
| a. |
QM or ATR Validation / Review of 8 Key Underwriting Factors
|
| i. |
Income / Assets
|
| • |
Validate borrower(s) monthly gross income
|
| • |
Validate funds required to close, required reserves
|
| • |
Review file documentation for required level of income and asset verifications
|
| ii. |
Employment Status
|
| • |
Review file documentation for required level of employment
|
| iii. |
Monthly Mortgage Payment
|
| • |
Confirm program, qualifying rate, terms
|
| iv. |
Simultaneous Loans
|
| • |
Validate all concurrent loans are included in the DTI to properly assess the ability to repay
|
| v. |
Mortgage Related Obligations : PITI, HOA, PMI, etc.
|
| • |
Validate subject loan monthly payment (PITI) and associated obligations
|
| vi. |
Debts / Obligations
|
| • |
Validate monthly recurring liabilities
|
| vii. |
DTI and/or Residual Income
|
| • |
Validate debt-to-income ratio (DTI) based upon income and debt documentation provided in the file
|
| • |
Documentation meets Appendix Q requirements for QM Loans
|
| viii. |
Credit History
|
| • |
Review credit report for credit history and required credit depth including any / all inquiries
|
| • |
Determine representative credit score from credit report
|
| b. |
Validate loan-to-value (LTV) and combined loan-to-value
|
| c. |
Review borrower's occupancy
|
| d. |
Validation through third party resource of the subject properties most recent twelve (12) month sales history
|
| e. |
Confirm sufficient evidence in loan file, by reviewing the underwriter’s decision to approve the loan based upon the borrower’s income, debt, and credit history, to support borrower's
willingness and ability to repay the debt
|
| f. |
Confirm that Final 1003 is sufficiently completed
|
| g. |
Provide Audit 1008 with accurate data based on file documentation
|
| h. |
Confirm Loan Approval conditions were met
|
| i. |
Review condominium questionnaire to verify all information is complete, prepared by an authorized representative, and address any red flags that may deem condominium project ineligible
|
| j. |
General QM for any loans originated under the GQM Rule
|
| i. |
Pricing Thresholds:
|
| a. |
Pricing for First Lien Loans:
|
| i. |
2.25% for a first-lien covered transaction with a loan amount greater than or equal to the applicable dollar amount threshold; and
|
| ii. |
3.5% for a first-lien covered transaction with a loan amount greater than or equal to the applicable dollar amount threshold; and
|
| iii. |
6.5% for a first-lien covered transaction with a loan amount less than the applicable dollar amount threshold.
|
| b. |
Pricing for Subordinate Lien Loans:
|
| i. |
3.5% for a subordinate-lien covered transaction with a loan amount greater than or equal to the applicable dollar amount threshold; and
|
| ii. |
6.5% for a subordinate-lien covered transaction with a loan amount less than the applicable dollar amount threshold.
|
| c. |
Pricing for Manufactured Homes:
|
| i. |
2.25% for a first-lien covered transaction secured by a manufactured home with a loan amount equal to or greater than the applicable dollar amount threshold; and
|
| ii. |
6.5% for a covered transaction secured by a manufactured home with a loan amount less than applicable dollar amount threshold.
|
| ii. |
Consider Income and Assets:
|
| o |
Consumer’s current or reasonably expected income or assets (other than the value of the dwelling that secures the loan;
|
| o |
The consumer’s debt obligations, alimony, child support; and
|
| o |
The monthly DTI or residual income.
|
| iii. |
Verification of Income and Assets:
|
| a. |
Verification of compliance with one of the “safe harbor” guidelines will meet the QM verification requirement. A creditor is allowed to “mix and match” provisions of the different guidelines
rather than only apply one guideline per loan.
|
| i. |
Chapters B3-3 through B3-6 of the Fannie Mae Single Family Selling Guide, published June 3, 2020;
|
| ii. |
Sections 5102 through 5500 of the Freddie Mac Single-Family Seller/Servicer Guide, published June 10, 2020;
|
| iii. |
Sections II.A.1 and II.A.4-5 of the Federal Housing Administration’s Single Family Housing Policy Handbook, issued October 24, 2019;
|
| iv. |
Chapter 4 of the U.S. Department of Veterans Affairs’ Lenders Handbook, revised February 22, 2019;
|
| v. |
Chapter 4 of the U.S. Department of Agriculture’s Field Office Handbook for the Direct Single Family Housing Program, revised March 15, 2019; and
|
| vi. |
Chapters 9 through 11 of the U.S. Department of Agriculture’s Handbook for the Single Family Guaranteed Loan Program, revised March 19, 2020.
