oversight

Birmingham Bancorp Mortgage Corporation, Nonsupervised Lender, West Bloomfield, Michigan, Substantially Complied with HUD's Requirements Regarding Underwriting of Loans but Not Its Quality Control Reviews

Published by the Department of Housing and Urban Development, Office of Inspector General on 2006-09-25.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                                               Issue Date
                                                                        September 25, 2006
                                                               Audit Report Number:
                                                                        2006-CH-1015




TO:        Brian D. Montgomery, Assistant Secretary for Housing-Federal Housing
            Commissioner, H


FROM:      Heath Wolfe, Regional Inspector General for Audit, 5AGA

SUBJECT: Birmingham Bancorp Mortgage Corporation, Nonsupervised Lender, West
            Bloomfield, Michigan, Substantially Complied with HUD’s Requirements
            Regarding Underwriting of Loans but Not Its Quality Control Reviews

                                   HIGHLIGHTS

 What We Audited and Why

             We audited Birmingham Bancorp Mortgage Corporation (Birmingham), a
             nonsupervised lender approved to originate, underwrite, and submit insurance
             endorsement requests under the U.S. Department of Housing and Urban
             Development’s (HUD) single-family direct endorsement program. The audit was
             part of the activities in our fiscal year 2006 annual audit plan. We selected
             Birmingham for audit because of its high default to claim rate. Our objectives
             were to determine whether (1) Birmingham’s quality control plan, as
             implemented, met HUD’s requirements and (2) Birmingham complied with
             HUD’s regulations, procedures, and instructions in the underwriting of Federal
             Housing Administration-insured loans.

 What We Found

             Birmingham’s quality control review process did not comply with HUD’s
             requirements. While Birmingham’s quality control plan fully met HUD’s
             requirements, it was not properly implemented. Birmingham substantially complied
             with HUD’s underwriting requirements on loans that went to claim between October
             1, 2003, and September 30, 2005. It approved only one of 17 Federal Housing
           Administration loans reviewed that did not meet HUD’s requirements. Because of
           Birmingham’s poor quality control reviews, HUD’s Federal Housing Administration
           insurance fund is at an increased risk for loss and abuse.

What We Recommend


           We recommend that HUD’s assistant secretary for housing-federal housing
           commissioner require Birmingham to reimburse HUD for any future loss from the
           claim paid on one loan once the associated property is sold and implement its
           quality control plan for reviewing loans with early payment defaults.

           For each recommendation without a management decision, please respond and
           provide status reports in accordance with HUD Handbook 2000.06, REV-3.
           Please furnish us copies of any correspondence or directives issued because of the
           audit.

Auditee’s Response


           We provided the results of our underwriting and quality control reviews to
           Birmingham’s management during the audit. We also provided our discussion
           draft audit report to Birmingham’s president and HUD’s staff during the audit.
           We conducted an exit conference with Birmingham’s president on August 28,
           2006.

           We asked Birmingham’s president to provide written comments on our discussion
           draft audit report by September 07, 2006. Birmingham’s president provided
           written comments to the discussion draft report dated September 06, 2006.
           Birmingham generally agreed with our finding and recommendation regarding its
           quality control reviews, but not finding 2 regarding its underwriting. The
           complete text of the auditee’s response, along with our evaluation of that
           response, can be found in appendix B of this report.




                                            2
                            TABLE OF CONTENTS

Background and Objectives                                                       4

Results of Audit

       Finding 1: Birmingham’s Quality Control Review Process Did Not Comply    5
                  with HUD’s Requirements

       Finding 2: Birmingham Substantially Complied with HUD’s Underwriting     7
                  Requirements

Scope and Methodology                                                           9

Internal Controls                                                               10

Followup on Prior Audits                                                        12

Appendixes
   A. Schedule of Questioned Costs                                              13
   B. Auditee Comments and OIG’s Evaluation                                     14
   C. Federal Requirements and Birmingham’s Requirements                        20
   D. Summary of Quality Control Deficiencies Using Birmingham’s Requirements   22




                                           3
                     BACKGROUND AND OBJECTIVES

Birmingham Bancorp Mortgage Corporation’s (Birmingham) headquarters and one lending
office are located in West Bloomfield, Michigan. Incorporated in the State of Michigan in 1985,
Birmingham was approved by the U.S. Department of Housing and Urban Development (HUD)
as a nonsupervised direct endorsement lender to originate Federal Housing Administration-
insured loans in July 1988. As a direct endorsement lender, Birmingham determines that the
proposed mortgage is eligible for insurance under the applicable program regulations and
submits the required documents to HUD without its prior review of the origination and closing of
the mortgage loan. Birmingham is responsible for complying with all applicable HUD
regulations and handbook instructions.

