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EXECUTIVE
SUMMARY
Third Party Due Diligence Review
Overview
Consolidated Analytics, Inc (“Consolidated Analytics”),
a third-party due diligence provider, performed the review described below on residential mortgage loans acquired by Rithm Capital Corp,
through a bulk purchase. The review included a total of one (1) residential mortgage loans, in connection with the securitization identified
as NRMLT 2026-NQM1 (the “Securitization”). The Review was conducted in June 2025 on mortgage loans originated in June 2025.
Scope of Review
Credit Review
Consolidated Analytics performed a “Credit
Review” to verify compliance with guidelines in effect at the time of loan origination, or other guidelines provided by Client prior
to review, and ensure the characteristics used by the underwriter are supported by the file documentation; and determine whether any loans
outside of those guidelines contain legitimate and approved exceptions with compensating factors.
The Credit Review attempted to confirm the
following:
| (a) | 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: |
| o | Loan Application: Complete loan application is present in the loan
file for all borrowers/guarantors; |
| o | Credit Report: Credit Report in file for all borrowers and meets
guideline seasoning requirements and contains OFAC clearance; |
| o | Income 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; |
| o | Asset Documentation: Confirmation of presence of asset documentation
requirements relative to loan type and guideline requirements for verification of closing funds and reserves; |
| o | Borrower/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); |
| o | Insurance 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; |
| o | Property Valuation: Confirm the presence of a complete appraisal
report and supporting secondary independent estimate of value; |
| o | Commercial 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; |
| o | Articles 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; |
| o | Certificate 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; |
| o | Borrower 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: |
| o | Note/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; |
| o | Mortgage/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; |
| o | Power 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; |
| o | Personal 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; |
| o | Affidavit 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; |
| o | Title Policy: Confirmation that the file contains evidence of title
insurance and that the title is free from material defects that could affect lien position; |
| o | Deed 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; |
| o | Purchase 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; |
| o | Settlement 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: |
| o | Borrower/Guarantor Eligibility: Review each borrower to ensure that
they meet eligibility requirements of underwriting guidelines; |
| o | Assets: Validate that the mortgage loan file contains adequately
qualified verification of assets to meet underwriting standards; |
| o | Debt-Service Coverage Ratios “DSCR”: Applicable to DSCR
loans, calculate the debt-service coverage ratio to ensure it meets minimum guideline standards; |
| o | Credit History: Review the borrower credit reports and any supplemental
credit history documentation to verify whether the borrower met guideline requirements; |
| o | Credit 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; |
| o | Occupancy: Confirm that the occupancy of the subject property used
for qualification of the loan is accurate and compliant with guideline requirements. For Business Purpose and Investment loans, verify
the presence of a borrower executed affidavit confirming the commercial/business purpose of the loan and ensure that no other documentation
in the loan file indicates the subject property is being used for non-business purposes; |
| o | Loan-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; |
| o | Insurance: 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; |
| o | Compensating Factors: Review and validate any compensating factors
used in the qualification of the loan and in consideration of loan level underwriting guideline exceptions; |
| o | Letters 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; |
| o | Exception Approvals: Confirm that any exceptions to underwriting
guidelines and/or investor guideline overlays were fully documented, properly approved, and supported; |
| o | Misrepresentation / 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. |
QM or ATR Validation / Review of 8 Key Underwriting
Factors
| · | Validate borrower(s) monthly gross income |
| · | Validate funds required to close, required reserves |
| · | Review file documentation for required level of income and asset verifications |
| · | Review file documentation for required level of employment |
| iii. | Monthly Mortgage Payment |
| · | Confirm program, qualifying rate, terms |
| · | Validate all concurrent loans are included in the DTI to properly assess
the ability to repay |
| v. | Mortgage Related Obligations : PITI, HOA, PMI, etc. |
| · | Validate subject loan monthly payment (PITI) and associated obligations |
| · | Validate monthly recurring liabilities |
| vii. | DTI and/or Residual Income |
| · | Validate debt-to-income ratio (DTI) based upon income and debt documentation
provided in the file |
| · | Review credit report for credit history and required credit depth including
any / all inquiries |
