EX-99.4 19 s148582_ex99-4.htm THIRD PARTY DUE DILIGENCE REPORT - CONSOLIDATED ANALYTICS NARRATIVE

Exhibit 99.4

 

Attachment A

Item 4: Description of the due diligence performed

 

PRPM 2023-NQM1

 

(1) Type of assets that were reviewed.

 

Consolidated Analytics, Inc. (“Consolidated Analytics”) performed certain due diligence services (the “Review”) described below on 19 mortgage loans acquired by PRP-LB 2023-NQM1, LLC, through a bulk purchase. The Review was conducted from January 2022 through October 2022 on mortgage loans originated between November 2021 and October 2022.

 

(2) Sample size of the assets reviewed.

 

The Review consisted of a sample population of 19 loans with an aggregate principal balance of $7,172,200.50.

 

(3) Determination of the sample size and computation.

 

The sample population was determined and provided by Consolidated Analytics’ client (as identified by Item 2). The Review was conducted consistent with the criteria for the nationally recognized statistical rating organizations S&P and DBRS Morningstar, NRSRO(s), identified in Item 3 of the ABS Due Diligence-15E. Consolidated Analytics does not know the size of the overall securitization population and other third-party review (“TPR”) firms may have reviewed loans within the overall securitization population.

 

(4) Quality or integrity of information or data about the assets: review and methodology.

 

Consolidated Analytics compared data fields on the bid tape provided by the Client to the data found in the actual mortgage loan file as captured by Consolidated Analytics. This comparison, when data was available, included the following data fields:

 

Property Type

Origination Date Original Appraised Value
Rate Lock Date Original PI Payment Borrower Last Name
Escrow Indicator Loan Purpose Loan Type
Maturity Date Property Units Occupancy
Orig Front End DTI Original Note Rate Original CLTV
Original LTV Original Term Sales Price
Orig Back End DTI Property Address Property City
Property State Property Zip UW FICO Utilized
AUS Type Amortization Type All Borrower Total Income
First Payment Date Lien Position Reserves
Original HOA Payment Qualifying DSCR  

 

(5) Origination of the assets and conformity to stated underwriting or credit extension guidelines, standards, criteria or other requirements: review and methodology.

 

Consolidated Analytics performed a “Credit Review” to verify compliance with guidelines in effect at the time of loan origination, or other guidelines provided by Client prior to review, and ensure the characteristics used by the underwriter are supported by the file documentation; and determine whether any loans outside of those guidelines contain legitimate and approved exceptions with compensating factors.

  

 

 

 

The Credit Review attempted to confirm the following:

 

(a)Credit Documentation: A review of the documentation underlying the credit decision was performed to determine sufficiency for consideration in the Credit Review. The Credit Documentation review consisted of the following:

 

oLoan Application: Complete loan application is present in the loan file for all borrowers/guarantors;

 

oCredit Report: Credit Report in file for all borrowers and meets guideline seasoning requirements and contains OFAC clearance;

 

oIncome Documentation / Lease Agreements: Confirmation of the presence of income documentation in the loan file when required by lender or Client specified underwriting guidelines. For rental properties where existing leases are required to be verified, verify their presence and sufficiency for purpose based on underwriting guideline standards;

 

oAsset Documentation: Confirmation of presence of asset documentation requirements relative to loan type and guideline requirements for verification of closing funds and reserves;

 

oBorrower/Guarantor Identification: Verify that the file contains a copy of a government issued identification verification for each borrower (i.e. driver’s license, state ID, passport);

 

oInsurance Certificate: Verify that the loan file contains a copy of the hazard insurance certificate for the subject property and that flood insurance is also documented when required;

 

oProperty Valuation: Confirm the presence of a complete appraisal report and supporting secondary independent estimate of value;

 

oCommercial Borrower Organizing Documentation: Confirm the presence an Operating Agreement, Bylaws, related amendments and filings or other organizing and operating documentation relative to the commercial borrower entity;

 

oArticles of Incorporation/Certificate of Formation: Confirm that each loan file contains a copy of the Articles of Incorporation establishing registration within the state of operation;

 

oCertificate of Good Standing: Confirm that each borrowing entity is active in the state of registration by confirming the presence of a web print out or certification of good standing for the state is in the file;

 

oBorrower Authority / Consent of Members: Confirm that the loan file contains evidence that the individual executing the loan agreements has been given signing authority on behalf of the borrowing entity.

