, a court could reform the loan terms
which could impact purchasers. Therefore, if the seller cannot be compelled to
repurchase the loan, the assignee could face exposure.
625488387 XXX XXX XXX 35092097 compliance 2 Ohio Consumer Sales Practices Act (Closing Disclosure Not Provided) Ohio Consumer Sales Practices Act: Consumer did not receive the required Closing The Consumer Sales Practices Act (CSPA) generally does not provide for assignee 2/XX/2007 OH Refinance - Rate/Term Primary No B B B B
Disclosure. liability. The Act provides that no claim or defense may be asserted under the
Act by the Attorney General or any consumer against a purchaser or assignee of a
mortgage loan for value for any action under the statute unless: (a) the
violation was committed by the purchaser or assignee; or (b) the assignee or
purchaser is affiliated by common control with the seller of the loan at the
time the loan was purchased or assigned.
The CSPA gives authority to the Office to bring class actions, grant
injunctions, and levy monetary fines. Additionally, the CSPA provides borrowers
with a private right of action. Therefore, it is possible that any action
commenced under the CSPA could result in reputational damage. Moreover, note
that since the borrower is allowed to seek equitable remedies in a court of law
as part of the private right of action, a court could reform the loan terms
which could impact purchasers. Therefore, if the seller cannot be compelled to
repurchase the loan, the assignee could face exposure.
625488387 XXX XXX XXX 35092098 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2007 2/XX/2008 OH Refinance - Rate/Term Primary No B B B B
borrower within three (3) days of application.
625488387 XXX XXX XXX 35092099 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2007 2/XX/2008 OH Refinance - Rate/Term Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488311 XXX XXX XXX 35092103 credit 3 Missing Document: Missing Final 1003 8/XX/2007 IL Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488311 XXX XXX XXX 35092104 compliance 2 (Doc Error) Initial GFE not provided 8/XX/2007 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488311 XXX XXX XXX 35092105 credit 3 Final Title Policy is missing. No evidence of title in file. File does not contain either Preliminary or Final Title 8/XX/2007 IL Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488311 XXX XXX XXX 35092106 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 8/XX/2007 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488311 XXX XXX XXX 35092107 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 8/XX/2007 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 08/XX/2007 used as disbursement date for
compliance testing.
625488311 XXX XXX XXX 35092108 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2007 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 07/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2007.
625488311 XXX XXX XXX 35092109 compliance 2 (Missing Data) Unable to determine if loan is a same lender refi Original Lender was not able to be determined. Unable to determine if correct 8/XX/2007 8/XX/2010 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
TILA rescission form was used.
625488311 XXX XXX XXX 35092110 compliance 2 Property Type Not Provided (Missing Data) Property Type. If property type is other than single family 8/XX/2007 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
residence, state and federal testing may be impacted.
625488311 XXX XXX XXX 35092111 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 08/XX/2007, prior to TILA ROR - 3yrs for rescindable transactions. 8/XX/2007 8/XX/2010 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 08/XX/2007.
625489498 XXX XXX XXX 35092234 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2007 3/XX/2008 NC Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625489498 XXX XXX XXX 35092235 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2007 3/XX/2008 NC Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625488909 XXX XXX XXX 35092236 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2007 NY Purchase Investment No B B B B
an application date of 08/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2007.
625488823 XXX XXX XXX 35092244 compliance 2 (Doc Error) Initial GFE not provided 4/XX/2007 VT Purchase Primary No B B B B
625488823 XXX XXX XXX 35092245 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2007 VT Purchase Primary No B B B B
an application date of 03/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2006.
625489250 XXX XXX XXX 35092248 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 3/XX/2007 FL Purchase Primary No C C C C
625488339 XXX XXX XXX 35092250 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2008 NM Purchase Primary Yes B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488203 XXX XXX XXX 35092279 compliance 2 (Missing Data) Unable to determine if loan is a same lender refi Original Lender was not able to be determined. Unable to determine if correct 3/XX/2004 3/XX/2007 GA Refinance - Cash-out - Debt Consolidation Primary No B B B B
TILA rescission form was used.
625488203 XXX XXX XXX 35092280 compliance 2 Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance Truth in Lending Act: Unable to determine if Notice of Right to Cancel was TILA ROR Form - Because this issue is not uniformly settled among the circuit 3/XX/2004 3/XX/2007 GA Refinance - Cash-out - Debt Consolidation Primary No B B B B
executed on the proper Model Form. The H-9 form was used instead of the H-8 courts, the continuing risk that the borrower may have an extended right to
form, however, the loan file does not contain evidence that the refinance was by rescind (3 additional years) if a creditor uses the incorrect Model Form
the original creditor. remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625488241 XXX XXX XXX 35092341 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2009 AL Refinance - Rate/Term Primary No B B B B
an application date of 05/XX/2009 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2009.
625488462 XXX XXX XXX 35092370 credit 3 Missing Document: Missing Final 1003 Yes 11/XX/2007 WI Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488462 XXX XXX XXX 35092371 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. Yes 11/XX/2007 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 11/XX/2007 used as disbursement date for
compliance testing.
625488462 XXX XXX XXX 35092372 compliance 3 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable Yes 11/XX/2007 WI Refinance - Cash-out - Debt Consolidation Primary No D D D D
Federal, State or Local compliance testing is unreliable.
625488462 XXX XXX XXX 35092373 compliance 2 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using Yes 11/XX/2007 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 10/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 05/XX/2007. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625488462 XXX XXX XXX 35092374 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. Yes 11/XX/2007 11/XX/2010 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488462 XXX XXX XXX 35092375 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a Yes 11/XX/2007 11/XX/2010 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625488462 XXX XXX XXX 35092376 credit 3 Missing Document: Appraisal not provided Yes 11/XX/2007 WI Refinance - Cash-out - Debt Consolidation Primary No D D D D
625488462 XXX XXX XXX 35092377 compliance 2 (Doc Error) Initial GFE not provided Yes 11/XX/2007 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488462 XXX XXX XXX 35092378 credit 3 Missing Document: Credit Report not provided Yes 11/XX/2007 WI Refinance - Cash-out - Debt Consolidation Primary No D D D D
625488462 XXX XXX XXX 35092379 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off Yes 11/XX/2007 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488462 XXX XXX XXX 35092380 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided Yes 11/XX/2007 WI Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489590 XXX XXX XXX 35092483 credit 3 Missing Document: Missing Final 1003 3/XX/2006 GA Purchase Primary No C C C C
625489590 XXX XXX XXX 35092484 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2006 GA Purchase Primary No B B B B
an application date of 02/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 09/XX/2005.
625489590 XXX XXX XXX 35092485 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2006 3/XX/2007 GA Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625489590 XXX XXX XXX 35092486 compliance 2 (Doc Error) Initial GFE not provided 3/XX/2006 GA Purchase Primary No B B B B
625489590 XXX XXX XXX 35092487 credit 3 Missing Document: Credit Report not provided 3/XX/2006 GA Purchase Primary No D D D D
625489590 XXX XXX XXX 35092488 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 3/XX/2006 GA Purchase Primary No C C C C
625489470 XXX XXX XXX 35092510 compliance 2 Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure 2/XX/2005 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
within a reasonably practicable time after using credit score.
625489470 XXX XXX XXX 35092511 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2005 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
an application date of 01/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/2004.
625489470 XXX XXX XXX 35092512 compliance 2 Payoff Statement Missing Missing Payoff Statement: Unable to determine if a prepayment penalty was 2/XX/2005 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
included in the pay-off which may impact high cost findings.
625488689 XXX XXX XXX 35092545 credit 3 Missing Document: Missing Final 1003 12/XX/2003 IL Purchase Primary No C C C C
625489062 XXX XXX XXX 35092550 credit 3 Missing Document: Appraisal not provided Valuation Type: Stated / Valuation Report Date: 01/XX/2002 Yes 1/XX/2002 GA Refinance - Cash-out - Debt Consolidation Primary No D D D D
625489062 XXX XXX XXX 35092551 compliance 2 Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. Yes 1/XX/2002 1/XX/2005 GA Refinance - Cash-out - Debt Consolidation Primary No B B B B
timing requirements.
625489062 XXX XXX XXX 35092552 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a Yes 1/XX/2002 1/XX/2005 GA Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625489062 XXX XXX XXX 35092553 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. Yes 1/XX/2002 GA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 01/XX/2002 used as disbursement date for
compliance testing.
625489062 XXX XXX XXX 35092554 compliance 3 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable Yes 1/XX/2002 GA Refinance - Cash-out - Debt Consolidation Primary No D D D D
Federal, State or Local compliance testing is unreliable.
