UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549


FORM ABS-15G/A

ASSET-BACKED SECURITIZER
REPORT PURSUANT TO SECTION 15G OF
THE SECURITIES EXCHANGE ACT OF 1934

MORGAN STANLEY CAPITAL I INC.

 

Check the appropriate box to indicate the filing obligation to which this form is intended to satisfy:

____Rule 15Ga-1 under the Exchange Act (17 CFR 240.15Ga-1) for the reporting period______________ to _________________

Date of Report (Date of filing) __________________

Commission File Number of securitizer: __________________

Central Index Key Number of securitizer:__________________

 

Name and telephone number, including area code, of the person
to contact in connection with this filing.

Indicate by check mark whether the securitizer has no activity to report for the initial period pursuant to Rule 15Ga-1(c)(l) [ ]

Indicate by check mark whether the securitizer has no activity to report for the quarterly period pursuant to Rule 15Ga-1(c)(2)(i) [ ]

Indicate by check mark whether the securitizer has no activity to report for the annual period pursuant to Rule 15Ga-1(c)(2)(ii) [ ]

Rule 15Ga-2 under the Exchange Act (17 CFR 240.15Ga-2)

Central Index Key Number of depositor: 0001547361

MORGAN STANLEY RESIDENTIAL MORTGAGE LOAN TRUST 2025-RPL1
(Exact name of issuing entity as specified in its charter)

Central Index Key Number of issuing entity (if applicable): Not applicable

Central Index Key Number of underwriter (if applicable): Not applicable

Chris Scott, (212) 761-4940

Name and telephone number, including area code, of the person
to contact in connection with this filing.

  

 

FINDINGS AND CONCLUSIONS OF THIRD-PARTY DUE DILIGENCE REPORTS

 

Item 2.01 Findings and Conclusions of a Third Party Due Diligence Report Obtained by the Issuer

The disclosures required by Rule 15Ga-2 (17 CFR 240.15Ga-2) is attached as Exhibits to this Form ABS-15G/A which amends the Form ABS-15G filed by Morgan Stanley Capital I Inc. on November 14, 2025 (the “Original Filing”)

 

 

EXPLANATORY NOTE

 

 

This Form ABS-15G/A amends the Original Filing and is being filed to (i) replace in its entirety the report attached to the Original Filing as 99.1 Third Party Due Diligence Report – AMC Diligence, LLC Executive Summary, and (ii) add additional schedules under 99.1 as listed in the Exhibit Index below.

 

 

  

 

 

SIGNATURES

 

Pursuant to the requirements of the Securities Exchange Act of 1934, the reporting entity has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.

 

MORGAN STANLEY CAPITAL I INC.

 

 

Date: November 18, 2025

By: /s/ Anthony Piperno

Name: Anthony Piperno

Title: Authorized Signatory

 

  

 

 

 

 

EXHIBIT INDEX

 

 

Exhibit Numbers

 

99.1 Third Party Due Diligence Report- AMC Diligence, LLC Executive Summary

 

Schedule 10 - Collection Comments Report (2 loans)

Schedule 11 - Pay History Report (2 loans)

Schedule 12 - Title Report (2 loans)

Schedule 13 - Modification Report (2 loans)

 

  

 

 Exhibit 99.1

MORGAN STANLEY CAPITAL I INC. ABS-15G/A

 

 

 

 

 

EXECUTIVE SUMMARY

 

DESCRIPTION OF SERVICES

(1) Type of assets that were reviewed.

AMC Diligence, LLC (“AMC”) performed due diligence services as described below utilizing various scopes of review. All of these mortgage loans, which were originated by multiple parties, were purchased by Morgan Stanley Mortgage Capital Holdings LLC (“Client”) and/or its affiliate in multiple bulk transactions and were reviewed by AMC on behalf of such party. The mortgage loans were reviewed via files imaged and provided by the Client or its designee for review.

.

(2) Sample size of the assets reviewed.

The Review was conducted on the portion of the securitization mortgage loan population reviewed by AMC. The Client may have utilized multiple third-party review (“TPR”) firms for the securitization and AMC may or may not have reviewed all of the mortgage loans in the securitization loan population for a specific scope of review. During the course of the selection of the final securitization population mortgage loans may have been eliminated from the originally envisioned securitization population for reasons that are unknown to AMC. Within the final securitization mortgage loan population, the Review sample was broken down into the following review scopes:

 

§“Compliance Only Review” 1,679 mortgage loans
§“Leases Review” 2 mortgage loans
§“Modification Review” 1,377 mortgage loans
§“Collection Comment Review”: 1,683 mortgage loans
§“Payment History Review”: 1,683 mortgage loans
§“Tax and Title Review” 1,683 mortgage loans

 

(3) Determination of the sample size and computation.

The sample size of the Review was conducted consistent with the criteria for the NRSRO(s) identified in Item 3 of the Form ABS Due Diligence-15E.

 

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

Not applicable.

 

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

 

LEASES

DOCUMENT REVIEW

For each Loan, AMC reviewed the Loan File and verified whether the following documents, if applicable, are included in the file and if the data on these documents is consistent and logical: (a) initial application (1003), (b) credit report, (c) employment documentation, (d) asset documentation, (e) sales contract, (f) hazard and/or flood insurance policies, (g) appraisal, (h) title/preliminary title, (i) mortgage/deed of trust, (j) note, (k) certificate of business purpose / non-owner occupancy, (l) articles of incorporation, if applicable, (m) operating agreement, and (n) background check.

CREDIT REVIEW

The credit review focused on the borrower’s experience in property management, credit profile and adherence to guidelines. The borrower’s assets are analyzed to determine there are sufficient funds for the required equity in the project. Conformity to applicable guidelines will all be assessed during the review. An income calculation will not be performed though the presence of income documentation if required by the guidelines will be noted.

Credit Application: For the Credit Application, AMC verified whether (a) the application is signed by all listed borrowers, (b) the application is substantially filled out, (c) all known borrower-owned properties are disclosed on the Real Estate Owned section or attachments, and (d) borrower’s property management/landlord experience.

Credit Report: AMC verified (a) whether a credit report is present for each borrower, (b) note and research the Real Estate Owned and fraud alerts, (c) and gather data including (i) representative FICO, (ii) scores from Equifax, Experian, and Transunion (if available), (iii) that the public records listed are disclosed on the application and adequately explained and in compliance with guidelines, and (iv) the number and length of trade lines.

 

 

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Employment and Income: AMC determined whether applicable supporting employment and income documentation required by the guidelines, was present in the mortgage loan file and where possible, wasn’t fraudulent.

Borrowing Entity: AMC verified the borrowing entity, if not an individual, is properly documented. In addition, AMC will verify if the business entity is a US or foreign entity and if the individual signing the loan documentation has the appropriate authority. Distinction will be made between guarantors and principals, individuals and business entities.

Property income: AMC determined whether all applicable supporting documentation as required by the guidelines is present in the file. No traditional borrower DTI ratios were calculated but instead a “Property DTI” were calculated per guidelines using the lease or expected lease amount and the property expenses. Documentation verifying property income may include: (a) leases and monthly rental income, (b) property vacancy, (c) balance sheets / financial statements, and (d) an appraisal analysis of market rents.

 

Valuation Review: AMC’s review included a review of the valuation materials utilized during the origination of the loan and in confirming the value of the underlying property. AMC’s review included verifying that the appraisal report was (i) materially complete, (ii) in conformity with the guideline requirements for the property type in question, (iii) completed by an appraiser that was actively licensed to perform the valuation, (iv) completed such that the named client on the appraisal report is the lender or a related entity that is permitted to engage the lender per Title XI of FIRREA, (iv) made on an “as is” basis or provides satisfactory evidence of completion of all material conditions including all inspections, licenses, and certificates (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.

