Exhibit 99.28
EXECUTIVE
SUMMARY
Third Party Due Diligence Review
Overview
Consolidated Analytics, Inc (“Consolidated Analytics”), a third-party due diligence provider, performed the review described below on behalf of its client, Blue River Mortgage V LLC. The review included a total of 3 newly originated closed end second lien mortgage loans, in connection with the securitization identified as GCAT 2026-CES1 (the “Securitization”). The Review was conducted from July 2026 through August 2026 on mortgage loans originated between July 2026 and August 2026.
Scope of Review
Credit Review
Consolidated Analytics performed a “Credit Review” to verify compliance with guidelines in effect at the time of loan origination, or other guidelines provided by Client prior to review, and ensure the characteristics used by the underwriter are supported by the file documentation; and determine whether any loans outside of those guidelines contain legitimate and approved exceptions with compensating factors.
The Credit Review attempted to confirm the following:
| a. | QM or ATR Validation / Review of 8 Key Underwriting Factors |
| 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 borrows income, debt, and credit history, to support borrower's willingness and ability to repay the debt |
| f. | Confirm that Final 1003 is sufficiently completed |
| g. | Provide Audit 1008 with accurate data based on file documentation |
| h. | Confirm Loan Approval conditions were met |
| i. | Review condominium questionnaire to verify all information is complete, prepared by an authorized representative, and address any red flags that may deem condominium project ineligible |
| j. | General QM for any loans originated under the GQM Rule |
| i. | Pricing Thresholds: |
| a. | 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. |
| ii. | Consider Income and Assets: |
| ○ | Consumer’s current or reasonably expected income or assets (other than the value of the dwelling that secures the loan; |
| ○ | The consumer’s debt obligations, alimony, child support; and |
| ○ | The monthly DTI or residual income. |
| iii. | Verification of Income and Assets: |
| a. | Verification in compliance with one of the “safe harbor” guidelines will meet the QM verification requirement. A creditor is allowed to “mix and match” provisions of the different guidelines rather than only apply one guideline per loan. |
The specific guidelines that the CFPB is designating for the safe harbor are: The GQM Rule provides that if the creditor verifies the consumer’s income or assets, debt obligations, alimony, child support, and monthly DTI or residual income by meeting the standards of certain specified third-party underwriting manuals, then a creditor is presumed to have complied with the verification requirement. These specified manuals are:
| i. | Chapters B3-3 through B3-6 of the Fannie Mae Single Family Selling Guide, published June 3, 2020; |
| ii. | Sections 5102 through 5500 of the Freddie Mac Single-Family Seller/Servicer Guide, published June 10, 2020; |
| iii. | Sections II.A.1 and II.A.4-5 of the Federal Housing Administration’s Single Family Housing Policy Handbook, issued October 24, 2019; |
| iv. | Chapter 4 of the U.S. Department of Veterans Affairs’ Lenders Handbook, revised February 22, 2019; |
| v. | Chapter 4 of the U.S. Department of Agriculture’s Field Office Handbook for the Direct Single Family Housing Program, revised March 15, 2019; and |
| vi. | Chapters 9 through 11 of the U.S. Department of Agriculture’s Handbook for the Single Family Guaranteed Loan Program, revised March 19, 2020. |
Compliance Review
Consolidated Analytics performed a “Compliance Review” to determine, as applicable, to the extent possible and subject to the caveats below, whether the loan complies with applicable regulatory requirements as noted below, each as amended, restated and/or replaced from time to time. The Compliance Review included the following:
| a. | Test Loan Estimate(s) for accuracy and completeness as well as timing requirements as required by TRID Regulations |
| b. | Test Closing Disclosure(s) for accuracy and completeness as well as timing requirements as required by TRID Regulations |
| 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 |
| iv. | Confirm a full three (3) day rescission period was provided to the borrower |
| j. | Confirm through NMLS the loan originator and originating firm's license status was active and properly disclosed on appropriate loan documents |
| k. | Check the Loan participants against the exclusionary list provided by Client or by the purchaser of the Loan(s) |
| l. | Review closing documents to ensure that the Mortgage Loan information is complete, accurate, and consistent with other documents; Confirm collateral documents have been recorded or sent for recording |
The Compliance Review did not include any federal, state or local laws, constitutional provisions, regulations or ordinances that are not expressly enumerated above. Furthermore, the findings reached by Consolidated Analytics are dependent upon its receiving complete and accurate data regarding the loans from loan originators and other third parties upon which Consolidated Analytics is relying in reaching such findings.
Valuation Review
Consolidated Analytics performed a “Valuation Review,” which included the following:
| a. | Review original valuation product provided, AVM, Exterior Only appraisal, or appraisal, to determine that property is in "average" condition or better, or property requires cosmetic improvements (as defined by the appraiser) that do not affect habitability. Should an area of concern be identified with the condition of the property, Consolidated Analytics will alert Client. |
| b. | Review applicable original valuation product to determine that the property is completely constructed, and that valuation of the property was determined on an “as is basis,” or that the property was identified as not completely constructed by originating appraiser. |
| c. | Review and determine if the applicable valuation product 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 product provided. |
| e. | Review adjustments (line item, net and gross adjustments) to ensure they are reasonable. |
| f. | Ensure that the origination appraisal product provided conforms to the guidelines provided from the Client. |
| g. | Review origination appraisal product to ensure all required documents were included, as applicable. |
| h. | Review location map provided within the appraisal product 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 or secondary valuation products were not required. |
For loans reviewed in a post-close valuation review scenario (3 loans in total):
An AVM, exterior only appraisal, or full appraisal was utilized as the original valuation product for all loans within the review population. An AVM was utilized for one (1) loan, an exterior only appraisal was utilized for zero (0) loans, and a full appraisal was utilized for zero (0) loans.
