Exhibit 99.6
BINOM 2026-NQM2
SLC BINOM Sponsor LLC
Opus
Capital Markets Consultants, LLC
| 5599 San Felipe Street,
Suite 420 | Houston, TX 77056 | www.opuscmc.com | 224.632.1300 |
Executive Narrative
September 11, 2026
Performed by
Opus Capital Markets
Consultants, LLC
For
SLC BINOM Sponsor
LLC
The report summarizes the results of a due diligence review performed on
a pool of eighty-eight (88) loans, that were directly or indirectly acquired by SLC BINOM Sponsor LLC. or an affiliate thereof (together
the “Customer”) from an originator (the “Originator”). The Customer is a client of Opus Capital Markets Consultants,
LLC (“Consultant”) under a reliance letter, and for which the Originator provided Consultant with a data tape, from which,
in each case, 100% of the loan population was chosen and loaded into the LauraMac underwriting software. Consultant performed a detailed
credit review of all loans.
As detailed herein, the pool contains fifty-one (51) ATR/QM Exempt loans,
of which all fifty-one (51) are DSCR loans, and thirty-seven (37) NQM loans that were re-underwritten in accordance with the lender guidelines
in terms of Exhibit A.
EXHIBIT A
Credit
Review
Credit Qualification
A re-underwriting review will be conducted in order to verify that the
requisite underwriting guidelines as specified by Client are met. Confirmation of the loan terms will be performed through recalculation
and review of documentation contained in the loan file provided to the Consultant. The Credit Qualification review will consist of the
following:
| a) | Guidelines: Determine whether each mortgage loan meets the requisite guideline requirements as
specified by the Client. In lieu of specific requirements, Consultant should consider Regulation Z including Appendix Q if applicable.
If the loan pre-dates the requirements of Regulation Z and Appendix Q, Consultant will consider Fannie Mae’s Single-Family guidelines. |
| b) | Employment: Review the file documentation for minimum required level of employment, income and
asset verifications pursuant to Client provided underwriting guidelines. |
| c) | Income: Recalculate borrower(s) monthly gross income and verify calculations of income as used
by the original loan underwriter at origination to determine compliance with the Client provided underwriting guidelines. |
| d) | Assets: Confirm the presence of adequate asset documentation to comply with the Client provided
underwriting guideline requirements for closing funds, reserves and borrower liquidity. |
| e) | Debt Ratio: Recalculate the debt-to-income ratio and verify the ratio accuracy used by the loan
underwriter at origination to determine compliance with Client provided underwriting guidelines and regulatory requirements. |
| f) | Property Valuation: Analyze all appraisals and alternative value tools used to qualify the loan
for integrity of comparable sales, completeness of data, eligibility of the appraiser and reasonableness of estimated value. Review the
appraisal to determine the appraisal(s) meet the requirements of Client provided underwriting guidelines. |
| g) | Loan-to-Value Ratio: Recalculate and verify the loan-to-value ratio and combined loan-to-value
ratio were accurate at origination and meet Client provided underwriting guideline and regulatory requirements. |
| h) | Credit History: Review the credit report to verify that the borrower(s) demonstrate adequate
credit depth to comply with the Client provided underwriting guideline requirements. |
| i) | Credit Scores: Verify that borrower(s) meet minimum credit score requirements of the Client provided
underwriting guidelines. |
| j) | Compensating Factors: Verify exceptions to the Client provided underwriting guidelines are documented
and reasonable. |
Document
Review
Document Review
A review of each loan file
will be performed to confirm the presence of material documentation as applicable to the specifics of the loan transaction. The Document
Review will consist of the following:
a) Collateral Docs
| ● | Title
Commitment / Policy: Verify the presence of the title commitment or final title policy. Confirm vested parties and the description of
the property, liens and tax assessments. |
| ● | Mortgage Note / Security Instrument: Verify the presence of the mortgage note or security instrument. Confirm that the document has been
executed by all borrowers and that all riders, addendums and endorsements are present and duly executed. |
| ● | Mortgage / Deed of Trust: Verify the presence of a copy of the Mortgage or Deed of Trust. Confirm that the documents have been executed
by all required parties and that all riders, addendums and exhibits are present and duly executed. If the loan closed within 12 months
of the review, Consultant will confirm the presence of a letter from the title company specifying the date the Mortgage / Deed of Trust
was sent for recording. If the closing did not occur within 12 months of the review and a copy of the recorded Mortgage /Deed of Trust
is not contained in the loan file, the Client will submit a report from an independent document custodian verifying the presence of a
recorded mortgage or a stamped / signed copy of the document stating the date the document was sent for recording. |
| ● | Conveyance
Deed: Verify as applicable that a proper conveyance deed is present in the loan file. Confirm the proper transfer of ownership interest
of the subject parties is detailed on the deed. |
b) Closing Docs
| ● | Final
Hud-1 Settlement Statement: If required, verify the presence of a final HUD-1. Verify the completeness of required data and signatures
or certification depending upon state compliance requirements. |
| ● | Final
Truth-in-Lending Disclosure: If required, verify the presence of a final Truth-in-Lending Disclosure. Verify the completeness of required
data and that all required signatures are present. |
| ● | Notice
of Right to Cancel: If required based on the specifics of the loan transaction, confirm the presence and required execution of the Notice
of Right to Cancel. |
| ● | Loan
Estimate: If required verify the presence of the current Loan Estimate (LE) at the time of origination |
| ● | Closing
Disclosure: If required verify the presence of the current Closing Disclosure (CD) at the time of origination. |
c) Credit Docs
| ● | Loan
Application: Verify the presence and completeness of both the initial and final loan applications. |
| ● | Underwriting
Worksheet: Verify the presence of the relative underwriting worksheet i.e. form 1008, FHA MCAW and VA’s Loan Analysis. |
| ● | Credit
Report: Verify the presence of a credit report for each borrower. Confirm that the credit report was pulled within the timing requirements
allowable per the Client provided underwriting guidelines. |
| ● | Housing Payment History: In the absence of housing payment histories on the borrower(s) credit report(s), verify that the file contains
a verification of rent or a verification of mortgage form. |
| ● | Letters
of Explanation: When Letters of Explanation are required by the Client provided underwriting guidelines, verify the presence of any such
letters exist in the loan file. |
| ● | Gift
Letters: When Gift Letters are required by the Client provided underwriting guidelines, verify the presence of any such letters exist
in the loan file. |
| ● | Income
Documentation: Verify the presence of income and employment related documentation required by the Client provided underwriting guidelines
for all borrowing parties contributing income to the debt ratio calculation. |
| ● | Asset
Documentation: Verify the presence of asset documentation required by the Client provided underwriting guidelines in the loan file. |
| ● | Property
Valuation Tools: Verify that each loan file contains adequate appraisal and other third party valuation tools to satisfy the minimum
required documentation under the relative Client provided underwriting guidelines. |
| ● | Proof
of Insurance: Verify the presence of insurance certificates for mortgage, hazard and flood insurance on an as needed basis depending
upon the specifics of the loan. Confirm that adequate coverage is present to meet the requirements of the Client provided underwriting
guidelines. |
Regulatory Compliance
For each Mortgage Loan, Consultant shall determine, to the extent possible
and subject to caveats below, whether such Mortgage Loan at the time of origination complied with:
| 1. | The “material”1 disclosure
requirements of the federal Truth-in-Lending Act (“TILA”), as amended by the
Home Ownership and Equity Protection Act (“HOEPA”) and Dodd-Frank, 15 U.S.C.