 

With regard to the use of comparable properties, AMC (i) reviewed the relative comparable data (gross and net adjustments, sale dates and distance from subject property) and ensure that such comparable properties are within standard appraisal guidelines; (ii) confirmed the property value and square footage of the subject property was bracketed by comparable properties, (iii) verified that comparable properties used are similar in size, style, and location to the subject, and (iv) checked for the reasonableness of adjustments when reconciling value between the subject property and comparable properties.

Other aspects of AMC’s review included (i) verifying that the address matched the mortgage note, (ii) reviewing pictures to ensure (a) that the property is in average or better condition and any repairs are noted where required and (b) that the subject property is the one for which the valuation was ordered and that there are no negative external factors; and (iii) confirming the appraiser noted an estimated lease amount to be used in instances where there is no lease in place.

Asset Review: AMC assessed whether the asset documentation required by the guidelines is present in the file. AMC verified that assets presented support the required reserves. Documentation reviewed may include: (a) depository account statements, (b) stock or security account statements, (c) settlement statements or other evidence of conveyance and transfer of funds if a sale of assets was involved, and (d) operating accounts from other properties.

Insurance: AMC (a) looked for the presence of rent loss insurance as required by the guidelines, (b) verified that hazard insurance meets the minimum required amount of coverage in the guidelines, (c) confirmed that the flood cert is for the correct borrower, property, lender and loan number, and (d) for properties in a flood zone per the flood cert, confirmed that flood insurance meets guideline requirements in the file and meets the minimum required amount of coverage.

Title: AMC verified whether the appropriate vestee is on the title document: if a purchase, the seller; if a refinance, the borrower. AMC also reviewed the Title Commitment for the disclosure issues such as assessments; covenants, conditions and restrictions); access problems; vicinity of property to military airports; prior leases; court orders/divorce decrees; public probate issues; foreclosures; bankruptcies; judgment liens; state and federal tax liens; and environmental liens. Review for instances of delinquent taxes (non-liens). In addition, AMC reviewed for Oil, Gas, Water or Mineral rights.

 

Fraud / Criminal Background: To the extent potentially fraudulent activity is identified as part of the document review, such information was reported to Client. In addition, AMC looked for an independent, third party fraud report and background check in each file and will review the results of the fraud report in conjunction with source documents found in the file to assess the likelihood of any misrepresentations associated with the origination of the loan.

 

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

AMC’s review included a review of the valuation materials utilized during the origination of the loan and in confirming the value of the underlying property. AMC’s review included verifying the appraisal report was (i) on the appropriate GSE

 

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form, (ii) materially complete, (iii) in conformity with the guideline requirements for the property type in question, (iv) completed by an appraiser that was actively licensed to perform the valuation, (v) completed such that the named client on the appraisal report is the lender or a related entity that is permitted to engage the lender per Title XI of FIRREA, (vi) made and signed prior to the final approval of the mortgage loan application, (vii) completed and dated within the guideline requirements, (vii) made on an “as is” basis or provides satisfactory evidence of completion of all material conditions including all inspections, licenses, and certificates (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.

 

With regard to the use of comparable properties, AMC’s review (i) captured the relative comparable data (gross and net adjustments, sale dates and distance from subject property) and ensured that such comparable properties are within standard appraisal guidelines; (ii) confirmed the property value and square footage of the subject property was bracketed by comparable properties, (iii) verified that comparable properties used are similar in size, style, and location to the subject, and (iv) checked for the reasonableness of adjustments when reconciling value between the subject property and comparable properties.

 

Other aspects of AMC’s review included (i) verifying that the address matched the mortgage note, (ii) verifying that the appraisal and the policies and procedures with regard to appraisal, including the appropriate level of review, when originating the mortgage loan, were followed, (iii) noting whether the property zip code was declared a FEMA disaster area after the valuation date and notifying the Client of same (iv) confirming the appraisal report does not include any apparent environmental problems, (v) confirming the appraisal notes the current use of the property is legal or legal non-conforming (grandfathered), (vi) reviewing pictures to ensure (a) that the property is in average or better condition and any repairs are noted where required and (b) that the subject property is the one for which the valuation was ordered and that there are no negative external factors; and (vii) confirming that the value product that was used as part of the origination decision was provided to AMC or if it was not provided that another valuation product was ordered in accordance with the Client’s specific valuation waterfall process. If more than one valuation was provided, AMC confirmed consistency among the valuation products and if there were discrepancies that could not be resolved, AMC created an exception

 

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

Please be advised that AMC did not make a determination as to whether the mortgage loans complied with federal, state or local laws, constitutional provisions, regulations or ordinances that are not expressly enumerated below. There can be no assurance that the Review uncovered all relevant factors relating to the origination of the mortgage loans, their compliance with applicable law and regulations 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 AMC are dependent upon its receiving complete and accurate data regarding the mortgage loans from mortgage loan originators and other third parties upon which AMC is relying in reaching such findings.

 

Please be further advised that AMC does not employ personnel who are licensed to practice law in the various jurisdictions, and the findings set forth in the reports prepared by AMC do not constitute legal advice or opinions. They are recommendations or conclusions based on information provided to AMC. Information contained in any AMC report 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 mortgage loan. 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 the potential liability related to the purchase or other transaction involving any such mortgage loan or mortgage loans, shall be made solely by the Client, or other agreed upon party, that has engaged AMC to prepare its reports pursuant to its instructions and guidelines. The Client, or other agreed upon party, acknowledges and agrees that the scoring models applied by AMC 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. AMC does not make any representation or warranty as to the value of any mortgage loan or mortgage loan’s collateral that has been reviewed by AMC.

 

AMC reviewed each mortgage loan to determine, as applicable, to the extent possible and subject to the caveats below, whether the mortgage loan complies with:

 

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FOR APPLICATION DATES BEFORE JANUARY 10, 2014

(I) Federal Truth in Lending Act (“TILA”), as implemented by Regulation Z, 12 C.F.R. Part 1026, as set forth below:

a)Rescission (§1026.23):
i)failure to provide the right of rescission notice;
ii)failure to provide the right of rescission notice in a timely manner and to the correct consumer(s);
iii)errors in the right of rescission notice;
iv)failure to provide the correct form of right of rescission notice;
v)failure to provide the three (3) business day rescission period; and
vi)any material disclosure violation on a rescindable loan that gives rise to the right of rescission under TILA, which means the required disclosures of the annual percentage rate, the finance charge, the amount financed, the total of payments, the payment schedule, the HOEPA disclosures;
b)TIL Disclosure (§§1026.17, 18 and 19) as applicable for loans with application dates prior to October 3, 2015:
i)review and comparison of the initial and final TIL disclosures, and any re-disclosed TIL(s);
ii)proper execution by all required parties;
iii)principal and interest calculations, and proper completion of the interest rate and payment summary; and
iv)timing of initial and re-disclosed TIL(s);
c)Tolerances (§§1026.18, 22 and 23):
i)inaccurate Annual Percentage Rate (APR) outside of applicable tolerance by comparing disclosed APR to re-calculated APR; and
ii)inaccurate Finance Charge outside of applicable tolerance by comparing disclosed Finance Charge to re-calculated Finance Charge;
d)High-cost Mortgage (§§1026.31, 32 and 33):
i)points and fees threshold test;
ii)APR threshold test;
iii)prepayment penalty test; and
iv)compliance with the disclosure requirements, limitation on terms and prohibited acts or practices in connection with a high-cost mortgage;
e)Higher-priced Mortgage Loan (§1026.35):
i)APR threshold test; and
ii)compliance with the escrow account and appraisal requirements;

