Suite 900
8350 Broad Street
McLean, VA 22102
Exhibit 99.1
|
|
|
| KPMG LLP Suite 900 8350 Broad Street McLean, VA 22102 |
Independent Accountants’ Agreed-Upon Procedures Report
Citi Affordable Depositor LLC
Citibank, N.A. (together, the “Company”)
Federal Home Loan Mortgage Corporation
Wells Fargo Securities, LLC
Jefferies LLC
(collectively, with the Company, the “Specified Parties”)
Re: FRETE 2026-ML39 Trust – Data File Procedures
We have performed the procedures described below on the specified attributes in an electronic data file entitled “FRETE ML 39_Securitization tape_10.29.2026_vF.xlsx” (the “Data File”) provided by the Company on October 29, 2026, containing information on 15 funding loans intended to be tax-exempt loans (the “Loans”), backed by multifamily mortgage loans that are secured by 14 related mortgaged real properties (the “Mortgaged Properties”) as of November 1, 2026 (the “Cut-Off Date”), which we were informed are intended to be included as collateral in the offering by FRETE 2026-ML39 Trust. The Company is responsible for the specified attributes identified by the Company in the Data File.
The Specified Parties have agreed to and acknowledged that the procedures performed are appropriate to meet the intended purpose of assisting the Specified Parties in evaluating the accuracy of the specified attributes in the Data File. This report may not be suitable for any other purpose. No other parties have agreed to or acknowledged the appropriateness of these procedures for the intended purpose or any other purpose.
The procedures performed may not address all the items of interest to a user of this report and may not meet the needs of all users of this report and, as such, users are responsible for determining whether the procedures performed are appropriate for their purposes. We make no representation regarding the appropriateness of the procedures either for the intended purpose or for any other purpose.
Unless otherwise stated, the following definitions have been adopted in presenting our procedures and findings:
| · | The term “compared” means compared to the information shown and found it to be in agreement, unless otherwise stated. Such compared information was deemed to be in agreement if differences were within the reporting threshold. |
| · | The term “recomputed” means recalculated and compared the result to the information shown and found it to be in agreement, unless otherwise stated. Such recomputed information was deemed to be in agreement if differences were within the reporting threshold. |
| · | The term “reporting threshold” means that dollar amounts, percentages and debt service coverage ratios were within $1.00, 0.1% and 0.01, respectively. |
| · | The term “Compared Attributes” means the list of fields in the Data File which were selected by the Company for us to perform comparison procedures for and are listed in Attachment A. |
| · | The term “Recomputed Attributes” means the list of fields in the Data File which were selected by the Company for us to perform recomputation procedures for and are listed in Attachment B. |
| KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. |
| · | The term “Calculation Methodology” means the formula listed in the Calculation Methodology column of Attachment B containing the calculation methodology for the Recomputed Attributes provided by the Company. |
| · | The term “Instructions” means the instructions provided by the Company pertaining to a procedure, specific attribute, methodology or value, as described in Attachment C. |
| · | The term “Loan Files” means the electronic copies of source documents made available by the Company and listed in Attachment A. We make no representations regarding the validity or accuracy of any of the source documents. |
| · | The term “Provided Information” means the Cut-Off Date, Calculation Methodology, Instructions and Loan Files. |
Prior to being provided the Data File, we received one or more earlier versions of the data file on which to perform our procedures. In performing those procedures, we identified differences which were communicated to the Company. The Data File represents the revised information reflecting resolution of differences communicated as determined appropriate by the Company. We performed the procedures on the Data File, and the results of those procedures are reflected herein.