625489062 XXX XXX XXX 35092555 compliance 2 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using Yes 1/XX/2002 GA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 12/XX/2001 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 07/XX/2001. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625488013 XXX XXX XXX 35092599 compliance 2 (Doc Error) GFE Error: There is no evidence that the interest rate was locked 4/XX/2010 MD Refinance - Rate/Term Primary No B B B B
prior to closing
625488013 XXX XXX XXX 35092600 compliance 2 (Missing Data) Last Rate Set Date Last Date Rate Set and Initial Rate Lock Date not provided. Worst Case Scenario 4/XX/2010 MD Refinance - Rate/Term Primary No B B B B
between Creditor Application Date and Transaction Date used to determine rate
used for testing.
625488013 XXX XXX XXX 35092601 compliance 2 Maryland Ability to Repay Not Verified Maryland SB270: File does not contain evidence that analysis of borrower’s No express provisions for assignee liability 4/XX/2010 MD Refinance - Rate/Term Primary No B B B B
ability to repay was performed based on verified income, obligations, assets,
and/or employment using PITI payment based on fully indexed rate, if applicable.
625488013 XXX XXX XXX 35092602 compliance 2 TIL-MDIA 2009 Three Day Waiting Period Irregular Transaction Truth in Lending Act (Early TIL Disclosure): Corrected TIL for APR inaccuracy TILA - 1yr affirmative. Unlimited as a defense to foreclosure. Assignee 4/XX/2010 4/XX/2011 MD Refinance - Rate/Term Primary No B B B B
was not received by the borrower at least three (3) business days prior to liability.
closing.
625488013 XXX XXX XXX 35092603 compliance 2 ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2010 4/XX/2011 MD Refinance - Rate/Term Primary No B B B B
borrower within three (3) days of application.
625488013 XXX XXX XXX 35092604 compliance 2 CHARM Booklet Disclosure Timing TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2010 4/XX/2011 MD Refinance - Rate/Term Primary No B B B B
CHARM Booklet, not provided to the borrower within three (3) days of
application.
625488013 XXX XXX XXX 35092605 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from $XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 4/XX/2010 4/XX/2013 MD Refinance - Rate/Term Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488013 XXX XXX XXX 35092606 compliance 2 RESPA (2010) - 0% Tolerance (Line 1203) With Cure RESPA (2010): 0% tolerance violation for 1203 fee with evidence of cure provided RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2010 MD Refinance - Rate/Term Primary No B B B B
on Final HUD-1 within the statute or implementing regulation, Regulation X, for these type of
violations.
625488013 XXX XXX XXX 35092607 compliance 2 RESPA (2010) - GFE Settlement charges Good Thru Date Less than 10 Days RESPA (2010): GFE does not provide minimum ten (10) business day availability RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2010 MD Refinance - Rate/Term Primary No B B B B
for estimate of charges and terms for all other settlement charges. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489643 XXX XXX XXX 35092647 credit 3 Missing Document: Missing Final 1003 8/XX/2006 TN Refinance - Cash-out - Other Primary No C C C C
625489643 XXX XXX XXX 35092648 compliance 1 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 8/XX/2006 TN Refinance - Cash-out - Other Primary No A A A A 6/XX/2019 Yes 2019/XX/26: c
Security Instrument Notary Date of 08/XX/2006 used as disbursement date for
compliance testing.
625489643 XXX XXX XXX 35092649 compliance 1 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable 8/XX/2006 TN Refinance - Cash-out - Other Primary No A A A A 6/XX/2019 Yes 2019/XX/26: Clearing
Federal, State or Local compliance testing is unreliable.
625489643 XXX XXX XXX 35092650 compliance 1 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using 8/XX/2006 TN Refinance - Cash-out - Other Primary No A A A A 6/XX/2019 Yes 2019/XX/26: Clearing
an application date of 07/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2006. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625489643 XXX XXX XXX 35092651 compliance 2 Property Type Not Provided (Missing Data) Property Type. If property type is other than single family 8/XX/2006 TN Refinance - Cash-out - Other Primary No B B B B
residence, state and federal testing may be impacted.
625489643 XXX XXX XXX 35092652 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2006 8/XX/2009 TN Refinance - Cash-out - Other Primary No B B B B
defense to foreclosure. Assignee liability.
625489643 XXX XXX XXX 35092653 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 8/XX/2006 TN Refinance - Cash-out - Other Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489643 XXX XXX XXX 35092654 compliance 2 (Doc Error) Initial GFE not provided 8/XX/2006 TN Refinance - Cash-out - Other Primary No B B B B
625489643 XXX XXX XXX 35092655 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2006 TN Refinance - Cash-out - Other Primary No B B B B
an application date of 07/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2006.
625489643 XXX XXX XXX 35092656 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 8/XX/2006 8/XX/2009 TN Refinance - Cash-out - Other Primary No B B B B
625489686 XXX XXX XXX 35092728 compliance 2 TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit 5/XX/2013 5/XX/2016 NY Refinance - Rate/Term Primary No B B B B
(Circuit 2, 5, 7, 8, 9, 10 or DC) Model Form for a refinancing by the same creditor. The H-8 form was used, the courts, the continuing risk that the borrower may have an extended right to
H-9 form should have been used. rescind (3 additional years) if a creditor uses the incorrect Model Form
remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625489686 XXX XXX XXX 35092729 compliance 2 RESPA (2010) - 0% Tolerance (Line 1203) Without Cure RESPA (2010): 0% tolerance violation for 1203 fee without evidence of sufficient RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 5/XX/2013 NY Refinance - Rate/Term Primary No B B B B
cure provided. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488256 XXX XXX XXX 35092734 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 8/XX/2007 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
625488256 XXX XXX XXX 35092735 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 8/XX/2007 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
Security Instrument Notary Date of 08/XX/2007 used as disbursement date for
compliance testing.
625488256 XXX XXX XXX 35092736 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2007 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488256 XXX XXX XXX 35092737 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 08/XX/2007, prior to TILA ROR - 3yrs for rescindable transactions. 8/XX/2007 8/XX/2010 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
Date three (3) business days from transaction date of 08/XX/2007.
625489075 XXX XXX XXX 35092903 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2006 NM Refinance - Cash-out - Other Primary Yes B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488411 XXX XXX XXX 35092904 compliance 2 Federal FACTA Disclosure FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 5/XX/2005 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
625489649 XXX XXX XXX 35092924 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2007 IL Refinance - Cash-out - Other Primary No B B B B
an application date of 06/XX/2007 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2007.
625488313 XXX XXX XXX 35092946 credit 3 Missing Document: Flood Certificate not provided 6/XX/2006 FL Refinance - Cash-out - Other Primary No C C C C
625488313 XXX XXX XXX 35092947 credit 3 Missing Document: Missing Final 1003 6/XX/2006 FL Refinance - Cash-out - Other Primary No C C C C
625488313 XXX XXX XXX 35092948 compliance 2 TILA HELOC - HELOC Brochure Not Provided Timely Unable to determine compliance with timing requirements due to missing Initial TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2006 6/XX/2009 FL Refinance - Cash-out - Other Primary No B B B B
Loan Application Date. defense to foreclosure. Assignee liability.
625488313 XXX XXX XXX 35092949 compliance 2 TILA HELOC - Important Terms Disclosure Not Provided Timely Unable to determine compliance with timing requirements due to missing Initial TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 6/XX/2006 6/XX/2009 FL Refinance - Cash-out - Other Primary No B B B B
Loan Application Date. defense to foreclosure. Assignee liability.
625488313 XXX XXX XXX 35092950 compliance 2 (Missing Data) Flood Hazard Zone Federal Compliance - (Missing Data) Flood Hazard Zone: Special Flood Hazard Zone 6/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B
indicator was not provided. The applicable flood zone related testing cannot be
performed.
625488313 XXX XXX XXX 35092951 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B
an application date of 05/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 12/XX/2005.
625488313 XXX XXX XXX 35092952 compliance 2 (Missing Data) Unable to determine if loan is a same lender refi Original Lender was not able to be determined. Unable to determine if correct 6/XX/2006 6/XX/2009 FL Refinance - Cash-out - Other Primary No B B B B
TILA rescission form was used.
625488313 XXX XXX XXX 35092953 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488313 XXX XXX XXX 35092954 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625488313 XXX XXX XXX 35092955 compliance 2 Notice of Right To Cancel Not Provided to All Required Parties Truth in Lending Act: Notice of Right to Cancel was not signed by all parties TILA ROR - 3yrs for rescindable transactions. 6/XX/2006 6/XX/2009 FL Refinance - Cash-out - Other Primary No B B B B
whose ownership interest is or will be subject to the security interest.
625488313 XXX XXX XXX 35092956 compliance 2 Right of Rescission Timing HELOC - Receipt Date Missing Missing RTC Signature Date. Unable to determine compliance with rescission Right to Rescind is not signed. 6/XX/2006 6/XX/2009 FL Refinance - Cash-out - Other Primary No B B B B
timing requirements.