As of September 15, 2006, Birmingham had 203 loan correspondents, seven principals, and two
authorized agents. Birmingham is primarily a wholesale and retail residential lender offering
Federal Housing Administration, U.S. Department of Veterans Affairs, and conventional
financing. It also offers commercial financing through private investors. For its retail
operations, Birmingham is authorized to originate loans in Michigan, Ohio, Indiana, and Florida.
For its wholesale operations, it conducts business in Michigan, Ohio, Indiana, Kentucky,
Tennessee, Georgia, Florida, and Texas.

We audited Birmingham as part of the activities in our fiscal year 2006 annual audit plan.
Between October 1, 2003, and September 30, 2005, Birmingham originated/sponsored 1,301
Federal Housing Administration loans totaling more than $142 million in original mortgage
amounts. Of these, 52 loans totaling more than $5.4 million in original mortgage amounts went
to claim, and/or the borrowers defaulted on their mortgage payments within the first six
payments. Birmingham’s default-to-claim rate was 8.27 percent for October 2003 through
September 2005.

Our objectives were to determine whether (1) Birmingham’s quality control plan, as
implemented, met HUD’s requirements and (2) Birmingham complied with HUD’s regulations,
procedures, and instructions in the underwriting of Federal Housing Administration-insured
loans.




                                               4
                                RESULTS OF AUDIT

Finding 1: Birmingham’s Quality Control Review Process Did Not
                  Comply with HUD’s Requirements
Birmingham did not comply with HUD’s quality control requirements. The written plan fully met
HUD’s requirements; however, it was not properly implemented. The deficiencies occurred
because of Birmingham’s disregard of HUD’s quality control requirements and its HUD-approved
plan. As a result, HUD lacked assurance of the accuracy, validity, and completeness of
Birmingham’s loan origination files.



 Loan Universe and Sample
 Selections

              Using HUD’s Single Family Data Warehouse system and hard-copy payment
              history documentation provided by its servicing lender, we identified 52 loans
              totaling more than $5.4 million in original mortgage amounts that were sponsored by
              Birmingham between October 1, 2003, and September 30, 2005. The loans went to
              claim, and/or the borrowers defaulted within the first six payments. We statistically
              selected 21 loans totaling more than $2 million in original mortgage amounts
              from the universe of the 52 loans that Birmingham quality control reviewed to
              determine whether the reviews complied with HUD’s quality control
              requirements.

 Birmingham’s Quality Control
 Plan Not Implemented

              Birmingham did not comply with HUD’s quality control requirements. The
              written plan fully met HUD’s requirements; however, we statistically selected 21
              early payment defaulted loans to determine whether Birmingham’s quality control
              reviews were in compliance with HUD’s requirements. Birmingham could not
              provide the quality control review sheets for two of the loans; therefore, we only
              reviewed 19 of the quality control review sheets. None of the 19 quality control
              reviews was performed in compliance with Birmingham’s quality control plan
              and/or HUD’s requirements as follows:

                     •   Three quality control reviews were not performed in a timely manner.
                         The number of days in which these loans were reviewed after the
                         borrowers defaulted on their mortgage accounts ranged from 130 to 163
                         days;




                                                5
                  •   Five quality control review sheets did not contain the date the quality
                      control reviewer completed the review;

                  •   Fifteen quality control review sheets did not contain evidence that a
                      reverification of borrowers’ employment, deposits, gift letters, credit
                      reports, or other sources of funds was performed; and

                  •   Fifteen quality control review sheets did not contain the results and/or
                      findings, and did not identify the action taken to resolve the
                      deficiencies found during Birmingham’s reviews when applicable.

Birmingham’s Quality Control
Plan Not Followed

           Birmingham did not follow its quality control plan, which was in compliance with
           HUD’s quality control plan requirements. According to the president,
           Birmingham quality control reviewed the loans that went into a 90-day default
           within the first seven payments instead of the loans that went into a 60-day default
           within the first six payments as required by HUD. Birmingham indicated that it
           used HUD’s Neighborhood Watch system to identify the early payment defaulted
           loans; however, the system does not report on the loans that default in less than
           90-days.

