RESIDENTIAL DUE DILIGENCE
Originators, conduits and investors need the assurance of well tested methods. Opus CMC provides precise pre- and post-closing quality control solutions across newly originated assets as well as thorough and independent evaluations of seasoned mortgage assets.
Our stringent quality control process can greatly reduce your recourse risks. Opus CMCs experience with US government agencies and government-sponsored enterprises is extensive, providing the confidence you need, ensuring that your loans meet the requirements for purchase.
In a market where investor recourse is a primary consideration, our due diligence strengthens credibility. Opus CMC has been reviewed by and meets the RMBS standards of Standard and Poor’s, Moody’s, DBRS, Fitch Ratings and KBRA. We provide an accurate and reliable picture of assets, increasing market confidence in sellers and their products. We also offer quality underwriting, combined with the qualitative analysis of data points including: reviews of servicing files, delinquency analysis, borrower correspondence and many others. This drives the due diligence that will identify underlying issues and potential fraud that may not be ascertained by looking at numbers alone.
You need detailed information to be able to make informed decisions and manage risk. Opus CMC provides specialized support for the evaluation and ongoing management of distressed assets. Our experienced team conducts a comprehensive review of the payment and servicing history, along with a valuation analysis and origination compliance audit, ensuring that you understand the larger picture. Our customizable services include:
- Payment History Analysis
- Servicing History Review
- Updated Title Review
- Collateral Review
- Regulatory Compliance Audit
- Valuation Reconciliation
- Modification Underwriting and Processing Support
Prior to purchasing or selling assets, it is necessary to ensure that they are of optimum quality. Opus CMC performs standard credit and compliance reviews to ensure that the assets our clients are purchasing or putting out in the market are of the highest quality.
Our services include performing an audit of all collateral documents including: Notes, Note Addendums/Riders, Name Affidavits, Name Change Documents (i.e. marriage certificate, death certificate), Modification Agreements, Lost Modification Agreements, Assumption Agreement, Mortgages / Deed of Trusts, Titles, Corporate Assignments, Allonges and Power of Attorneys to verify accuracy, completeness, proper conveyance and execution. Opus CMC will confirm that the mortgage is valid and free of encumbrances. Cooperative and leasehold property ownership will include a review of the corresponding security agreements, abstracts and land lease agreements, as applicable. Opus CMC can take curative actions to clear collateral exceptions if requested by the client.
Compliance isn’t magic, it is hard work and attention to detail. It is also not something to go at alone. If you are looking for a partner who can help you understand and comply with the regulatory requirements, Opus CMC may be your answer. Opus CMC provides mortgage loan file reviews which include the new Qualified Mortgage and Ability-to-Repay requirements in compliance with the new Consumer Finance Protection Bureau and HUD guidance. Opus can provide loan level compliance reviews as well as work with your staff to insure systems and operations are following your policies and procedures.
Our reviews include both Credit and Compliance or Compliance only review types and can be customized for client needs. We cover:
- Regulatory compliance review to verify the mortgage loan closed in compliance with applicable federal, state, and local anti-predatory lending statutes in effect at the time of origination
- Ability to Repay review for evidence the creditor considered and verified the eight (8) underwriting factors:
1. Income and assets
2. Current employment status
3. Monthly qualifying payments for the proposed loan
4. Monthly payment on any simultaneous loans
5. Monthly payment for mortgage related obligations for the proposed loans
6. Debts, alimony, and child support
7. Qualifying monthly DTI and/or residual income
8. Credit history
- Qualified Mortgage review of all available QM types including:
– Legacy QM
– Revised QM with APOR
– Agency QM
– Agency QM with APOR
– Government QM
- Regulatory compliance review in line with the most recently dated Structured Finance Association (SFA) TRID Compliance Review Scope
- TRID Review including:
– Eligibility
– Timing Requirements
– Tolerance Violations
– Loan Estimates
– Closing Disclosures
- Material compliance disclosures review set forth in Reg Z, including the Truth in Lending Disclosure and the Notice of Right-to-Cancel, if applicable
- Material disclosures review and comparison with a report outlining any TILA violations
- State High-Cost Testing
- Federal Higher Priced Mortgage Loan Testing including:
– Escrow requirements
– HPML appraisal rule
- Servicing Compliance Review
– Identify areas of potential regulatory risk based on current servicing procedures and practices - Real Estate Settlement Procedures Act (Regulation X)
- Mortgage Disclosure Information Act (MDIA), as applicable
- Home Ownership Equity Protection Act (HOEPA)
- Home Mortgage Disclosure Act (HMDA)
- Equal Credit Opportunity Act (Regulation B)
- Fair Credit Report Act (Regulation V)
- National Flood Insurance Act (NFIP)
Opus CMC is the premier expert in forensic due diligence reviews. Our process and quality results provide the highest confidence of success to our clients. We have created a very thorough and in-depth review that covers all areas necessary to ensure a proper forensic analysis. Our reviews include:
- Employment and Income Verification
- Asset Verification
- Verification of Deposits/Assets
- Guideline Conformity
- Regulatory Compliance
- Valuation Reconciliation
- Red Flag and document consistency