Exhibit
99.4
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 residential mortgage loans acquired by
SLC BINOM Sponsor LLC c/o Specialty Lending Company LLC through a bulk purchase. The review included a total of 147 newly originated residential
mortgage loans acquired through a bulk purchase in connection with the securitization identified as BINOM 2026-NQM2 (the “Securitization”).
The Review was conducted from December 2025 through September 2026 on mortgage loans originated between November 2025 and June 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 |
| · | Validate borrower(s) monthly gross income |
| · | Validate funds required to close, required reserves |
| · | Review file documentation for required level of income and asset verifications |
| · | Review file documentation for required level of employment |
| iii. | Monthly Mortgage Payment |
| · | Confirm program, qualifying rate, terms |
| · | 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 |
| · | 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 |
| · | 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 |
| 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 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. In relation to cash out refinances
of investment property loans, documentation provided in the loan file will be reviewed only to validate the use of cash out proceeds for
business purposes at the origination/consummation of the loan. In the event use of proceeds cannot be validated, or are deemed to be utilized
for consumer purposes, the loan would then be subject to a “Compliance Review” of 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 |
| 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 |
| i. | Federal High Cost Mortgage provisions |
| ii. | Federal Higher Priced Mortgage Loans provisions |
| iii. | Local and/or State Anti-predatory and High Cost provisions |
| g. | Determine whether specified federal disclosures were provided timely based upon comparison of the application
date to the dates on such disclosures |
| ii. | Home Ownership Counselling Disclosure |
| h. | Compliance with QM as it relates to: |
| 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 appraisal, determination 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 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
LCA risk score was eligible for Collateral Rep and Warranty relief. In the event the CU score was greater than 2.5 or the LCA score was
not eligible for R&W relief, an additional valuation product was obtained to confirm value was supported within 10% tolerance. In
some instances, based on guidance from the seller, CDA’s were ordered on loans that had an acceptable CU score or R&W eligibility. |
Consolidated Analytics applied a cascade methodology
to determine if the original appraised value was reasonably supported when compared to an independent third party valuation product.
For loans reviewed in a post-close valuation review scenario (147
loans in total):
Eighty-nine (89) loans had CU scores of 2.5 or less or were eligible
for Collateral Rep and Warranty relief.
One (1) loan had a Secondary Appraisal, eleven (11) loans had an
AVM, and seventy-two (72) loans had Desktop Reviews. Consolidated Analytics has independent access to the Desktop Reviews ordered by the
Aggregator.
If a loan with an AVM or Desktop Review fell outside of a -10% tolerance,
was inconclusive, or a PIW was present, then an additional valuation product was completed. There was one (1) occurrence of this.
Product totals may not sum due to multiple products for each
loan.
TAPE INTEGRITY REVIEW RESULTS SUMMARY
Of the one hundred forty-seven (147) mortgage
loans reviewed, one hundred (100) unique mortgage loans (68.03% by loan count) had a total of one-hundred eighty-three (183) discrepancies
across twenty-two (22) 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 |
| Loan Type |
68 |
37.16% |
| Total Qualified Assets Post-Close |
30 |
16.39% |
| Calculated DSCR |
21 |
11.48% |
| Final Qualifying Property Value |
12 |
6.56% |
| Property Type |
10 |
5.46% |
| Application Date |