|
| a. |
Test Loan Estimate(s) for accuracy and completeness as well as timing requirements as required by TRID Regulations
|
| b. |
Test Closing Disclosure(s) for accuracy and completeness as well as timing requirements as required by TRID Regulations
|
| c. |
Tolerance Testing
|
| i. |
Compare Loan Estimate and Closing Disclosures
|
| ii. |
Identify Tolerance Violations and applicable cost to cure
|
| d. |
Comprehensive review of Closing Disclosure to determine transaction accuracy
|
| e. |
Recalculation of APR and Finance Charge
|
| f. |
Testing of:
|
| i. |
Federal High-Cost Mortgage provisions
|
| ii. |
Federal Higher Priced Mortgage Loans provisions
|
| iii. |
Local and/or State Anti-predatory and High-Cost provisions
|
| iv. |
HOEPA Points and Fees
|
| g. |
Determine whether specified federal disclosures were provided timely based upon comparison of the application date to the dates on such disclosures
|
| i. |
Service Provider List
|
| ii. |
Home Ownership Counselling Disclosure
|
| iii. |
ARM Disclosure
|
| h. |
Compliance with QM as it relates to:
|
| i. |
APR Test
|
| ii. |
Points & Fees Test
|
| iii. |
Prepayment Penalty Test
|
| iv. |
Product Eligibility Testing
|
| i. |
Notice of Right to Cancel (Rescission) Review
|
| i. |
Confirm transaction date, expiration date, and disbursement date
|
| ii. |
Confirm document is properly executed by all required parties to the transaction
|
| iii. |
Confirm the correct Right of Rescission document was executed for the transaction type
|
| j. |
Confirm through NMLS the loan originator and originating firm's license status was active and properly disclosed on appropriate loan documents
|
| k. |
Check the Loan participants against the exclusionary list provided by Client or by the purchaser of the Loan(s)
|
| l. |
Review closing documents to ensure that the Mortgage Loan information is complete, accurate, and consistent with other documents; Confirm
collateral documents have been recorded or sent for recording
|
| b. |
Review appraisal, determination that property is completely constructed and appraisal is on an “as is basis,” or property is identified as not completely constructed by
originating appraiser.
|
| c. |
Review and determine if the appraisal report was performed on appropriate GSE forms and if the appraiser indicated in the body of the subject appraisal that the appraisal
conforms to USPAP standards.
|
| d. |
Review and determine the relevance of the comparable properties and ensure that a rational and reliable value was provided and supported as of the effective date of the
Origination Appraisal.
|
| e. |
Review adjustments (line item, net and gross adjustments) to ensure they are reasonable.
|
| f. |
Ensure that the appraisal conforms to the guidelines provided from the Client.
|
| g. |
Review appraisal to ensure all required documents were included.
|
| h. |
Review location map provided within the appraisal for external obsolescence.
|
| i. |
Ensure highest and best use and zoning complies with guidelines.
|
| j. |
Confirm there are no marketability issues that affect the subject property.
|
| k. |
Ensure subject property does not suffer any functional obsolescence.
|
| l. |
Where applicable, determine if the file did not contain the appraisal or other valuation method and a review could not be performed.
|
| m. |
Additional valuation products were not required when the CU score provided was 2.5 or below or the appraisal was eligible for FHLMC Collateral Rep and Warrant Relief. In the
event the CU score was greater than 2.5, or the appraisal was Not Eligible for FHLMC Collateral R&W Relief, an additional valuation product was obtained to confirm value was supported within 10% tolerance. Based on guidance from the
seller, secondary valuation products may have been provided on loans that had an acceptable CU score or were Eligible for FHLMC R&W Relief.