 

(II) Federal Real Estate Settlement Procedures Act (“RESPA”), as implemented by Regulation X, 12 C.F.R. Part 1024, as set forth below:

a)Good Faith Estimate (GFE) (§1024.7) as applicable for loans with application dates prior to October 3, 2015:
i)confirm the presence of the current GFE form in effect at the time of origination;
ii)verify GFE was provided to the borrower(s) within three (3) business days of application;
iii)verify all sections of the GFE were accurately completed and that information was reflected in the appropriate locations;
iv)determine whether a valid and properly documented changed circumstance accompanies any changes to loan terms and/or fees on any revised GFEs over the applicable tolerance(s); and
v)confirm the presence of a settlement service provider list, as applicable.
b)Final HUD-1/A Settlement Statement (HUD) (§1024.8) as applicable for loans with application dates prior to October 3, 2015:
i)confirm current applicable HUD form was provided;
ii)determination that the loan file contains the final HUD;
iii)escrow deposit on the final HUD matches the initial escrow statement amount; and
iv)verify all sections of the final HUD were accurately completed and that information was reflected in the appropriate locations.
c)GFE and Final HUD Comparison (§1024.7) as applicable for loans with application dates prior to October 3, 2015:
i)review changes disclosed on the last GFE provided to the borrower(s) to determine that such changes were within the allowed tolerances;
ii)confirm loan terms and fees disclosed on the third page of the final HUD accurately reflect how such items were disclosed on the referenced GFE, page 2 of the final HUD and loan documents; and
iii)review any documented cure of a tolerance violation to determine that the proper reimbursement was made and a revised HUD was provided at or within 30 days of settlement.

 

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d)Additional RESPA/Regulation X Disclosures and Requirements (§1024.6, 15, 17, 20, and 33):
i)confirm the presence of the Servicing Disclosure Statement form in the loan file;
ii)verify the Servicing Disclosure Statement was provided to the borrower(s) within three (3) business days of application;
iii)confirm the presence of the Special Information Booklet in the loan file or that the loan file contains documentary evidence that the disclosure was provided to the borrower;
iv)confirm the Special Information Booklet was provided within three (3) business days of application;
v)confirm the presence of the Affiliated Business Arrangement Disclosure in the loan file in the event the lender has affiliated business arrangements;
vi)confirm the Affiliated Business Arrangement Disclosure was provided no later than three (3) business days of application;
vii)confirm the Affiliated Business Arrangement Disclosure is executed; and
viii)confirm the presence of the Initial Escrow Disclosure Statement in the loan file and proper timing.

 

(III) The disclosure requirements and prohibitions of Section 50(a)(6), Article XVI of the Texas Constitution and associated regulations;

 

(IV) The disclosure requirements and prohibitions of state, county and municipal laws and ordinances with respect to “high-cost” loans, “covered” loans, “higher-priced” loans, “home” loans or any other similarly designated loan as defined under such authorities, or subject to any other laws that were enacted to combat predatory lending, as may have been amended from time to time;

 

(V) Federal and state specific late charge and prepayment penalty provisions;

 

(VI) Document Review

AMC reviewed each mortgage loan file and verified if the following documents, if applicable, for the Review scope in question at the time of review, were included in the file and if the data on these documents was consistent:

 

FOR APPLICATION DATES ON OR AFTER JANUARY 10, 2014

For mortgage loans with application dates on or after January 10, 2014 additional compliance testing was applicable and conducted by AMC. Testing during this period included all items as referenced in the FOR APPLICATION DATES BEFORE JANUARY 10, 2014 section above plus:

 

(VII) Federal Truth in Lending Act (“TILA”), as implemented by Regulation Z, 12 C.F.R. Part 1026 testing included:

a)With respect to brokered loans, the Prohibitions and Restrictions related to Loan Originator Compensation and Steering (§1026.36):
i)review relevant documentation to determine if compensation to a Loan Originator was based on a term of the transaction;
ii)review relevant document to determine if there was dual compensation; and

 

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iii)review the presence of the loan option disclosure and to determine if the Steering Safe Harbor provisions were satisfied.
(1)Note: Where available, AMC reviewed the relevant documents in the loan file and, as necessary, attempted to obtain the loan originator compensation agreement and/or governing policies and procedures of the loan originator. In the absence of the loan originator compensation agreement and/or governing policies and procedures, AMC’s review was limited to formal general statements of entity compliance provided by the loan originator, if any. These statements, for example, were in the form of a letter signed by the seller correspondent/loan originator or representations in the mortgage loan purchase agreement between the Client and seller correspondent;
b)Homeownership counseling (§1026.36):
i)determine if the creditor obtained proof of homeownership counseling in connection with a loan to a first time homebuyer that contains a negative amortization feature;
c)Mandatory Arbitration Clauses (§1026.36):
i)determine if the terms of the loan require arbitration or any other non-judicial procedure to resolve any controversy or settle any claims arising out of the transaction;
d)Prohibition on Financing Credit Insurance (§1026.36):
i)determine if the creditor financed, directly or indirectly, any premiums or fees for credit insurance; and
e)Nationwide Mortgage Licensing System (NMLS) & Registry ID on Loan Documents (§1026.36):
i)review for presence of loan originator organization and individual loan originator name and NMLSR ID, as applicable, on the credit application, note or loan contract, security instrument, Loan Estimate and Closing Disclosure; and
ii)verify the data against the NMLSR database, as available.

 

(VIII) Federal Real Estate Settlement Procedures Act (“RESPA”), as implemented by Regulation X, 12 C.F.R. Part 1024, as set forth below:

a)Additional RESPA/Regulation X Disclosures and Requirements (§1024.6, 15, 17, 20, and 33):
i)confirm that the creditor provided the borrower a list of homeownership counseling organizations within three (3) business days of application; and
ii)confirm that the list of homeownership counseling organizations was obtained no earlier than 30 days prior to when the list was provided to the loan applicant.

 

(IX) 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, as set forth below:

a)The general Ability to Repay (ATR) underwriting standards (12 C.F.R. 1026.43(c));
b)Refinancing of non-standard mortgages (12 C.F.R. 1026.43(d));
c)Qualified Mortgages (QM) (12 C.F.R. 1026.43(e) (including qualified mortgages as separately 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
d)Balloon-payment qualified mortgages made by certain creditors (12 C.F.R. 1026.43(f)).

 

AMC reviews applicable loans for compliance with the ATR and QM rule requirements based upon each loan’s originator designation (Safe Harbor QM, Higher-priced QM, Temporary SHQM, Temporary HPQM, Non-QM, Exempt from ATR). AMC determines the loan’s status under the ATR or QM rule requirements and assigns a due diligence loan designation. Generally, AMC notes as a material exception if the due diligence findings do not confirm the originator’s loan designation. Additionally, AMC notes if an originator loan designation was not provided.

 

Qualified Mortgage

With respect to QM (Safe Harbor and Higher-priced) designated loans, AMC 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, (iv) the creditor considered and verified income or assets at or before consummation, (v) the creditor appropriately considered debt obligations, alimony and child support, and (vi) at the time of consummation, if the debt-to-income ratio exceeds 43% (calculated in accordance with Appendix Q to Regulation Z). This portion of the Review includes a recalculation of all income and liabilities with attention to the appropriate documentation of each source.

 

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, AMC reviews the loan to determine whether, based on available information in the

 

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loan file the loan satisfied (i), (ii) and (iii) in the preceding paragraph and reviews the Automated Underwriting System output within the file to confirm agency eligibility.

 

For each QM designated loan that satisfied the applicable requirements enumerated above, AMC 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 applicable percentage.

 

The Review also includes determining, as applicable, whether a loan is a qualified mortgage 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.).

