SALUDA GRADE MORTGAGE FUNDING LLC ABS-15G
Exhibit 99.5
EXECUTIVE
SUMMARY
TABLE
OF CONTENTS
Contents
| I.
Overview |
2 |
| II.
Due Diligence Review |
2 |
| A. Credit
Review |
2 |
| B. Valuation
Review |
2 |
| C. Compliance
Review |
3 |
| 1) Truth
In Lending Act - 12 CFR §1026 (“TILA”) |
3 |
| 2) Real
Estate Settlement Procedures Act – 12 CFR §1024 (“RESPA”) |
10 |
| 3) Equal
Credit Opportunity Act – 12 CFR §1002 (“ECOA”) |
10 |
| III.
Client Data Tape |
11 |
| IV.
Loan Products |
12 |
| V.
Summary of Ratings for all credit agencies |
12 |
| VI.
Tape Integrity Review Summary |
16 |
| VII.
Additional Loan Population Summary |
16 |
| VIII.
Diligence Reports Summary |
18 |

I.
Overview
Visionet
performed a Due Diligence review of Non-Agency Mortgage loans originated by numerous lenders and obtained by our client. The review
was conducted between June 2023 and August 2026 and covered loans originated between April 2023 through July 2026.
Visionet
followed the Nationally Recognized Statistical Rating Organizations (NRSRO) criteria while reviewing the loans. The population
consists of a sample of 214 loans with an aggregate principal balance of $24,132,712.
Each
loan was re-underwritten as per applicable client guidelines, a regulatory compliance review was performed through compliance
ease, where all the required tests were compliant with TRID and the Risk Indicator showing acceptable results. In addition to
this, data tape was compared with the images of loan files to ascertain accuracy and completeness.
II.
Due DILIGENCE REVIEW
Visionet
performed a re-underwriting review of loans to verify compliance with the applicable Guidelines that was in effect at the time
of Loan origination and ensured that the characteristics used by the underwriter are supported by the file documentation provided
and that any Loans outside of those Guidelines contain legitimate and approved exceptions with compensating factors. The credit
review included
| i. | Credit
Report (Credit scores, Liabilities, public records etc.,) |
| iv. | Employment,
Income and Assets |
| v. | Title,
Hazard, and Flood |
Visionet
performed a review of the property appraisal provided by the Client in connection with the Loans to do the following:
| i. | Determine
whether the appraised value is supported at or within a 10% variance based on an AVM
Report or other third-party valuation product. |
| ii. | Determine
whether the property meets Client-supplied eligibility requirements. |
| iii. | Determine
whether the appraisal is made on an “As Is” basis or provides satisfactory
evidence of completion |
| iv. | Review
appraisal data for consistency with the Loan file documentation |
| v. | Validate
that zoning is acceptable as per Guidelines |
Visionet
reviewed each Loan to determine, as applicable, to the extent possible and subject to the caveats below, whether the Loan complies
with the applicable Federal, State, and local regulatory requirements as noted below, each as amended, restated and/or replaced
from time to time.
| 1) | Truth
In Lending Act - 12 CFR §1026 (“TILA”) |
| a. | Finance
Charge Test (12 CFR §1026.18(d)(1) |
| i. | It
is understated by no more than $100; or |
| ii. | It
is greater than the amount required to be disclosed |
| b. | Rescission
Finance Charge Test (12 CFR §1026.23(h)(2)i) |
| i. | It
is understated by no more than $35; or |
| ii. | It
is greater than the amount required to be disclosed |
| iii. | Rescission
Total of Payments Test (12 CFR §1026.23(h)(2)(ii) |
| iv. | Is
understated by no more than $35; or |
| v. | Is
greater than the amount required to be disclosed |
| c. | Foreclosure
Rescission Finance Charge and Total of Payments Tests(12 CFR §1026.23(h) |
| d. | APR
Test 12 CFR §1026.22(a)(2), (4) |
| i. | The
disclosed annual percentage rate (APR) is considered accurate because it is not more
than 1/8 of 1 percentage (for regular transactions) or 1/4 of 1 percentage (for irregular
transactions) point above or below the APR as determined in accordance with the actuarial
method; or |
| ii. | The
disclosed APR results from the disclosed finance charge, and the disclosed finance charge
is considered accurate under §1026.18(d)(1) (the finance charge test), or for purposes
of rescission the disclosed finance charge is considered accurate under §1026.23(g)
or (h) (the rescission finance charge test or the foreclosure rescission finance charge
test), whichever applies |
e. Right
of Rescission Test (12 CFR §1026.23(a)(3), §1026.15(a)(3),
| i. | The
funding date is not before the third business day following consummation |
| ii. | The