§ 1601 et seq. and implemented by Regulation Z, 12 C.F.R. Part 1026, including the material
provisions relating to Higher-Priced Mortgage Loans in Regulation Z, 12 C.F.R. §§
1026.35, and the early TIL disclosure provisions of the Mortgage Disclosure Improvement Act
(“MDIA”), as implemented by Regulation Z, 12 C.F.R. §§ 1026.17 et seq;
and as amended by the TILA-RESPA Integrated Disclosure (“TRID”) Rule, as set
forth below: |
| a. | For Right of Rescission |
| i. | A review of the Notice of Right to Cancel, including a verification of the transaction date and expiration date, ensuring proper execution
of the Notice of Right to Cancel by all required parties, verifying the disbursement date and determining if a full three (3) day rescission
period was adequately provided to the borrower(s). |
| A. | This review is also to be performed on transactions that are exempt from the rescission requirement but on which a Notice of Right
to Cancel was provided. |
| B. | A condition must be placed if the transaction is a refinance by the original creditor and the borrower was provided the Form H-8 rescission
notice. Consultant will note in the condition whether there was a new advance that is subject to rescission per TILA/Regulation Z. |
| b. | For TILs (Application Dates prior to 10/3/2015) |
| i. | Confirm the initial TIL disclosure and final TIL disclosures were provided. |
| ii. | Review and compare the initial and final TIL, and any re-disclosed TIL(s), with a report outlining any TILA violations, including a recalculation of disclosed finance charge,
proper execution by all required parties, principal and interest calculations, proper completion of the interest rate and payment summary,
recalculation of disclosed APR, and a review to determine disclosure differences were within the allowed tolerances and disclosures were
provided within the required timeframes; |
| c. | For TRID Disclosures (Application Dates on or after 10/3/2015) |
| i. | Confirm the initial Loan Estimate (LE) was delivered within three (3) business days of application and seven (7) business days prior to consummation
in accordance with Client’s Underwriting Guidelines; |
| ii. | Review the required sections of each LE to ensure they were populated in accordance with the TRID Rules. (If the file reflects more than one LE was provided, each
revised LE must have corresponding Change of Circumstance documentation. The 0% and 10% fee tolerance evaluations will be based on the
fee amounts disclosed on the initial LE and any valid changes documented and disclosed after the initial LE; |
| iii. |
|
Confirm the Closing Disclosure (CD) confirm the borrower received the initial CD at
least three (3) business days prior to consummation; |
| iv. | | Review the required sections of each CD to ensure they were populated in accordance with the TRID Rules. (Any fee tolerance issues to be
cured at closing or within 60 days of loan consummation.) |
1 These “material” disclosures include
the required disclosures of the APR, the finance charge, the amount financed, the total number of payments, the payment schedule, and
if the loan is subject to the Homeownership and Equity Protection Act (“HOEPA”), the disclosure requirements and prohibitions
of that statute which are set forth in 12 C.F.R. §§ 1026.32(c) and (d).
| 2. | Section 4 of the Real Estate Settlement Procedures Act (“RESPA”), 12 U.S.C. §2603 and 2604, as implemented by Regulation
X, 12 C.F.R. Part 1024, and as amended by the TRID Rule; |
| 3. | The disclosure requirements and prohibitions of Section 50(a)(6), Article XVI of the Texas Constitution; |
| 4. | Confirmation that one of the following are in the loan file, per the Fair Credit Reporting Act: Consumer Credit Score Disclosure,
Your Credit Score and the Price You Pay for Credit, or Notice to Home Loan Applicant; |
| 5. | Sections 1411 and 1412 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) amending TILA,
as implemented by Regulation Z, 12 C.F.R. 1026.43: the general Ability to Repay underwriting standards (12 C.F.R. 1026.43(c)); refinancing
of non-standard mortgages (12 C.F.R. 1026.43(d)); Qualified Mortgages (12 C.F.R. 1026.43(e) (including qualified mortgages as defined
by the Department of Housing and Urban Development (24 C.F.R. 201 and 203 et seq.) and the Department of Veterans Affairs (38 C.F.R. Part
36 et seq.; and Balloon-payment qualified mortgages made by certain creditors (12 C.F.R. 1026.43(f)) In accordance with “Ability
to Repay and Qualified Mortgage Review” description below; |
| 6. | The Loan Originator Compensation and Prohibitions on Steering provisions of TILA, as implemented by Regulation Z, 12 C.F.R 1026.36; |
| 7. | The requirements for Higher-Price Mortgage Loans, as implemented by Regulation Z, 12 C.F.R. 1026.35; |
| 8. | The appraisal and valuation requirements of TILA and the Equal Credit Opportunity Act, as implemented by Regulation Z, 12 C.F.R. 1026.35
and Regulation B, 12 C.F.R. 1002.14, respectively; |
| 9. | The counseling requirements of TILA, as implemented by Regulation Z, 12 C.F.R. 1026.36(k) and RESPA, as implemented by Regulation
X, 12 C.F.R. 1024.20; |
| 10. | The escrow requirements of TILA and RESPA, as implemented by Regulation Z, 12 C.F.R 1026.35, and Regulation X, 12 C.F.R 1024.17, respectively; |
| 11. | The disclosure requirements and prohibitions of any applicable state, county and municipal laws and ordinances, as amended, that have
been enacted to regulate so-called “predatory lending”: |
| 12. | Consultant shall confirm that any mortgage property located in an area identified on a flood hazard map or flood insurance rate map
issued by the Federal Emergency Management Agency as having special flood hazards is subject to a qualified flood insurance policy that
appears to be is in effect. |
| 13. | For any loans designated as TILA exemption, Consultant shall review the loan file for evidence that the primary purpose of the loan
was for commercial or business purposes, including, but not limited to a business purpose certification. |
| 14. | Verification, in accordance with 12 C.F.R. 1026.36, that the mortgage loan
originator organization and individual mortgage loan originator names and applicable NMLS Registry ID(s) are properly disclosed on required
loan documents and accurately validated against the NMLS Registry database, as available. |
| 15. | Documentation. Review of the following documents for regulatory compliance: |
| a. | Final HUD-1 Settlement Statement (“HUD-1”), if applicable |
| i. | If the loan is in an escrow state, the HUD-1 will be considered final as follows: |
| i. | If HUD-1 is not marked Final, it must be stamped certified by the closing agent. |
| ii. | There should be no markings indicating that the HUD-1 is estimated. |
| B. | HUD-1 is signed by all parties (including closing agent) or stamped certified by the closing agent; and |
| C. | If HUD-1 is stamped, the HUD-1 / stamp should be signed or initialed by the closing agent; if the stamp does not contain the signature
or initials, it must identify the name of the closing agent. |
| b. | Final Truth in Lending Disclosure (“TIL”), if applicable |
| c. | Loan Estimate, if applicable |
| i. | The Loan Estimate will be considered delivered based on the date issued, subject to the three-day mailing rule unless the file contains
documentation indicating earlier receipt. The loan file may contain one or more Loan Estimates with the latest one provided up until three
business days prior to the issuance of an initial Closing Disclosure. |
| d. | Closing Disclosure, if applicable |
| i. | The Closing Disclosure in the loan file will be considered delivered based on the date issued, subject to the three-day mailing rule
unless the file contains documentation indicating earlier receipt. The loan file may |
| | contain one or more Closing Disclosures with the
latest one provided up until the consummation date being considered the Final with any delivered post consummation considered as a corrected
Closing Disclosure. |
| e. | Notice of Right to Cancel (if applicable) |
| f. | Initial TIL, if applicable |
| g. | Good Faith Estimate (“GFE”), if applicable |
| i. | Third party fees on the HUD-1 or Closing Disclosure if applicable referred to as HUD-1/Closing Disclosure, must be shown as paid to
the third-party provider. A condition must be set if a third-party fee is paid to the lender, investor, etc. or the payee is blank. |
| ii. | CONSULTANT will condition for evidence in the file indicating that a charge on the HUD-1/Closing Disclosure exceeds the actual cost
to the borrower (i.e. cost printed / stamped on the face of the document showing an amount less than the charge on the HUD-1/Closing Disclosure).