625488313 XXX XXX XXX 35092957 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 6/XX/2006 FL Refinance - Cash-out - Other Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488313 XXX XXX XXX 35092958 credit 3 Final Title Policy is missing. No evidence of title in file. File does not contain either Preliminary or Final Title. 6/XX/2006 FL Refinance - Cash-out - Other Primary No C C C C
625488998 XXX XXX XXX 35093002 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 9/XX/2005 CA Refinance - Cash-out - Other Primary No B B B B
625488998 XXX XXX XXX 35093003 compliance 2 Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit 9/XX/2005 9/XX/2008 CA Refinance - Cash-out - Other Primary No B B B B
Model Form for a refinance by a creditor that is not considered the original courts, the continuing risk that the borrower may have an extended right to
creditor. The H-9 form was used, the H-8 form should have been used. rescind (3 additional years) if a creditor uses the incorrect Model Form
remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625488247 XXX XXX XXX 35093009 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 06/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2007.
625488658 XXX XXX XXX 35093018 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2004 12/XX/2005 FL Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488658 XXX XXX XXX 35093019 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2004 12/XX/2005 FL Purchase Primary No B B B B
borrower within three (3) days of application.
625489227 XXX XXX XXX 35093073 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 12/XX/2007 SC Refinance - Cash-out - Other Primary No B B B B
625489227 XXX XXX XXX 35093074 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2007 SC Refinance - Cash-out - Other Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489227 XXX XXX XXX 35093075 compliance 2 South Carolina Home Loan (Complaint Agency Disclosure Not Provided) South Carolina Home Loan: Borrower not provided with a document specifying the Exceptions occurring more than 6 years ago may be outside the states statute of 12/XX/2007 12/XX/2013 SC Refinance - Cash-out - Other Primary No B B B B
agency designated to receive complaints or inquiries about the origination and limitations. Due to the potential remedies available to a court, this exception
making of the loan. carries elevated risk to an assignee during the initial 6 years after occurrence
of the violation. After the expiration of this 6 year period, the exception
retains risk for claims raised as a defense to foreclosure, but not at the same
level as during the initial 6 years for affirmative claims.
625489227 XXX XXX XXX 35093076 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. Final TIL is initialed by Borrower but not dated. Unable to determine when TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 12/XX/2007 12/XX/2010 SC Refinance - Cash-out - Other Primary No B B B B
Borrower initialed document. defense to foreclosure. Assignee liability.
625489126 XXX XXX XXX 35093214 credit 3 Missing Document: Missing Final 1003 12/XX/2006 PA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489126 XXX XXX XXX 35093215 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 12/XX/2006 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 12/XX/2006 used as disbursement date for
compliance testing.
625489126 XXX XXX XXX 35093216 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 12/XX/2006 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 11/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2006.
625489126 XXX XXX XXX 35093217 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 12/XX/2006 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489126 XXX XXX XXX 35093218 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2006 12/XX/2007 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489126 XXX XXX XXX 35093219 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 12/XX/2006, prior to TILA ROR - 3yrs for rescindable transactions. 12/XX/2006 12/XX/2009 PA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 12/XX/2006.
625489126 XXX XXX XXX 35093220 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 12/XX/2006 PA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488760 XXX XXX XXX 35093239 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 12/XX/2005 IA Refinance - Cash-out - Other Investment No C C C C
625488760 XXX XXX XXX 35093240 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 12/XX/2005 IA Refinance - Cash-out - Other Investment No B B B B
an application date of 11/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2005.
625488188 XXX XXX XXX 35109057 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2007 CA Refinance - Rate/Term Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488188 XXX XXX XXX 35109058 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2007 10/XX/2008 CA Refinance - Rate/Term Primary No B B B B
borrower within three (3) days of application.
625488188 XXX XXX XXX 35109059 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 10/XX/2007 10/XX/2008 CA Refinance - Rate/Term Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488188 XXX XXX XXX 35109060 compliance 2 TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Truth in Lending Act: Actual Date(s) on Notice of Right to Cancel occurs prior TILA ROR - 3yrs for rescindable transactions. 10/XX/2007 10/XX/2010 CA Refinance - Rate/Term Primary No B B B B
Date to expected date(s).
625488188 XXX XXX XXX 35109061 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 10/XX/2007 CA Refinance - Rate/Term Primary No B B B B
following clauses:
625488288 XXX XXX XXX 35109093 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2008 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488288 XXX XXX XXX 35109094 compliance 2 ARM Disclosure Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2008 4/XX/2009 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
borrower within three (3) days of application.
625489297 XXX XXX XXX 35080942 credit 3 Missing Document: Missing Final 1003 Tested 8/XX/2002 KS Refinance - Rate/Term Primary No C C C C
625489297 XXX XXX XXX 35080943 credit 1 Title: Evidence of title is missing Tested 8/XX/2002 KS Refinance - Rate/Term Primary No A A A A 3/XX/2018 Yes 2018/XX/06: Final title provided.
625489297 XXX XXX XXX 35080944 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver Tested 8/XX/2002 KS Refinance - Rate/Term Primary No B B B B
following clauses:
625489297 XXX XXX XXX 35080945 compliance 2 (Doc Error) Initial GFE not provided Tested 8/XX/2002 KS Refinance - Rate/Term Primary No B B B B
625489297 XXX XXX XXX 35080946 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off Tested 8/XX/2002 KS Refinance - Rate/Term Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489297 XXX XXX XXX 35080947 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. Tested 8/XX/2002 KS Refinance - Rate/Term Primary No B B B B
Security Instrument Notary Date of 08/XX/2002 used as disbursement date for
compliance testing.
625489297 XXX XXX XXX 35080948 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using Tested 8/XX/2002 KS Refinance - Rate/Term Primary No B B B B
an application date of 07/XX/2002 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2002.
625489297 XXX XXX XXX 35080949 compliance 3 (Missing Data) Missing Information to Determine LTV Unable to determine LTV or CLTV due to missing information. State compliance Tested 8/XX/2002 KS Refinance - Rate/Term Primary No C C C C
testing is unreliable.
625489297 XXX XXX XXX 35080950 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA Tested 8/XX/2002 8/XX/2003 KS Refinance - Rate/Term Primary No B B B B
borrower.
625489297 XXX XXX XXX 35080951 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA Tested 8/XX/2002 8/XX/2003 KS Refinance - Rate/Term Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489297 XXX XXX XXX 35080952 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. Tested 8/XX/2002 8/XX/2005 KS Refinance - Rate/Term Primary No B B B B
625489297 XXX XXX XXX 35080953 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a Tested 8/XX/2002 8/XX/2005 KS Refinance - Rate/Term Primary No B B B B
defense to foreclosure. Assignee liability.
625489587 XXX XXX XXX 35081238 credit 3 Missing Document: Missing Final 1003 9/XX/2006 MN Refinance - Cash-out - Other Primary No C C C C
625489587 XXX XXX XXX 35081239 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2006 MN Refinance - Cash-out - Other Primary No B B B B
an application date of 08/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2006.
625489587 XXX XXX XXX 35081240 compliance 2 Minnesota Residential Mortgage Originator and Servicer Licensing Act Minnesota Residential Originator and Servicer Licensing Act: Mortgage loan Assignee liability is unclear. Purchasers and assignees of Minnesota mortgage 9/XX/2006 MN Refinance - Cash-out - Other Primary No B B B B
(Impermissible Prepayment Penalty) contains an impermissible prepayment penalty exceeding 60 days interest on the loans would not appear to be liable for violations of the Act. However,
unpaid principal balance. effective 8/XX/07, although there does not appear to be any explicit assignee
liability, because a new private right of action permits a court to award
statutory damages equal to the amount of all lender fees included in the amount
of the principal of the residential mortgage loan, there is the potential that
secondary market participants may be adversely affected.
625489587 XXX XXX XXX 35081241 compliance 2 Minnesota Residential Mortgage Originator and Servicer Licensing Act (Prepayment Minnesota Residential Originator and Servicer Licensing Act: Prepayment penalty 9/XX/2006 MN Refinance - Cash-out - Other Primary No B B B B
Penalty Disclosure Not Provided at application) disclosure not provided to borrower.
625489587 XXX XXX XXX 35081242 compliance 2 Minnesota Residential Mortgage Originator and Servicer Licensing Act (Prepayment Minnesota Residential Originator and Servicer Licensing Act: Prepayment penalty 9/XX/2006 MN Refinance - Cash-out - Other Primary No B B B B
Penalty Disclosure Not Provided at closing) disclosure not provided to borrower.
625489587 XXX XXX XXX 35081243 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2006 9/XX/2007 MN Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489587 XXX XXX XXX 35081244 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization doesnt disclose a recording service fee of $XXX as prepaid XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 9/XX/2006 9/XX/2009 MN Refinance - Cash-out - Other Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. finance charge which was disclosed on HUD 1 for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489571 XXX XXX XXX 35081297 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2007 MD Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 01/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/2006.