consumer may exercise the right to rescind until midnight of the third business day following
consummation |
| iii. | Validate
Right of Rescission Notice was provided and provides the correct date for ability to
cancel |
| f. | Dual
Broker Compensation Test (12 CFR §1026.36(d)(2) |
| i. | If
any loan originator receives compensation directly from a consumer in a consumer credit
transaction secured by a dwelling, no loan originator shall receive compensation, directly
or indirectly, from any other person other than the consumer in connection with the transaction
for loan origination activities |
| g. | Loan
Originator Credits Test (12 C.F.R. §1026.36(d)(1)) |
| i. | Test
that the initial disclosure (GFE/TIL/LE) does not contain any broker fees paid by the
broker |
| h. | Financing
of Single Premium Credit Insurance Test (12 CFR §1026.36 (i)) |
| i. | A
creditor may not finance, directly or indirectly, any premiums or fees for credit insurance
in connection with a consumer credit transaction secured by a dwelling (including a home
equity line of credit secured by the consumer’s principal dwelling |
| 2. | Initial
TIL Disclosure (Pre-TRID) |
| a. | Initial
TIL Disclosure Date Test (12 CFR §1026.17(b),1026.19(a) |
| i. | The
loan is a mortgage transaction subject to the Real Estate Settlement Procedures Act (12
U.S.C. §2601 et seq.) that is secured by the consumer’s dwelling; and |
| ii. | The
initial TIL disclosure date is not later than the third business day (counting days on
which the creditor’s offices are open to the public for carrying on substantially
all of its business functions) after the creditor receives the consumer’s written
application; and |
| iii. | The
initial TIL disclosure date is not later than the seventh business day (counting all
calendar days except Sunday and specified legal public holidays) before consummation
of the transaction, or the application date of the loan is before July 30, 2009; and |
| iv. | The
loan is a “residential mortgage transaction” subject to the Real Estate Settlement
Procedures Act (12 U.S.C. §2601 et seq.); and |
| v. | The
initial TIL disclosure date is before consummation or three business days after the creditor
receives the consumer’s written application, whichever is earlier |
| 3. | TILA
RESPA Integrated Disclosures (TRID) |
| a. | Initial
Loan Estimate Delivery Date Test (from application) (12 CFR §1026.19(e)(1)(iii)(A)) |
| i. | The
creditor shall deliver or place in the mail the disclosures required under §1026.19(e)(1)(i)
(provision of loan estimate form) not later than the third business day after the creditor
receives the consumer’s application |
| b. | Initial
Loan Estimate Delivery Date Test (prior to consummation) (12 CFR §1026.19(e)(1)(iii)(B)) |
| i. | The
creditor shall deliver or place in the mail the disclosures required under §1026.19(e)(1)(e)(1)(i)
(provision of loan estimate form) not later than the seventh business day before consummation
of the transaction |
| c. | Written
List of Service Providers (SSPL) Disclosure Date Test (12 CFR §1026.19(e)(1)(vi)) |
| i. | If
the consumer is permitted to shop for a settlement service, the creditor shall provide
the consumer with a written list identifying available providers of that settlement service
and stating that the consumer may choose a different provider for that service. The creditor
must identify at least one available provider for each settlement service for which the
consumer is permitted to shop. The creditor shall provide this written list of settlement
service providers separately from the disclosures required by
§1026.19(e)(1)(e)(1)(i) but in accordance with the timing requirements in §1026.19(e)(1)(e)(1)(iii) |
| d. | Your
Home Loan Toolkit (§1026.19) |
| i. | Verify
there is evidence that the disclosure was provided to the borrower |
| ii. | Validate
Your Home Loan Toolkit was delivered or placed in the mail not later than three (3) business
days after receipt of application |
| e. | Borrowers
Intent to Proceed (§1026.19); (§1026.25) |
| i. | Verify
there is evidence in the file indicating the borrowers intent to proceed |
| ii. | If
the lender documents the borrowers intent to proceed on a standalone disclosure, validate
the borrower signed and dated the disclosure |
| f. | Revised
Loan Estimate Delivery Date Test (prior to consummation) (12 CFR §1026.19(e)(4)(ii)) |
| i. | The
creditor shall not provide a revised version of the disclosures required under §1026.19(e)(1)(i)
on or after the date on which the creditor provides the disclosures required under §1026.19(f)(1)(i).