| |
· |
Determine representative credit score from credit report |
| b. | Validate loan-to-value (LTV) and combined loan-to-value |
| c. | Review borrower's occupancy |
| d. | Validation through third party resource of the subject properties most recent twelve (12) month sales history |
| e. | Confirm sufficient evidence in loan file, by reviewing the underwriter’s decision to approve the loan based upon the borrows
income, debt, and credit history, to support borrower's willingness and ability to repay the debt |
| f. | Confirm that Final 1003 is sufficiently completed |
| g. | Provide Audit 1008 with accurate data based on file documentation |
| h. | Confirm Loan Approval conditions were met |
| i. | Review condominium questionnaire to verify all information is complete, prepared by an authorized representative, and address any
red flags that may deem condominium project ineligible |
Compliance Review
Consolidated Analytics performed a “Compliance Review”
to determine, as applicable, to the extent possible and subject to the caveats below, whether the loan complies with applicable regulatory
requirements as noted below, each as amended, restated and/or replaced from time to time. In relation to cash out refinances of investment
property loans, documentation provided in the loan file will be reviewed only to validate the use of cash out proceeds for business purposes
at the origination/consummation of the loan. In the event use of proceeds cannot be validated, or are deemed to be utilized for consumer
purposes, the loan would then be subject to a “Compliance Review” of applicable regulatory requirements as noted below, each
as amended, restated and/or replaced from time to time. The Compliance Review included the following:
| a. | Test Loan Estimate(s) for accuracy and completeness as well as timing requirements as required by TRID Regulations |
| b. | Test Closing Disclosure(s) for accuracy and completeness as well as timing requirements as required by TRID Regulations |
|
i. |
Compare Loan Estimate and Closing Disclosures |
| |
ii. |
Identify Tolerance Violations and applicable cost to cure |
| d. | Comprehensive review of Closing Disclosure to determine transaction accuracy |
| e. | Recalculation of APR and Finance Charge |
|
i. |
Federal High Cost Mortgage provisions |
| |
ii. |
Federal Higher Priced Mortgage Loans provisions |
| |
iii. |
Local and/or State Anti-predatory and High Cost provisions |
| |
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 |
| |
ii. |
Home Ownership Counselling Disclosure |
| h. | Compliance with QM as it relates to: |
| |
iii. |
Prepayment Penalty Test |
| |
iv. |
Product Eligibility Testing |
| |
i. |
Notice of Right to Cancel (Rescission) Review |
| |
i. |
Confirm transaction date, expiration date, and disbursement date |
| |
ii. |
Confirm document is properly executed by all required parties to the transaction |
| |
iii. |
Confirm the correct Right of Rescission document was executed for the transaction type |
| |
iv. |
Confirm a full three (3) day rescission period was provided to the borrower(s) |
| 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 receiving complete and accurate data regarding the loans from loan originators and other
third parties upon which Consolidated Analytics is relying in reaching such findings.
Valuation Review
Consolidated Analytics performed a “Valuation
Review,” which included the following:
| a. | Review original appraisal and all additional property valuation documentation to determine whether source, format and type meet program
and guideline eligibility requirements, and that property is in "average" condition or better. If the property requires cosmetic
improvements (as defined by the appraiser), confirm that they do not affect habitability. |
| b. | As applicable, assess rental income schedules |
| c. | 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. |
| d. | 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. |
| e. | 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. |
| f. | Review adjustments (line item, net and gross adjustments) to ensure they are reasonable. |
| g. | Ensure that the appraisal conforms to the guidelines provided from the Client. |
| h. | Review appraisal to ensure all required documents were included. |
| i. | Review location map provided within the appraisal for external obsolescence. |
| j. | Ensure highest and best use and zoning complies with guidelines. |
| k. | Confirm there are no marketability issues that affect the subject property. |
| l. | Ensure subject property does not suffer any functional obsolescence. |
| m. | As applicable, assess rental income schedules |
| n. | Where applicable, determine if the file did not contain the appraisal or other valuation method and a
review could not be performed. |
| o. | Additional valuation products were not required when the CU score provided was 2.5 or below or the Federal
Home Loan Mortgage Corporation Loan Collateral Advisor appraisal (“LCA”) risk score was eligible for Collateral Rep and Warranty
relief. In the event the CU score was greater than 2.5 or the LCA appraisal risk score was not eligible for Collateral Rep and Warranty
relief, an additional valuation product was obtained to confirm value was supported within 10% tolerance. In some instances, based on
guidance from the seller, CDA’s were ordered on loans that had an acceptable CU score or Collateral Rep and Warranty relief eligibility. |
Consolidated Analytics applied a cascade methodology
to determine if the original appraised value was reasonably supported when compared to an independent third-party valuation product.