625489121 XXX XXX XXX 35082147 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2007 11/XX/2008 TX Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625489121 XXX XXX XXX 35082148 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2007 11/XX/2008 TX Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625489121 XXX XXX XXX 35082149 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 11/XX/2007 TX Purchase Primary No B B B B
625489121 XXX XXX XXX 35082150 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2007 11/XX/2008 TX Purchase Primary No B B B B
defense to foreclosure. Assignee liability.
625489447 XXX XXX XXX 35082423 compliance 2 Idaho Residential Mortgage Practices Act (Rate Lock Agreement Not Provided) Idaho Residential Mortgage Practices Act: Rate Lock-In/Float Disclosure not The Residential Mortgage Practices Act does not appear to provide for assignee 6/XX/2004 ID Refinance - Rate/Term Primary No B B B B
provided to borrower. liability.
625489447 XXX XXX XXX 35082424 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 6/XX/2004 6/XX/2007 ID Refinance - Rate/Term Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489447 XXX XXX XXX 35082425 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 05/XX/2004, prior to TILA ROR - 3yrs for rescindable transactions. 6/XX/2004 6/XX/2007 ID Refinance - Rate/Term Primary No B B B B
Date three (3) business days from transaction date of 06/XX/2004.
625489447 XXX XXX XXX 35082426 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2004 ID Refinance - Rate/Term Primary No B B B B
an application date of 05/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 12/XX/2003.
625489447 XXX XXX XXX 35082427 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2004 ID Refinance - Rate/Term Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489725 XXX XXX XXX 35082486 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2005 NJ Purchase Primary Yes B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489531 XXX XXX XXX 35082495 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 4/XX/2008 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
Within 3 Business Days of Application Disclosure to applicant within three (3) business days of application. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488181 XXX XXX XXX 35082511 credit 3 Missing Document: Missing Final 1003 2/XX/2005 NY Refinance - Rate/Term Primary No C C C C
625488181 XXX XXX XXX 35082512 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2005 2/XX/2006 NY Refinance - Rate/Term Primary No B B B B
borrower.
625488181 XXX XXX XXX 35082513 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2005 2/XX/2006 NY Refinance - Rate/Term Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488181 XXX XXX XXX 35082514 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 2/XX/2005 2/XX/2008 NY Refinance - Rate/Term Primary No B B B B
625488181 XXX XXX XXX 35082515 compliance 2 (Doc Error) Initial GFE not provided 2/XX/2005 NY Refinance - Rate/Term Primary No B B B B
625488181 XXX XXX XXX 35082516 credit 1 Final Title Policy is missing. No evidence of title in file. 2/XX/2005 NY Refinance - Rate/Term Primary No A A A A 4/XX/2018 Yes 2018/XX/27: [GS Comment 4/XX/2018]: Final Title Policy Located 2018/XX/30: Received Final Title Policy. Exception cleared.
625488181 XXX XXX XXX 35082517 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2005 NY Refinance - Rate/Term Primary No B B B B
an application date of 01/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/2004.
625488181 XXX XXX XXX 35082518 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine reason for under disclosure due to missing itemization of XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 2/XX/2005 2/XX/2008 NY Refinance - Rate/Term Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. amount financed.. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488733 XXX XXX XXX 35082554 credit 3 Missing Document: Missing Final 1003 5/XX/2005 FL Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488733 XXX XXX XXX 35082555 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2005 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 04/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 11/XX/2004.
625488568 XXX XXX XXX 35082801 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2007 MD Purchase Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488258 XXX XXX XXX 35082819 credit 3 Missing Document: Missing Final 1003 7/XX/2003 NY Purchase Primary No C C C C
625488258 XXX XXX XXX 35082820 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 7/XX/2003 NY Purchase Primary No C C C C
625488258 XXX XXX XXX 35082821 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2003 NY Purchase Primary No B B B B
an application date of 06/XX/2003 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 05/XX/2003.
625489380 XXX XXX XXX 35082910 credit 1 Missing Document: Security Instrument - Subject Lien not provided 2/XX/2008 CT Refinance - Rate/Term Primary No A A A A 5/XX/2018 Yes 2018/XX/24: Document provided in trailing docs.
625489380 XXX XXX XXX 35082911 credit 3 Missing Document: Missing Final 1003 2/XX/2008 CT Refinance - Rate/Term Primary No C C C C
625489380 XXX XXX XXX 35082912 compliance 1 Missing Document: Missing Lender's Initial 1003 2/XX/2008 CT Refinance - Rate/Term Primary No A A A A 5/XX/2018 Yes 2018/XX/24: Cleared as redundant
625489380 XXX XXX XXX 35082913 compliance 1 (Missing Doc) Incomplete loan images/file Loan file only contains the HUD, TIL, approval, title, and appraisal. 2/XX/2008 CT Refinance - Rate/Term Primary No A A A A 5/XX/2018 Yes 2018/XX/24: Note provided in trailing docs.
625489380 XXX XXX XXX 35082914 compliance 1 Missing Document: Note - Subject Lien not provided 2/XX/2008 CT Refinance - Rate/Term Primary No A A A A 5/XX/2018 Yes 2018/XX/24: Note provided in trailing docs.
625489380 XXX XXX XXX 35082915 credit 3 Missing Document: Note Addendum - Prepayment not provided A rider to the security instrument reflects that there is a prepayment penalty, 2/XX/2008 CT Refinance - Rate/Term Primary No C C C C
however the note provided does not show the prepayment and there is no note
rider in the image file adding one.
625489380 XXX XXX XXX 35082916 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2008 CT Refinance - Rate/Term Primary No B B B B
an application date of 01/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 01/XX/2008.
625489380 XXX XXX XXX 35082917 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2008 CT Refinance - Rate/Term Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489380 XXX XXX XXX 35082918 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2008 2/XX/2009 CT Refinance - Rate/Term Primary No B B B B
Loan Application Date.
625489380 XXX XXX XXX 35082919 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 2/XX/2008 2/XX/2009 CT Refinance - Rate/Term Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488581 XXX XXX XXX 35083103 credit 3 Missing Document: Mortgage Insurance Certificate (MIC) not provided 2/XX/2008 FL Purchase Primary No C C C C
625488450 XXX XXX XXX 35083117 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 6/XX/2003 SC Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 06/XX/2003 used as disbursement date for
compliance testing.
625488450 XXX XXX XXX 35083118 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 06/XX/2003, prior to TILA ROR - 3yrs for rescindable transactions. 6/XX/2003 6/XX/2006 SC Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 06/XX/2003.
625489675 XXX XXX XXX 35083393 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 1/XX/2007 MD Construction-Permanent Primary No B B B B
Security Instrument Notary Date of 01/XX/2007 used as disbursement date for
compliance testing.
625488161 XXX XXX XXX 35083668 credit 3 Missing Document: Missing Final 1003 3/XX/2002 WI Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488161 XXX XXX XXX 35083669 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2002 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 02/XX/2002 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 09/XX/2001.
625488161 XXX XXX XXX 35083670 compliance 2 Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. 3/XX/2002 3/XX/2005 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
timing requirements.
625488161 XXX XXX XXX 35083671 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2002 3/XX/2005 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625488161 XXX XXX XXX 35083672 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 3/XX/2002 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
following clauses:
625488161 XXX XXX XXX 35083673 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 3/XX/2002 3/XX/2005 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625488161 XXX XXX XXX 35083674 compliance 2 Note Error: Note late charge percentage exceeds maximum per state Late charge not allowed per state (WI) - max late charge for WI is 5% - note 3/XX/2002 WI Refinance - Cash-out - Debt Consolidation Primary No B B B B
states 10%
625488185 XXX XXX XXX 35083707 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 9/XX/2006 AZ Purchase Primary No B B B B
an application date of 08/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/2006.
625488185 XXX XXX XXX 35083708 compliance 2 ARM Disclosure Prior to Closing Timing TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2006 9/XX/2007 AZ Purchase Primary No B B B B
borrower at least three (3) days prior to consummation for a loan that did not
start as an ARM.
625488185 XXX XXX XXX 35083709 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 9/XX/2006 9/XX/2007 AZ Purchase Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488185 XXX XXX XXX 35083710 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from The Lender's TIL reflects the expiration of MI after 120 months, however based XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 9/XX/2006 9/XX/2007 AZ Purchase Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. on the loan amount and value the MI expires after month 136. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488743 XXX XXX XXX 35083711 credit 3 Missing Document: Missing Final 1003 2/XX/1999 OH Refinance - Cash-out - Other Primary No C C C C
625488743 XXX XXX XXX 35083712 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/1999 OH Refinance - Cash-out - Other Primary No B B B B
an application date of 01/XX/1999 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/1998.