|
|
Fields Reviewed
|
Discrepancy Count
|
Percentage
|
|
Borrower 1 Income from Employment Total
|
51
|
24.40%
|
|
Cash Disbursement Date
|
32
|
15.31%
|
|
Lock Date
|
28
|
13.40%
|
|
Lock Expiration Date
|
23
|
11.00%
|
|
Closing/Settlement Date
|
13
|
6.22%
|
|
Borrower 2 Total Income
|
10
|
4.78%
|
|
Borrower 1 Self-Employment Flag
|
10
|
4.78%
|
|
Mortgage Origination Channel
|
7
|
3.35%
|
|
Qualifying Total Debt Income Ratio
|
7
|
3.35%
|
|
Property Type
|
6
|
2.87%
|
|
Application Date
|
5
|
2.39%
|
|
Borrower 1 First Name
|
4
|
1.91%
|
|
Qualifying FICO
|
3
|
1.44%
|
|
Property Value
|
2
|
0.96%
|
|
Borrower 1 Origination FICO
|
2
|
0.96%
|
|
Borrower 2 Origination FICO
|
2
|
0.96%
|
|
Monthly Total Escrow Payment
|
2
|
0.96%
|
|
Number of Units
|
1
|
0.48%
|
|
Borrower 2 Self-Employment Flag
|
1
|
0.48%
|
|
Grand Total
|
209
|
100.00%
|
|
Overall Loan Results:
|
|||
|
Event Grade
|
Loan Count
|
Original Principal Balance
|
Percent of Sample
|
|
Event Grade A
|
270
|
$331,318,966.00
|
97.47%
|
|
Event Grade B
|
7
|
$8,954,470.00
|
2.53%
|
|
Event Grade C
|
0
|
$0.00
|
0%
|
|
Event Grade D
|
0
|
$0.00
|
0%
|
|
Total Sample
|
277
|
$340,273,436.00
|
100.00%
|
|
Credit Results:
|
||
|
Event Grade
|
Loan Count
|
Percent of Sample
|
|
Event Grade A
|
277
|
100.00%
|
|
Event Grade B
|
0
|
0%
|
|
Event Grade C
|
0
|
0%
|
|
Event Grade D
|
0
|
0%
|
|
Total Sample
|
277
|
100.00%
|
|
Compliance Results:
|
||
|
Event Grade
|
Loan Count
|
Percent of Sample
|
|
Event Grade A
|
270
|
97.47%
|
|
Event Grade B
|
7
|
2.53%
|
|
Event Grade C
|
0
|
0%
|
|
Event Grade D
|
0
|
0%
|
|
Total Sample
|
277
|
100.00%
|
|
Valuation Results:
|
||
|
Event Grade
|
Loan Count
|
Percent of Sample
|
|
Event Grade A
|
277
|
100.00%
|
|
Event Grade B
|
0
|
0%
|
|
Event Grade C
|
0
|
0%
|
|
Event Grade D
|
0
|
0%
|
|
Total Sample
|
277
|
100.00%
|
|
Exception Level Grade
|
Exception Category
|
Total
|
|
|
Credit
|
A
|
No Credit Findings
|
206
|
|
Missing VOM or VOR
|
9
|
||
|
Borrower 1 IRS Transcripts Missing
|
6
|
||
|
Purchase Contract is Incomplete
|
5
|
||
|
The Total Hazard Coverage is LESS than the Required Coverage Amount
|
5
|
||
|
Hazard Insurance Policy is Missing
|
5
|
||
|
Flood Certificate Missing
|
5
|
||
|
Third Party Fraud Report not Provided
|
4
|
||
|
Borrower 2 IRS Transcripts Missing
|
4
|
||
|
Borrower 1 3rd Party VOE Prior to Close Missing
|
3
|
||
|
Audited DTI Exceeds AUS DTI
|
3
|
||
|
Missing Property Tax Cert
|
3
|
||
|
Purchase Contract is Missing
|
3
|
||
|
Borrower 1 Photo Identification not provided
|
3
|
||
|
Title Coverage is Less than Subject Lien
|
3
|
||
|
Income and Employment Do Not Meet Guidelines
|
3
|
||
|
Property Title Issue
|
2
|
|
Audited Reserves are less than Guideline Required Reserves (Dollar Amount)
|
2
|
||
|
Asset 5 Expired
|
2
|
||
|
Asset 2 Does Not Meet Guideline Requirements
|
2
|
||
|
Asset Qualification Does Not Meet Guideline Requirements
|
2
|
||
|
Missing income documentation
|
2
|
||
|
Borrower 2 3rd Party VOE Prior to Close Missing
|
2
|
||
|
Borrower 2 Photo Identification not provided
|
2
|
||
|
The Note is Missing
|
2
|
||
|
Missing Verification of Subject Property Taxes, Insurance, HOA or Other Payments
|
2
|
||
|
Asset 7 Does Not Meet Guideline Requirements
|
2
|
||
|
Audited Reserves are less than Guideline Required Reserves (Number of Months)
|
2
|
||
|