Variations of less than $1 are deemed to be within reasonable limits and are not to be reported. |
| iii. | Any refunds that are provided to the borrower must be accompanied by a revised HUD-1/Closing Disclosure to show the final, accurate
charges to the borrower. |
Each loan reviewed will be assigned a Compliance condition grade in accordance
with the Rating Agency Criteria as more fully described in Section 2(f).
Consultant will not make a determination as to whether the loans comply
with federal, state or local laws, constitutional provisions, regulations or ordinances that are not expressly enumerated above. Furthermore,
the findings reached by Consultant are dependent upon its receipt of complete and accurate data regarding the loans from loan originators
and other third parties upon which Consultant is relying in reaching such findings.
Ability to Repay and Qualified Mortgage Review
| 1. | For Agency Eligible Loans Only: Consultant reviews applicable loans for compliance with the Qualified Mortgage (QM)
rule requirements set forth in Regulation Z (12 C.F.R. 1026.43 et seq.) based upon the loan’s designation (Safe Harbor QM, Rebuttable
Presumption QM, Exempt). Consultant determines the loan’s status under the QM rule requirements and assigns a due diligence loan
designation. Consultant notes as a material exception if the due diligence findings do not confirm the same loan designation. Additionally,
Consultant notes if a loan designation was not provided. Consultant will verify if each loan meets the requirements for a QM under §
1026.43(e)(2)—whether the loan is a safe harbor QM under § 1026.43(e)(1)(i) or a rebuttable presumption QM under § 1026.43(e)(1)(ii).
Consultant will verify the presence of documentation for lender determination of QM and indicating factors in its ability-to-repay determination,
including how the originator applied its policies and procedures in verification. For loans applications taken on or after June 1, 2021,
Consultant will verify whether the loan meets the requirements of the revised general QM definition effective March 1, 2021. |
| 2. | For loans for which applications were received prior to July 1, 2021, if a loan was designated as QM and identified as eligible for
guarantee, purchase, or insurance by an applicable agency as permitted under the QM final rule, Consultant reviews the loan to determine
whether, based on available information in the loan file the loan satisfied (i), (ii) and (iii) in the paragraph (3)(a)(i) below and reviews
the Automated Underwriting System output within the file to confirm agency eligibility. |
| 3. | For Non-Agency Eligible Loans: Consultant reviews applicable loans for compliance with the Ability to Repay (ATR) but
not Qualified Mortgage (QM) rule requirements set forth in Regulation Z (12 C.F.R. 1026.43 et seq.). |
a. Qualified Mortgage:
| i. | For QM (Safe Harbor or HPCT) designated loans, Consultant reviews the loan to determine whether, based on available information in
the loan file: (i) the loan contains risky loan features and terms (e.g. an interest only feature or negative amortization), (ii) the
“points and fees” exceed the applicable QM threshold, (iii) the monthly payment was calculated appropriately. Consultant reviews
to the applicable consider and verify requirements under the QM rule depending on whether the QM was originated under the original general
QM definition or the revised general QM definition effective March 1, 2021. |
| ii. | For each QM designated loan that satisfied the applicable requirements enumerated above, Consultant then determines whether the loan
is a Safe Harbor QM or Higher Priced QM by comparing the loan’s actual annual percentage rate, as recalculated, to the applicable
average prime offer rate plus a certain percentage. For QM designated loans originated under the revised general QM definition effective
March 1, 2021, Consultant also determines whether the loan exceeds the pricing thresholds for QM loans. |
b. Ability to Repay:
| i. | The ability to repay portion of the review for non-agency eligible loans only will focus on the eight factors detailed in the ATR
Rule as detailed below for non-agency eligible loans. The Consultant will review the |
| | loan file to determine if the creditor verified and
considered each of the eight factors utilizing reasonably reliable third-party documentation at or before consummation. |
| 1. | Current or reasonably expected income or assets that the consumer will rely on to repay the loan. |
| 2. | Current employment status |
| 3. | Monthly mortgage payment for subject loan using the introductory or fully indexed rate, whichever is higher, and monthly, fully amortized
payments that are substantially equal |
| 4. | Monthly payment on any simultaneous loans secured by the subject property. |
| 5. | Monthly payments for property taxes and hazard/flood insurance and certain other costs related to the property such as homeowner’s
association fees or ground rent. |
| 6. | Debts, alimony, and child support obligations |
| 7. | Monthly debt-to-income ratio or residual income |
| ii. | For loans designated as agency eligible, Consultant will not review for compliance with the requirements of Appendix Q or General
Ability to Repay. |
| iii. | Consultant reviews loans to determine their conformity with the ATR/QM factors above and is not rendering an independent assessment
or analysis. Consultant’s review is based on information contained in the loan file at the time it is provided to Consultant, and
only reflects information as of that point in time and does not mean any regulator, judicial or agency will agree with the Consultant’s
conclusion. |
| a) | Regulatory Compliance Disclaimer
|
Please be advised that Consultant will not make a determination as to whether loans complied with federal, state or local laws, constitutional
provisions, regulations or ordinances that are not expressly enumerated herein. There can be no assurance that the review uncovered all
issues relating to the origination of the mortgage loans, their compliance with applicable law and regulation and the original appraisals
relating to the mortgaged properties or uncovered all relevant factors that could affect the future performance of the mortgage loans.
Furthermore, the findings reached by Consultant are dependent upon its receiving complete and accurate data regarding the mortgage loans
from loan originators and other third parties upon which Consultant is relying in reaching such findings.