625488743 XXX XXX XXX 35083713 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing itemization of amount XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 2/XX/1999 2/XX/2002 OH Refinance - Cash-out - Other Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488743 XXX XXX XXX 35083714 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 2/XX/1999 2/XX/2002 OH Refinance - Cash-out - Other Primary No B B B B
625488743 XXX XXX XXX 35083715 credit 3 Missing Valuation: Appraisal not provided 2/XX/1999 OH Refinance - Cash-out - Other Primary No C C C C
625488743 XXX XXX XXX 35083716 compliance 2 (Doc Error) TIL Error: Borrower signature not dated. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 2/XX/1999 2/XX/2002 OH Refinance - Cash-out - Other Primary No B B B B
defense to foreclosure. Assignee liability.
625488743 XXX XXX XXX 35083717 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 2/XX/1999 2/XX/2002 OH Refinance - Cash-out - Other Primary No B B B B
defense to foreclosure. Assignee liability.
625489582 XXX XXX XXX 35083802 credit 3 Missing Document: FHA Case Number Assignment not provided 9/XX/2009 FL Purchase Primary No C C C C
625489582 XXX XXX XXX 35083803 credit 3 Missing Document: FHA Mortgage Insurance Certificate not provided 9/XX/2009 FL Purchase Primary No C C C C
625489582 XXX XXX XXX 35083804 credit 3 Missing Document: HUD/VA 92900-A not provided 9/XX/2009 FL Purchase Primary No C C C C
625489582 XXX XXX XXX 35083805 compliance 2 FHA Case Number Assignment Date Missing FHA Case # Assignment Date missing. Creditor application date used as FHA case # 9/XX/2009 FL Purchase Primary No B B B B
assignment date for purposes of any applicable compliance testing.
625488635 XXX XXX XXX 35083859 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 9/XX/2000 9/XX/2003 VA Refinance - Rate/Term Primary No B B B B
625488637 XXX XXX XXX 35083878 compliance 2 (Doc Error) GFE Error: There is no evidence that the interest rate was locked 4/XX/1999 GA Refinance - Cash-out - Debt Consolidation Primary No B B B B
prior to closing
625488637 XXX XXX XXX 35083879 compliance 2 Right of Rescission Timing - Note Date used as Transaction Date Unable to conclusively determine date of consummation. Note date used as 4/XX/1999 GA Refinance - Cash-out - Debt Consolidation Primary No B B B B
transaction date for purposes of determining compliance with rescission timing
requirements
625488637 XXX XXX XXX 35083880 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL Itemization did not disclose the closing attorney fee of $XXX as prepaid XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 4/XX/1999 4/XX/2002 GA Refinance - Cash-out - Debt Consolidation Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. finance charges. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489212 XXX XXX XXX 35083946 credit 3 Missing Document: Missing Final 1003 8/XX/2006 NJ Refinance - Cash-out - Other Primary Yes C C C C
625489212 XXX XXX XXX 35083947 compliance 2 (Doc Error) Initial GFE not provided 8/XX/2006 NJ Refinance - Cash-out - Other Primary Yes B B B B
625489212 XXX XXX XXX 35083948 credit 1 Final Title Policy is missing. No evidence of title in file. 8/XX/2006 NJ Refinance - Cash-out - Other Primary Yes A A A A 6/XX/2018 Yes 2018/XX/13: Received Final title, exception cleared.
625489212 XXX XXX XXX 35083949 compliance 2 Initial TIL not provided 8/XX/2006 8/XX/2007 NJ Refinance - Cash-out - Other Primary Yes B B B B
625489212 XXX XXX XXX 35083950 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 8/XX/2006 NJ Refinance - Cash-out - Other Primary Yes B B B B
625489212 XXX XXX XXX 35083951 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 8/XX/2006 NJ Refinance - Cash-out - Other Primary Yes B B B B
Security Instrument Notary Date of 08/XX/2006 used as disbursement date for
compliance testing.
625489212 XXX XXX XXX 35083952 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 08/XX/2006, prior to TILA ROR - 3yrs for rescindable transactions. 8/XX/2006 8/XX/2009 NJ Refinance - Cash-out - Other Primary Yes B B B B
Date three (3) business days from transaction date of 08/XX/2006.
625489212 XXX XXX XXX 35083953 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2006 NJ Refinance - Cash-out - Other Primary Yes B B B B
an application date of 08/XX/2006 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/2006.
625489212 XXX XXX XXX 35083954 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2006 NJ Refinance - Cash-out - Other Primary Yes B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489212 XXX XXX XXX 35083955 credit 3 Missing Valuation: Appraisal not provided 8/XX/2006 NJ Refinance - Cash-out - Other Primary Yes C C C C
625488800 XXX XXX XXX 35084167 credit 3 Missing Document: Missing Final 1003 11/XX/2005 AZ Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488800 XXX XXX XXX 35084168 compliance 2 (Doc Error) TIL Error: Final TIL not signed by all required parties TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 11/XX/2005 11/XX/2008 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B
defense to foreclosure. Assignee liability.
625488800 XXX XXX XXX 35084169 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 11/XX/2005 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 11/XX/2005 used as disbursement date for
compliance testing.
625488800 XXX XXX XXX 35084170 compliance 2 Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission TILA ROR - 3yrs for rescindable transactions. 11/XX/2005 11/XX/2008 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B
timing requirements.
625488800 XXX XXX XXX 35084171 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 11/XX/2005, prior to TILA ROR - 3yrs for rescindable transactions. 11/XX/2005 11/XX/2008 AZ Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 11/XX/2005.
625488345 XXX XXX XXX 35084316 credit 3 Missing Valuation: Appraisal not provided 10/XX/2009 IL Refinance - Rate/Term Investment No C C C C
625488806 XXX XXX XXX 35084406 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 3/XX/2008 CA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 03/XX/2008 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 12/XX/2007.
625488806 XXX XXX XXX 35084407 credit 3 Missing Document: Missing Final 1003 3/XX/2008 CA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488283 XXX XXX XXX 35084452 credit 3 Missing Document: Missing Final 1003 4/XX/2007 FL Refinance - Cash-out - Other Primary No C C C C
625488283 XXX XXX XXX 35084453 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2007 FL Refinance - Cash-out - Other Primary No B B B B
an application date of 03/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2007.
625488184 XXX XXX XXX 35084537 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 6/XX/2006 LA Refinance - Cash-out - Other Primary No B B B B
an application date of 05/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 05/XX/2006.
625488184 XXX XXX XXX 35084538 compliance 2 RESPA Disclosure - Missing Signature on Affiliated Business Arrangement RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2006 LA Refinance - Cash-out - Other Primary No B B B B
Disclosure Arrangement Disclosure. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488184 XXX XXX XXX 35084539 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 6/XX/2006 LA Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488539 XXX XXX XXX 35084592 compliance 1 (Missing Doc) Incomplete loan images/file Loan file does not contain any origination documentation. No 6/XX/2007 IL Refinance - UTD Investment No A A A A 5/XX/2018 Yes 2018/XX/23: Received Loan Images - exception cleared
625488539 XXX XXX XXX 35084593 credit 3 Missing Document: Missing Final 1003 No 6/XX/2007 IL Refinance - UTD Investment No C C C C
625488539 XXX XXX XXX 35084594 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off No 6/XX/2007 IL Refinance - UTD Investment No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488539 XXX XXX XXX 35084595 compliance 2 (Doc Error) Initial GFE not provided No 6/XX/2007 IL Refinance - UTD Investment No B B B B
625488539 XXX XXX XXX 35084596 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. No 6/XX/2007 IL Refinance - UTD Investment No B B B B
Security Instrument Notary Date of 06/XX/2007 used as disbursement date for
compliance testing.
625488539 XXX XXX XXX 35084597 compliance 3 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable No 6/XX/2007 IL Refinance - UTD Investment No D D D D
Federal, State or Local compliance testing is unreliable.
625488539 XXX XXX XXX 35084598 compliance 2 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using No 6/XX/2007 IL Refinance - UTD Investment No B B B B
an application date of 05/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 12/XX/2006. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625488448 XXX XXX XXX 35084688 compliance 1 (Missing Doc) Incomplete loan images/file Loan file does not contain any origination documentation. 2/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No A A A A 5/XX/2018 Yes 2018/XX/23: Received Loan Images - exception cleared
625488448 XXX XXX XXX 35084689 credit 3 Missing Document: Missing Final 1003 2/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No C C C C
625488448 XXX XXX XXX 35084690 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 2/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488448 XXX XXX XXX 35084691 credit 2 Security Instrument is not on a FNMA/FHLMC form and does not contain the Homestead Exemption Waiver 2/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
following clauses:
625488448 XXX XXX XXX 35084692 compliance 2 (Doc Error) Initial GFE not provided 2/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488448 XXX XXX XXX 35084693 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 2/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 02/XX/2006 used as disbursement date for
compliance testing.
625488448 XXX XXX XXX 35084694 compliance 1 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable 2/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No A A A A 6/XX/2018 Yes 2018/XX/12: Received HUD, exception cleared
Federal, State or Local compliance testing is unreliable.