9 |
4.92% |
| Escrow Waiver in File |
6 |
3.28% |
| Borrower 1 Self-Employment Flag |
4 |
2.19% |
| Qualifying LTV |
3 |
1.64% |
| Qualifying CLTV |
3 |
1.64% |
| Property Attachment Type |
3 |
1.64% |
| Total Closing Costs |
3 |
1.64% |
| Borrower 1 SSN |
2 |
1.09% |
| DSCR |
1 |
0.55% |
| Borrower 1 Citizen |
1 |
0.55% |
| Qualifying FICO |
1 |
0.55% |
| Borrower 1 Origination TransUnion |
1 |
0.55% |
| Borrower 1 Marital Status |
1 |
0.55% |
| T & I Payment |
1 |
0.55% |
| Months Since Foreclosure |
1 |
0.55% |
| Number of Units |
1 |
0.55% |
| Months Since Bankruptcy |
1 |
0.55% |
| Grand Total |
183 |
100.00% |
Summary of Results
OVERALL RESULTS SUMMARY
Final Loan Grades
| |
Overall Loan Results: |
|
| |
Event
Grade |
Loan
Count |
Original
Principal Balance |
Percent
of Sample |
| |
Event
Grade A |
137 |
$52,890,846.00 |
93.20% |
| |
Event
Grade B |
10 |
$4,520,750.00 |
6.80% |
| |
Event
Grade C |
0 |
$0.00 |
0% |
| |
Event
Grade D |
0 |
$0.00 |
0% |
| |
Total
Sample |
147 |
$57,411,596.00 |
100.00% |
| |
Credit Results: |
| |
Event
Grade |
Loan
Count |
Percent
of Sample |
| |
Event
Grade A |
141 |
95.92% |
| |
Event
Grade B |
6 |
4.08% |
| |
Event
Grade C |
0 |
0% |
| |
Event
Grade D |
0 |
0% |
| |
Total
Sample |
147 |
100.00% |
| |
Compliance
Results (As applicable, 1 loan within population did not receive a Compliance Review): |
| |
Event
Grade |
Loan
Count |
Percent
of Sample |
| |
Event
Grade A |
144 |
98.63% |
| |
Event
Grade B |
2 |
1.37% |
| |
Event
Grade C |
0 |
0% |
| |
Event
Grade D |
0 |
0% |
| |
Total
Sample |
146 |
100.00% |
| |
Valuation Results: |
| |
Event
Grade |
Loan
Count |
Percent
of Sample |
| |
Event
Grade A |
145 |
98.64% |
| |
Event
Grade B |
2 |
1.36% |
| |
Event
Grade C |
0 |
0% |
| |
Event
Grade D |
0 |
0% |
| |
Total
Sample |
147 |
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 |
41 |
| HMDA
Data Tape Not Provided |
37 |
| Hazard
Insurance Policy is Partial |
25 |
| Approval/Underwriting
Summary Partially Provided |
23 |
| Missing
Business Entity Formation Document |
17 |
| Income
and Employment Do Not Meet Guidelines |
11 |
| The
Deed of Trust is Incomplete |
9 |
| Borrower
1 Gap Credit Report is Missing |
5 |
| Personal
Guaranty Agreement Incomplete |
5 |
| Title
Document is Partially Present |
5 |
| Property
Title Issue |
4 |
| Purchase
Contract is Incomplete |
4 |
| Asset
2 Does Not Meet Guideline Requirements |
4 |
| All
Interested Parties Not Checked with Exclusionary Lists |
4 |
| Asset
1 Does Not Meet Guideline Requirements |
4 |
| Missing
verification of taxes, insurance, and/or HOA fees for non-subject property |
4 |
| Third
Party Fraud Report Partially Provided |
3 |
| The
Note is Incomplete |
3 |
| The
Final 1003 is Missing |
3 |
| Asset
Qualification Does Not Meet Guideline Requirements |
3 |
| The
Note is Missing |
3 |
| Fraud
Report Shows Uncleared Alerts |
3 |
| |
|
Loan
does not conform to program guidelines |
3 |
| Borrower
1 Gap Credit Report is Incomplete |
3 |
| Missing
Lease Agreement |
3 |
| Flood
Certificate Partially Provided |
2 |
| Condo
Rider is Missing |
2 |
| Third
Party Fraud Report not Provided |
2 |
| Housing
History Does Not Meet Guideline Requirements |
2 |
| The
Deed of Trust is Missing |
2 |
| Audited
Reserves are less than Guideline Required Reserves (Dollar Amount) |
2 |
| Missing
VOM or VOR |
2 |
| Audited
Reserves are less than Guideline Required Reserves (Number of Months) |
2 |
| Business
Purpose Affidavit/Disclosure Missing |
2 |
| 1-4
Family Rider is Missing |
2 |
| Excessive
Seller Contributions |
2 |
| Missing
explanation and supporting documentation for large deposit(s) |
2 |
| The
Final 1003 is Incomplete |
2 |
| Missing
Personal Guaranty |
2 |
| Application
Profile Missing |
2 |
| Missing
Verification of Subject Property Taxes, Insurance, HOA or Other Payments |
2 |
| Approval/Underwriting
Summary Not Provided |
2 |
| Missing
Letter of Explanation (Credit) |
1 |
| Title
Document Missing |
1 |
| Title
Coverage is Less than Subject Lien |
1 |
| Borrower
1 Business Bank Statements Missing |
1 |
| Flood
Certificate Missing |
1 |
| Asset
3 Does Not Meet Guideline Requirements |