 

(b)Legal Documentation: A review of the documentation required to secure the lender’s interest in the loan and the borrower(s)’ obligations thereunder was conducted with the purpose of validating their presence in the mortgage loan file and sufficiency of execution:

 

oNote/Loan Agreement/Security Instrument/Extension: Verification of the presence of the note, loan agreement or security instrument as applicable and that the agreement is properly executed by all parties. Confirm that all applicable allonges or addenda to the note are evidenced in the loan file and duly executed by all responsible parties. If the subject loan has reached or is nearing maturity confirm that an extension agreement is present and duly executed by all required parties;

 

oMortgage/Deed of Trust/Assignment of Rents: Verify that a mortgage or deed of trust is in file and is duly executed and notarized and that it contains all applicable riders including an assignment of rents;

 

oPower of Attorney: If closing docs are executed by a POA confirm that the POA complies with all applicable underwriting and legal requirements including those for timing, form, authority and execution;

 

 

 

 

oPersonal Guaranty: Verify that the requisite individual ownership percentage of a commercial entity borrower as stipulated within Client or lender underwriting guidelines has provided a personal guaranty for the loan;

 

oAffidavit of Commercial Purpose/Occupancy Certification: Verify that each file contains a borrower statement verifying that the loan is for commercial purpose and that the subject property will not be owner occupied;

 

oTitle Policy: Confirmation that the file contains evidence of title insurance and that the title is free from material defects that could affect lien position;

 

oDeed for Conveyance of Title: Confirm that the applicable Grant or Warranty Deed is evidenced in the loan file and properly conveys interest in the subject property;

 

oPurchase Contract: If applicable, confirm the presence of a valid and executed Purchase and Sale Agreement along with any counter offers and modified terms of sale;

 

oSettlement Statement: As applicable based on loan type and origination date, confirm the presence of a final settlement statement in the mortgage loan file.

 

(c)Guidelines: The underwriting guidelines as specified by Client served as the criteria under which each loan qualification review took place. Qualification criteria includes:

 

oBorrower/Guarantor Eligibility: Review each borrower to ensure that they meet eligibility requirements of underwriting guidelines;

 

oAssets: Validate that the mortgage loan file contains adequately qualified verification of assets to meet underwriting standards;

 

oDebt-Service Coverage Ratios “DSCR”: Calculate the debt-service coverage ratio to ensure it meets minimum guideline standards;

 

oCredit History: Review the borrower credit reports and any supplemental credit history documentation to verify whether the borrower met guideline requirements;

 

oCredit Scores: Review each borrower/guarantor credit report to validate that the credit score used in qualification is accurate and whether it meets minimum loan qualification and underwriting standards as specified in the underwriting guidelines;

 

oOccupancy: Confirm that the occupancy of the subject property used for qualification of the loan is accurate and compliant with guideline requirements. Confirm that the borrower has executed an affidavit of commercial/business purpose and that no other documentation that shows the subject property might be a primary residence;

 

oLoan-to-Value Ratios: Recalculate the Loan-to-Value Ratio utilizing the Purchase Contract, Property Valuations and/or Loan Agreements to determine whether initial, as-is and as-repaired LTV and CLTV meet loan qualification and underwriting guideline standards based on the calculation methods set forth in underwriting guidelines;

 

oInsurance: Confirm the adequacy of hazard insurance coverage and that premiums are included in PITI calculations. If required based on flood zone, confirm the presence and adequacy of flood insurance coverage and that premiums are included in PITI calculations;

 

oCompensating Factors: Review and validate any compensating factors used in the qualification of the loan and in consideration of loan level underwriting guideline exceptions;

 

 

 

 

oLetters of Explanation: Confirm the presence of Letters of Explanation (LOX) where required per underwriting guidelines and that each such LOX adequately addresses the eligibility scenario under question;

 

oException Approvals: Confirm that any exceptions to underwriting guidelines and/or investor guideline overlays were fully documented, properly approved, and supported;

 

oMisrepresentation / Fraud Review: Validate that an independent third-party fraud report was obtained for each guarantor when required by underwriting guidelines and that red flags on third party fraud reports have been reviewed.

 

(6) Value of collateral securing the assets: review and methodology.