625488448 XXX XXX XXX 35084695 compliance 1 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using 2/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No A A A A 6/XX/2018 Yes 2018/XX/12: Received HUD, exception cleared
an application date of 01/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/2005. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625488448 XXX XXX XXX 35084696 compliance 2 Property Type Not Provided (Missing Data) Property Type. If property type is other than single family 2/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
residence, state and federal testing may be impacted.
625488448 XXX XXX XXX 35084697 compliance 1 RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No A A A A 6/XX/2018 Yes 2018/XX/12: Received HUD, exception cleared
Disclosure to borrower. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488448 XXX XXX XXX 35084698 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 2/XX/2006 2/XX/2009 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488448 XXX XXX XXX 35084699 compliance 1 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 2/XX/2006 2/XX/2009 NY Refinance - Cash-out - Debt Consolidation Primary No A A A A 6/XX/2018 Yes 2018/XX/12: Received TIL, exception cleared
defense to foreclosure. Assignee liability.
625488448 XXX XXX XXX 35084700 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 2/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488448 XXX XXX XXX 35084701 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2006 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 01/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 08/XX/2005.
625488448 XXX XXX XXX 35084702 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine reason for under disclosure due to missing itemization of XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 2/XX/2006 2/XX/2009 NY Refinance - Cash-out - Debt Consolidation Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. prepaid finance charges. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488159 XXX XXX XXX 35084703 credit 3 Missing Document: Missing Final 1003 11/XX/2005 WA Refinance - Rate/Term Primary No C C C C
625488159 XXX XXX XXX 35084704 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 11/XX/2005 WA Refinance - Rate/Term Primary No B B B B
625489369 XXX XXX XXX 35084814 credit 3 Missing Document: FHA Case Number Assignment not provided 7/XX/2010 MA Refinance - Rate/Term Primary Yes C C C C
625489369 XXX XXX XXX 35084815 compliance 2 (Doc Error) GFE Error: Rate lock period not provided. GFE Date: 06/XX/2010 7/XX/2010 MA Refinance - Rate/Term Primary Yes B B B B
625489369 XXX XXX XXX 35084816 compliance 2 (Doc Error) GFE Error: Interest rate available through date not provided. GFE Date: 06/XX/2010 Interest Rate Available Through Date is blank for GFE dated 7/XX/2010 MA Refinance - Rate/Term Primary Yes B B B B
06/XX/2010.
625489369 XXX XXX XXX 35084817 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure due to missing Itemization of Amount XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 7/XX/2010 7/XX/2014 MA Refinance - Rate/Term Primary Yes B B B B
calculated Finance Charge of $XXX in the amount of $XXX. Financed. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489369 XXX XXX XXX 35084818 credit 3 Missing Document: FHA Mortgage Insurance Certificate not provided 7/XX/2010 MA Refinance - Rate/Term Primary Yes C C C C
625489369 XXX XXX XXX 35084819 credit 3 Missing Document: Missing Final 1003 7/XX/2010 MA Refinance - Rate/Term Primary Yes C C C C
625489369 XXX XXX XXX 35084820 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2010 MA Refinance - Rate/Term Primary Yes B B B B
an application date of 06/XX/2010 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 03/XX/2010.
625489369 XXX XXX XXX 35084821 compliance 2 RESPA - Initial GFE Not Provided Within 3 Business Days of Application Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2010 MA Refinance - Rate/Term Primary Yes B B B B
Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489369 XXX XXX XXX 35084822 compliance 2 TIL-MDIA - Initial TIL Not Provided within 3 Business Days of Application Unable to determine compliance with timing requirements due to missing Initial TILA MDIA - subject to a 1 year SOL for affirmative claims under TILA, Unlimited 7/XX/2010 7/XX/2011 MA Refinance - Rate/Term Primary Yes B B B B
Loan Application Date. as a defense to foreclosure. Assignee liability.
625489369 XXX XXX XXX 35084823 compliance 2 RESPA Servicing Disclosure: Servicing Disclosure Statement Not Provided Within 3 Unable to determine compliance with timing requirements due to missing Initial Lender's loan application not in file. RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 7/XX/2010 MA Refinance - Rate/Term Primary Yes B B B B
Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489369 XXX XXX XXX 35084824 credit 3 Missing Valuation: Appraisal not provided 7/XX/2010 MA Refinance - Rate/Term Primary Yes C C C C
625489308 XXX XXX XXX 35086759 credit 3 Missing Document: Missing Final 1003 12/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489308 XXX XXX XXX 35086761 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 12/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 12/XX/2006 used as disbursement date for
compliance testing.
625489308 XXX XXX XXX 35086762 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 12/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 11/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625489308 XXX XXX XXX 35086763 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 12/XX/2006, prior to TILA ROR - 3yrs for rescindable transactions. 12/XX/2006 12/XX/2009 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 12/XX/2006.
625489308 XXX XXX XXX 35086764 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 12/XX/2006 12/XX/2009 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
are estimates. defense to foreclosure. Assignee liability.
625489122 XXX XXX XXX 35087860 credit 3 Missing Document: Missing Final 1003 9/XX/2009 MA Purchase Primary Yes C C C C
625489122 XXX XXX XXX 35087861 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 9/XX/2009 MA Purchase Primary Yes B B B B
625489122 XXX XXX XXX 35087862 compliance 2 Massachusetts Mortgage Lender and Broker Regulation (Ability to Repay not Massachusetts Mortgage Lender and Broker Regulation: File does not contain 9/XX/2009 MA Purchase Primary Yes B B B B
Verified) evidence that analysis of borrower’s ability to repay was performed based on
verified income, obligations, assets, and/or employment using PITI payment based
on fully indexed rate and fully amortizing payment, if applicable
625487951 XXX XXX XXX 35088030 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 10/XX/2004 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 10/XX/2004 which is 0 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2004.
625487951 XXX XXX XXX 35088031 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 10/XX/2004 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625487951 XXX XXX XXX 35088032 compliance 2 Initial TIL not provided 10/XX/2004 10/XX/2005 IL Refinance - Cash-out - Debt Consolidation Primary No B B B B
625488601 XXX XXX XXX 35088558 credit 3 Missing Document: Missing Final 1003 8/XX/2007 NJ Refinance - Cash-out - Debt Consolidation Primary Yes C C C C
625488601 XXX XXX XXX 35088559 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 8/XX/2007 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
625488601 XXX XXX XXX 35088560 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2007 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
an application date of 07/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2007.
625488601 XXX XXX XXX 35088561 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 8/XX/2007 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625488601 XXX XXX XXX 35088562 compliance 2 ARM Disclosure Compliant TIL variable rate disclosure: ARM loan program disclosure does not match terms TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2007 8/XX/2008 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
of loan.
625488601 XXX XXX XXX 35088563 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 08/XX/2007, prior to TILA ROR - 3yrs for rescindable transactions. 8/XX/2007 8/XX/2010 NJ Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
Date three (3) business days from transaction date of 08/XX/2007.
625488410 XXX XXX XXX 35088966 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine cause of underdisclosure due to missing final itemization of XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 11/XX/2004 11/XX/2007 MD Refinance - Rate/Term Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. fees. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625488245 XXX XXX XXX 35089208 credit 3 Missing Document: Missing Final 1003 11/XX/2004 IL Purchase Primary No C C C C
625488245 XXX XXX XXX 35089209 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 11/XX/2004 IL Purchase Primary No B B B B
an application date of 11/XX/2004 which is 0 months prior to consummation. A
lookback was performed to determine this application date.
625488245 XXX XXX XXX 35089210 compliance 2 Illinois Prepayment Penalty Illinois Prepayment Penalty (llinois Interest Act): Prepayment penalty not PPP Expired. Prepayment charge not allowed per state (IL) - max prepayment 11/XX/2004 IL Purchase Primary No B B B B
permissible on a loan with an interest rate greater than 8%. charge for (IL) is 3% - note states 5%. Lender is XXX
625488901 XXX XXX XXX 35089596 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2000 NC Purchase Primary No B B B B
an application date of 08/XX/2000 which is 0 months prior to consummation. A
lookback was performed to determine this application date.
625488901 XXX XXX XXX 35089597 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2000 8/XX/2001 NC Purchase Primary No B B B B
application due to missing information.
625488901 XXX XXX XXX 35089598 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 8/XX/2000 8/XX/2001 NC Purchase Primary No B B B B
Loan Application Date.
625489215 XXX XXX XXX 35089608 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Unable to determine under disclosure, it appears lender used an index lower than XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 12/XX/2006 12/XX/2009 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. available within look back. Lowest index within look back is 5.29310%. for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
liability.