The consumer must receive a revised version of the disclosures required under §1026.19(e)(1)(i)
not later than four business days prior to consummation. If the revised version of the
disclosures required §1026.19(e)(1)(i)
is not provided to the consumer in person, the consumer is considered to have received such version three business days after
the creditor delivers or places such version in the mail |
| g. | Valid
Change of Circumstances Test |
| i. | The
changed circumstance(s) form was provided and the reason for re- disclosure is: |
| a. | Changed
circumstance affecting settlement charges; or |
| b. | Changed
circumstance affecting eligibility; or |
| c. | Revisions
requested by the consumer; or |
| d. | Expiration
of initial loan estimate; or |
| e. | Delayed
settlement date on a construction loan for new construction transactions only; or |
| f. | The
date the rate was set was not provided and Interest rate dependent charges change once
the interest rate is locked;” or |
| g. | The
reason for re-disclosure is “Decrease in charges affecting settlement or eligibility,
a consumer-requested revision, or other non-tolerance-related re-disclosure;” or |
| h. | The
initial loan estimate was not delivered timely |
| h. | Initial
Closing Disclosure Delivery Date Test (12 CFR §1026.19(f)(1)(ii)) |
| i. | The
creditor shall ensure that the consumer receives the disclosures required under paragraph
§1026.19(f)(1)(i) no later than three business days before consummation |
| i. | Revised
Closing Disclosure Delivery Date Test (waiting period vs. no waiting period required)
(12 CFR §1026.19(f)(2)(i) & (ii)) |
| i. | If
the disclosures provided under §1026.19(f)(1)(i) become inaccurate before consummation,
the creditor shall provide corrected disclosures reflecting any changed terms to the
consumer so that the consumer receives the corrected disclosures at or before consummation |
| ii. | If
the consumer determines that the extension of credit is needed to meet a bona fide personal
financial emergency, the consumer may modify or waive the three-business-day waiting
period for the revised closing disclosure after receiving the disclosures |
| j. | TRID
Tolerance Testing - Charges That Cannot Increase Test (12 CFR §1026.19(e)(3)(i)) |
| i. | An
estimated closing cost disclosed pursuant to §1026.19(e) is in good faith if the
charge paid by or imposed on the consumer does not exceed the amount originally disclosed
under §1026.19(e)(1)(i) |
| k. | TRID
Tolerance Testing - Charges That in Total Cannot Increase More Than 10% Test (12 CFR
§1026.19(e)(3)(ii)) |
| i. | The
aggregate amount of charges for third-party services and recording fees paid by or imposed
on the consumer does not exceed the aggregate amount of such charges disclosed under
§1026.19(e)(1)(i) by more than 10 percent |
| l. | TRID
Tolerance Testing - Lender Credits That Cannot Decrease Test (12 CFR §1026.19(e)(3)(i)) |
| i. | An
estimated closing cost disclosed pursuant to §1026.19(e) is in good faith if the
charge paid by or imposed on the consumer does not exceed the amount originally disclosed
under §1026.19(e)(1)(i) |
| m. | TRID
Reimbursement Amount Test (12 CFR §1026.19(f)(2)(v)) |
| i. | Refunds
related to the good faith analysis. If amounts paid by the consumer exceed the amounts
specified under §1026.19(e)(3)(i) or (ii), the creditor complies with §1026.19(e)(1)(i)
if the creditor refunds the excess to the consumer no later than 60 days after consummation |
| n. | TRID
Reimbursement Date Test (12 CFR §1026.19(f)(2)(v)) |
| i. | Refunds
related to the good faith analysis. If amounts paid by the consumer exceed the amounts
specified under §1026.19(e)(3)(i) or (ii), the creditor complies with §1026.19(e)(1)(i)
if the creditor refunds the excess to the consumer no later than 60 days after consummation |
| o. | Disclosure
of Escrow Account (§1026.38(l)(7) |
| i. | If
the loan indicates an escrow account will be established |
| a. | Verify
all amounts disclosed in the Projected Payments Table are accurate (§1026.38) (c);
(§1026.37(c) |
| b. | Verify
all amounts disclosed in the Estimated Taxes, Insurance and Assessments (ETIA) are accurate
(§1026.37(c)(4),(5) |
| c. | Verify
all amounts disclosed in Section G – Initial Escrow Payment and Closing are accurate
(§1026.37(g)(3) |
| d. | Verify
all amounts disclosed in the Escrow Account Section are accurate (§1026.38(l)(7) |
| ii. | If
the loan indicates an escrow account will not be established |
| a. | Verify
all amounts disclosed in the Projected Payments Table are accurate (§1026.38(c);
(§1026.37(c) |
| b. | Verify
all amounts disclosed in the Estimated Taxes, Insurance and Assessments (ETIA) are accurate
(§1026.37(c)(4), (5) |
| c. | Verify
all amounts disclosed in the Escrow Account Section are accurate (§1026.38(l)(7) |
| p. | Disclosure