 

For each QM designated loan that does not satisfy the applicable requirements enumerated above, AMC then determines whether the loan complies with the ATR rule consideration and verification requirements and provides a due diligence designation of Non-QM compliant or non-compliant.

 

General Ability to Repay

AMC reviews the loan to determine whether, based on available information in the loan file, the creditor considered, as applicable, the following eight underwriting factors, and verified such information using reasonably reliable third-party records, at or before consummation: (i) the consumer's current or reasonably expected income or assets, (ii) if the creditor relied on income from the consumer's employment in determining repayment ability, the consumer's current employment status; (iii) the consumer's monthly payment; (iv) the consumer's monthly payment on any simultaneous loan that the creditor knows or has reason to know will be made; (v) the consumer's monthly payment for mortgage-related obligations; (vi) the consumer's current debt obligations, alimony, and child support; (vii) the consumer's monthly debt-to-income ratio or residual income; and (viii) the consumer's credit history. This portion of the Review also focuses on full recalculation of income and debts, as well as the documentation provided to support each item used in originator’s determination of the ability to repay.

 

Note: for loans designated as QM – agency eligible, AMC will not review for compliance with the requirements of Appendix Q or General Ability to Repay.

 

AMC reviews loans to determine their conformity with the ATR/QM factors above, and is not rendering an independent assessment or opinion, warranting or representing that a loan will be deemed to conform to Safe Harbor, Rebuttable Presumption, ATR or other status based on any additional or revised factors that may be considered by legislative, regulatory, administrative or judicial authorities (“Authorities”). AMC does not represent or warrant that the factors for which it is reviewing the loans constitute all of the factors and/or criteria that Authorities may consider in determining the status of a loan. AMC’s review is based on information contained in the loan file at the time it is provided to AMC to review, and only reflects information as of that point in time.

 

(X) The Equal Credit Opportunity Act, as implemented by Regulation B, 12 C.F.R. Part 1002, as set forth below:

a)Providing Appraisals and Other Valuations (12 C.F.R. 1002.14):
i)timing and content of the right to receive copy of appraisal disclosure;
ii)charging of a fee for a copy of the appraisal or other written valuation;
iii)timing of creditor providing a copy of each appraisal or other written valuation;
iv)with respect to a borrower that has waived the three (3) business day disclosure requirement, confirm that the borrower has signed the waiver or other acknowledgment at least three (3) business days prior to consummation; and (2) confirm that the lender has provided copies of appraisals and other written valuations at or prior to consummation.

 

(XI) FIRREA Review

AMC confirmed that the appraiser and the appraisal made by such appraiser both satisfied the requirements of Title XI of FIRREA. Specifically, AMC reviewed the appraisal for conformity to industry standards, including ensuring the appraisal was complete, that the comparables and adjustments were reasonable and that pictures were provided and were accurate. 

 

FOR APPLICATION DATES ON OR AFTER OCTOBER 3, 2015

For mortgage loans with application dates on or after October 3, 2015 additional compliance testing was applicable and conducted by AMC. Testing during this period included all items as referenced in the FOR APPLICATION DATES

 

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BEFORE JANUARY 10, 2014 and FOR APPLICATION DATES ON OR AFTER JANUARY 10. 2014 sections above plus:

 

With regard to TILA-RESPA Integrated Disclosure (“TRID”) testing, AMC implemented the TRID scope of review referenced within the Regulatory Compliance section (III) based on (i) the RMBS 3.0 TRID Compliance Review Scope published by the Structured Finance Industry Group (the "SFIG Compliance Review Scope") and (ii) outside counsel’s interpretations of the published regulations as of the date of review of each mortgage loan. AMC worked with outside counsel and continues to obtain updated interpretations relative to the informal guidance provided by the Consumer Financial Protection Bureau (“CFPB”) which has caused alterations in the review scope and severity of TRID related exceptions, including applicable cures. (This will continue as necessary as additional guidance becomes available, as well as any future rulemaking.) While AMC continues to make a good faith effort to identify material TRID exceptions and apply the appropriate grading, the implementation of new regulations (including TRID) that impact residential mortgages carries certain interpretive risk and continues to evolve, impacting the review scope and exception severity. AMC has worked closely with the NRSROs and Client to disclose, as mutually agreed upon by the parties, the relevant exceptions per AMC’s suggested review implementation as reviewed by outside counsel; however, no assurances can be provided and/or are given that AMC has included within its Review all areas that may represent risk to the securitization trust, or that areas of risk identified by AMC will result in the potential level of risk indicated by an Event Level or NRSRO grade.

 

Please be further advised that AMC does not employ personnel who are licensed to practice law in the various jurisdictions, and the findings set forth in the reports prepared by AMC do not constitute legal advice or opinions. They are recommendations or conclusions based on information provided to AMC. Information contained in any AMC report 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 mortgage loan. 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 the potential liability related to the purchase or other transaction involving any such mortgage loan or mortgage loans, shall be made solely by the Client, or other agreed upon party, that has engaged AMC to prepare its reports pursuant to its instructions and guidelines. The Client, or other agreed upon party, acknowledges and agrees that the scoring models applied by AMC 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. AMC does not make any representation or warranty as to the value of any mortgage loan or mortgage loans collateral that has been reviewed by AMC.

 

AMC reviewed each residential mortgage loan to determine, as applicable, to the extent possible and subject to the caveats below, whether the mortgage loan complies with:

 

(XII) Sections 1098 and 1100A of Dodd-Frank amending TILA and RESPA, as implemented by Regulation Z, 12 C.F.R. Part 1026, as set forth below (applicable only for mortgage loans with application dates on or after October 3, 2015):

a)Loan Estimate (LE) (§§1026.19 and 37):
i)confirm the presence of LE for applications on or after October 3, 2015;
ii)confirm the initial LE date indicates it was delivered or placed in the mail within three (3) business days of application;
iii)confirm that certain sections of each LE determined to carry assignee liability were accurately completed and that information was reflected in the appropriate locations, which, in certain instances, was based solely on the information disclosed on the LE;
iv)confirm the initial LE was delivered or placed in the mail not later than seven (7) business days prior to consummation of the transaction, or such period was waived due to a bona fide financial emergency;
v)confirm that any written estimate of terms or costs provided prior to receipt of a LE contained the required disclosures;
vi)confirm that each revised LE is accompanied by valid written documentation explaining the reason for re-disclosure to allow for fee increases based on a valid change of circumstance and was timely provided within 3 business days of issuance;
vii)confirm the presence and timely provision of a settlement service provider list (when consumer is given the opportunity to shop for services);
viii)confirm borrower received LE not later than four (4) business days prior to consummation; and

 

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ix)confirm LE was not provided to the borrower on or after the date of the CD.
b)Closing Disclosure (CD) (§§1026.19 and 38):
i)confirm the presence of CD for applications on or after October 3, 2015;
ii)confirm the borrower received CD at least three (3) business days prior to consummation, or that such period was waived due to a bona fide financial emergency;
iii)confirm that certain sections of each CD determined to carry assignee liability were accurately completed and that information was reflected in the appropriate locations, which, in certain instances, was based solely on the information disclosed on the CD;
iv)confirm that a revised CD was received in a timely manner if the initial or any revised CD became inaccurate;
v)identify tolerance violations based on the charges disclosed on the initial and interim LE’s, initial CD, and reflected on the final CD;
vi)with respect to tolerance violations based on the disclosed charges on the LE and CD, confirm that the creditor cured the violations no later than 60 days after consummation, or within 60 days of discovery; and
vii)with respect to applicable exception remediation measures for numerical exceptions, confirm that a letter of explanation, as well as a refund as applicable, was delivered or placed in the mail no later than 60 days after discovery of the exception establishing the need for a revised CD or with respect to exception remediation measures for non-numerical exceptions, that a corrected CD was delivered or placed in the mail no later than 60 days after consummation. (In an attempt to establish a best practices approach to pre-securitization due diligence, as it applies to TILA RESPA Integrated Disclosure testing, the Structured Finance Industry Group (“SFIG”) has a working group that consists of industry participants including third party review providers and law firms who agreed to a standardized approach to remediation considerations. This approach is intended to be based on a reasoned legal analysis that expressly assumes that courts will interpret TRID in accordance with the principals of liability set forth in the letter to the MBA from Richard Cordray, the Director of the CFPB. No assurances can be provided that the courts in question will interpret TRID in accordance with the SFIG Compliance Review Scope.)
c)Your Home Loan Toolkit (§1026.19):
i)confirm the presence of Your Home Loan Toolkit in the mortgage loan file or that the mortgage loan file contains documentary evidence that the disclosure was provided to the borrower; and
ii)confirm Your Home Loan Toolkit was delivered or placed in the mail not later than three (3) business days after receipt of application.
  