625489215 XXX XXX XXX 35089609 credit 3 Missing Document: Missing Final 1003 12/XX/2006 VA Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489215 XXX XXX XXX 35089610 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 12/XX/2006 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 11/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625489215 XXX XXX XXX 35089611 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2006 12/XX/2007 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
application due to missing information.
625489215 XXX XXX XXX 35089612 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 12/XX/2006 12/XX/2007 VA Refinance - Cash-out - Debt Consolidation Primary No B B B B
Loan Application Date.
625489431 XXX XXX XXX 35089954 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 1/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
an application date of 12/XX/2005 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625489431 XXX XXX XXX 35089955 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 1/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
Within 3 Business Days of Application Business Arrangement Disclosure to applicant within three (3) business days of within the statute or implementing regulation, Regulation X, for these type of
application due to missing information. violations.
625489431 XXX XXX XXX 35089956 compliance 2 ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2006 1/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
application due to missing information.
625489431 XXX XXX XXX 35089957 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 1/XX/2006 1/XX/2007 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
Loan Application Date.
625489431 XXX XXX XXX 35089958 credit 3 Missing Document: Missing Final 1003 1/XX/2006 FL Refinance - Cash-out - Debt Consolidation Primary No C C C C
625489431 XXX XXX XXX 35089959 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from Under disclosure is due to the lender utilizing an index value of 3.6183% per XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 1/XX/2006 1/XX/2009 FL Refinance - Cash-out - Debt Consolidation Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. the approval, however the lowest index value available in the lookback period is for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
3.7508%. liability.
625488415 XXX XXX XXX 35090143 credit 3 Missing Document: Missing Final 1003 5/XX/2001 SC Refinance - Cash-out - Other Primary No C C C C
625488415 XXX XXX XXX 35090144 compliance 2 (Doc Error) Initial GFE not provided 5/XX/2001 SC Refinance - Cash-out - Other Primary No B B B B
625488415 XXX XXX XXX 35090146 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 5/XX/2001 SC Refinance - Cash-out - Other Primary No B B B B
Security Instrument Notary Date of 05/XX/2001 used as disbursement date for
compliance testing.
625488415 XXX XXX XXX 35090147 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 5/XX/2001 SC Refinance - Cash-out - Other Primary No B B B B
an application date of 04/XX/2001 which is 1 months prior to consummation. A
lookback was performed to determine this application date.
625488415 XXX XXX XXX 35090148 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 5/XX/2001 5/XX/2004 SC Refinance - Cash-out - Other Primary No B B B B
625488415 XXX XXX XXX 35090149 compliance 2 Final TIL Not Provided to Borrower At or Before Consummation Truth in Lending Act: Final TIL was not provided to the borrower by closing. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 5/XX/2001 5/XX/2004 SC Refinance - Cash-out - Other Primary No B B B B
defense to foreclosure. Assignee liability.
625488762 XXX XXX XXX 35090275 compliance 3 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable Yes 1/XX/2005 NY Refinance - Cash-out - Other Primary No D D D D
Federal, State or Local compliance testing is unreliable.
625488762 XXX XXX XXX 35090276 compliance 2 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using Yes 1/XX/2005 NY Refinance - Cash-out - Other Primary No B B B B
an application date of 12/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. Due to missing HUD-1
or Closing Disclosure, no fees were used in testing.
625488762 XXX XXX XXX 35090277 compliance 2 ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 1/XX/2005 1/XX/2006 NY Refinance - Cash-out - Other Primary No B B B B
borrower.
625488762 XXX XXX XXX 35090278 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 1/XX/2005 1/XX/2006 NY Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower.
625488762 XXX XXX XXX 35090279 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. Yes 1/XX/2005 1/XX/2008 NY Refinance - Cash-out - Other Primary No B B B B
625488762 XXX XXX XXX 35090280 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a Yes 1/XX/2005 1/XX/2008 NY Refinance - Cash-out - Other Primary No B B B B
defense to foreclosure. Assignee liability.
625488762 XXX XXX XXX 35090281 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off Yes 1/XX/2005 NY Refinance - Cash-out - Other Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625488762 XXX XXX XXX 35090282 compliance 2 (Doc Error) Initial GFE not provided Yes 1/XX/2005 NY Refinance - Cash-out - Other Primary No B B B B
625488762 XXX XXX XXX 35090283 credit 3 Missing Document: Missing Final 1003 Yes 1/XX/2005 NY Refinance - Cash-out - Other Primary No C C C C
625488762 XXX XXX XXX 35090284 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. Yes 1/XX/2005 NY Refinance - Cash-out - Other Primary No B B B B
Security Instrument Notary Date of 01/XX/2005 used as disbursement date for
compliance testing.
625488874 XXX XXX XXX 35090305 compliance 2 Massachusetts Home Loan - Borrower's Interest Tangible Net Benefit Worksheet Not Massachusetts Home Loan: No evidence in loan file of document or worksheet The regulations do not clarify the enforcement provisions of Mass. Gen. L. c. 2/XX/2007 2/XX/2010 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
in File indicating how the lender determined that the home loan is in the borrower's 183. Accordingly, the consequences of a compliance failure remain unclear. In
interest. particular, it is probable that a violation of the "borrower's interest"
standard can be raised as a defense to, or otherwise impede, foreclosure. Also,
it is possible that a violation of the "borrower's interest" standard would
constitute a violation of the Massachusetts unfair and deceptive acts and
practices statute.
625488874 XXX XXX XXX 35090306 compliance 2 Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 2/XX/2007 2/XX/2011 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
are estimates. defense to foreclosure. Assignee liability.
625489443 XXX XXX XXX 35090913 credit 3 Missing Document: Missing Final 1003 8/XX/2006 NY Refinance - Cash-out - Debt Consolidation UTD No C C C C
625489443 XXX XXX XXX 35090914 credit 3 Missing Document: Security Instrument - Subject Lien not provided 8/XX/2006 NY Refinance - Cash-out - Debt Consolidation UTD No D D D D
625489443 XXX XXX XXX 35090915 compliance 1 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. Note 8/XX/2006 NY Refinance - Cash-out - Debt Consolidation UTD No A A A A 7/XX/2019 Yes 2019/XX/04: Received Final HUD-1, exception cleared
Date of 08/XX/2006 used as disbursement date for compliance testing.
625489443 XXX XXX XXX 35090916 compliance 1 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable 8/XX/2006 NY Refinance - Cash-out - Debt Consolidation UTD No A A A A 7/XX/2019 Yes 2019/XX/04: Received Final HUD-1, exception cleared
Federal, State or Local compliance testing is unreliable.
625489443 XXX XXX XXX 35090917 compliance 1 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using 8/XX/2006 NY Refinance - Cash-out - Debt Consolidation UTD No A A A A 7/XX/2019 Yes 2019/XX/04: Received Final HUD-1, exception cleared
an application date of 07/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2006. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625489443 XXX XXX XXX 35090918 compliance 2 New York Late Charge Percent Testing Note late charge exceeds maximum per state. $XXX late charge exceeds 2% maximum per state (NY) 8/XX/2006 NY Refinance - Cash-out - Debt Consolidation UTD No B B B B
625489443 XXX XXX XXX 35090919 compliance 2 New York Prepayment Penalty New York Prepayment Penalty: Loan with an interest rate greater than 6% contains PPP is expired. Prepayment penalty prohibited per state (NY). 8/XX/2006 NY Refinance - Cash-out - Debt Consolidation UTD No B B B B
a prepayment penalty greater than 12 months.
625489443 XXX XXX XXX 35090920 compliance 2 Right of Rescission Timing - Note Date used as Transaction Date Unable to conclusively determine date of consummation. Note date used as 8/XX/2006 NY Refinance - Cash-out - Debt Consolidation UTD No B B B B
transaction date for purposes of determining compliance with rescission timing
requirements
625489443 XXX XXX XXX 35090921 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 8/XX/2006 8/XX/2009 NY Refinance - Cash-out - Debt Consolidation UTD No B B B B
625489443 XXX XXX XXX 35090922 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a 8/XX/2006 8/XX/2009 NY Refinance - Cash-out - Debt Consolidation UTD No B B B B
defense to foreclosure. Assignee liability.
625489443 XXX XXX XXX 35090923 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off 8/XX/2006 NY Refinance - Cash-out - Debt Consolidation UTD No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625489443 XXX XXX XXX 35090924 credit 3 Missing Document: Appraisal not provided 8/XX/2006 NY Refinance - Cash-out - Debt Consolidation UTD No D D D D
625489443 XXX XXX XXX 35090925 compliance 2 (Doc Error) Initial GFE not provided 8/XX/2006 NY Refinance - Cash-out - Debt Consolidation UTD No B B B B
625489443 XXX XXX XXX 35090926 credit 3 Missing Document: Credit Report not provided 8/XX/2006 NY Refinance - Cash-out - Debt Consolidation UTD No D D D D
625489443 XXX XXX XXX 35090927 compliance 2 Unable to determine occupancy, compliance results were generated using a 8/XX/2006 NY Refinance - Cash-out - Debt Consolidation UTD No B B B B
defaulted value of Primary.