of Seller Paid Closing Costs (§1026.38(t)(5)(v)(B) |
| i. | In
transactions involving a seller, validate whether the lender disclosed all costs being
paid by the seller on the borrowers Closing Disclosure |
| ii. | If
seller paid fees are present on the borrower’s Closing Disclosure, review the seller’s
Closing Disclosure or alternative documentation for accuracy of disclosure |
| q. | Post-consummation
Event and Revised Closing Disclosure Delivery Date Test |
| i. | The
post-consummation revised closing disclosure delivery date is not more than 60 calendar
days after the consummation date, or closing / settlement date if no consummation date
was provided and |
| ii. | The
provided reimbursement date is not more than 60 calendar days after the consummation
date, or closing / settlement date if no consummation date was provided |
| r. | Non-numeric
Clerical Error and Post-consummation Revised Closing Disclosure Delivery Date Test (12
CFR §1026.19(f)(2)(iv)) |
| i. | A
creditor does not violate §1026.19(f)(1)(i) if the disclosures provided under §1026.19(f)(1)(i)
contain non-numeric clerical errors, provided the creditor delivers or places in the
mail corrected disclosures no later than 60 days after consummation |
| s. | Loan
Calculation Test on the Closing Disclosure (12 CFR §1026.38) |
| iv. | Total
Interest Percentage |
| 4. | Qualified
Mortgage / Ability To Repay – Dodd Frank |
| a. | Classification
of QM designated loan |
| i. | Validate
whether the mortgage loan is a Safe Harbor QM or Higher Priced QM by comparing the mortgage
loan’s actual annual percentage rate, as recalculated, to the applicable average
prime offer rate plus a certain applicable percentage |
| ii. | Determination
of conformity thresholds (Safe Harbor or Rebuttable Presumption |
| b. | Negative
Amortization Loan (12 CFR 1026.43(e)(2)(i)(A)) |
| i. | A
qualified mortgage is a covered transaction that provides for regular periodic payments
that are substantially equal, except for the effect that any interest rate change after
consummation has on the payment in the case
of an adjustable-rate or step-rate mortgage, that does not result in an increase of the principal balance |
| c. | Interest
Only Loan (12 CFR 1026.43(e)(2)(i)(B)) |
| i. | A
qualified mortgage is a covered transaction that provides for regular periodic payments
that are substantially equal, except for the effect that any interest rate change after
consummation has on the payment in the case of an adjustable-rate or step-rate mortgage,
that does not allow the consumer to defer repayment of principal |
| d. | Balloon
Payment Loan (12 CFR 1026.43(e)(2)(i)(C)) |
| i. | A
qualified mortgage is a covered transaction that provides regular periodic payments that
are substantially equal, except for the effect that any interest rate change after consummation
has on the payment in the case of an adjustable-rate or step-rate mortgage, that does
not result in a balloon payment |
| e. | Loan
Term (12 CFR 1026.43(e)(2)(iii)) |
| i. | A
qualified mortgage is a covered transaction for which the loan term does not exceed 30 years |
| f. | Points
and Fees (12 CFR §1026.43(e)(3)) |
| i. | Points
and fees do not exceed the qualified mortgage points and fees threshold |
| g. | DTI
(12 CFR §1026.43(e)(2)(vi)) |
| i. | The
ratio of the consumer’s total monthly debt to total monthly income at the time of consummation does not exceed 43 percent,
calculated in accordance with Appendix Q |
| h. | Prepayment
Penalty (12 CFR 1026.43(g)) |
| i. | A
covered transaction must not include a prepayment penalty unless: |
| a. | The
prepayment penalty is otherwise permitted by law; and the transaction: |
| b. | Has
an annual percentage rate that cannot increase after consummation. |
| c. | Is
a qualified mortgage under paragraph (e)(2), (e)(4), or (f) of this section; and |
| d. | Is
not a Higher Priced Mortgage Loan, as defined in § 1026.35(a) |
| 5. | Home
Ownership and Equity Protection Act – HOEPA (Sections 32) |
| a. | Federal
HOEPA coverage (12 CFR §1026.32(a)(1)(i), (ii) |
| i. | Tests
that the loan is/is not secured by the consumer’s principal dwelling; or |
| ii. | Tests
that the loan is/ is not an open-end credit plan; or |
| iii. | That
the application date of the loan occurs before/ after the effective date of October 1,
1995; or |
| iv. | That
the date the creditor received application occurs on or after January 10, 2014, the effective
date of the High-Cost Mortgage amendments |
| b. | High-Cost
Mortgage APR threshold test (12 CFR §1026.32(a)(1)(i)(A), (C)) |
| i. | The
loan is secured by a first-lien transaction, and the annual percentage rate (APR) does
not exceed the Average Prime Offer Rate by more than 6.5%; or |
| ii. | The
loan is a subordinate-lien transaction, and the annual percentage rate (APR), does not