Please be further advised that Consultant does not employ personnel who
are licensed to practice law in various jurisdictions, and the findings set forth in the reports prepared by Consultant do not constitute
legal advice or opinions. They are recommendations or conclusions based on information provided to Consultant. All final decisions as
to whether to purchase or enter into a transaction related to any individual mortgage loan or the mortgage loans in the aggregate, any
investment strategy and any legal conclusions, including potential liability related to the purchase or other transaction involving any
such loans, shall be made solely by the Client, or other agreed upon party, that has engaged Consultant to prepare its reports pursuant
to its instructions and guidelines. Client, or other agreed upon party, acknowledges and agrees that the scoring models applied by Consultant
are designed to identify potential risk and the Client, or other agreed upon party, assumes sole responsibility for determining the suitability
of the information for its particular use.
| b) | Seasoning And Certain Compliance Exceptions
|
Pursuant to the applicable NRSRO criteria, Consultant graded certain compliance exceptions as non-material based on seasoning of the mortgage
loan. Certain mortgage loans were seasoned beyond the applicable period under TILA in which affirmative claims could be brought by a consumer.
The time period is not limited for claims, other than rescission, which are raised as a defense to foreclosure. Information contained
in any Consultant reports related to the applicable statute of limitations for certain claims may not be accurate or reflect the most
recent controlling case law. Further, a particular court in a particular jurisdiction may extend, not enforce or otherwise allow claims
beyond the statute of limitations identified in the report based on certain factors, including the facts and circumstances of an individual
loan.
Additional Disclosures and Requirements:
Consultant will confirm compliance with current documentation and timing
requirements in effect at origination of the Mortgage Loan including:
| ● | Servicing Transfer Disclosure (for applications prior to 10/03/2015): |
| o | Confirm the presence of the Servicing Transfer Disclosure form in file |
| o | Verify the Servicing Transfer Disclosure was provided to the borrower(s) within three general business
days of “Application” |
| ● | Special Information Booklet (for applications prior to 10/03/2015)/ Home Loan Tool Kit (for applications
on or after 10/03/2015): |
| o | Confirm the presence of the Home Loan Tool Kit is in file for covered loans. |
| o | Confirm the Home Loan Tool Kit is provided within three general business days of application |
| ● | Initial Escrow Disclosure Statement |
| o | Confirm the presence of the Initial Escrow Disclosure Statement in file |
| o | Confirm the Initial Escrow Disclosure Statement was provided at closing or within 45 days after settlement |
Equal Credit Opportunity Act (Regulation B)
| ● | Confirm
the lender has provided the borrower a disclosure of the right to receive a copy of appraisals within three (3) business days of application.
This disclosure requirement may be met by disclosure on the Loan Estimate pursuant to 12 CFR § 1026.27(m)(1). |
| ● | Confirm that the lender has provided (delivered) copies of appraisals and all other written valuations (as disclosed to the borrower on
the HUD-1 and/or contained in the Mortgage Loan File) to the borrower at least three (3) business days prior to consummation Opus uses
the following test: Was appraisal/valuation documentation processed at least six (6) days prior to account opening/ consummation date
(3 day rule plus 3 days mailing time)? |
| ● | For
a borrower that has waived the 3-business day disclosure requirement, confirm that the borrower has either (1) signed the waiver at least
three (3) business days prior to consummation or (2) has signed an acknowledgment that the waiver occurred at least three (3) business
days prior to consummation. Additionally, confirm that the lender has provided copies of appraisals and other written valuations at or
prior to consummation. |
Fair Credit Report Act (Regulation V)
| ● | Confirm
that the lender has provided the borrower the risk-based pricing notice (as required by 12 CFR § 1022.73) or credit score disclosure
(as required by 12 CFR § 1022.74(d)), as applicable; (a) If the lender has provided the risk-based pricing notice, confirm the disclosure
was provided before consummation, but not earlier than the approval decision was communicated to the consumer; and (b) If the lender
has provided the credit score disclosure, confirm the disclosure was provided before consummation. |
| ● | Confirm
that the lender has provided a copy of the disclosure of credit score and the Notice to Home Loan Applicant (as required by 15 U.S.C.
§ 1681g) before consummation. |
High-Cost, State & Local Anti-Predatory Regulations
In addition to federal thresholds, Consultant will review the anti-predatory
lending statutes in the following states and local municipalities, as applicable, as well as any additional applicable regulations implemented
during the Term of this SOW.
| ● | Arkansas Home Loan Protection Act, Ark. Stat. Ann. § 23-53-101 et seq. |
| ● | California Anti-Predatory Lending Statute, Cal. Fin. Code § 4970 et seq. |
| ● | California Higher-Priced Mortgage Loan Statute, Cal. Fin. Code §4995 et seq. |
| ● | Colorado Consumer Equity Protection Act, Colo, Rev. Stat. § 5-3.5-101 et seq..
|
| ● | Connecticut Abusive Home Loan Lending Practices Act, Conn. Stat. Ann. §36a- 746 et seq., as amended
from time to time. |
| ● | Connecticut Nonprime Home Loans Statute, Conn. Gen. Stat.
§§ 36a-760 et seq. (as originally enacted and as amended by Senate Bill 949). |
| ● | District of Columbia Home Loan Protection Act, D.C. Official
Code § 26-1151.01 et seq., as implemented by 20 D.C. Municipal Reg § 2000.1 et seq. |
| ● | Florida Fair Lending Act, Fla. Stat. Ann. § 494.0078
et seq. (for loans closed before July 1, 2014). |
| ● | Georgia Fair Lending Act, Ga.
Stat. Ann. § 7-6A-1 et seq. (as originally enacted by House Bill 02-1361 and as modified
by Senate Bill 03-53). |
| ● | Idaho Residential Mortgage Practices Act, Idaho Code § 26-3101 et seq. |
| ● | Illinois High Risk Home Loan Regulations, 38 Ill. Admin. Code §345.10 et seq. |
| ● | Illinois High Risk Home Loan Act, Public Act. 93-0561 (2003) codified at 815, ILCS §§ 137/5
et seq., and as amended by SB 1692 (2012), effective January 10, 2014. |
| ● | Illinois Predatory Lending Database Program,
Public Act 95-0691 (SB 1167). |
| ● | City of Chicago, Illinois, Anti-Predatory Lending Ordinance,
Chicago Municipal Code, §§ 2-32-440; 2-32-455; 2-92-325; 4-4-155; 8-4-325. |
| ● | Cook County, Illinois,
Anti-Predatory Lending Ordinance, Cook County Code of Ordinances § 34-341. |
| ● | Cook County, Illinois,
Anti-Predatory Lending Pilot Program, Illinois House
Bill 4050 (2005). |
| ● | Indiana Home Loan Practices Act,
as amended by HB 1179 (2005), Ind. Code §24-9-1 et seq. |
| ● | Section 16a-3-308a of the Kansas Consumer Credit Code, Kan. Stat. Ann. §16a.101 et seq. |
| ● | Kansas Consumer Credit Code |
| ● | Kentucky Anti-Predatory Lending Statute, Ky. Rev. Stat. § 360.100 et seq. |
| ● | Maine, An Act to Enhance Consumer Protections in Relation to Certain Mortgages (for loans closed prior
to September 27, 2011), Me. Rev. Stat. Ann. Tit. 9-A, §§ 8-103(1); 8-206(8);8-206A, as amended by Legislative Documents 1869
(2007), 2125 (2008) and 1439 (2009). |
| ● | Maine Consumer Credit Code - Truth-in-Lending, (for loans closed on or after September 27, 2011), Me.