Missing final HUD-1 from sale of non-subject property
|
2
|
||
|
Verified Liquid Assets Insufficient For Closing
|
2
|
||
|
Borrower 1 Credit Report is Missing
|
1
|
||
|
ATR: Current Employment Not Verified
|
1
|
||
|
Title Document Missing
|
1
|
||
|
HO-6 Insurance Policy is Missing
|
1
|
||
|
PUD Rider is Missing
|
1
|
||
|
Housing History Does Not Meet Guideline Requirements
|
1
|
||
|
The Deed of Trust is Missing
|
1
|
||
|
Borrower 1 Paystubs Missing
|
1
|
||
|
Hazard Insurance Effective Date is after the Disbursement Date
|
1
|
||
|
Loan does not conform to program guidelines
|
1
|
||
|
Asset 3 Does Not Meet Guideline Requirements
|
1
|
||
|
Approval/Underwriting Summary Not Provided
|
1
|
||
|
Borrower Non-US Citizen Identification Document Missing
|
1
|
||
|
Borrower 1 W2/1099 Missing
|
1
|
||
|
The Deed of Trust is Incomplete
|
1
|
||
|
Asset 6 Expired
|
1
|
||
|
The Final 1003 is Incomplete
|
1
|
||
|
Borrower 2 Credit Report is Missing
|
1
|
||
|
All Interested Parties Not Checked with Exclusionary Lists
|
1
|
||
|
Missing verification of taxes, insurance, and/or HOA fees for non-subject property
|
1
|
||
|
Hazard Insurance Effective Date is after the Expiration Date
|
1
|
||
|
Asset 2 Missing
|
1
|
|
Borrower 2 Non-US Citizen Identification Document Missing
|
1
|
||
|
Flood Insurance Policy Missing
|
1
|
||
|
Guideline Seasoning not Met
|
1
|
||
|
Total Credit Grade (A) Exceptions:
|
323
|
||
|
Compliance
|
A
|
No Compliance Findings
|
229
|
|
Charges That Cannot Increase Test
|
16
|
||
|
Charges That In Total Cannot Increase More Than 10% Test
|
15
|
||
|
Initial Loan Estimate Delivery Date Test (from application)
|
10
|
||
|
RESPA Homeownership Counseling Organizations Disclosure Date Test
|
10
|
||
|
Initial Closing Disclosure Delivery Date Test
|
9
|
||
|
Evidence of Appraisal Delivery to Borrower not Provided or Late (12 CFR 1002.14(a)(1))
|
7
|
||
|
TRID: Missing Closing Disclosure
|
4
|
||
|
Lender Credits That Cannot Decrease Test
|
2
|
||
|
TILA Finance Charge Test
|
2
|
||
|
TRID: Missing Loan Estimate
|
2
|
||
|
Missing Required Affiliated Business Disclosure
|
1
|
||
|
TILA Right of Rescission Test
|
1
|
||
|
TILA Post-Consummation Revised Closing Disclosure Finance Charge Test
|
1
|
||
|
Revised Closing Disclosure Delivery Date and Changed Circumstances Date Test
|
1
|
||
|
Right of Rescission is Partially Provided
|
1
|
||
|
Total Compliance Grade (A) Exceptions:
|
311
|
||
|
B
|
Charges That Cannot Increase Test
|
5
|
|
|
TILA Finance Charge Test
|
1
|
||
|
Charges That In Total Cannot Increase More Than 10% Test
|
1
|
||
|
Total Compliance Grade (B) Exceptions:
|
7
|
||
|
Property
|
A
|
No Property Findings
|
267
|
|
Third Party Valuation Product Not Provided within 10% Tolerance
|
5
|
||
|
Appraisal is Missing
|
2
|
||
|
External Obsolescence Present
|
1
|
||
|
Property/Appraisal General
|
1
|
||
|
Condo Approval Missing
|
1
|
||
|
Property Issue(s) are Present
|
1
|
||
|
Total Property Grade (A) Exceptions:
|
278
|
|
Final Loan Grade
|
|
|
A
|
Loan meets Credit, Compliance, and Valuation Guidelines
|
|
B
|
The loan substantially meets published Client/Seller guidelines and/or eligibility in the validation of income, assets, or credit, is in material compliance with all applicable laws and
regulations, and the value and valuation methodology is supported and substantially meets published guidelines.