exceed the Average Prime Offer Rate by more than 8.5% |
| c. | High-Cost
Mortgage Points and Fees Threshold Test (12 CFR §1026.32(a)(1)(ii)(A),
(B)) |
| i. | The
total points and fees does not exceed allowable limits per the given loan amount |
| d. | High-Cost
Mortgage Prepayment Penalty Threshold Test (12 CFR §1026.32(a)(1)(iii)) |
| i. | The
loan contract or open-end credit agreement does not allow the creditor to charge: |
| a. | A
prepayment penalty of more than 36 months after consummation or account opening; or |
| b. | Prepayment
penalties that can exceed, in total, more than 2 percent of the amount prepaid |
| e. | High-Cost
Mortgage (12 CFR §1026.32(a)(1)) |
| f. | High-Cost
Mortgage Repayment Ability Test (12 CFR §1026.34(a)(4), 1026.43) |
| g. | Other
high costs tests pursuant to (12 CFR §1026.32(a)(1)) |
| iii. | Negative
amortization |
| viii. | Financing
of points and fees |
| 6. | Higher
Priced Mortgage Loan – HMPL (section 35) |
| a. | Higher
Priced Mortgage Loan test (12 CFR §1026.35(a)(1)) |
| b. | Higher
Priced Mortgage Loan required escrow account test (12 CFR §1026.35(a)(1),
(b)(2)(i)(A)) |
| c. | Higher
Priced Mortgage Loan prepayment term test |
| d. | Higher
Priced Mortgage Loan escrow account test (12 CFR §1026.35(a)) |
| 7. | Prohibited
Acts – Brokers Comp |
| a. | Broker
Compensation Test (12 CFR §1026.36(d)(2) |
| i. | If
any loan originator receives compensation directly from a consumer in a consumer credit
transaction secured by a dwelling: |
| a. | No
loan originator shall receive compensation, directly or indirectly, from any person other
than the consumer in connection with the transaction; and |
| b. | No
person who knows or has reason to know of the consumer- paid compensation to the loan
originator (other than the consumer)
shall pay any compensation to a loan originator, directly or indirectly, in connection with the transaction |
| 8. | Nationwide
Mortgage Licensing System (NMLS) Tests (12 CFR §1026.36) |
| a. | review
for presence of mortgage loan originator organization and individual mortgage loan originator
name and NMLSR ID, as applicable, on the credit application, note or mortgage loan contract,
security instrument, Loan Estimate and Closing Disclosure; and |
| b. | verify
the data against the NMLSR database, as available |
| 2) | Real
Estate Settlement Procedures Act – 12 CFR §1024 (“RESPA”) |
| a. | Homeownership
Counseling Organizations Disclosure Date Test (12 CFR §1024.20(a)) |
| i. | Not
later than three business days after a lender, mortgage broker, or dealer receives an
application, or information sufficient to complete an application, the lender must provide
the loan applicant with a clear and conspicuous written list of homeownership counseling
organizations that provide relevant counseling services in the loan applicant’s
location |
| ii. | The
list of homeownership counseling organizations distributed to each loan applicant under
this section shall be obtained no earlier than 30 days prior to the time when the list
is provided to the loan applicant |
| a. | Good
Faith Estimate Disclosure Test (12 CFR §1024.7) |
| i. | Not
later than 3 business days after a loan originator (broker or lender) receives an application
for a federally related mortgage loan, or information sufficient to complete an application,
the loan originator must provide the applicant with a GFE |
| b. | Good
Faith Estimate Disallowed Credit and Charge test (GFE Block 2) |
| i. | Looks
for any amounts entered for both a loan discount fee and a yield spread premium or a
lender credit |
| ii. | Only
one charge or one credit affecting the interest rate is allowed under the new RESPA regulations |
| 3) | Equal
Credit Opportunity Act – 12 CFR §1002 (“ECOA”) |
| 1. | ECOA
Valuation Rule (12 CFR §1002.14(a)(1)) |
| a. | Review
all applicable loans for the Disclosure of Right to Receive a Copy of Appraisals. Validate
if the customer(s) waived their right to receive copies of their appraisals three business
days prior to consummation/account opening |
| b. | Review
all applicable loans for proof that lender delivered copies of appraisals and other written
valuations three business days before consummation (closed end), or account opening (open-end) |
| c. | If
the customer(s) waived their right to receive copies of their appraisals three business
days prior to consummation/account opening, review the post-Closing submission for an
Acknowledgment of Receipt of Appraisal Report, or other
proof that the lender provided provides the copies either at, or prior to, consummation or account opening |
| d. | State
Specific tests (varies by state and applicability, by at a minimum includes: |
| i. | Consumer
/ Home Loan tests |
| iii. | Higher
Priced Mortgage Loan tests |
| v. | Points
and fees threshold tests |
| vii. | Negative
Amortization tests |
III.
