99.2
Deloitte
Deloitte & Touche LLP
Suite 1200
695 Town Center Drive
Costa Mesa, CA 92626-7188
USA
Tel: +1 714-436-7100
Fax: +1 714-436-7200
www.deloitte.com
INDEPENDENT AUDITORS' REPORT
Board of Directors and Audit Committee
Ameriquest Mortgage Company
We have examined Ameriquest Mortgage Company's (the "Company") compliance
with its established minimum servicing standards described in the
accompanying Management's Assertion dated March 17, 2004, as of and for
the year ended December 31, 2003. Management is responsible for
compliance with those minimum servicing standards. Our
responsibility is to express an opinion on Ameriquest Mortgage Company's
compliance based on our examination.
Our examination was conducted in accordance with attestation standards
established by the American Institute of Certified Public Accountants and,
accordingly, including examining, on a test basis, evidence about
the Company's compliance with its minimum servicing standards and
performing such other procedures as we considered necessary in the
circumstances. We believe that our examination provides a
reasonable basis for our opinion. Our examination does not
provide a legal determination on the Company's compliance with its
minimum servicing standards.
Our examination disclosed noncompliance during the period from July 1, 2003
to December 31, 2003 with the requirement, stated in the Company's
established minimum servicing standards set forth in Appendix I,
item I.1.b.,to prepare reconciliations of custodial bank accounts within
45 calendar days after the cutoff date. The maximum extent of
noncompliance with the 45-day standard was approximately 25% of all
custodial bank account reconciliations performed for July 2003 and a
maximum of 65 days to reconcile. The extent of noncompliance with
the 45-day standard declined to approximately 12% of all custodial
bank account reconciliations for the month of December 2003.
In our opinion, except for the material noncompliance described in the
preceding paragraph, Ameriquest Mortgage Company complied, in all
material respects, with the aforementioned minimum servicing standards as
of and for the year ended December 31, 2003, as set forth in Appendix I.
/s/: Deloitte & Touche LLP
Deloitte & Touche LLP
March 17, 2004
Ameriquest Mortgage Company logo here
March 17, 2004
Management's Assertion
As of and for the year ended December 31, 2003, Ameriquest Mortgage Company
(the "Company") has complied, in all material respects, except as described
in the following paragraph, with the Company's established minimum servicing
standards for residential mortgage loans as set forth in Appendix I
(the "Standards"). The Standards are based on the Mortgage Bankers
Association of America's Uniform Single Attestation Program for Mortgage
Bankers. As of and for this same period Ameriquest Mortgage Company,
had in effect a fidelity bond ranging from $21,000,000 to $50,000,000
and an errors and omissions policy in the amount of $15,000,000.
During the period from July 1, 2003 to December 31, 2003 some custodial bank
account reconciliations were not prepared within 45 calendar days after the
cutoff date, as required under the Standards, but were prepared within 65
days. The maximum extent of noncompliance with the 45 day standard was
approximately 25% of all custodial bank account reconciliations performed
for July 2003 and a maximum of 65 days to reconcile. The extent of
noncompliance with the 45 day standard declined to approximately 12% of all
custodial bank account reconciliations for the month of December 2003.
Midyear systems conversions were a significant factor contributing to the
delays, but will ultimately provide more efficient and accurate reporting
to investors. The Company is addressing the delays in the reconciliation
process to achieve the 45 day reconciliation requirement.
/s/: Kirk Langs
Kirk Langs
President
Chief Operating Officer
/s/: Jane Johnson
Jane Johnson
Senior Vice President
Director of Loan Servicing
/s/: Karen Christensen
Karen Christensen
Executive Vice President
Chief Financial Officer
1100 Town & Country Road, Suite 1100, Orange, CA 92868 Phone (714) 564-0600
APPENDIX I
MIMIMUM SERVICING STANDARDS
AS SET FORTH IN THE MORTGAGE BANKERS ASSOCIATION OF AMERICA'S
UNIFORM SINGLE ATTESTATION PROGRAM FOR MORTGAGE BANKERS
I. Custodial Bank Accounts
1. Reconciliations shall be prepared on a monthly basis for all custodial
bank accounts and related bank clearing accounts. These
reconciliations shall:
a Be mathematically accurate;
b Be prepared within forty-five (45) calendar days after the cutoff;
c Be reviewed and approved by someone other than the person who
prepared the reconciliation; and
d Document explanations for reconciling items. These reconciling
items shall be resolved within ninety (90) calendar days of
their original identification.
2. Funds of the servicing entity shall be advanced in cases where there
is an overdraft in an investor's or a mortgagor's account.
3. Each custodial account shall be maintained at a federally insured
depository institution in trust for the applicable investor.
4. Escrow funds held in trust for a mortgagor shall be returned to
the mortgagor within thirty (30) calendar days of payoff of the
mortgage loan.
II. Mortgage Payments
1. Mortgage payments shall be deposited into the custodial bank accounts
and related bank clearing accounts within two business days of receipt.
2. Mortgage payments made in accordance with the mortgagor's loan
documents shall be posted to the applicable mortgagor records within
two business days of receipt.
3. Mortgage payments shall be allocated to principal, interest, insurance,
taxes or other escrow items in accordance with the mortgagor's loan
documents.
4. Mortgage payments identified as loan payoffs shall be allocated in
accordance with the mortgagor's loan documents.
III. DISBURSEMENTS
1. Disbursements made via wire transfer on behalf of a mortgagor or
investor shall be made only by authorized personnel.
2. Disbursements made on behalf of a mortgagor or investor shall be posted
within two business days to the mortgagor's or investor's records
maintained by the servicing entity.
3. Tax and insurance payments shall be made on or before the penalty or
insurance policy expiration dates, as indicated on tax bills and
insurance premium notices, respectively, provided that such support has
been received by the servicing entity at least thirty (30) calendar
days prior to these dates.
4. Any late payment penalties paid in conjunction with the payment of any tax
bill or insurance premium notice shall be paid from the servicing entity's
funds and not charged to the mortgagor, unless the late payment was due to
the mortgagor's error or omission.
5. Amounts remitted to investors per the servicer's investor reports shall
agree with canceled checks, or other form of payment, or custodial bank
statements.
6. Unused checks shall be safeguard so as to prevent unauthorized access.
IV. INVESTOR ACCOUNTING AND REPORTING
1. The servicing entity's investor reports shall agree with, or reconcile to,
investors' records on a monthly basis as to the total unpaid principal
balance and number of loans serviced by the servicing entity.
V. MORTGAGOR LOAN ACCOUNTING
1. The servicing entity's mortgage loan records shall agree with, or reconcile
to, the records of mortgagors with respect to the unpaid principal balance
on a monthly basis.
2. Adjustments on ARM loans shall be computed based on the related mortgage
note and any ARM rider
3. Escrow accounts shall be analyzed, in accordance with the mortgagor's
loan documents, on at least an annual basis.
4. Interest on escrow accounts shall be paid, or credited, to mortgagors
in accordance with the applicable state laws.
VI. DELINQUENCIES
1. Records documenting collection efforts shall be maintained during the
period a loan is in default and shall be updated at least monthly.
Such records shall describe the entity's activities in monitoring
delinquent loans including, for example, phone calls, letters and
mortgage payment rescheduling plans in cases where the delinquency is
deemed temporary (e.g., illness or unemployment).
VII. INSURANCE POLICIES
1. A fidelity bond and errors and omissions policy shall be in effect on the
servicing entity throughout the reporting period in the amount of
coverage represented to investors in management's assertion.