 

Consolidated Analytics performed a “Valuation Review,” which included the following:

 

1.Review original appraisal, determination that property is in “average” condition or better, or property requires cosmetic improvements (as defined by the appraiser) that do not affect habitability
2.Review appraisal, determination that property is completely constructed and appraisal is on an “as is basis,” or property is identified as not completely constructed by originating appraiser.
3.Review and determine if the appraisal report was performed on appropriate GSE forms and if the appraiser indicated in the body of the subject appraisal that the appraisal conforms to USPAP standards.
4.Review and determine the relevance of the comparable properties and ensure that a rational and reliable value was provided and supported as of the effective date of the Origination Appraisal.
5.Review adjustments (line item, net and gross adjustments) to ensure they are reasonable.
6.Review appraisal to ensure all required documents were included.
7.Review location map provided within the appraisal for external obsolescence.
8.Ensure highest and best use and zoning complies with guidelines.
9.Confirm there are no marketability issues that affect the subject property.
10.Ensure subject property does not suffer any functional obsolescence.
11.Where applicable, determine if the file did not contain the appraisal or other valuation method and a review could not be performed.
12.Additional valuation products were not required when the CU score provided was 2.5 or below. In the event the CU score was greater than 2.5, an additional valuation product was obtained to confirm value was supported within 10% tolerance. In some instances, CDA’s were ordered on loans that had an acceptable CU score based on guidance from the seller.

 

Consolidated Analytics applied a cascade methodology to determine if the original appraised value was reasonably supported when compared to an independent third party valuation product.

 

For loans reviewed in a post-close valuation review scenario (19 loans in total):

 

One (1) loan had a Secondary Appraisal, zero (0) loans had AVMs, and eleven (11) loans had Desktop Reviews. Consolidated Analytics has independent access to the Desktop Reviews ordered by the Aggregator.

 

If a loan with an AVM or Desktop Review fell outside of a -10% tolerance, was inconclusive, or a PIW was present, then a Field Review, a Broker Price Opinion (BPO) along with a Reconciliation of the values or a 2nd Appraisal was completed. There was one (1) occurrence of this.

 

Zero (0) loans had a Field Review or BPO, and zero (0) loans had an Exterior Only Appraisal Review.

 

 

 

 

Product totals may not sum due to multiple products for each loan

 

(7) Compliance of the originator of the assets with federal, state and local laws and regulations: review and methodology.

 

Consolidated Analytics performed a “Compliance Review” to determine, as applicable, to the extent possible and subject to the caveats below, whether the loan complies with applicable regulatory requirements as noted below, each as amended, restated and/or replaced from time to time. In relation to cash out refinances of investment property loans, documentation provided in the loan file will be reviewed only to validate the use of cash out proceeds for business purposes at the origination/consummation of the loan. In the event use of proceeds cannot be validated, or are deemed to be utilized for consumer purposes, the loan would then be subject to a “Compliance Review” of applicable regulatory requirements as noted below, each as amended, restated and/or replaced from time to time. The Compliance Review included the following:

 

a.Test Loan Estimate(s) for accuracy and completeness as well as timing requirements as required by TRID Regulations
b.Test Closing Disclosure(s) for accuracy and completeness as well as timing requirements as required by TRID Regulations
c.Tolerance Testing
i.Compare Loan Estimate and Closing Disclosures
ii.Identify Tolerance Violations and applicable cost to cure
d.Comprehensive review of Closing Disclosure to determine transaction accuracy
e.Recalculation of APR and Finance Charge
f.Testing of:
i.Federal High Cost Mortgage provisions
ii.Federal Higher Priced Mortgage Loans provisions
iii.Local and/or State Anti-predatory and High Cost provisions
iv.HOEPA Points and Fees
g.Determine whether specified federal disclosures were provided timely based upon comparison of the application date to the dates on such disclosures
i.Service Provider List
ii.Home Ownership Counselling Disclosure
iii.ARM Disclosure
h.Compliance with QM as it relates to:
i.APR Test
ii.Points & Fees Test
iii.Prepayment Penalty Test
iv.Product Eligibility Testing
i.Notice of Right to Cancel (Rescission) Review
i.Confirm transaction date, expiration date, and disbursement date
ii.Confirm document is properly executed by all required parties to the transaction
iii.Confirm the correct Right of Rescission document was executed for the transaction type
j.Confirm through NMLS the loan originator and originating firm’s license status was active and properly disclosed on appropriate loan documents
k.Check the Loan participants against the exclusionary list provided by Client or by the purchaser of the Loan(s)
l.Review closing documents to ensure that the Mortgage Loan information is complete, accurate, and consistent with other documents; Confirm collateral documents have been recorded or sent for recording

 

The Compliance Review did not include any federal, state or local laws, constitutional provisions, regulations or ordinances that are not expressly enumerated above. Furthermore, the findings reached by Consolidated Analytics are dependent upon its receiving complete and accurate data regarding the loans from loan originators and other third parties upon which Consolidated Analytics is relying in reaching such findings.