Client Data Tape
For
One hundred forty-three (143) mortgage loans, Visionet compared data fields on the data tape provided by Client to the data found
in the actual file as captured by Visionet. This comparison, when data was available, included the following data fields:
| 1003
Application Date |
First
Payment Date |
Originator
DTI |
| Borrower
Citizenship |
Interest
Only Term |
Originator
Front End DTI |
| Borrower
First Name |
Interest
Rate |
Property
Type |
| Borrower
Last Name |
Lien
Position |
Property
Zip Code |
| Borrower
Self-Employment Flag |
Loan
Amount |
Property
Address |
| Borrower
Sex - Female |
Loan
Type |
Property
City |
| Borrower
Sex - Male |
Loan
Program |
Property
State |
| Co-Borrower
First Name |
LTV |
Qualifying
FICO |
| Co-Borrower
Last Name |
Margin |
Sales
Price |
| Co-Borrower
SSN |
Maturity
Date |
Closing/Settlement
Date |
| Borrower
SSN |
Borrower
Birth Date |
DTI |
| Channel |
Note
Date |
Property
Value |
| CLTV |
Number
of Units |
Original
Term |
IV.
Loan Products
Below
is the break-up of Loan products that were delivered to Client by Visionet:
| Loan
Products |
Loan
Count |
Percentage |
| HELOC |
214 |
100% |
| Total |
214 |
100% |
V.
Summary of Ratings for all credit agencies
Initial
Overall Results:
| |
Initial
Grade Results - Overall |
| |
DBRS |
Kroll |
S&P |
Fitch |
Moody |
% |
| A |
157 |
157 |
157 |
157 |
157 |
73.36% |
| B |
0 |
0 |
0 |
0 |
0 |
0.00% |
| C |
51 |
51 |
51 |
51 |
51 |
23.83% |
| D |
6 |
6 |
6 |
6 |
6 |
2.80% |
Final
Overall Results:
| |
Final
Grade Results - Overall |
| |
DBRS |
Kroll |
S&P |
Fitch |
Moody |
% |
| A |
212 |
212 |
212 |
212 |
212 |
99.07% |
| B |
2 |
2 |
2 |
2 |
2 |
0.93% |
| C |
0 |
0 |
0 |
0 |
0 |
0.00% |
| D |
0 |
0 |
0 |
0 |
0 |
0.00% |
Initial
Grade Results - CREDIT
| |
Initial
Grade Results - Credit |
| |
DBRS |
Kroll |
S&P |
Fitch |
Moody |
% |
| A |
166 |
166 |
166 |
166 |
166 |
77.57% |
| B |
0 |
0 |
0 |
0 |
0 |
0.00% |
| C |
46 |
46 |
46 |
46 |
46 |
21.50% |
| D |
2 |
2 |
2 |
2 |
2 |
0.93% |
Initial
Grade Results - PROPERTY
| |
Initial
Grade Results - Property |
| |
DBRS |
Kroll |
S&P |
Fitch |
Moody |
% |
| A |
129 |
207 |
207 |
207 |
207 |
60.28% |
| B |
0 |
0 |
0 |
0 |
0 |
0.00% |
| C |
4 |
7 |
7 |
7 |
7 |
1.87% |
| D |
0 |
0 |
0 |
0 |
0 |
0.00% |
| N/A |
81 |
0 |
0 |
0 |
0 |
37.85% |
Initial
Grade Results - COMPLIANCE
| |
Initial
Grade Results - Compliance |
| |
DBRS |
Kroll |
S&P |
Fitch |
Moody |
% |
| A |
177 |
177 |
177 |
177 |
177 |
82.71% |
| B |
32 |
32 |
32 |
32 |
32 |
14.95% |
| C |
0 |
0 |
0 |
0 |
0 |
0.00% |
| D |
5 |
5 |
5 |
5 |
5 |
2.34% |
Final
Grade Results – CREDIT
| |
Final
Grade Results - Credit |
| |
DBRS |
Kroll |
S&P |
Fitch |
Moody |
% |
| A |
214 |
214 |
214 |
214 |
214 |
100.00% |
| B |
0 |
0 |
0 |
0 |
0 |
0.00% |
| C |
0 |
0 |