(XIII) Document Review

AMC reviewed each mortgage loan file and verified if the following documents, if applicable, were included in the file and if the data on these documents was consistent (where applicable):

 

(8) Other: review and methodology.

 

Modification Review: AMC conducted a review of the modification, or modifications, contained within the mortgage loan file.

Collection Comment Review: Following the acquisition of the mortgage loans but before securitization, AMC performed a review utilizing individual mortgage loan collection comments provided by the servicer in order to provide a brief summary outlining current performance status, the borrower’s ability to pay, relative future/current risk (including hardship, life changes, etc.), possible servicer remedies, loss mitigation efforts, and modifications.

 

Payment History Review: AMC performed a review utilizing individual mortgage loan payment history reports provided by the servicer of the mortgage loans. Using the MBA methodology, AMC created a payment string using a 24 or 36 month look back for each mortgage loan within the payment history random sample population.

 

Title Review: As requested by the Client, a title review was included in AMC’s scope of review. To facilitate this review, the Client provided AMC with identifying data on the population of mortgage loans. Data provided by the client, included mortgage loan and servicer identification numbers as well as subject property address, borrower names, origination date, original mortgage loan amount for the subject mortgage and title policies from origination as it relates to the subject mortgage. Using the data provided, AMC ordered a current owner’s title search on these mortgage loans through a service

 

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provider. Upon receipt and review of the current owner’s title search results, AMC identified whether or not the subject mortgage was of record, whether any deed vesting concerns of substance were present, and whether the title search report revealed any liens and/or judgments which could affect the seniority of the subject mortgage, including potentially superior post origination liens and/or judgments such as Property Tax Liens, Municipal Liens, and Association Super Liens. AMC reviewed the title policies for all liens and/or judgments that were recorded before the recordation of the subject mortgage to determine if any identifiable liens and/or judgments were listed as an exception on Schedule B of the applicable title policies.

 

The final review results reflected in the Overall Review Results Summary herein may include additional exceptions identified after AMC’s initial review was completed where loan level issues were identified by external parties as a result of separate, distinct quality control evaluation of the loan files. In such cases, any additional exceptions cited by any such quality control evaluation would either be reflected (i) as an open exception or (ii) remediated if required documentation and/or curative actions were provided to AMC. The exception totals reflected herein, and corresponding Exception Rating, include exceptions that were so subsequently identified, if any. Please note that only a limited number of loans, if any, reflected in the Review Results Summary were subject to such external quality control evaluations.

 

(9) Disclaimer.

Except as expressly enumerated and discussed above, please be advised that AMC has not performed any review to determine whether the mortgage loans covered in this Report complied with federal, state or local laws, constitutional provisions, regulations, ordinances or any other laws or guidance, including, without limitation, licensing and general usury laws (“Applicable Law”).  Further, there can be no assurances that in performing the review and preparing this Report that AMC has uncovered all relevant factors and potential issues relating to the origination of the mortgage loans, their compliance with Applicable Law, or the original appraisals relating to the mortgaged properties, or that AMC has uncovered all relevant factors that could affect the future performance of the mortgage loans. Please note that the results set forth in this Report are dependent upon receipt of complete and accurate data regarding the mortgage loans from mortgage loan originators, sponsors, issuers, underwriters, and other third parties upon which AMC is relying in reaching such results.  Except as expressly stated herein, AMC did not verify the data relied upon in performing its review and producing this Report.  In addition, the findings and conclusions set forth in this Report are provided on an “as is” basis and are based on available information and Applicable Law as of the date of this Report, and AMC does not undertake any obligation to update or provide any revisions to this Report to reflect events, circumstances, changes in Applicable Law, or changes in expectations after the date this Report was issued.  AMC also hereby disclaims any representation or warranty as to accuracy or completeness of the Report, the inclusion or omission of any facts or information, or as to its suitability, sufficiency or appropriateness for the purposes of the transaction parties or investors or the use of the Report in preparation of any other document in connection with the subject transaction). 

 

Please be further advised that AMC does not employ personnel who are licensed to practice law in the various jurisdictions covered in this Report, and the results set forth in this Report do not constitute legal advice or legal opinions whatsoever. The findings are recommendations or conclusions based on information provided to AMC, and are not statements of fact or legal conclusions. Information contained in the Report 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 mortgage loan.  The authorities administering the Applicable Law that was part of the review have broad discretionary powers which may permit such authorities, among other things, to withdraw exemptions accorded by statute or regulation, to impose additional requirements or to reach a conclusion that is not consistent with the results set forth in the Report. All decisions as to whether to issue, purchase, hold, sell or otherwise transact in securities backed by the mortgage loans reviewed in this Report, any investment strategy and any legal conclusions, including the potential liability related to the purchase or other transaction involving any such securities, shall be made solely by the parties to or investors in the transaction. The results set forth in this Report do not constitute tax or investment advice.  The scoring models in this Report are designed to identify potential risk in the securities backed by the mortgage loans reviewed, and each party or investor assumes sole responsibility for determining the suitability of the information for its particular use. AMC does not make any representation or warranty (express or implied) as to the value of any mortgage loan or mortgage loan’s collateral that has been reviewed by AMC.

 

SUMMARY OF FINDINGS & CONCLUSIONS OF REVIEW

The NRSRO criteria referenced for this report and utilized for grading descriptions is based upon the requirements of Fitch Ratings, Inc. (“Fitch”).

 

 

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OVERALL REVIEW RESULTS SUMMARY (1,681 Mortgage Loans)

There were 1,681 mortgage loans in the securitization population reviewed by AMC. After all documents were presented, under the applicable Fitch NRSRO grading criteria 187 (11.12%) had an Overall grade of “A”, 1,219 (72.52%) had an Overall grade of “B”, 115 (6.84%) loans had exceptions that generated an Overall grade of “C”, and 160 (9.52%) had an Overall grade of “D”.

 

Loan Level: Fitch NRSRO Grade Loan Count % of Loans
A 187 11.12%
B 1,219 72.52%
C 115 6.84%
D 160 9.52%
Total 1,681 100.00%

 

COMPLIANCE RESULTS SUMMARY (1,679 Mortgage Loans)

Under the Fitch applicable grading criteria, 275 mortgage loans (16.38%) are retaining rating agency grades of “C” or “D” and 1,218 mortgage loans (72.54%) retaining a grade of “B”. The remaining 186 mortgage loans (11.08%) are rating agency grade “A” with no exceptions noted.

 

Pursuant to the applicable NRSRO criteria, AMC graded certain compliance exceptions as non-material based upon seasoning of the mortgage loans. 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 is raised as a defense to foreclosure. Information contained in any AMC report 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 mortgage loan.