625489443 XXX XXX XXX 35090928 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 8/XX/2006 NY Refinance - Cash-out - Debt Consolidation UTD No B B B B
an application date of 07/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 02/XX/2006.
625488551 XXX XXX XXX 35091128 compliance 2 FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure. There is no Assignee Liability. 12/XX/2006 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
625488551 XXX XXX XXX 35091129 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. 12/XX/2006 12/XX/2010 MA Refinance - Cash-out - Debt Consolidation Primary Yes B B B B
625489069 XXX XXX XXX 35091139 compliance 2 Missing Document: Missing Lender's Initial 1003 2/XX/2006 NY Refinance - Cash-out - Other Primary No B B B B
625489069 XXX XXX XXX 35091140 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 2/XX/2006 NY Refinance - Cash-out - Other Primary No B B B B
an application date of 1/XX/2006 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 8/XX/2005.
625489069 XXX XXX XXX 35091141 compliance 2 RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Unable to determine compliance with timing requirements due to missing Initial RESPA (Sections 4 and 5) contains no explicit assignee liability provisions 2/XX/2006 NY Refinance - Cash-out - Other Primary No B B B B
Within 3 Business Days of Application Loan Application Date. within the statute or implementing regulation, Regulation X, for these type of
violations.
625489069 XXX XXX XXX 35091142 compliance 2 TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper TILA ROR Form - Because this issue is not uniformly settled among the circuit 2/XX/2006 2/XX/2009 NY Refinance - Cash-out - Other Primary No B B B B
(Circuit 2, 5, 7, 8, 9, 10 or DC) Model Form for a refinancing by the same creditor. The H-8 form was used, the courts, the continuing risk that the borrower may have an extended right to
H-9 form should have been used. rescind (3 additional years) if a creditor uses the incorrect Model Form
remains. Because of this uncertainty, we continue to recommend that creditors
use Model Form H-8 only for refinances involving a new creditor and Model Form
H-9 for refinances involving the same creditor.
625488031 XXX XXX XXX 35091255 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2002 GA Refinance - Rate/Term Primary No B B B B
an application date of 06/XX/2002 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2002.
625488031 XXX XXX XXX 35091256 compliance 2 ARM Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2002 7/XX/2003 GA Refinance - Rate/Term Primary No B B B B
Loan Application Date.
625488031 XXX XXX XXX 35091257 compliance 2 CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial TILA - subject to a 1 year SOL for affirmative claims under TILA 7/XX/2002 7/XX/2003 GA Refinance - Rate/Term Primary No B B B B
Loan Application Date.
625488838 XXX XXX XXX 35091293 credit 3 Missing Document: Missing Final 1003 7/XX/2007 OR Purchase Primary No C C C C
625488838 XXX XXX XXX 35091294 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 7/XX/2007 OR Purchase Primary No B B B B
an application date of 06/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 06/XX/2007.
625487996 XXX XXX XXX 35091356 credit 3 Missing Document: Missing Final 1003 Yes 1/XX/2008 FL Refinance - UTD Primary No C C C C
625487996 XXX XXX XXX 35091357 compliance 2 Due to lack of appraised value, compliance tests requiring an LTV were run off Yes 1/XX/2008 FL Refinance - UTD Primary No B B B B
an assumed value of a contract sales price or original loan amount, whichever
applies.
625487996 XXX XXX XXX 35091358 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. Yes 1/XX/2008 FL Refinance - UTD Primary No B B B B
Security Instrument Notary Date of 01/XX/2008 used as disbursement date for
compliance testing.
625487996 XXX XXX XXX 35091359 compliance 3 Missing Final HUD-1: No Document Used For Fee Testing Missing Final HUD-1. No document containing fees provided. Any applicable Yes 1/XX/2008 FL Refinance - UTD Primary No D D D D
Federal, State or Local compliance testing is unreliable.
625487996 XXX XXX XXX 35091360 compliance 2 Missing Initial Loan Application No Fees No evidence of application date located in file. Compliance tests were run using Yes 1/XX/2008 FL Refinance - UTD Primary No B B B B
an application date of 12/XX/2007 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 07/XX/2007. Due to missing HUD-1 or Closing Disclosure, no fees
were used in testing.
625487996 XXX XXX XXX 35091361 compliance 2 Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided. TILA ROR - 3yrs for rescindable transactions. Yes 1/XX/2008 1/XX/2011 FL Refinance - UTD Primary No B B B B
625487996 XXX XXX XXX 35091362 compliance 2 TILA - Final TIL Missing Missing Final TIL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a Yes 1/XX/2008 1/XX/2011 FL Refinance - UTD Primary No B B B B
defense to foreclosure. Assignee liability.
625487996 XXX XXX XXX 35091363 compliance 2 ARM Disclosure Status TIL variable rate disclosure: ARM loan program disclosure not provided to the TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 1/XX/2008 1/XX/2009 FL Refinance - UTD Primary No B B B B
borrower.
625487996 XXX XXX XXX 35091364 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA Yes 1/XX/2008 1/XX/2009 FL Refinance - UTD Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489606 XXX XXX XXX 35091550 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 2/XX/2006 ME Refinance - Cash-out - Debt Consolidation Primary No B B B B
Security Instrument Notary Date of 02/XX/2006 used as disbursement date for
compliance testing.
625489606 XXX XXX XXX 35091551 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 02/XX/2006, prior to TILA ROR - 3yrs for rescindable transactions. 2/XX/2006 2/XX/2009 ME Refinance - Cash-out - Debt Consolidation Primary No B B B B
Date three (3) business days from transaction date of 02/XX/2006.
625489476 XXX XXX XXX 35091565 credit 3 Missing Document: Missing Final 1003 4/XX/2004 SC Refinance - Cash-out - Other Primary No C C C C
625489476 XXX XXX XXX 35091566 compliance 2 Disbursement Date Missing Disbursement Date Missing: Evidence of disbursement date not found in file. 4/XX/2004 SC Refinance - Cash-out - Other Primary No B B B B
Security Instrument Notary Date of 04/XX/2004 used as disbursement date for
compliance testing.
625489476 XXX XXX XXX 35091567 compliance 2 Missing Initial Loan Application Test No evidence of application date located in file. Compliance tests were run using 4/XX/2004 SC Refinance - Cash-out - Other Primary No B B B B
an application date of 03/XX/2004 which is 1 months prior to consummation. A
lookback was performed to determine this application date. The final date used
for testing was 10/XX/2003.
625489476 XXX XXX XXX 35091568 compliance 2 (Missing Data) Unable to determine if loan is a same lender refi Original Lender was not able to be determined. Unable to determine if correct 4/XX/2004 4/XX/2007 SC Refinance - Cash-out - Other Primary No B B B B
TILA rescission form was used.
625489476 XXX XXX XXX 35091569 compliance 2 South Carolina CHL Complaint Agency Disclosure Timing Test Unable to determine compliance with timing requirements due to missing Initial Exceptions occurring more than 6 years ago may be outside the states statute of 4/XX/2004 4/XX/2010 SC Refinance - Cash-out - Other Primary No B B B B
Loan Application Date. limitations. Due to the potential remedies available to a court, this exception
carries elevated risk to an assignee during the initial 6 years after occurrence
of the violation. After the expiration of this 6 year period, the exception
retains risk for claims raised as a defense to foreclosure, but not at the same
level as during the initial 6 years for affirmative claims.
625489476 XXX XXX XXX 35091570 compliance 2 CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, TILA - subject to a 1 year SOL for affirmative claims under TILA 4/XX/2004 4/XX/2005 SC Refinance - Cash-out - Other Primary No B B B B
CHARM Booklet, not provided to the borrower.
625489476 XXX XXX XXX 35091571 compliance 2 TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Truth in Lending Act: Subject loan transaction disbursed on 04/XX/2004, prior to TILA ROR - 3yrs for rescindable transactions. 4/XX/2004 4/XX/2007 SC Refinance - Cash-out - Other Primary No B B B B
Date three (3) business days from transaction date of 04/XX/2004.
625489476 XXX XXX XXX 35091572 compliance 2 Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from TIL itemization did not disclose an attorney fee of $XXX as a prepaid finance XXX TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years 4/XX/2004 4/XX/2007 SC Refinance - Cash-out - Other Primary No B B B B
calculated Finance Charge of $XXX in the amount of $XXX. charge. Also, it appears a lower index was used at origination than the 4% for rescindable transactions. Unlimited as a defense to foreclosure. Assignee
available within the look-back period. liability.
625488496 XXX XXX XXX 35091867 credit 1 Final Title Policy is missing. No evidence of title was found in file. 9/XX/2002 NE Refinance - Cash-out - Other Primary No B B B B