           Birmingham did not follow its quality control plan procedures because it believed
           that certain components, in particular reverification of the borrowers’
           employment, assets and income, were not necessary because it did not have a
           history of fraud or misrepresentation.

           As a result of Birmingham’s disregard of its HUD-approved quality control plan,
           HUD cannot be assured of the accuracy, validity, and completeness of the loan
           origination files. Appendix D of this report provides a summary of Birmingham’s
           quality control deficiencies.

Recommendation

           We recommend that HUD’s assistant secretary for housing-federal housing
           commissioner require Birmingham to

           1A.    Implement its quality control plan for reviewing loans that are early
                  payment defaults to ensure its compliance with HUD’s requirements and
                  its HUD approved plan.




                                             6
Finding 2: Birmingham Substantially Complied with HUD’s
                    Underwriting Requirements
Birmingham substantially complied with HUD’s underwriting requirements for Federal Housing
Administration loans. For the 17 loans reviewed, only one did not meet HUD’s requirements. The
17 loans went to claim between October 1, 2003, and September 30, 2005. The one improperly
underwritten loan contained underwriting deficiencies that were material as well as technical. The
deficiencies occurred because Birmingham’s quality control plan was not adequately implemented.
As a result of the improperly underwritten loan, HUD paid a claim.



 Underwriting Deficiencies of
 Federal Housing
 Administration Loans

               Birmingham sponsored and closed 1,301 Federal Housing Administration-insured
               loans totaling more than $142 million between October 1, 2003, and September
               30, 2005. Of these, 17 loans totaling more than $2 million in original mortgage
               amounts went to claim. We reviewed all 17 loans for compliance with HUD’s
               underwriting requirements.

               Birmingham improperly underwrote one (loan number 151-7683555) of the 17
               loans with a total mortgage value of more than $155,000. The one loan was a
               purchase transaction. As of September 15, 2006, HUD had paid more than a
               $162,000 claim for the loan.

               Loan number 151-7683555

               Birmingham improperly approved the loan using the borrower’s regular earnings
               and commission income without developing an average for the commission
               income and providing a sound rationalization for acceptance. The mortgage
               credit analysis worksheet listed compensating factors that were valid; however,
               they did not adequately justify the inclusion of the borrower’s commission
               income due to the conflicting pay documentation contained in the Federal
               Housing Administration casebinder. For example, the loan application, mortgage
               credit analysis worksheet, and paystubs in the casebinder contained different
               monthly earning amounts.

               Further, the borrower’s commission income was not consistent or supported by
               the pay documentation. The paystubs in the casebinder identified year-to-date
               balances that did not change although the borrower earned wages or commission
               for two consecutive pay periods. Based on the inconsistencies in the borrower’s
               income information, we excluded the borrower’s commission income from the
               calculation of the borrower’s debt-to-income ratios. Therefore, Birmingham
               approved the loan when the borrower’s mortgage payment-to-effective income


                                                 7
           ratio was 49.2 percent and total fixed payment to effective income ratio was 80
           percent.

           Paragraphs 2-12 and 2-13 of HUD Handbook 4155.1, REV-4 and REV-5, specify
           that the ratio of mortgage payments to effective income (front ratio) generally
           may not exceed 29 percent and the ratio of total fixed payments to effective
           income (back ratio) may not exceed 41 percent unless significant compensating
           factors are presented. The handbook allows greater latitude in considering
           compensating factors for the front ratio than the back ratio.

Underwriting Procedures and
Controls Adequate


           Birmingham’s underwriting procedures and controls for Federal Housing
           Administration-insured loans were adequate. Further, in December 2005,
           Birmingham implemented the Data Integrity Search and Score report, which is a
           comprehensive electronic fraud prevention and identification tool to assist with
           the detection and prevention of fraud. Although Birmingham implemented the
           Data Integrity Search and Score report, it needs to ensure that it implements its
           HUD-approved quality control plan (see finding 1 of this report). The plan serves
           as a control mechanism to minimize or prevent improper underwriting of loans;
           protect Birmingham and HUD from unacceptable risk and guard against errors,
           omissions, and fraud; thus decreasing the risk to the Federal Housing
           Administration fund. Using the Data Integrity Search and Score report in
           conjunction with an implemented control process would provide greater assurance
           that the risk to the Federal Housing Administration was at an acceptable level.