|
|
C
|
The loan does not meet the published guidelines and/or violates one material law or regulation, and/or the value and valuation methodology is not supported or did not meet published
guidelines.
|
|
D
|
Loan is missing documentation to perform a sufficient review.
|
|
Credit Event Grades
|
|
|
A
|
The loan meets the published guidelines without any exceptions. Employment, income, assets and occupancy are supported and justifiable. The borrower’s willingness and ability to repay
the loan is documented and reasonable.
|
|
B
|
The loan substantially meets the published guidelines, but reasonable compensating factors were considered and documented for exceeding published guidelines. Employment, income, assets
and occupancy are supported and justifiable. The borrower’s willingness and ability to repay the loan is documented and reasonable.
|
|
C
|
The loan does not substantially meet the published guidelines. There are not sufficient compensating factors that justify exceeding the guidelines published. Employment, income, assets
or occupancy are not supported and justifiable. The borrower’s willingness and ability to repay the loan were not documented or are unreasonable.
|
|
D
|
There was not sufficient documentation to perform a review, or the credit file was not furnished.
|
|
Compliance Event Grades
|
|
|
A
|
The loan complies with all applicable laws and regulations. The legal documents accurately reflect the agreed upon loan terms and are executed by all applicable parties.
|
|
B
|
Nonmaterial exceptions identified but do not impact the enforceability of the mortgage loan or statute of limitations has expired on the loan. Remedy to cure or reasonably good faith
effort to re-disclose was made to conform to applicable laws and regulations. All cures are fully documented by copies of the originator refund letter to the borrower, referencing the violation, canceled check, and proof of delivery.
|
|
C
|
The loan violates one material law or regulation. A benefit to the borrower cannot be determined. Required material disclosures are absent from the loan file, or the legal documents do
not accurately reflect the loan terms agreed upon. All required applicants did not execute the documents.
|
|
D
|
There was not sufficient documentation to perform a review, or the required legal documents were not furnished.
|
|
Valuation Event Grades
|
|
|
A
|
Secondary value is supported within 10% of the original appraisal value. AVM used as a secondary valuation product has a value within 10% of the original appraised value and an FSD score
less than or equal to .15. The appraisal was performed on an "as-is" basis and the property is complete and habitable at origination. The appraiser was appropriately licensed, and the appraisal form is compliant with Uniform Standards
of Professional Appraisal Practices (USPAP), Financial Institutions Reform, Recovery and Enforcement Act of 1989 (FIRREA) and satisfies applicable legal and regulatory requirements.
|
|
B
|
Additional secondary valuation products were obtained to support the original appraised value within 10%. The valuation methodology substantially meets the published guidelines, but
reasonable compensating factors were considered and documented for exceeding guidelines. The appraisal was performed on an "as-is" basis and the property is complete and habitable. The appraiser was appropriately licensed and used GSE
approved forms.
|
|
C
|
The value cannot be supported within 10% of the original appraisal. The valuation methodology did not meet the published guidelines and there were not sufficient compensating factors
for exceeding published guidelines. The property is in below “average” condition, or the property is not complete or requires significant repairs. The appraisal was not performed on an “as is” basis. The appraiser was not
appropriately licensed, or the appraisal was not performed using USPAP and FIRREA compliant appraisal forms
|
|
D
|
The appraisal is missing from the loan file or there was not sufficient valuation documentation to perform a review. AVM was used as a secondary value with a FSD > 0.15, or an AVM
performed by a non-Fitch-reviewed vendor.
|