Rev. Stat. Ann. tit. 9-A, §§ 8-501 et seq., as amended from time to time. |
| ● | Maryland Commercial Law, Md. Code Ann., Com. Law §§ 12-124.1; 12-127; 12- 409.1; 12-1029.
|
| ● | Maryland Regulations for Higher
Priced Mortgage Loans, as promulgated under the Maryland Mortgage Lender Law, Md. Code Ann., Fin. Instit.
Code §§ 11-501 et seq.; Md. Code Regs. §§ 09.03.06.01 et seq. |
| ● | Massachusetts High-Cost Mortgage Regulations, 209 CMR Parts
32 and 40, as amended from time to time. |
| ● | Massachusetts Predatory Home Loan
Practices Act, M.G.L. Chapter 183C, §§ 1 et seq. |
| ● | Massachusetts “Borrower’s Interest” Standard,
M.G.L. Chapter 183, §28C. |
| ● | Massachusetts Mortgage Lender and Broker Regulations, 940 CMR §800 (15-17). |
| ● | Massachusetts Regulations for Higher Priced Mortgage Loans, 209 CMR §§ 32.00 et.seq., as amended
from time to time. |
| ● | Massachusetts Subprime ARMs to First Time Homebuyers, M.G.L. Chapter 184, §17B.5. |
| ● | Michigan Consumer Mortgage Protection Act, Mich. Stat. Ann. § 445-1631 et seq. |
| ● | Minnesota Mortgage Originator and Servicer Licensing Act, § 58.137 et seq. (S.F. 2988 (2002)), as amended by House File 1004 (2007)
and Senate File 988 (2007). |
| ● | Nebraska Mortgage Bankers Registration and Licensing Act, Neb. Stat § 45-702 et seq. |
| ● | Nevada Anti-Predatory Lending Law, Assembly Bill No. 284 (2003) and Amended by Assembly Bill No. 440
(2007), codified as NRS § 598D.010 et seq. |
| ● | New Jersey Home Ownership Security
Act of 2002, NJ Stat. Ann. § C:46:10B-22 et seq., as amended from time to time. |
| ● | New Mexico Home Loan Protection Act, Senate Bill 449 (Regular Session 2003), codified at NM Rev. Stat.
§ 58-21A-1 et seq. and as amended from time to time. |
| ● | New York High-Cost Home Loan Regulations, 3 NYCCR Part 41 (2001). |
| ● | New York High-Cost Home Loan Act, N.Y. Bank. L. Ch. 626., as codified
in NY Bank. Law § 6-l, and as implemented by 3 NYCCR Part 41 as amended from time to
time. |
| ● | New York Subprime Home Loans Statute, NY Bank. Law § 6-m. |
| ● | North Carolina Anti-Predatory Lending Law, N.C. Gen. Stat. §§ 24-1.1A to 24- 10.2 and North
Carolina Amendments to Anti-Predatory Lending Law, N.C. Gen. Stat. §§ 24-9; 24-1.1(E)(a); 24-10.2(a), as amended from time to
time. |
| ● | Ohio Anti-Predatory Lending Statute, HB 386 as amended by Senate Bill 185
(2006), and as codified in various sections of the Ohio Code. |
| ● | Ohio Consumer Sales Practices
Act, Ohio Rev. Code Ann. § 1345.01, as implemented by Ohio Admin. Rules § 109 4-3-01 et seq. |
| ● | City of Cleveland Heights, Ohio,
Anti-Predatory Lending Ordinance, Ordinance No. 72-2003 (PSH), Mun. Code §§ 757.01 et seq. |
| ● | Summit County, Ohio, Anti-Predatory
Lending Ordinance, Ordinance No. 2004- 618, Muni. Code §§ 201.01 et seq. |
| ● | Oklahoma Anti-Predatory Lending Law, House Bill No. 1574 (2003), as codified in various sections of
Title 14A of the Oklahoma Consumer Credit Code. |
| ● | Oklahoma Higher-Priced Mortgage
Loans Law, Okla. Admin. Code §§ 160:45-9- 1 et seq. |
| ● | Pennsylvania Consumer Equity Protection Act, 63 Pa. Cons. Stat. Ann. § 456.501 et seq. |
| ● | Rhode Island Home Loan Protection
Act, R.I. Gen. L. 34-25.1-2 et seq, as implemented by Emergency Banking Regulation 3 (2006) and Final Banking Regulation 3 (2007) and
amended by Senate Bill 371 (2007). |
| ● | City of Providence, Rhode Island, Anti-Predatory Lending Ordinance, Chapter 2006-33, Ordinance No. 245.
|
| ● | South Carolina High-Cost and Consumer Home Loans Act, S.C. Code § 37-23-10 et seq. |
| ● | Tennessee Home Loan Protection Act, Tenn. H.R. 3597 (2006), as codified at Tenn. Code Ann. §§
45-20-101 et seq. |
| ● | Texas High-Cost Home Loan Statute,
Tx. Fin. Code Ann. § 343.201 et seq. |
| ● | Section 50(a)(6), Article XVI of the Texas Constitution |
| ● | Section 50(f)(2), Article XVI of the Texas Constitution |
| ● | Utah Residential Mortgage Practices Amendments, Utah Code Ann. § 61-2c-102 et seq. |
| ● | Utah High-Cost Home Loan Act, Utah Code § 61-2d-101 et seq. |
| ● | Vermont Interest Act, 9 V.S.A. § 104, implemented by
Regulation B-98-2. |
| ● | Virginia Mortgage Lender and Broker Act (for loans originated prior to July 1, 2003), Va. Code Ann.
§§ 6.1-413; 6.1-422; 6.1-428. |
| ● | Virginia Mortgage Lender and Broker Act (for loans originated on or after July 1, 2003 to September
30, 2010, as amended), Va. Code Ann. §§ 6.1-411, 6.1-422.1, 6.1-425.1 and 6.1-425.2. |
| ● | Virginia Mortgage Lender and Broker Act (for loans originated on or after October 1, 2010), Va. Code
Ann. §§ 6.2-1600 et seq., as amended from time to time. |
| ● | Virginia Senate Bill 797 (2008), effective July 1, 2008 (uncodified). |
| ● | Washington House Bill 2770, Mortgage Lending Ownership |
| ● | West Virginia Residential Mortgage Lender, Broker and Servicer Act, W.Va. Code §
31-17 et seq. |
| ● | Wisconsin Responsible High-Cost Mortgage Lending Act, Wis.