The procedures we were instructed by the Company to perform for all Loans and related Mortgaged Properties in the Data File and the associated findings are as follows:
| A. | We compared the Compared Attributes in the Data File (except for those with “Provided by Company” in the “Source Document(s)” column of Attachment A) to the corresponding information included in the Loan Files, utilizing the Instructions, as applicable. The Company indicated that the absence of any of the information in the Loan Files or the inability to agree the indicated information from the Data File to the Loan Files for each of the attributes identified, utilizing the Instructions as applicable, constituted an exception (except for those Compared Attributes with “Provided by Company” in the “Source Document(s)” column of Attachment A). The document priority is the order provided by the Company, which is listed in the “Source Document(s)” column of Attachment A, with the highest priority document listed first. |
| B. | We recomputed the Recomputed Attributes in the Data File using (i) the corresponding information contained in the Data File, (ii) the Calculation Methodology and (iii) the Instructions, as applicable. |
We found such information to be in agreement without exception.
We were engaged by the Company to perform this agreed-upon procedures engagement. We conducted our engagement in accordance with attestation standards established by the American Institute of Certified Public Accountants, which involves us performing the specific procedures agreed to and acknowledged above and reporting on findings based on performing those procedures. We were not engaged to, and did not, conduct an examination or review, the objective of which would be the expression of an opinion or conclusion, respectively, on the specified attributes in the Data File. Accordingly, we do not express such an opinion or conclusion. Had we performed additional procedures, other matters might have come to our attention that would have been reported.
We are required to be independent of the Company and to meet our other ethical responsibilities, in accordance with the relevant ethical requirements related to our agreed-upon procedures engagement.
The procedures performed were applied based on the information included in the Data File and Provided Information, without verification or evaluation of such information by us; therefore, we express no opinion or any other form of assurance regarding (i) the reasonableness of the information provided to us by the Company, (ii) the physical existence of the Loans or related Mortgaged Properties, (iii) the reliability or accuracy of the Provided Information which was used in our procedures, or (iv) matters of legal interpretation.
2
The procedures performed were not intended to address, nor did they address: (i) the conformity of the origination of the Loans to stated underwriting or credit extension guidelines, standards, criteria or other requirements, (ii) the value of collateral securing any such Loans being securitized, (iii) the compliance of the originator of the Loans with federal, state, and local laws and regulations, or (iv) any other factor or characteristic of the Loans or related Mortgaged Properties that would be material to the likelihood that the issuer of the certificates will pay interest and principal in accordance with applicable terms and conditions. The procedures performed were not intended to satisfy any criteria for due diligence published by the nationally recognized statistical rating organizations (“NRSROs”).
The terms of our engagement are such that we have no responsibility to update this report because of events and circumstances that may subsequently occur.
This report is intended solely for the information and use of the Specified Parties. It is not intended to be and should not be used by any other person or entity, including investors or the NRSROs, who are not identified in the report as the Specified Parties but may have access to this report as required by law or regulation.
/s/ KPMG LLP
McLean, Virginia
November 4, 2026
3
ATTACHMENT A
COMPARED ATTRIBUTES
| Attribute | Source Document(s) |
| Annex # | Provided by Company |
| Group | Provided by Company |
| Freddie Mac Loan Number | Provided by Company |
| Freddie Mac Underwriting Group | Provided by Company |