In some instances, additional valuation products were provided. One (1) loan had AVMs, zero (0) loans had exterior only appraisals, and zero (0) loans had a second full appraisal.
Product totals may not sum due to multiple products for each loan
TAPE INTEGRITY REVIEW RESULTS SUMMARY
Of the zero (0) mortgage loans reviewed, zero (0) unique mortgage loans (0% by loan count) had a total of zero (0) discrepancies across zero (0) data fields. A blank or zero value on the data tape when an actual value was captured by Consolidated Analytics was not treated as a data variance.
| Fields Reviewed | Discrepancy Count | Percentage |
| Grand Total | 0 | 0 |
Summary of Results
OVERALL RESULTS SUMMARY
Final Loan Grades
| Overall Loan Results: | |||
| Event Grade | Loan Count | Original Principal Balance | % by Loan Count |
| A | 3 | $1,200,000.00 | 100.00% |
| B | 0 | $0 | 0% |
| C | 0 | $0 | 0% |
| D | 0 | $0 | 0% |
| Total | 3 | $1,200,000.00 | 100.00% |
| Credit Results: | ||
| Event Grade | Loan Count | % by Loan Count |
| A | 3 | 100.00% |
| B | 0 | 0% |
| C | 0 | 0% |
| D | 0 | 0% |
| Total | 3 | 100.00% |
| Compliance Results: | ||
| Event Grade | Loan Count | % by Loan Count |
| A | 3 | 100.00% |
| B | 0 | 0% |
| C | 0 | 0% |
| D | 0 | 0% |
| Total | 3 | 100.00% |
| Valuation Results: | ||
| Event Grade | Loan Count | % by Loan Count |
| A | 3 | 100.00% |
| B | 0 | 0% |
| C | 0 | 0% |
| D | 0 | 0% |
| Total | 3 | 100.00% |
Exception Category Summary
The table below summarizes the individual exceptions which carried an associated “A”, “B”, “C”, or “D” level exception grade. One loan may have carried more than one exception. In such cases, the exception with the lowest grade would drive the loan grade for that particular area of the review. The overall loan grade is the lowest grade for any one particular review scope (ex. a loan with a Compliance Grade of “B”, a Credit Grade of “A”, and a Property Grade of “A” would receive an overall Loan Grade of “B”).
| Exception Type | Exception Level Grade | Exception Category | Total |
| Credit | A | No Credit Findings | 2 |
| Property Title Issue | 1 | ||
| Total Credit Grade (A) Exceptions: | 3 | ||
| Compliance | A | No Compliance Findings | 3 |
| Total Compliance Grade (A) Exceptions: | 3 | ||
| Property | A | No Property Findings | 2 |
| Property has been listed for sale in the past 12 months | 1 | ||
| Total Property Grade (A) Exceptions: | 3 |
Event Grade Definitions
| Final Loan Grade | |
| A | Loan meets Credit, Compliance, and Valuation Guidelines |
| B | The loan substantially meets published Client/Seller guidelines and/or eligibility in the validation of income, assets, or credit, is in material compliance with all applicable laws and regulations, and the value and valuation methodology is supported and substantially meets published guidelines. |
| C | The loan does not meet the published guidelines and/or violates one material law or regulation, and/or the value and valuation methodology is not supported or did not meet published guidelines. |
| D | Loan is missing documentation to perform a sufficient review. |
| Credit Event Grades | |
| A | The loan meets the published guidelines without any exceptions. The employment, income, assets and occupancy are supported and justifiable. The borrower’s willingness and ability to repay the loan is documented and reasonable. |
| B | The loan substantially meets the published guidelines but reasonable compensating factors were considered and documented for exceeding published guidelines. The employment, income, assets and occupancy are supported and justifiable. The borrower’s willingness and ability to repay the loan is documented and reasonable. |
| C | The loan does not substantially meet the published guidelines. There are not sufficient compensating factors that justify exceeding the published guidelines. The employment, income, assets or occupancy are not supported and justifiable. The borrower’s willingness and ability to repay the loan were not documented or are unreasonable. |
| D | There was not sufficient documentation to perform a review or the credit file was not furnished. |
| Compliance Event Grades | |
| A | The loan is in compliance with all applicable laws and regulations. The legal documents accurately reflect the agreed upon loan terms and are executed by all applicable parties. |
| B | The loan is in material compliance with all applicable laws and regulations. The legal documents accurately reflect the agreed upon loan terms and are executed by all applicable parties. Client review required. |
| C | The loan violates one material law or regulation. The material disclosures are absent or the legal documents do not accurately reflect the agreed upon loan terms or all required applicants did not execute the documents. |
| D | There was not sufficient documentation to perform a review or the required legal documents were not furnished. |
| Valuation Event Grades | |
| A | The appraisal or applicable valuation product was performed on an "as-is" basis and the property is complete and habitable at origination. The appraiser was appropriately licensed and used GSE approved forms. If an AVM was provided, the AVM conformed with guidelines and FSD score was within allowable thresholds. No secondary valuation products were required. |
| B | The valuation methodology substantially meets the published guidelines, but reasonable compensating factors were considered and documented for exceeding guidelines. The appraisal or applicable valuation product was performed on an "as-is" basis and the property is complete and habitable. The appraiser was appropriately licensed and used GSE approved forms. No secondary valuation products were required. |
| C | 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 or applicable valuation product was not performed on an “as is” basis. The appraiser was not appropriately licensed or did not use GSE approved forms. If an AVM was provided as the origination product, the AVM did not conform with guidelines and an additional valuation product was not provided. |
| D | The file was missing an origination valuation product or there was not sufficient valuation documentation to perform a review. No secondary valuation products were required. |