For loans reviewed in a post-close valuation
review scenario (1 loan in total):
One (1) loan had a Desktop Review, zero (0) loans
had an AVM, zero (0) loans had a BPO, and zero (0) loans had a Second Appraisal. Consolidated Analytics has independent access to the
Desktop Review ordered by the Aggregator.
If a loan with an AVM or Desktop Review fell
outside of a -10% tolerance, was inconclusive, or the AVM FSD score did not meet allowable thresholds, then a Desktop Review, Field Review,
Broker Price Opinion (BPO) along with a Reconciliation of the value, or a 2nd appraisal was required.
There were zero (0) occurrences of this.
Product totals may not sum due to multiple
products for each loan
TAPE INTEGRITY REVIEW RESULTS SUMMARY
Of the one (1) mortgage loan reviewed, one (1) unique
mortgage loans (100.00 % by loan count) had a total of two (2) tape discrepancies across two (2) 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 |
| T & I Payment |
1 |
50.00% |
| DSCR |
1 |
50.00% |
| Grand Total |
2 |
100.00% |
Summary of Results
OVERALL RESULTS SUMMARY
Final Loan Grades
| Overall Loan Results: |
|
| Event Grade |
Loan Count |
Original Principal Balance |
Percent of Sample |
| Event Grade A |
1 |
$766,000.00 |
100.00% |
| Event Grade B |
0 |
$0.00 |
0% |
| Event Grade C |
0 |
$0.00 |
0% |
| Event Grade D |
0 |
$0.00 |
0% |
| Total Sample |
1 |
$766,000.00 |
100.00% |
| Credit Results: |
| Event Grade |
Loan Count |
Percent of Sample |
| Event Grade A |
1 |
100.00% |
| Event Grade B |
0 |
0% |
| Event Grade C |
0 |
0% |
| Event Grade D |
0 |
0% |
| Total Sample |
1 |
100.00% |
| Compliance Results (As applicable, 1 loan within population did not receive a Compliance Review): |
| Event Grade |
Loan Count |
Percent of Sample |
| Event Grade A |
0 |
0% |
| Event Grade B |
0 |
0% |
| Event Grade C |
0 |
0% |
| Event Grade D |
0 |
0% |
| Total Sample |
0 |
100.00% |
| Valuation Results: |
| Event Grade |
Loan Count |
Percent of Sample |
| Event Grade A |
1 |
100.00% |
| Event Grade B |
0 |
0% |
| Event Grade C |
0 |
0% |
| Event Grade D |
0 |
0% |
| Total Sample |
1 |
100.00% |
Exception Category Summary
The table below summarizes the individual exceptions which carried an associated
“A”, “B”, “C”, or “D” level exception grade. One loan may have carried more than one exception.
In such cases, the exception with the lowest grade would drive the loan grade for that particular area of the review. The overall loan
grade is the lowest grade for any one particular review scope (ex. a loan with a Compliance Grade of “B”, a Credit Grade of
“A”, and a Property Grade of “A” would receive an overall Loan Grade of “B”).
| Exception Type |
Exception Level Grade |
Exception Category |
Total |
| Credit |
A |
No Credit Findings |
1 |
| Total Credit Grade (A) Exceptions: |
1 |
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. |