Stat. § 428.202, as implemented by Wis. Admin. Code DFI-Bkg 46.01 et seq. |
Flood Insurance Testing
National Flood Insurance Program (NFIP)
Each mortgage loan will be reviewed to ensure adherence to flood insurance
coverage requirements as outlined under the NFIP, including identification of flood zones and subsequent policy documentation for evidence
of adequate coverage amounts.
Homeowner’s Flood Affordability Act (HFIAA)
Each mortgage loan made by an FDIC-supervised institution or servicer acting
on its behalf shall require the escrow of all premiums and fess for flood insurance for any designated loan secured by residential improved
real estate or a mobile home, made, increased, extended or renewed on or after January 1, 2016.
Frequency – Payable with same frequency as payments designated for
the loans
Exceptions
| ● | Loan is an extension of credit primarily for business, commercial or agricultural purposes |
| ● | Loan is in a subordinate position to a senior lien secured by the same residential improved real estate
or mobile for which the borrower has obtained flood insurance |
| ● | Flood Insurance coverage for the residential real estate is provided by a policy that |
| b. | Provided by a condominium association, cooperative or other applicable group and |
| c. | The premium for which is paid by the condominium association, cooperative, homeowners association, or other group as a common expense. |
Misrepresentation
and Third-Party Review
Validate that fraud reports and independent third-party property valuations
reports are in the file. The review will consist of the
following:
Misrepresentation Review
and Valuation Review
Review on each loan to identify potential misrepresentations of income,
employment, identity, occupancy, transaction and appraisal misrepresentation or other areas of potential misrepresentation. The Misrepresentation
may include the following:
| ● | Signatures:
Validate signature consistency across documents. To the extent imaged or hard copy files are provided, Consultant will utilize reasonable
efforts to validate the consistency of signatures across documents. |
| ● | Alerts:
Assess credit report alerts for accuracy and potential issues. |
| ● | Social
Security Numbers: Compare SSN(s) across all file documents. |
| ● | Document
Integrity: Review for apparent alterations to loan documents. To the extent imaged or hard copy files are provided, Consultant will utilize
reasonable review of alterations to the loan documents. |
| ● | Data
Consistency: Review the documents contained in the loan file for consistency of data. |
| ● | Third
Party Fraud Tools: To the extent a third party fraud tool is contained in the loan file, the Consultant will ensure high level or critical
warnings are reviewed and addressed. |
Independent Third-Party Values
Review each loan to determine whether a third-party valuation product was required and if required, that the third-party product value
was compared to the original appraised value to identify a value variance and apply the appropriate rating agency grade after reviewing
the required valuation products.
i) Consultant will perform the following steps.
| ● | Value
is based on as-is condition or provides satisfactory completion of all material conditions including inspections, licenses, and certifications
(including certificates of occupancy) to be made or issued with respect to all occupied portions of the mortgaged property and with respect
to the use and occupancy of the same, have been made or obtained from the appropriate authorities. |
| ● | Property
is described in average or better condition |
| ● | No
apparent appraiser independence violation statements |
| ● | Appraisal
addresses any adverse comments |
| ● | Appraisal
is completed on appropriate GSE Forms |
| ● | Appraisal
contains required attachments. |
| ● | Appraiser
was appropriately licensed at the time the appraisal was signed |
If the valuation vendor does not supply the updated valuation product directly to the Consultant, the Client will authorize the valuation
vendor to issue an attestation with sufficient information for the Consultant to determine the correct valuation product was utilized
to verify the accuracy of the origination appraisal. Consultant did not receive an attestation for any of the third party valuation products.
Value Review Disclaimer
| ● | The individuals performing the above procedures are not persons providing valuations for the purpose of the Uniform Standards of Professional
Appraisal Practice (“USPAP”) or necessarily licensed as appraiser under Federal or State law, and the services being performed
do not constitute appraisal reviews for the purposes of USPAP or Federal or State law. |
| ● | Opus
makes no representation or warranty as to the value of the mortgaged property, notwithstanding that Opus may have reviewed the valuation
information for reasonableness. |
| ● | Opus
is not an Appraisal Management Company (“AMC”) and therefore does not opine on the actual value of the underlying property. |
| ● | Opus is not a creditor within the meaning of the Equal Credit Opportunity Act (“ECOA”) or other lending laws and regulations,
and therefore Opus will not have communications with or responsibility to any individual concerning property valuations. |
Properties in FEMA declared disaster zones.
If a FEMA declared disaster occurs after the inspection date on the appraisal,
Consultant will review the file to determine if an exterior inspection to ensure:
| ● | No
apparent damage to the property |
| ● | Property
appears to be occupied |
DSCR
Loan Review
A re-underwriting review will be conducted in order
to verify that the requisite underwriting guidelines as specified by Client (the “Underwriting Guidelines”) are met.
Confirmation of the loan terms will be performed through recalculation and review of documentation contained in the loan file provided
to the Consultant. The Credit Qualification review guidelines will consist of the following:
Borrower Underwriting:
| ● | Borrower Liquidity: Review
and confirm borrower’s liquidity position adheres to Underwriting Guidelines. |
| ● | Credit / Background Check:
Review and confirm that each guarantor and/or owner of the borrowing entity's requirements meet Underwriting Guidelines, including
OFAC. |
| ● | Property management questionnaire:
Review the questionnaire to confirm management experience meets Underwriting Guidelines. |
| ● | Borrowing Entity: Confirm
the entity is in good standing and duly formed (if applicable documents are in the file). Verify the individual signing on behalf of the
organization has the authority to bind the entity (if applicable documents are in the file). |
| ● | Loan-to-Value (LTV)/Loan-to-Cost
(LTC) Limits: Confirm the LTV/LTC meets Underwriting Guidelines per Underwriting Guidelines. |
| ● | Permitted Loan Terms: Confirm
the loan terms are eligible per the Underwriting Guidelines. |
| ● | Property Requirements and
Market Requirements: Confirm the loan Property and Market Requirements are eligible per the Underwriting Guidelines. |
| ● | DSCR—ensure components
of Debt Service Coverage Ratio are identified correctly: Recalculation of DSCR |
Title Insurance Requirements are met per Guidelines
only as follows
| ● | Confirm Loss payee language
must be present and required insurance policies and coverage amounts meet the Underwriting Guidelines |
| ● | Condominium Eligibility:
Confirm Condo Master Policy is present and meets the Underwriting Guidelines |
| ● | Property Insurance: Confirm
each mortgaged property has a policy in place and proper coverage amount in adherence to the Underwriting Guidelines. |
| ● | Preliminary/Commitment Title:
Review and confirm first lien holder position, validate no loan file discrepancies, delinquent taxes, and/or additional liens at time
of consummation. |
Credit Document Check
| ● | Loan
Application: Verify the presence and completeness of both the initial and final loan applications. |
| ● | Credit
Report: Verify the presence of a credit report for each borrower. Confirm that the credit report was pulled within the timing requirements
allowable per the Client provided underwriting guidelines. |
| ● | Housing
Payment History: In the absence of housing payment histories on the borrower(s) credit report(s), verify that the file contains
a verification of rent or a verification of mortgage form. |
| ● | Letters
of Explanation: When Letters of Explanation are required by the Client provided underwriting guidelines, verify the presence of any such