Recommendation


           We recommend that HUD’s assistant secretary for housing-federal housing
           commissioner require Birmingham to

           2A.    Reimburse HUD for any future loss from the $162,425 claim paid on the
                  one loan (151-7683555) with a total mortgage value of more than
                  $155,000. The estimated risk to the Federal Housing Administration fund
                  is $47,103.




                                            8
                         SCOPE AND METHODOLOGY

We performed our audit work between January and August 2006. We conducted our audit at
Birmingham’s West Bloomfield, Michigan, headquarters office and HUD’s Chicago regional
office. The audit covered the period October 1, 2003, through September 30, 2005. We
extended this period as necessary. We conducted the audit in accordance with generally
accepted government auditing standards.

To achieve our objectives, we relied on computer-processed data contained in HUD’s Single Family
Data Warehouse and hard-copy payment histories provided by Birmingham obtained from the loan
servicers, since it service release its Federal Housing Administration loans after closing. In
addition, we interviewed HUD’s and Birmingham’s management and staff and borrowers’
employers. Further, we reviewed HUD’s rules, regulations, and guidance for the underwriting
and quality control review of Federal Housing Administration loans.

Using HUD’s data system, we identified that Birmingham sponsored and closed 1,301 Federal
Housing Administration-insured loans totaling more than $142 million between October 1, 2003,
and September 30, 2005. Of these, 17 loans totaling more than $2 million in original mortgage
amounts went to claim. We reviewed all 17 loans for compliance with HUD’s underwriting
requirements.

Additionally, using HUD’s Single Family Data Warehouse system and hardcopy payment history
documentation provided by Birmingham obtained from the loan servicers, since it service release its
Federal Administration loans after closing, we identified 52 loans totaling more than $5.4 million in
original mortgage amounts that were sponsored by Birmingham between October 1, 2003, and
September 30, 2005. The loans went to claim and/or the borrowers defaulted within the first six
payments. We statistically selected 21 loans totaling more than $2 million in original mortgage
amounts using statistical sampling software to review for compliance with HUD’s requirements.
Our sampling criteria used a 90 percent confidence level, 5 percent estimated error rate, and a
precision of plus or minus 10 percent.




                                                  9
                             INTERNAL CONTROLS

Internal control is an integral component of an organization’s management that provides
reasonable assurance that the following objectives are being achieved:

   •   Effectiveness and efficiency of operations,
   •   Reliability of financial reporting,
   •   Compliance with applicable laws and regulations, and
   •   Safeguarding resources.

Internal controls relate to management’s plans, methods, and procedures used to meet its
mission, goals, and objectives. Internal controls include the processes and procedures for
planning, organizing, directing, and controlling program operations. They include the systems
for measuring, reporting, and monitoring program performance.


 Relevant Internal Controls

              We determined the following internal controls were relevant to our objectives:

              •       Program operations - Policies and procedures that management has
                      implemented to reasonably ensure that a program meets its objectives.

              •       Validity and reliability of data - Policies and procedures that management
                      has implemented to reasonably ensure that valid and reliable data are
                      obtained, maintained, and fairly disclosed in reports.

              •       Compliance with laws and regulations - Policies and procedures that
                      management has implemented to reasonably ensure that resource use is
                      consistent with laws and regulations.

              •       Safeguarding resources - Policies and procedures that management has
                      implemented to reasonably ensure that resources are safeguarded against
                      waste, loss, and misuse.

              We assessed the relevant controls identified above.

              A significant weakness exists if internal controls do not provide reasonable
              assurance that the process for planning, organizing, directing, and controlling
              program operations will meet the organization’s objectives.




                                               10
Significant Weakness


           Based on our audit, we believe the following item is a significant weakness:

           •      Birmingham needs to implement its quality control plan for reviewing
                  loans that are early payment defaults to ensure compliance with HUD’s
                  requirements and its HUD-approved plan (see finding 1).




                                            11
                        FOLLOWUP ON PRIOR AUDITS

This is the first audit of Birmingham by HUD’s Office of Inspector General (OIG). The two most
recent independent auditor’s reports for Birmingham covered the years ending December 31, 2003,
and 2004. Both reports resulted in no findings. During the week of November 1, 2004, HUD’s
Quality Assurance Division performed a quality assurance review of Birmingham. The review
resulted in findings related to loan origination and underwriting. All of the findings were closed as
of August 3, 2005.