| Sponsor Loan Number | Provided by Company |
| Footnotes | Provided by Company |
| Number of Properties | Borrower Loan Agreement, Appraisal Report, Engineering Report, Property Condition Assessment |
| Property Name | Provided by Company |
| Originator | Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note, Borrower Loan Agreement, Funding Loan Agreement |
| Street Address | Appraisal Report, Engineering Report, Property Condition Assessment, Site Inspection Report, Plan and Cost Review, Certificate of Occupancy, USPS Website, Mortgaged Property Website |
| Property City | Appraisal Report, Engineering Report, Property Condition Assessment, Site Inspection Report, Plan and Cost Review, Certificate of Occupancy, USPS Website |
| Property State | Appraisal Report, Engineering Report, Property Condition Assessment, Site Inspection Report, Plan and Cost Review, Certificate of Occupancy, USPS Website |
| Metropolitan Statistical Area (1) | MSA Report |
| Zip Code | Appraisal Report, Engineering Report, Property Condition Assessment, Site Inspection Report, Plan and Cost Review, Certificate of Occupancy, USPS Website |
| County | Appraisal Report, Engineering Report, Property Condition Assessment, Site Inspection Report, Plan and Cost Review, Certificate of Occupancy, USPS Website |
| Property Type | Appraisal Report, Engineering Report, Property Condition Assessment, Site Inspection Report, Plan and Cost Review |
| Property Subtype | Appraisal Report, Engineering Report, Property Condition Assessment, Site Inspection Report, Plan and Cost Review, Regulatory Agreement, Regulatory Agreement Analysis Document |
| MF Product Type | Provided by Company |
| Year Built | Appraisal Report, Conversion Review Memo, Construction Risk Review |
| Year Renovated | Appraisal Report, Conversion Review Memo, Construction Risk Review |
| Total Units | Rent Roll, Appraisal Report |
| Total Units - Commercial | Appraisal Report |
| Commercial Sq. Ft | Appraisal Report |
A- 1
ATTACHMENT A
| Attribute | Source Document(s) |
| Unit of Measure | Rent Roll, Appraisal Report |
| Affordable LI Units (<=80% AMI) (2) | Regulatory Agreement, Regulatory Agreement Analysis Document, Tax Credit Reservation Letter, Tax Credit Application, Tax Credit Allocation Committee Board Meeting Agenda Exhibit, Legal Issues Analysis Document, Appraisal Report, Amended and Restated Limited Partnership Agreement |
| Affordable LI Units (<=60% AMI) (2) | Regulatory Agreement, Regulatory Agreement Analysis Document, Tax Credit Reservation Letter, Tax Credit Application, Tax Credit Allocation Committee Board Meeting Agenda Exhibit, Legal Issues Analysis Document, Appraisal Report, Amended and Restated Limited Partnership Agreement |
| Affordable VLI Units (<=50% AMI) (2) | Regulatory Agreement, Regulatory Agreement Analysis Document, Tax Credit Reservation Letter, Tax Credit Application, Tax Credit Allocation Committee Board Meeting Agenda Exhibit, Legal Issues Analysis Document, Appraisal Report, Amended and Restated Limited Partnership Agreement |
| Occupancy As of Date | Rent Roll |
| Loan/Bond Fully Funded (Y/N) | Provided by Company |
| Loan/Bond Purpose | Credit Memo |
| Cut-Off Date | Provided by Company |
| Note Date | Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note |
| Conversion Date | Notice of Conversion |
| Anticipated Closing Date | Provided by Company |
| First Payment Date (3) | Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note, Notice of Conversion |
| Payment Date | Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note, Notice of Conversion |
| Late Charge Grace Period | Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note |
| Mandatory Prepayment Date | Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note |
| Maturity Date | Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note, Notice of Conversion |
| Extended Maturity Date(s) | Provided by Company |
| Description or Condition of Extension(s) | Provided by Company |
| Loan Term to Extension Maturity Date(s) (Original) | Provided by Company |
| Original Loan/Bond Amount | Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note, Notice of Conversion |
A- 2
ATTACHMENT A
| Attribute | Source Document(s) |
| Cut-Off Date Loan/Bond Amount | Servicer Balance Statement |