0 |
0 |
0 |
0.00% |
| D |
0 |
0 |
0 |
0 |
0 |
0.00% |
Final
Grade Results – PROPERTY
| |
Final
Grade Results – Property |
| |
DBRS |
Kroll |
S&P |
Fitch |
Moody |
% |
| A |
133 |
214 |
214 |
214 |
214 |
62.15% |
| B |
0 |
0 |
0 |
0 |
0 |
0.00% |
| C |
0 |
0 |
0 |
0 |
0 |
0.00% |
| D |
0 |
0 |
0 |
0 |
0 |
0.00% |
| N/A |
81 |
0 |
0 |
0 |
0 |
37.85% |
Final
Grade Results – COMPLIANCE
| |
Final
Grade Results - Compliance |
| |
DBRS |
Kroll |
S&P |
Fitch |
Moody |
% |
| A |
212 |
212 |
212 |
212 |
212 |
99.07% |
| B |
2 |
2 |
2 |
2 |
2 |
0.93% |
| C |
0 |
0 |
0 |
0 |
0 |
0.00% |
| D |
0 |
0 |
0 |
0 |
0 |
0.00% |
Event
Grade Definitions
| Final
Loan Grades |
| A |
Loan
meets Credit, Compliance, and Valuation Guidelines |
| B |
The
loan substantially meets published Client/Seller guidelines and/or eligibility in the validation of income, assets, or credit,
is in material compliance with all applicable laws and regulations, and the value and valuation methodology is supported and
substantially meets published guidelines. |
| C |
The
loan does not meet the published guidelines and/or violates one material law or regulation, and/or the value and valuation
methodology is not supported or did not meet published guidelines. |
| D |
Loan
is missing documentation to perform a sufficient review. |
| Credit
Event Grades |
| A |
The
loan meets the published guidelines without any exceptions. Employment, income, assets and occupancy are supported and justifiable.
The borrower’s willingness and ability to repay the loan is documented and reasonable. |
| B |
The
loan substantially meets the published guidelines, but reasonable compensating factors were considered and documented for
exceeding published guidelines. Employment, income, assets and occupancy are supported and justifiable. The borrower’s
willingness and ability to repay the loan is documented and reasonable. |
| C |
The
loan does not substantially meet the published guidelines. There are not sufficient compensating factors that justify exceeding
the guidelines published. Employment, income, assets or occupancy are not supported and justifiable. The borrower’s
willingness and ability to repay the loan were not documented or are unreasonable. |
| D |
There
was not sufficient documentation to perform a review, or the credit file was not furnished. |
| Compliance
Event Grades |
| A |
The
loan 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. |
VI.
Tape Integrity Review Summary
Of
the Two Hundred and Fourteen (214) mortgage loans reviewed, Twelve (12) mortgage loans had tape discrepancies across Three (3)
unique data fields.
| Field
Label |
#
Variances |
#
Loans |
%
of Loans |
| ApplicationDate |
2 |
214 |
0.93% |
| Borrower1
Self-Employment Flag |
3 |
214 |
1.40% |
| DTI |
7 |
214 |
3.27% |
VII.