 

Fitch NRSRO Grade Loan Count % of Loans
A 186 11.08%
B 1,218 72.54%
C 115 6.85%
D 160 9.53%
Total 1,679 100.00%

 

LEASES CREDIT REVIEW RESULTS SUMMARY (2 Mortgage Loans)

Of the 1,681 mortgage loans in the securitization population, 2 loans were originated as a Lease and required a full credit review. The following table reflects the 2 mortgage loans that were subject to a Credit review.

 

Under the applicable NRSRO grading criteria, 1 (50.00%) received an “A” Credit Review grade and 1 mortgage loan (50.00%) received an “B” Credit Review grade.

 

Credit NRSRO  Grade Loan Count % of Loans
A 1 50.00%
B 1 50.00%
C 0 0.00%
D 0 0.00%
Total 2 100.00%

 

 

PROPERTY/VALUATION REVIEW RESULTS SUMMARY (2 Mortgage Loan)

Of the 1,681 mortgage loans in the securitization population, 2 loans were originated as a Lease and required a property/valuation review. The following table reflects the 2 mortgage loans that were subject to a Property Review.

 

 

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Under the applicable NRSRO grading criteria, 2 mortgage loans (100.00%) received an “A” Property Review grade.

 

Property NRSRO Grade Loan Count % of Loans
A 2 100.00%
B 0 0.00%
C 0 0.00%
D 0 0.00%
Total 2 100.00%

 

 

REVIEW EXCEPTION SUMMARY (1,681 Mortgage Loans)

The summaries below detail the exceptions from the review that would have resulted in a “B”, “C”, or “D” grade for a given mortgage loan. Please note that exception grades of EV1, EV2, and EV3 may not result in a corresponding “B”, “C”, or “D” grade per relevant rating agency guidelines due to considerations including statute of limitations and specific characteristics of ratings by a given NRSRO. Also note that some mortgage loans may have multiple exceptions and, as a result, may have an exception or multiple exceptions in any one exception category.

 

 

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COMPLIANCE REVIEW EXCEPTION SUMMARY (1,679 Mortgage Loans)

Exception Type Fitch Final Exception Rating Exception Category Total

Compliance D Missing, Incorrect, or Incomplete HUD-1 132
Incomplete File 28
Total Compliance Grade (D) Exceptions: 160
C ATR/QM Defect 319
State Defect 22
State HPML 2
Compliance 2
TILA 1
Total Compliance Grade (C) Exceptions: 346
B RESPA 1,249
TILA 649
Missing Application Date 629
TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 505
Missing Non-Required Data 496
TRID Defect 418
Safe Act 324
Missing, Incorrect, or Incomplete GFE 269
FACTA 207
TIL-MDIA 176
Missing Required Data 145
Missing, Incorrect, or Incomplete Final TIL 130
LTV Test 125
ECOA 106
Misc. State Level 96
State Defect 86
Missing Required Data (other than HUD-1 or Note) 86
Loan Package Documentation 78
State Late Charge 31
Final TIL Estimated 27
Missing, Incorrect, or Incomplete Final or Initial 1003 23
ATR/QM Defect 17
Federal HPML 15
TRID 13
Compliance 5
Missing, Incorrect, or Incomplete HUD-1 5
ATR/QM 4
Missing Disclosure 4
State HPML 4
Other TILA Violations 3
Missing Document 2
FHA 1
GSE 1
Missing, Incorrect, or Incomplete Initial TIL 1
Total Compliance Grade (B) Exceptions: 5,930
Total Compliance Exceptions: 6,436

 

LEASE REVIEW EXCEPTION SUMMARY (2 Mortgage Loans)

Exception Type Fitch Final Exception Rating Exception Category Total
Credit B Guideline 1
Total Credit Grade (B) Exceptions: 1
Total Credit Exceptions: 1
Total Property Exceptions: 0

 

COLLECTION COMMENT REVIEW SUMMARY (1,683 Mortgage Loans)

Of the mortgage loans subject to the collection comment review, 1,532 mortgage loans (91.03%) triggered an EV1 or EV2 exception level, and 151 mortgage loans (8.97%) triggered an EV3.

 

Servicing Review Grade Loan Count % of Loans
1 1,272 75.58%
2 260 15.45%
3 151 8.97%
Total 1,683 100.00%

 

PAYMENT HISTORY REVIEW SUMMARY (1,683 Mortgage Loans)

A Payment History Review was completed on 1,683 mortgage loans. Of the 1,683 mortgage loans subjected to the Payment History Review, 1,680 mortgage loans (99.82%) had complete pay history strings and 3 mortgage loans (0.18%) had incomplete pay history strings. Of the mortgage loans reviewed, 501 mortgage loans (29.77%) did not show delinquency within the look back period and 1,182 mortgage loans (70.23%) showed at least one delinquency within the look back period.

 

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Of the 1,683 mortgage loans reviewed, all 1,683 mortgage loans (100.00%) were reviewed with a cut-off date of August 31, 2025, and with a twenty-four month look back period.

 

Category Loan Count % of Loans
No Delinquency, No Missing Data 498 29.59%
Delinquency, No Missing Data 1,182 70.23%
No Delinquency, At Least One Month Missing 3 0.18%
Delinquency, At Least One Month Missing 0 0.00%
Total 1,683 100.00%

 

Lookback Loan Count % of Loans
Twenty-Four (24) Months 1,683 100.00%
Total 1,683 100.00%

 

SitusAMC TITLE REVIEW SUMMARY (1,683 Mortgage Loans)

As part of the due diligence services, the Client provided SitusAMC with identifying data on 1,683 mortgage loans. Based on the scope of review set forth herein, the critical findings are summarized as follows:

 

·Except with respect to 6 mortgage loan files, there are no potential issues concerning origination deed vesting. With respect to the 6 mortgage loan files, all the mortgage loan files contain a Title Policy on which there are no stated exceptions which explicitly preclude coverage.
·Except with respect to 136 Association Liens across 56 mortgage loan files, no unresolved Super Position HOA Liens recorded after the subject mortgage which were entitled to limited or full lien priority over the subject mortgage were identified. 52 of these Association Liens were determined to be passed the statutory timeline for enforceability.
·Except with respect to 331 Municipal Liens across 123 mortgage loan files, no unresolved Municipal Liens which had limited or full lien priority over the subject mortgage were located.
·Except with respect to 19 Property Tax Liens across 13 mortgage loan files, no unresolved Property Tax Liens which had limited or full lien priority over the subject mortgage were located.
·Except with respect to 34 Prior Liens across 25 mortgage loan files which were recorded prior to the subject mortgage, all Prior Liens identified in our review have been resolved. With respect to the 34 Prior Liens across 25 mortgage loan files, 28 Prior Liens were determined to be mitigated as the mortgage loan files contain a Title Policy on which there are no stated exceptions which explicitly preclude coverage, 4 Prior Liens were determined to be mitigated as the timeline for enforceability has passed, and 2 Prior Liens could not be mitigated as the loan files contained insufficient title evidence.
·Except with respect to 45 Prior Mortgages across 42 mortgage loan files which were recorded prior to the subject mortgage, all Prior Mortgages identified in our review have been resolved. With respect to the 45 Prior Mortgages across 42 mortgage loan files, 36 Prior Mortgages were determined to be mitigated as the mortgage loan files contain a Title Policy on which there are no stated exceptions which explicitly preclude coverage, 4 Prior Mortgages were determined to be mitigated as the timeline for enforceability has passed, and 5 Prior Mortgages could not be mitigated as the loan files contained insufficient title evidence.
·Except with respect to 4 mortgage loans, there are no potential issues concerning the enforceability of the subject mortgage. With respect to the 4 mortgage loans, 2 loan files contained evidence of Release/Satisfaction of the subject mortgage, and 2 loan files contained evidence of Foreclosure/Extinguishment of the subject mortgage.
·As to any Miscellaneous Items of substance, the items in this category typically defy standard categorization or summarization and are individually detailed.