                                                 12
                                   APPENDIXES

Appendix A

                SCHEDULE OF QUESTIONED COSTS

                            Recommendation       Unsupported
                                number               1/
                                   2A               $47,103
                                  Total             $47,103


1/   Unsupported costs are those costs charged to a HUD-financed or HUD-insured program
     or activity when we cannot determine eligibility at the time of the audit. Unsupported
     costs require a decision by HUD program officials. This decision, in addition to
     obtaining supporting documentation, might involve a legal interpretation or clarification
     of departmental policies and procedures. The amount above reflects that, upon sale of the
     mortgaged property, the Federal Housing Administration’s average loss experience is
     about 29 percent of the claim amount based upon statistics provided by HUD.




                                            13
Appendix B

        AUDITEE COMMENTS AND OIG’s EVALUATION

Ref to OIG Evaluation   Auditee Comments




Comment 1




                          14
Ref to OIG Evaluation                Auditee Comments




Comment 2




                        OIG Evaluation of Auditee Comments




Comment 3




                                        15
Ref to OIG Evaluation   Auditee Comments




Comment 4




Comment 5




Comment 6




                          16
Ref to OIG Evaluation   Auditee Comments




                          17
                       OIG Evaluation of Auditee Comments

Comment 1   Birmingham believes it should not be required to indemnify HUD on loan
            number 151-7683555 because there was no material underwriting deficiencies.
            We disagree. The commission income used by Birmingham to qualify the
            borrower for a Federal Housing Administration loan was not consistent or
            supported by the pay documentation. Additionally, Birmingham improperly
            approved the loan using the borrower’s regular earnings and commission
            income without developing an average for the commission income and
            providing a sound rationalization for acceptance, since this income was earned
            for less than two years. Consequently, the borrower defaulted within the first
            three payments. Birmingham did not use due diligence when it approved this
            loan for Federal Housing Administration insurance because the loan did not
            meet HUD’s requirements.

Comment 2   Birmingham contends that it is unable to determine when borrowers default less
            than 90 days on their mortgage loans within the first six payments due to the
            information not being available. We contacted HUD and were informed that
            Neighborhood Watch identifies loans, reported by the servicing lender, that are
            90 days or more delinquent. We also contacted the lender that serviced
            approximately 88 percent of Birmingham’s Federal Housing Administration
            loans and were informed that the company can provide payment history
            information to the originating lender if it is stated in the sales contract and the
            information is not considered protected applicable laws. Since Birmingham was
            not aware that it could obtain loan payment information data from this particular
            lender on a regular basis if it is stipulated in the sales contract, and HUD does
            not have another system that reports 60 day defaulted loans, we removed the 57
            loans identified as early payment defaults that were not quality control reviewed
            from this audit report.

Comment 3   We stated in the audit report that Birmingham implemented the Data Integrity
            Search and Score system. However, Birmingham needs to implement the
            procedures identified in its quality control plan as required by HUD.

Comment 4   We agree that Birmingham does not have hardcopy payment documentation
            since it service release its Federal Housing Administration loans after closing;
            therefore, we adjusted the audit report.

Comment 5   We agree that Birmingham reviewed two of the five loans timely. However, the
            remaining three loans were not. The number of days in which these loans were
            reviewed after the borrowers’ mortgage accounts went into default, based on the
            borrowers defaulting more than 90-days within the first six payments, ranged
            from 130 to 163 days after the borrowers defaulted.

Comment 6    During our review of Birmingham’s processes for underwriting and quality
             control reviewing its Federal Housing Administration loans, Birmingham



                                           18
made several improvements to its operations to ensure compliance with
HUD’s requirements.




                           19
Appendix C
         FEDERAL REQUIREMENTS AND BIRMINGHAM’s
                     REQUIREMENTS

                                  Quality Control Requirements

HUD Handbook 4060.1, REV-1, “Mortgagee Approval Handbook,” chapter 6, states that

   •   The quality control plan must be in writing. Lenders must have fully functioning quality
       control programs from the date of their initial Federal Housing Administration approval
       until final surrender or termination of the approval.

   •   Quality control of servicing must be an ongoing function. Due to the importance of the
       aspects of servicing, lenders must perform monthly reviews of delinquent loan servicing,
       claims, and foreclosures.

   •   The quality control program must provide for the review and confirmation of information
       on all loans selected for review.

   •   A new credit report must be obtained for each borrower whose loan is included in a
       quality control review unless the loan was a streamline refinance or was processed using
       a Federal Housing Administration-approved automated underwriting system that is
       exempted from this requirement.