letters exist in the loan file. |
| ● | Gift
Letters: When Gift Letters are required by the Client provided underwriting guidelines, verify the presence of any such letters exist
in the loan file. |
| ● | Asset
Documentation: Verify the presence of asset documentation required by the Client provided underwriting guidelines in the loan file. |
| ● | Property
Valuation Tools: Verify that each loan file contains adequate appraisal and other third-party valuation tools to satisfy the minimum
required documentation under the relative Client provided underwriting guidelines. |
| ● | Proof
of Insurance: Verify the presence of insurance certificates for mortgage, hazard and flood insurance on an as needed basis depending
upon the specifics of the loan. Confirm that adequate coverage is present to meet the requirements of the Client provided underwriting
guidelines. |
Document Review
A review of each loan file will be performed to confirm
the presence of material documentation as applicable to the specifics of the loan transaction. The Document Review will consist of the
following:
| ● | Title Commitment / Policy: Verify
the presence of the title commitment or final title policy. Confirm vested parties and the description of the property, liens and tax
assessments. |
| ● | Mortgage
Note / Security Instrument: Verify the presence of the mortgage note or security instrument. Confirm that the document has been executed
by all borrowers and that all riders, addendums and endorsements are present and duly executed. |
| ● | Mortgage
/ Deed of Trust: Verify the presence of a copy of the Mortgage or Deed of Trust. Confirm that the documents have |
| | been
executed by all required parties and that all riders, addendums and exhibits are present and duly executed. If the loan closed within
12 months of the review, Consultant will confirm the presence of a letter from the title company specifying the date the Mortgage / Deed
of Trust was sent for recording. If the closing did not occur within 12 months of the review and a copy of the recorded Mortgage /Deed
of Trust is not contained in the loan file, the Client will submit a report from an independent document custodian verifying the presence
of a recorded mortgage or a stamped / signed copy of the document stating the date the document was sent for recording. |
| ● | Conveyance
Deed: Verify as applicable that a proper conveyance deed is present in the loan file. Confirm the proper transfer of ownership interest
of the subject parties is detailed on the deed. |
| ● | Verifying
presence of a complete Certification of Non-Owner Occupancy. |
Compliance
| ● | State
and Local High Cost Mortgage regulations, including: |
| o | Cook County High Cost Ordinance |
| o | City of Chicago High Cost Ordinance |
| ● | Anti-predatory
lending laws, including: |
| o | Minnesota §58 on or after 8/1/2008 |
| o | Virginia Lender and Broker Act after 6/1/2008 |
Data
Compare
Client will provide a data tape with the following data fields and Consultant
will compare the field to the applicable source document and report any variance
| ● | Borrower Self-Employment Flag |
| ● | Primary Appraised Property Value |
| ● | Qualifying Housing Debt Income
Ratio |
| ● | Qualifying Interest Rate |
Rating
Agency Grading Criteria
Fitch Ratings Grading Criteria
Grading shall be provided for each exception, each
exception category and holistically for each loan. The methodology for the application of the RMBS grading as defined by Fitch in their
current industry publications as updated from time to time.
Moody’s Investor Services Grading Criteria
Grading shall be provided for each exception, each
exception category and holistically for each loan. The methodology for the application of the RMBS grading as defined by Moody’s
in their current industry publications as updated from time to time.
Kroll Bond Rating Agency LLC Grading Criteria
Grading shall be provided for each exception, each
exception category and holistically for each loan. The methodology for the application of the RMBS grading as defined by Kroll in their
current industry publications as updated from time to time.
S&P Global Ratings Grading Criteria
Grading shall be provided for each exception, each
exception category and holistically for each loan. The methodology for the application of the RMBS grading as defined by Standard &
Poor’s in their current industry publications and updated from time to time.
DBRS Morningstar Grading Criteria
Grading shall be provided for each exception, each
exception category and holistically for each loan. The methodology for the application of the RMBS grading as defined by DBRS in their
current industry publications and updated from time to time.
Opus Grading Criteria
Grading shall be provided for each exception, each exception category and
holistically for each loan. The following grading is not intended for securitization reviews and Opus will not issue a Rating Agency Narrative,
Reliance or Form ABS Due Diligence 15E if Client elects to utilize the following grading criteria. The methodology for the application
of grading is defined by Opus and updated from time to time shall be determined as follows:
Opus Credit Grades
| ● | Level 1 Credit Grade Definition: Loan was originated in
accordance with the mortgage loan originator underwriting guidelines without exception. |
| ● | Level 2 Credit Grade Definition: Loan was originated in
substantial compliance with the originator's underwriting guidelines and there are sufficient compensating factors for any exceptions. |
| ● | Level 3 Credit Grade Definition: Loan was not originated
in substantial compliance with the originator's underwriting guidelines and there are insufficient compensating factors for the exceptions
or is missing material documentation.
|
Opus Property Grades
| ● | Level 1 Property Grade Definition:
Property value appears to be within 10% of original appraised amount and there are no material deficiencies in the appraisal process. |
| ● | Level 2 Property Grade Definition:
Property value appears to be within 10% of original appraised amount, but minor issues in the appraisal process were identified. |
| ● | Level 3 Property Grade Definition:
Property value does not appear to fall within 10% of the original appraised value and/or material deficiencies exist with respect to the
appraisal process or the file is missing material documentation.
|
Opus Compliance Grades
| ● | Level 1 Compliance Grade Definition: Loan complies with
all applicable laws and regulations reviewed under the applicable scope of work. |
| ● | Level 2 Compliance Grade Definition: There are minor issues
regarding legal and/or regulatory compliance, but such issues do not represent risks to the enforceability of the borrower's obligation
under the loan documents and will not result in assignee liability to the investor. |
| ● | Level 3 Compliance Grade Definition: Loan is not in compliance
with laws and regulations reviewed under the applicable scope of work or the loan is missing material documentation. |
Pool Details
| Purpose |
| Type |
Count |
%
of Pool |
| Cash
out Refi |
17 |
19.32% |
| Purchase |
59 |
67.05% |
| Rate
/ Term Refi |
12 |
13.64% |
| Total |
88 |
100.00% |
| Property
Type |
| Type |
Count |
%
of Pool |
| Single
Family Detached |
48 |
54.55% |
| Co-op |
0 |
0.00% |
| Condo,
Low Rise |
3 |
3.41% |
| Condo,
High Rise |
1 |
1.14% |
| PUD |
17 |
19.32% |
| 1
Family Attached |
3 |
3.41% |
| 2
Family |
8 |
9.09% |
| 3
Family |
2 |
2.27% |
| 4
Family |
6 |
6.82% |
| Total |
88 |
100.00% |
| Occupancy |
| Type |
Count |
%
of Pool |
| Primary
Residence |
32 |
36.36% |
| Second
Home |
3 |
3.41% |
| Investment
Property |
53 |
60.23% |
| Total |
88 |
100.00% |
| Product
Type |
| Type |
Count |
%
of Pool |
| Fixed |
88 |
100.00% |
| ARM |
0 |
0.00% |
| Total |
88 |
100.00% |
Tape Discrepancies
| Data
Element |
Count |
Accuracy |
| Borrower
1 Last Name |
1 |
98.86% |
| Borrower
2 Self-Employment Flag |
7 |
92.05% |
| Interest
Only Flag |
3 |
96.59% |
| Primary
Appraised Property Value |
2 |
97.73% |
| Property
Type |
1 |
98.86% |
| Qualifying
CLTV |
11 |
87.50% |
| Qualifying
Loan Amount |
1 |
98.86% |
| Qualifying
LTV |
11 |
87.50% |
| Qualifying
Total Debt Income Ratio |
18 |
79.55% |
| Total
Number of Loans |
88 |
|
Multiple Loans to One Borrower: TPR firm reviewed common
identifiers for all loans in the population and confirmed there was six (6) obligors with multiple loans in the pool.