 

ADDITIONAL SUMMARY

Some % of Loans may not add to 100% due to rounding

 

AMC Diligence, LLC (1,681 Mortgage Loans)

 

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Amortization Type Loan Count % of Loans
Fixed 1,481 88.10%
Adjustable 189 11.24%
Unknown 11 0.65%
Total 1,681 100.00%
     
Lien Position Loan Count % of Loans
1 1,668 99.23%
2 1 0.06%
Unknown 12 0.71%
Total 1,681 100.00%
     
Loan Purpose Loan Count % of Loans
Cash Out: Debt Consolidation 293 17.43%
Cash Out: Home Improvement/Renovation 5 0.30%
Cash Out: Other/Multi-purpose/Unknown Purpose 277 16.48%
Limited Cash-Out 11 0.65%
First Time Home Purchase 266 15.82%
Other-than-first-time Home Purchase 271 16.12%
Rate/Term Refinance - Lender Initiated 34 2.02%
Rate/Term Refinance - Borrower Initiated 455 27.07%
Unavailable 69 4.10%
Total 1,681 100.00%
     
Original Term Loan Count % of Loans
0-120 Months 2 0.12%
121-180 Months 103 6.13%
181-240 Months 80 4.76%
241-360 Months 1,463 87.03%
361+ Months 21 1.25%
Unknown 12 0.71%
Total 1,681 100.00%
     
Property Type Loan Count % of Loans
Single Family Detached 1,035 61.57%
Co-op 1 0.06%
Condo, Low Rise 96 5.71%
Condo, High Rise 11 0.65%
PUD 208 12.37%

 

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Townhouse 6 0.36%
Single-wide Manufactured Housing 15 0.89%
1 Family Attached 36 2.14%
2 Family 49 2.91%
3 Family 9 0.54%
4 Family 10 0.59%
Unavailable 205 12.20%
Total 1,681 100.00%
     
Occupancy Loan Count % of Loans
Primary 1,503 89.41%
Investment 86 5.12%
Second Home 33 1.96%
Unknown 59 3.51%
Total 1,681 100.00%

 

 

 

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 Exhibit 99.1 - Schedule 10

MORGAN STANLEY CAPITAL I INC. ABS-15G/A

 

 

 

Redacted ID LOANID LOANID2 SLOANID Final Current Event Level Current Exceptions Servicing Comments Status Date Last Action Date per Servicer
186554176 XXXX   XXXX 1   LOAN STATUS: The current loan status is Performing.
PAY HISTORY: The loan is next due for XX/XX/XXXX.
BORROWER CONTACT: The last contact with the borrower or authorized third party on the borrower's behalf was XX/XX/XXXX.  Agent spoke with borrower regarding escrow change.
EVIDENCE OF DISPUTE: No evidence of borrower dispute.
REASON FOR DEFAULT: The loan is performing and delinquency reason is not applicable.
FORECLOSURE: No evidence of current foreclosure activity.
BANKRUPTCY: There is no evidence of current or prior bankruptcy.
LITIGATION: There is no evidence of litigation on the file.
TITLE ISSUES: There is no evidence of title issues.
PROPERTY CONDITION: There is no evidence of property damage.  The property condition is UTD.  The current occupancy status is owner occupied.
ADDITIONAL INFORMATION: N/A
08/31/2025 08/15/2025
186554177 XXXX   XXXX 3 [3] Damaged Interior - Active insurance claim but unclear who holds funds or covered by bid

[1] Written Dispute - Servicer responded within XX days and no further communication from mortgagor
LOAN STATUS: The current loan status is Performing.
PAY HISTORY: The loan is next due for XX/XX/XXXX.
BORROWER CONTACT: The last contact with the borrower or authorized third party on the borrower's behalf was XX/XX/XXXX.  Borrower called in scheduled a payment for XX/XX/XXXX.
EVIDENCE OF DISPUTE: Evidence of borrower dispute dated XX/XX/XXXX.  The dispute type is Written and the reason is Payment Dispute.  The dispute is resolved and the status indicates Servicer responded within XX days and no further communication from mortgagor.  Comment's dated XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX, and XX/XX/XXXX indicates response to dispute via E-OSCAR sent. On XX/XX/XXXX borower called in regarding late payment reported. Borrower disputed the late reporting. Advised borrower to sent dispute.
REASON FOR DEFAULT: The loan is performing and delinquency reason is not applicable.
FORECLOSURE: No evidence of current foreclosure activity.
BANKRUPTCY: There is no evidence of current or prior bankruptcy.
LITIGATION: There is no evidence of litigation on the file.
TITLE ISSUES: There is no evidence of title issues.
PROPERTY CONDITION: There is evidence of property damage and the nature of the damage is unavailable in the information provided.  Comment dated XX/XX/XXXX indicates borrower called in to claim as roof need to be repaired. On XX/XX/XXXX borrower called for damage check. wanted to know why the claim check is not sent. On XX/XX/XXXX borrower was advised check was finalized on XX/XX/XXXX will take XX business days for endorsement. On XX/XX/XXXX borrower was check received and deposited in the amount of $XX.XX. Advised timeframe of XX business days. On XX/XX/XXXX the check in the amount of $XX.XX reissued for the third time. On XX/XX/XXXX borrower stated ceiling came down and made repair from out of pocket. Check not received yet. No indication of inspection report.  Property repair is in process.  The property condition is UTD.  The current occupancy status is owner occupied.
ADDITIONAL INFORMATION: N/A
08/31/2025 08/20/2025

 

 

 

 

 Exhibit 99.1 - Schedule 11

MORGAN STANLEY CAPITAL I INC. ABS-15G/A

 

 

 

Redacted ID LOANUID LOANID LOANID2 SLOANID First Payment Date Data Cutoff Date Pay History Scope Pay History Summary (MBA) Months of Data Missing During Lookback Delinquency During Lookback
186554176   XXXX   XXXX XX/XX/XXXX 08/31/2025 24 000000000000000000000000 0 0
186554177   XXXX   XXXX XX/XX/XXXX 08/31/2025 24 000000000000000001000000 0 1

 

 

 

 

 Exhibit 99.1 - Schedule 12

MORGAN STANLEY CAPITAL I INC. ABS-15G/A

 

 

Loan ID Client LN SitusAMC ID Seller LN Servicer LN Address City ST Zip Trade Title Report Effective Date Title Report Date Tax Certificate Effective Date Subject Lien Recorded Number of Pages Recorded Subject Mortgage Originator Origination Balance Origination Date Recording Date Mortgage Book Mortgage Page Mortgage Doc Number County of Recording State of Recording Critical Defect SMtg Open Address Variation Origination Vesting Current Vesting SMtg First Position Mortgage Prior Lien / Judgment Municipal Lien Association Super Lien Property Tax Lien Property Tax Status SMtg Lien Position (Mortgages) Critical Exception Count Prior Mortgage Exception Count Prior Mortgage Exception Total Prior Mortgage Exception Details Prior Lien Exception Count Prior Lien Exception Total Prior Lien Exception Details Municipal Lien Exception Count Municipal Lien Exception Total Municipal Lien Exception Details Property Tax Lien Exception Count Property Tax Lien Exception Total Property Tax Lien Exception Details Association Lien Exception Count Association Lien Exception Total Association Lien Exception Details IRS Lien Exception Count IRS Lien Exception Total IRS Lien Exception Details Deed Vesting Exception Categories Property Tax Status Issue DQ Property Tax Amount Property Tax Status Details Final Event Level Title Exceptions Title Comments
186554176 XXXX XXXX XXXX   XXXX XXXX XX XXXX XXXX 10/09/2025 10/13/2025   Yes 19 XXXX XXXX XX/XX/XXXX XX/XX/XXXX     XXXX XXXX XX Pass Pass Pass Pass Pass Pass Pass Pass Pass Pass Pass 1 0       0     0     0     0     0             2 Subordinate Mortgage