 

(8) Other: review and methodology.

 

Not applicable.

 

 

 

 

Attachment B

Item 5: Summary of findings and conclusions of review

 

Summary of Results

 

OVERALL RESULTS SUMMARY

 

After giving consideration to the grading criteria, 47.37% of the loans received an Overall “B” grade and 52.63% of the loans received an Overall “A” grade.

 

Final Loan Grades

 

Overall Loan Results:

 

Event Grade Loan Count Original Principal Balance Percent of
Sample
Event Grade A 10 $3,053,012.50 52.63%
Event Grade B 9 $4,119,188.00 47.37%
Event Grade C 0 $0.00 0.00%
Event Grade D 0 $0.00 0.00%
Total Sample 19 $7,172,200.50 100.00%

 

Credit Results:

 

Event Grade Loan Count Percent of Sample
Event Grade A 11 57.89%
Event Grade B 8 42.11%
Event Grade C 0 0%
Event Grade D 0 0%
Total Sample 19 100.00%

 

Compliance Results (As applicable, 8 loans within population did not receive a Compliance Review)

 

Event Grade Loan Count Percent of Sample
Event Grade A 11 100.00%
Event Grade B 0 0%
Event Grade C 0 0%
Event Grade D 0 0%
Total Sample 11 100.00%

 

Valuation Results:

 

Event Grade Loan Count Percent of Sample
Event Grade A 15 78.59%
Event Grade B 4 21.05%
Event Grade C 0 0.00%
Event Grade D 0 0.00%
Total Sample 19 100.00%

 

 

 

 

Exception Category Summary

 

The table below summarizes the individual exceptions which carried an associated “A”, “B”, “C”, or “D” level exception grade. One loan may have carried more than one exception. In such cases, the exception with the lowest grade would drive the loan grade for that particular area of the review. The overall loan grade is the lowest grade for any one particular review scope (ex. a loan with a Compliance Grade of “B”, a Credit Grade of “A”, and a Valuation Grade of “A” would receive an overall Loan Grade of “B”).

 

Exception
Type
Exception
Level Grade
Exception Category Total
Credit A Missing Title Insurance Policy 5
Insufficient Title Insurance Coverage 4
Final Loan Application is Partial 4
Missing Closing Protection Letter 4
Missing Payoff Statement 3
Missing Tax Certificate 3
Borrower Income Verification does not match Approval 2
No Credit Findings 2
Borrower Liabilities Verification Indicator is Partial 2
Maximum LTC 2
Maximum LTV 2
Borrower Employment Verification does not meet guidelines 2
Missing Purchase Contract Addendum 1
Asset Documents are Incomplete 1
Minimum Liquidity 1
Insufficient Lease Agreement 1
Insufficient Hazard Insurance Coverage 1
Missing Flood Certificate 1
Missing Settlement Statement 1
Missing Hazard Insurance Policy 1
Underwriting FICO does not meet Guideline Minimum Required 1
Missing Lease Agreement 1
Missing Operating Agreement 1
Missing Conveyance Deed 1
Missing Condo Questionaire 1
Total Credit Grade (A) Exceptions: 48
B Housing history does not meet guidelines 3
Loan amount is less than the minimum required loan amount 1
Borrower Liabilities Verification Indicator is Partial 1
Liquid Reserves are less than Guidelines Required 1
Cash to Borrower Exceeds Maximum Allowable 1
Age Of Credit Report 1
DSCR is less than guideline minimum 1
Total Credit Grade (B) Exceptions: 9
 Compliance  A No Compliance Findings 9
Higher-Priced Mortgage Loan 3
TILA Right of Rescission Test 1
TRID Initial Closing Disclosure Date and Funding Date Validation Test 1
ATR/QM Status is Pending 1
Higher-Priced Mortgage Loan Right to Receive Appraisal Disclosure Alert (12 CFR 1026.35(c)(5)). 1
Total Compliance Grade (A) Exceptions: 16
Valuation  A Missing Appraisal Review 3
Ineligible Appraisal Type 2
No Property Findings 2
Missing Rent Range 2
Is Completion Certificate in file is No 1
Property located in FEMA Declared Disaster Area with no subsequent Property Inspection 1
UCDP Summary Report is Missing 1
Age Of Background Report 1
Missing Master Condo Policy 1
Missing Appraisal Review 3
Insufficient Appraisal Variance 1
Total Valuation Grade (A) Exceptions: 18
B Minimum Square Footage 1
Age Of Appraisal 1
Total Valuation Grade (B) Exceptions: 2