Property Inspection Waivers: No loans had a Property Inspection
Waiver.
Loan Grading Definitions
Credit
| S&P |
Moody’s |
Fitch |
Kroll |
DBRS |
Definition |
| A |
A |
A |
A |
A |
Loan
conforms to all applicable guidelines, no conditions noted |
| B |
B |
B |
B |
B |
Loan
does not meet every applicable credit guideline. However, most of the loan characteristics are within the guidelines and
there are documented and significant compensating factors |
| C |
C |
C |
C |
C |
The
loan does not meet every applicable credit guideline, and most of the loan characteristics are outside of guidelines; or there are
weak or no compensating factors |
| D |
D |
D |
D |
D |
The
loan file is missing critical documentation required to perform the review |
Compliance
| S&P |
Moody’s |
Kroll |
DBRS |
Definition |
| A |
A |
A |
A |
The
loan was originated in compliance with applicable federal, state, and local predatory and high cost, TILA, and Regulation Z laws
and regulations |
| B |
B |
B |
B |
The
loan was originated in compliance with applicable federal, state, and local predatory and high cost, TILA, and Regulation Z laws
and regulations; however, minor evidentiary issue(s) exist |
| C |
C |
C |
C |
The
loan includes material violation(s) with applicable federal, state, and local predatory and high cost, TILA, and Regulation Z laws
and regulations |
| D |
D |
D |
D |
The
loan file is missing critical documentation required to perform the review |
| Fitch |
Definition |
| A |
The
loan was originated in compliance with applicable federal, state, and local predatory and high cost, TILA, and Regulation Z laws
and regulations |
| B |
The
loan is in compliance with all applicable laws and regulations and a benefit to the borrower is present and documented |
| C |
The
loan includes material violation(s) with applicable federal, state, and local predatory and high cost, TILA, and Regulation Z laws
and regulations |
| D |
The
loan file is missing critical documentation required to perform the review |
Property Valuation
| Moody’s |
Fitch |
Kroll |
DBRS |
Definition |
| A |
A |
A |
A |
Value
is within a 10% variance of third party product. Appraisal meets lender guidelines. Subject property is 100% complete. Property condition
is average or better. Standard GSE form was utilized. Appraiser is licensed. Appraisal is complete. |
| B |
B |
B |
B |
Meets
all terms for an A, but property requires cosmetic or minor repairs that do not affect value or habitability |
| C |
C |
C |
C |
Any
of the following items: Origination value and third party valuation product value has a variance of 10% or greater, cannot validate
value, property is incomplete, property condition is less than average, GSE form was not utilized, and/or the appraisal and/or does
not meet guidelines |
| D |
D |
D |
D |
The
loan file was missing the appraisal and/or other valuations products needed to complete the review |
| S&P |
Definition |
| A |
First
Level Review Value is within a 10% variance to the original appraisal. Appraisal meets lender guidelines. Subject property is 100%
complete. Property condition is average or better. Standard GSE form was utilized. Appraiser is licensed. Appraisal is complete. |
| B |
First
Level Review Value is greater than a 10% variance to the original appraisal but the second level review value is within 10% variance
of the original appraised value. In addition, property requires cosmetic or minor repairs that do not affect value or habitability |
| C |
Any
of the following items: Second Level Review Value is greater than a 10% variance to the original appraisal, cannot validate value,
property is incomplete, property condition is less than average, GSE form was not utilized, and/or the appraisal and/or does not
meet guidelines |
| D |
The
loan file was missing the appraisal and/or other valuations products needed to complete the review |
Loan Review Findings
The following summarizes Consultant’s final
loan securitization and event grades assigned to the final reviewed loan pool and reported in the Agency Grading Report dated September
10, 2026.
Overall
Grade Summary
| Kroll NRSRO Grade |
#
of Loans |
%
of Loans |
| A |
86 |
97.79% |
| B |
2 |
2.27% |
| C |
0 |
0.00% |
| D |
0 |
0.00% |
Compliance
Grade Summary
| Kroll NRSRO Grade |
#
of Loans |
%
of Loans |
| A |
87 |
98.86% |
| B |
1 |
1.14% |
| C |
0 |
0.00% |
| D |
0 |
0.00% |
Credit
Grade Summary
| Kroll NRSRO Grade |
#
of Loans |
%
of Loans |
| A |
87 |
98.86% |
| B |
1 |
1.14% |
| C |
0 |
0.00% |
| D |
0 |
0.00% |
Property
Grade Summary
| Kroll NRSRO Grade |
#
of Loans |
%
of Loans |
| A |
88 |
100.00% |
| B |
0 |
0.00% |
| C |
0 |
0.00% |
| D |
0 |
0.00% |
Overall
Grade Summary
| S&P
NRSRO Grade |
#
of Loans |
%
of Loans |
| A |
81 |
92.05% |
| B |
7 |
7.95% |
| C |
0 |
0.00% |
| D |
0 |
0.00% |
Compliance
Grade Summary
| S&P
NRSRO Grade |
#
of Loans |
%
of Loans |
| A |
87 |
98.86% |
| B |
1 |
1.14% |
| C |
0 |
0.00% |
| D |
0 |
0.00% |
Credit
Grade Summary
| S&P
NRSRO Grade |
#
of Loans |
%
of Loans |
| A |
87 |
98.86% |
| B |
1 |
1.14% |
| C |
0 |
0.00% |
| D |
0 |
0.00% |
Property
Grade Summary
| S&P
NRSRO Grade |
#
of Loans |
%
of Loans |
| A |
83 |
94.32% |
| B |
5 |
5.68% |
| C |
0 |
0.00% |
| D |
0 |
0.00% |
Loans Reviewed
(88 Loans)
| 1000649611 |
1000668643 |
1000668645 |
1000668647 |
| 1000668649 |
1000668651 |
1000668653 |
1000668655 |
| 1000668657 |
1000668659 |
1000668661 |
1000668663 |
| 1000668665 |
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If you have any questions, please contact Uriah Clavier
at Uriah.Clavier@opuscmc.com