Prior Mortgage - Title Policy Coverage

Prior Lien - Title Policy Coverage
XXXX
186554177 XXXX XXXX XXXX   XXXX XXXX XX XXXX XXXX 09/29/2025 10/08/2025   Yes 15 XXXX XXXX XX/XX/XXXX XX/XX/XXXX     XXXX XXXX XX Pass Pass Pass Pass Pass Pass Pass Pass Pass Pass Pass 1 0       0     0     0     0     0             1    

 

 

 

  

 

 

 

Loan ID Client LN SitusAMC ID Seller LN Address City ST Zip Trade Origination Balance Origination Date Unique Exception ID Exception Grade Raw Exception Grade Exception Category Exception Subcategory Exception Type SOL Expired SOL Expiration Date Exception Detail Title Policy Title Policy Insurer Title Policy Effective Date Title Policy Exception Paid on HUD CBR Status Borrower Vested on Title Policy Lien Amount Accrual Rate Lienholder Recording Date Additional Exception Information
186554176 XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XX/XX/XXXX 34721243 2 2 Title Diligence Subordinate Mortgage Subordinate Mortgage                     XXXX   XXXX XX/XX/XXXX XXXX
186554176 XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XX/XX/XXXX 34721245 2 2 Title Diligence Lien Priority Prior Mortgage - Title Policy Coverage No     Final XXXX XX/XX/XXXX No No Open   XXXX   XXXX XX/XX/XXXX XXXX
186554176 XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XX/XX/XXXX 34721246 2 2 Title Diligence Lien Priority Prior Lien - Title Policy Coverage No     Final XXXX XX/XX/XXXX No No     XXXX   XXXX XX/XX/XXXX XXXX

 Exhibit 99.1 - Schedule 13

MORGAN STANLEY CAPITAL I INC. ABS-15G/A

 

 

 

Modification Only Extract

Run Date - 11/XX/2025 3:57:29 PM  

Unique ID AMC Loan ID Customer Loan ID Seller Loan ID Servicer Loan ID Borrower Name Street City State Zip Has Modification? Mod Doc Status Mod Amortization Type Total Amount Deferred Mod UPB Mod Principal Forgiven Mod Amount Capitalized Mod Deferred Balance Mod Accruing UPB Mod Date Mod First Payment Date Mod Maturity Date Mod Original Term Mod Amortization Term Mod Original Interest Rate Mod P&I Mod P&I - Calculated Mod Payment Frequency Mod Interest Collection Type Mod Interest Only? Mod Interest Only Period Mod Interest Only Period Expiration Mod Balloon? Mod Neg Am? Mod Months Extended Mod Neg Am Cap (% of UPB) Principal Reduction Alternative Balance Eligible Principal Reduction Alt Amount PRA Year 1 Anniversary Date PRA Year 1 Reduction Amount PRA Year 2 Anniversary Date PRA Year 2 Reduction Amount PRA Year 3 Anniversary Date PRA Year 3 Reduction Amount Mod Program Type Mod Cure Mod Teaser Rate Mod Rate Change Frequency (Payments)  Mod Payment Change Frequency (Payments)  Mod First Interest Rate Change Date Mod First Payment Change Date Mod Next Interest Rate Change Date Mod Next Payment Change Date Mod Index Type / ARM Type Mod Lookback Period Mod Rounding Factor Mod Rounding Method Mod Initial Rate Cap Mod Initial Rate Floor Mod Initial Rate Maximum Mod Initial Rate Minimum Mod Life Rate Cap Mod Life Rate Floor Mod Life Rate Maximum Mod Life Rate Minimum Mod Periodic Rate Cap Mod Periodic Rate Floor Mod Margin Step 1 Rate Change Date Step 1 Payment Change Date Step 1 Rate Step 1 P&I Step 1 # Payments Step 2 Rate Change Date Step 2 Payment Change Date Step 2 Rate Step 2 P&I Step 2 # Payments Step 3 Rate Change Date Step 3 Payment Change Date Step 3 Rate Step 3 P&I Step 3 # Payments Step 4 Rate Change Date Step 4 Payment Change Date Step 4 Rate Step 4 P&I Step 4 # Payments Step 5 Rate Change Date Step 5 Payment Change Date Step 5 Rate Step 5 P&I Step 5 # Payments Step 6 Rate Change Date Step 6 Payment Change Date Step 6 Rate Step 6 P&I Step 6 # Payments Step 7 Rate Change Date Step 7 Payment Change Date Step 7 Rate Step 7 P&I Step 7 # Payments Step 8 Rate Change Date Step 8 Payment Change Date Step 8 Rate Step 8 P&I Step 8 # Payments Step 9 Rate Change Date Step 9 Payment Change Date Step 9 Rate Step 9 P&I Step 9 # Payments Step 10 Rate Change Date Step 10 Payment Change Date Step 10 Rate Step 10 P&I Step 10 # Payments Mod Prepayment Penalty? Mod Prepayment Penalty Period (months) Mod Prepayment Penalty Percent Amount Year 1 Mod Prepayment Penalty Percent Amount Year 2 Mod Prepayment Penalty Percent Amount Year 3 Mod Prepayment Penalty Percent Amount Year 4 Mod Prepayment Penalty Percent Amount Year 5 Mod Prepayment Balance Allowance  Mod Prepayment Balance Type Mod Hard Penalty Period (Months) Mod Maximum Prepayment Penalty Amount Mod Prepayment Penalty Enforcement Mod Prepayment Penalty Expiration Date Mod Prepayment Penalty Months Interest Mod Stated Penalty Amount Mod Prepayment Terms Mod Extension Deferment? Mod Extension Date New Maturity Date Mod Extension Months Latest Mod Deferment Date Number of Deferments Total Mod Deferment Amount Active Temp Mod? Temp Mod Expiraton Date Temp Mod Status Temp Mod Reverts To Temp Mod Amortization Type Temp Mod UPB Temp Mod Accruing UPB Temp Mod Principal Forgiven Temp Mod Deferred Balance Temp Mod Date Temp Mod First Payment Date Temp Mod Maturity Date Temp Mod Original Interest Rate Temp Mod PI Temp Mod Interest Only Temp Mod Interest Only Period Mod Comments Post Mod Other Change Post Mod Change Date Post Mod Forgiveness Amount Post Mod Change Comment
186554176 XXX XXX XXX   XXX XXX XXX XXX XXX Yes Complete Fixed XXX XXX XXX XXX XXX XXX 8/XX/2022 8/XX/2022 1/XX/2049 318 318 7.350% XXX XXX Monthly In Arrears No     No No 3   No                 Non-HAMP Cure default without capitalization                                                                                                                                                 No                               No           XXX No                                 No      
186554177 XXX XXX XXX   XXX XXX XXX XXX XXX Yes Complete Fixed XXX XXX XXX XXX XXX XXX 3/XX/2022 3/XX/2022 2/XX/2062 480 480 4.500% XXX XXX Monthly In Arrears No     No No 149   No                 Non-HAMP Cure default without capitalization                                                                                                                                                 No                               No           XXX No                                 No