 

 

 

 

TAPE INTEGRITY REVIEW RESULTS SUMMARY

 

Of the nineteen (19) mortgage loans reviewed, fourteen (14) unique mortgage loans (73.68% by loan count) had a total of forty-seven (47) tape discrepancies across eighteen (18) data fields. A blank or zero value on the data tape when an actual value was captured by Consolidated Analytics was not treated as a data variance.

 

Fields Reviewed Discrepancy
Count
Percentage
Guarantor Last Name 8 17.02%
Borrower Email 7 14.89%
Borrower Billing Phone Number 7 14.89%
Property Acquisition Date 6 12.77%
Guarantor Last Name 3 6.38%
Original Collateral Value Date 2 4.26%
Most Recent Property Valuation Date 2 4.26%
Cost Basis 2 4.26%
Property Address 1 2.13%
Origination Date 1 2.13%
Original PI Payment 1 2.13%
Property Type 1 2.13%
Closing Date 1 2.13%
Original Collateral Value 1 2.13%
Purchase Price 1 2.13%
Interest Rate 1 2.13%
Original Credit Report Date 1 2.13%
Number of Guarantors 1 2.13%
Grand Total 47 100.00%

 

 

 

 

Event Grade Definitions

 

 

Final Loan Grade

A Loan meets Credit, Compliance, and Valuation Guidelines
B The loan substantially meets published Client/Seller guidelines and/or eligibility in the validation of income, assets, or credit, is in material compliance with all applicable laws and regulations, and the value and valuation methodology is supported and substantially meets published guidelines.
C The loan does not meet the published guidelines and/or violates one material law or regulation, and/or the value and valuation methodology is not supported or did not meet published guidelines.
D Loan is missing documentation to perform a sufficient review.

 

Credit Event Grades
A The loan meets the published guidelines without any exceptions. The employment, income, assets and occupancy are supported and justifiable. The borrower’s willingness and ability to repay the loan is documented and reasonable.
B The loan substantially meets the published guidelines but reasonable compensating factors were considered and documented for exceeding published guidelines. The employment, income, assets and occupancy are supported and justifiable. The borrower’s willingness and ability to repay the loan is documented and reasonable.
C The loan does not substantially meet the published guidelines. There are not sufficient compensating factors that justify exceeding the published guidelines. The employment, income, assets or occupancy are not supported and justifiable. The borrower’s willingness and ability to repay the loan were not documented or are unreasonable.
D There was not sufficient documentation to perform a review or the credit file was not furnished.

 

Compliance Event Grades
A The loan is in compliance with all applicable laws and regulations. The legal documents accurately reflect the agreed upon loan terms and are executed by all applicable parties.
B The loan is in material compliance with all applicable laws and regulations. The legal documents accurately reflect the agreed upon loan terms and are executed by all applicable parties. Client review required.
C The loan violates one material law or regulation. The material disclosures are absent or the legal documents do not accurately reflect the agreed upon loan terms or all required applicants did not execute the documents.
D There was not sufficient documentation to perform a review or the required legal documents were not furnished.

 

Valuation Event Grades
A The value is supported within 10% of the original appraisal by the AVM or there are other supporting documents in the originators loan file package (CDA, Field Review or Second Appraisal). The appraisal was performed on an “as-is” basis and the property is complete and habitable at origination. The appraiser was appropriately licensed and used GSE approved forms.
B The value is not supported within 10% of the original appraisal by the AVM and there are no other valuation support documents in the loan file provided by the Seller. The valuation methodology substantially meets the published guidelines but reasonable compensating factors were considered and documented for exceeding guidelines. The appraisal was performed on an “as-is” basis and the property is complete and habitable. The appraiser was appropriately licensed and used GSE approved forms.
C The value is not supported within 10% of the original appraisal. The valuation methodology did not meet the published guidelines and there were not sufficient compensating factors for exceeding published guidelines. The property is in below “average” condition or the property is not complete or requires significant repairs. The appraisal was not performed on an “as is” basis. The appraiser was not appropriately licensed or did not use GSE approved forms.
D The file was missing the appraisal or there was not sufficient valuation documentation to perform a review.