| Maturity Balance/Unit ($) | Provided by Company |
| Rate Type | Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note |
| Interest Adjustment Period (months) | Provided by Company |
| First Interest Adjustment Date In Trust | Provided by Company |
| Rate Index | Provided by Company |
| Margin | Provided by Company |
| Gross Interest Rate | Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note, Notice of Conversion |
| Interest Calculation | Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note |
| Rate Rounding Methodology | Provided by Company |
| Interest Accrual Period Day Of Month (Start/End) | Provided by Company |
| Monthly Debt Service (5) | Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note, Notice of Conversion |
| Monthly Debt Service Amount (at Cap) | Provided by Company |
| Loan Amortization Type | Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note, Notice of Conversion |
| IO Period | Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note, Notice of Conversion |
| Interest Only Begin Date | Provided by Company |
| Interest Only End Date | Provided by Company |
| Amortization Term (Original) | Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note |
| Prepayment Provision (7) | Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note, Notice of Conversion |
| Defeasance To Maturity (Y/N) | Borrower Loan Agreement |
| Partial Defeasance Permitted (Y/N) | Borrower Loan Agreement |
| Bond Payment Frequency | Provided by Company |
| UW Date | Credit Approval Package Spreadsheet |
| Appraisal Valuation Date | Appraisal Report |
| Appraised Value | Appraisal Report |
| Appraised Value Type | Appraisal Report |
| UW EGI | Credit Approval Package Spreadsheet |
A- 3
ATTACHMENT A
| Attribute | Source Document(s) |
| UW Expenses | Credit Approval Package Spreadsheet |
| UW NOI | Credit Approval Package Spreadsheet |
| UW NCF | Credit Approval Package Spreadsheet |
| Appraiser UW NCF DSCR | Provided by Company |
| Appraiser UW NCF DSCR (IO) | Provided by Company |
| Appraiser UW EGI | Provided by Company |
| Appraiser UW Expenses | Provided by Company |
| Appraiser UW NOI | Provided by Company |
| Appraiser UW NCF | Provided by Company |
| Most Recent Financial End Date | Operating Statement Analysis Report Spreadsheet |
| Most Recent EGI | Operating Statement Analysis Report Spreadsheet |
| Most Recent Expenses | Operating Statement Analysis Report Spreadsheet |
| Most Recent NOI | Operating Statement Analysis Report Spreadsheet |
| Most Recent NCF | Operating Statement Analysis Report Spreadsheet |
| 2nd Most Recent Financial End Date | Operating Statement Analysis Report Spreadsheet |
| 2nd Most Recent EGI | Operating Statement Analysis Report Spreadsheet |
| 2nd Most Recent Expenses | Operating Statement Analysis Report Spreadsheet |
| 2nd Most Recent NOI | Operating Statement Analysis Report Spreadsheet |
| 2nd Most Recent NCF | Operating Statement Analysis Report Spreadsheet |
| 3rd Most Recent Financial End Date | Operating Statement Analysis Report Spreadsheet |
| 3rd Most Recent EGI | Operating Statement Analysis Report Spreadsheet |
| 3rd Most Recent Expenses | Operating Statement Analysis Report Spreadsheet |
| 3rd Most Recent NOI | Operating Statement Analysis Report Spreadsheet |
| 3rd Most Recent NCF | Operating Statement Analysis Report Spreadsheet |
| Rental/Income/Age Restrictions (Y/N) | Regulatory Agreement, Regulatory Agreement Analysis Document, HAP Contracts, HAP Agreement, HAP Contract Analysis Document, Tax Credit Reservation Letter, Tax Credit Application, Tax Credit Allocation Committee Board Meeting Agenda Exhibit, Legal Issues Analysis Document, Credit Memo |
| Type of Regulatory Agreement(s) | Regulatory Agreement, Regulatory Agreement Analysis Document, HAP Contracts, HAP Agreement, HAP Contract Analysis Document, Tax Credit Reservation Letter, Tax Credit Application, Tax Credit Allocation Committee Board Meeting Agenda Exhibit, Legal Issues Analysis Document, Credit Memo, Amended and Restated Limited Partnership Agreement |
| Description of Regulatory Agreement(s) (8) | Regulatory Agreement, Regulatory Agreement Analysis Document, HAP Contracts, HAP Agreement, HAP |
A- 4
ATTACHMENT A
| Attribute | Source Document(s) |