   •   Documents contained in the loan file should be checked for sufficiency and subjected to
       written reverification. Examples include the borrower’s employment or other sources of
       income, deposits, gift letters, alternate credit sources, rent payments, and other sources of
       funds.

   •   Each direct endorsement loan selected for a quality control review must be reviewed for
       compliance with HUD’s underwriting requirements, sufficiency of documentation, and
       soundness of the underwriting.

   •   Each loan selected for quality control review must be reviewed to determine whether
       required conditions were met before closing, and the quality control review report and
       followup, including review findings and actions taken plus procedural information, must
       be retained by the lender for a period of two years.

           Birmingham’s Early Payment Default Quality Control Plan Requirements

Birmingham, on a monthly basis, reviews the default figures, both retail and wholesale,
published on Neighborhood Watch. It also monitors all reports received from those wholesalers
to whom the company sells loans to review all loans reported as having gone into default within


                                                20
the first six payments due. The purpose of the review of the early payment default is to evaluate
the accuracy, validity, and completeness of the loan’s origination operation and note any patterns
of deficiencies.

The review process also includes the monitoring of 10 percent of retail closed loan production
and 20 percent of all wholesale production randomly selected its independent reviewer from
Birmingham’s loan portfolio on a monthly basis. Birmingham ensures that all loans selected by
way of random or discretionary sampling are reviewed within 60 days of the end of the month in
which they closed for compliance with the policies and requirements of HUD and those of its
investors. The compliance review will include reverification and may include borrower
interviews. In all cases, this will include the verifications of employment, deposits, credit
reports, gift funds or other sources of funds and financial statements and whether the settlement
statement and universal residential loan application statement are filled out and properly
certified.

In the file review of all selected cases, documents will be compared to order to identify any
discrepancies and exceptions to company policy and the requirements of HUD or its investors.
The review will note any material exceptions, errors or omissions, or unacceptable patterns or
trends, as well as suspected fraud and/or intentional violation of law or regulation. This would
involve comparison of the preliminary loan application; original verification of employment,
deposit, credit report, and other relevant loan documents with the final loan application; and all
reverified documents. Upon thorough review of the file, a written report of the findings shall be
submitted to the senior management outlining any deficiencies and procedural recommendations
to correct them.

On a monthly basis Birmingham’s quality control committee shall determine whether there are
identified any material deficiencies in the loan files or lending procedures and if so, whether all
conflicting information or discrepancies were resolved and properly documented in writing
before submission to HUD for insurance endorsement.

                                HUD’s Underwriting Requirements

Chapter 2, section 2-7(d), of HUD Handbook 4155.1, REV-4, CHG-1, states that commission
income must be averaged over the previous two years. The borrower must provide copies of
signed tax returns for the last two years, along with the most recent pay stub. Borrowers with
commission income received for more than one but less than two years may be considered
favorable provided the underwriter is able to make a sound rationalization for acceptance and can
document the likelihood of continuance.

Chapter 2, section 5, paragraph 2-12, of the handbook states that debt-to-equity ratios are used to
determine whether the borrower can reasonably be expected to meet the expenses involved in
homeownership. If the mortgage payment expense-to-effective income ratio exceeds 29 percent
and/or the total fixed payment-to-effective income exceeds 41 percent, significant compensating
factors should be documented and recorded on the mortgage credit analysis worksheet.




                                                 21
Appendix D

 SUMMARY OF QUALITY CONTROL DEFICIENCIES USING
         BIRMINGHAM’s REQUIREMENTS
                    Untimely                                              No evidence of
                     quality   Quality control                              the quality
                     control     completion      Reverification was not   control results
      Loan number    review     date missing          performed           and/or findings
      261-8761593                     X                    X                     X
      413-3859629                                          X                     X
      261-8157173                                          X                     X
      261-8280307                                          X                     X
      261-8657444      X                                   X                     X
      151-7529678                    X                     X                     X
      263-3723350
      263-3709161                    X                     X                    X
      263-3738644
      262-1496269                                          X                    X
      261-8296053                                          X                    X
      411-3764224
      151-7662628                    X                     X                    X
      261-8328599                                          X                    X
      201-3339864      X                                   X                    X
      151-6767382                                          X                    X
      261-8684275
      151-7613384                    X                    X                     X
      263-3384038      X                                  X                     X
         Totals        3             5                    15                    15




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