Additional Loan Population Summary
| Amortization
Type |
#
Loans |
%
of Loans |
| ARM |
214 |
100% |
| Total |
214 |
100% |
| |
|
|
| Lien
Position |
#
Loans |
%
of Loans |
| 1 |
10 |
4.67% |
| 2 |
204 |
95.33% |
| Total |
214 |
100% |
| Original
Amortization Term |
#
Loans |
%
of Loans |
| 60
Months |
0 |
0.00% |
| 120
Months |
32 |
14.95% |
| 240
Months |
182 |
85.05% |
| 360
Months |
0 |
0.00% |
| Total |
214 |
100% |
| Occupancy |
#
Loans |
%
of Loans |
| Primary |
206 |
96.26% |
| Secondary |
1 |
0.47% |
| Investment |
7 |
3.27% |
| Total |
214 |
100% |
| Property
Type |
#
Loans |
%
of Loans |
| Single
Family Detached |
128 |
59.81% |
| Condo,
Low Rise |
42 |
7.48% |
| PUD
(Attached, Detached & Semi Detached) |
69 |
32.24% |
| Multi
Family |
1 |
0.47% |
| Other |
0 |
0.00% |
| Total |
214 |
100% |
| Property
State |
#
Loans |
%
of Loans |
| AL |
3 |
1.40% |
| AR |
1 |
0.47% |
| AZ |
9 |
4.21% |
| CA |
75 |
35.05% |
| CO |
9 |
4.21% |
| CT |
4 |
1.87% |
| DE |
1 |
0.47% |
| FL |
12 |
5.61% |
| GA |
5 |
2.34% |
| IA |
3 |
1.40% |
| IL |
3 |
1.40% |
| IN |
3 |
1.40% |
| KS |
1 |
0.47% |
| KY |
1 |
0.47% |
| LA |
3 |
1.40% |
| MA |
2 |
0.93% |
| MD |
3 |
1.40% |
| MI |
3 |
1.40% |
| MN |
1 |
0.47% |
| MS |
1 |
0.47% |
| NC |
4 |
1.87% |
| NE |
2 |
0.93% |
| NH |
1 |
0.47% |
| NJ |
9 |
4.21% |
| NM |
2 |
0.93% |
| NV |
3 |
1.40% |
| NY |
2 |
0.93% |
| OK |
2 |
0.93% |
| OR |
3 |
1.40% |
| PA |
7 |
3.27% |
| RI |
1 |
0.47% |
| SC |
1 |
0.47% |
| SD |
1 |
0.47% |
| TN |
3 |
1.40% |
| TX |
17 |
7.94% |
| VA |
6 |
2.80% |
| WA |
6 |
2.80% |
| WV |
1 |
0.47% |
| Total |
214 |
100% |
VIII.
Diligence Reports Summary
Visionet
furnished the following reports on this transaction:
Disclaimer:
Visionet Systems, Inc. (“the Company”) is a leading digital technology and business process outsourcing solutions
provided for the BFSI industry. With a unique combination of technology, knowledge expert and proprietary mortgage technology
products, we deliver industry-leading solutions to global BFSI clients.
Visionet
Systems, Inc. focuses on end-to-end services and solutions. We perform mortgage credit and compliance due diligence, pre-fund
and post-close quality control, and mortgage servicing reviews. Services include valuation, risk management, and specialized staffing
and advisory assistance. Our clients are financial entities including investment banks, commercial banks, mortgage companies,
government agencies and mortgage insurers. Our primary focus is on securitized residential mortgage loans (prime, QM & Non-QM,
performing and re-performing), mortgage servicing rights purchases, and new originations (quality control).
Ratings,
analysis, reports, and other opinions (referred to collectively as “Reports”) issued by the Company are provided “as
is” and without representation or warranty of any kind. The Company hereby disclaims any representation or warranty (whether
express or implied) as to accuracy, completeness, merchantability, or fitness for a particular purpose. Reports are not a recommendation
to buy, sell, or retain any security. All reports are deemed jointly prepared and no individual shall be exclusively deemed the
“author” of any Report. Individuals identified in a Report were involved in, but are not solely responsible for, the
contents of any Report. Unless expressly stated otherwise, Reports do not assess any risk other than credit risk. In particular,
any rating or grading in a Report does not take into consideration the risk of any security (or any portion thereof) due to changes
in market conditions. The Company does not provide investment, legal, or tax advice, and the Reports may not be construed as such.
Reports are issued for the benefit of the entity requesting the Report, only, and may not be used by third parties without the
express written consent of the Company and the requesting party. Reports are based on available information and current regulations
as of the date of the Report, and the Company disclaims any obligation to update Reports due to a change of fact of regulation
which occurs after the date of issuance. Neither supplemental factual investigation nor enhanced reviews can guarantee that all
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not as statements of fact as to credit worthiness, investment, financial, or other recommendation to purchase, sell, or hold any
security. Reports may contain assumptions and/or predictions regarding future events which are “forward-looking” and
inherently cannot be verified as facts. Consequently, Reports may be affected by future events or conditions which were not anticipated
at the time the Report was made. Such forward-looking statements necessarily involve risks and uncertainties which may result
in future performance that is materially different from the Report’s assumptions and/or conclusions. As such, Reports are
not a guaranty of future performance nor a prospectus related to the underlying securities (if any), and under reliance should
not be placed upon the Reports in the purchase, sale, or holding of any security.