1 |
| Missing
Letter of Explanation (Income) |
1 |
| Purchase
Contract is Missing |
1 |
| Audited
LTV Exceeds Guideline LTV |
1 |
| Rent
Loss Coverage Not Sufficient |
1 |
| Verified
Liquid Assets Insufficient For Closing |
1 |
| Rent
Loss Insurance Missing |
1 |
| Audited
DTI Exceeds Guideline DTI |
1 |
| HO6
Master Insurance Policy is Missing |
1 |
| No
evidence of required debt payoff |
1 |
| HO6
Master Insurance Policy is Partial |
1 |
| OFAC
Check Not Completed and/or Cleared |
1 |
| Missing
letter of explanation |
1 |
| Total
Credit Grade (A) Exceptions: |
281 |
| B |
DSCR
is less than guideline minimum |
2 |
| Loan
does not conform to program guidelines |
1 |
| Audited
CLTV Exceeds Guideline CLTV |
1 |
| Audited
HCLTV Exceeds Guideline HCLTV |
1 |
| |
|
Housing
History Does Not Meet Guideline Requirements |
1 |
| Audited
LTV Exceeds Guideline LTV |
1 |
| Missing
explanation and supporting documentation for large deposit(s) |
1 |
| Audited
Reserves are less than Guideline Required Reserves (Dollar Amount) |
1 |
| Audited
Reserves are less than Guideline Required Reserves (Number of Months) |
1 |
| Total
Credit Grade (B) Exceptions: |
10 |
| Compliance |
A |
No
Compliance Findings |
89 |
| Missing
Required Affiliated Business Disclosure |
9 |
| Evidence
of Appraisal Delivery to Borrower not Provided or Late (12 CFR 1002.14(a)(1)) |
5 |
| Intent to
Proceed is Missing |
3 |
| Charges
That Cannot Increase Test |
3 |
| eSigned
Documents Consent is Missing |
3 |
| Higher-Priced
Mortgage Loan Test |
3 |
| Initial
Closing Disclosure Delivery Date Test |
3 |
| Homeownership
Counseling Disclosure Is Missing |
2 |
| Higher-Priced
Mortgage Loan Evidence of Appraisal Delivery to the Borrower Not Provided (12 CFR 1026.35(c)(6)) |
1 |
| Qualified
Mortgage Lending Policy Points and Fees Test |
1 |
| High-Cost
Mortgage Pre-Loan Counseling Date Test |
1 |
| Charges
That In Total Cannot Increase More Than 10% Test |
1 |
| Revised
Loan Estimate Delivery Date Test (prior to consummation) |
1 |
| CA AB 260
Higher-Priced Mortgage Loan Test |
1 |
| Missing
Initial Escrow Disclosure |
1 |
| High-Cost
Mortgage Late Fee Test |
1 |
| High-Cost
Mortgage Timing of Disclosure Test |
1 |
| Initial
Loan Estimate Delivery Date Test (from application) |
1 |
| RESPA Homeownership
Counseling Organizations Disclosure Date Test |
1 |
| High-Cost
Mortgage Points and Fees Threshold Test |
1 |
| TRID: Missing
Loan Estimate |
1 |
| Lender Credits
That Cannot Decrease Test |
1 |
| Loan Originator
NMLS is Not Valid |
1 |
| Total
Compliance Grade (A) Exceptions: |
135 |
| B |
Charges
That Cannot Increase Test |
2 |
| Total
Compliance Grade (B) Exceptions: |
2 |
| Property |
A |
No Property
Findings |
95 |
| Property/Appraisal
General |
14 |
| Property
Issue(s) are Present |
5 |
| Third Party
Valuation Product Not Provided within 10% Tolerance |
2 |
| External
Obsolescence Present |
2 |
| Condo Approval
Missing |
1 |
| Subject
property appraisal is not on an as-is basis (Primary Value) |
1 |
| Was lowest
appraised value used to qualify is No |
1 |
| Incorrect
Appraisal Form For Property Type |
1 |
| |
|
HOA
Questionnaire is Missing |
1 |
| Total
Property Grade (A) Exceptions: |
123 |
| B |
Third Party
Valuation Product Not Provided within 10% Tolerance |
1 |
| Property
Issue(s) are Present |
1 |
| Total
Property Grade (B) Exceptions: |
2 |
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
value is supported within 10% of the original appraisal by the AVM or there are other supporting documents in the originators loan
file package (CDA, Field Review or Second Appraisal). The appraisal 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. |
| B |
The
value is not supported within 10% of the original appraisal by the AVM and there are no other valuation support documents in the
loan file provided by the Seller. 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 is not 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 did not use GSE approved forms. |
| D |
The
file was missing the appraisal or there was not sufficient valuation documentation to perform a review. |