| Contract Analysis Document, Tax Credit Reservation Letter, Tax Credit Application, Tax Credit Allocation Committee Board Meeting Agenda Exhibit, Legal Issues Analysis Document, Credit Memo, Amended and Restated Limited Partnership Agreement | |
| Loan/Bond Level Set Aside | Provided by Company |
| Description of Restrictive Agreement Set Asides | Provided by Company |
| Number of LIHTC Units | Regulatory Agreement, Regulatory Agreement Analysis Document, Tax Credit Reservation Letter, Tax Credit Application, Tax Credit Allocation Committee Board Meeting Agenda Exhibit, Legal Issues Analysis Document, Amended and Restated Limited Partnership Agreement |
| Number of HAP Contract Units | Provided by Company |
| HAP Contract Expiration Date | HAP Contracts, HAP Agreement, HAP Contract Analysis Document, Legal Issues Analysis Document |
| Hap Contract Rents | Provided by Company |
| Single Purpose Borrowing Entity / Single Asset Borrowing Entity | Provided by Company |
| Borrowing Entity Name | Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note |
| Borrowing Entity State of Organization | Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note |
| Borrowing Entity Ownership Type | Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note |
| Guarantor Entity Name | Guaranty Agreement, Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note, Borrower Loan Agreement |
| Guarantor State of Organization | Provided by Company |
| Guarantor Ownership Type | Provided by Company |
| Sponsor Name | Provided by Company |
| Tenants-In-Common (Y/N) | Tenancy In Common Agreement, Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note, Borrower Loan Agreement |
| Recourse to Borrower (Y/N) | Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note, Borrower Loan Agreement |
| Recourse to Guarantor (Y/N) | Guaranty Agreement, Borrower Loan Agreement |
| Crossed Loans/Bonds (Y/N) | Provided by Company |
| Lien Position | Title Policy |
| Title Vesting (Fee/Leasehold/Both) | Title Policy, Deed of Trust |
| Ground Lease (Y/N) | Title Policy, Ground Lease Documents |
| Ground Lease Rent | Title Policy, Ground Lease Documents |
| Ground Lease Maturity Date | Title Policy, Ground Lease Documents |
A- 5
ATTACHMENT A
| Attribute | Source Document(s) |
| Ground Lease Extension (Y/N) | Title Policy, Ground Lease Documents |
| Lockbox (Y/N) | Cash Management Agreement, Lockbox Agreement |
| Cash Management (Description or N/A) | Cash Management Agreement, Lockbox Agreement |
| Engineering Reserve/Deferred Maintenance | Provided by Company |
| Tax Reserve (Initial) (10) | Servicer Balance Statement |
| Tax Reserve (Monthly) | Servicer Balance Statement |
| Insurance Reserve (Initial) (10) | Servicer Balance Statement |
| Insurance Reserve (Monthly) | Servicer Balance Statement |
| Replacement Reserve (Initial) (10) | Servicer Balance Statement |
| Replacement Reserve (Monthly) | Servicer Balance Statement |
| Replacement Reserve - Contractual - Cap ($ or N/A) | Provided by Company |
| Interest Rate Cap Reserve (Initial) | Provided by Company |
| Interest Rate Cap Reserve (Monthly) | Provided by Company |
| Other Reserve (Initial) (10) | Servicer Balance Statement |
| Other Reserve (Monthly) | Servicer Balance Statement |
| Other Reserve Description | Servicer Balance Statement |
| Other Escrow Reserve Description | Provided by Company |
| Springing Reserve Type | Provided by Company |
| Springing Reserve Amount | Provided by Company |
| Seismic Report Date | Seismic Report, Conversion Review Memo, Construction Risk Review, Engineering Report, Property Condition Assessment, Plan and Cost Review |
| Seismic SEL (%) | Seismic Report, Conversion Review Memo, Construction Risk Review, Engineering Report, Property Condition Assessment, Plan and Cost Review |
| Seismic Insurance if PML >= 20% (Y/N) | Seismic Report, Conversion Review Memo, Construction Risk Review, Engineering Report, Property Condition Assessment, Plan and Cost Review |
| Environmental Report Date (Phase I) | Phase I Report |
| Environmental Report Date (Phase II) | Phase II Report |
| Environmental Insurance (Y/N) | Environmental Insurance Certificate |
| Zoning Status | Zoning Report, Zoning Letter, Appraisal Report |
| If Legal Non-Conforming (Describe Issue) | Provided by Company |
| Green Advantage | Provided by Company |
| RAD (Y/N) | Provided by Company |
| Non-Compliance Provisions (Y/N) | Provided by Company |
A- 6
ATTACHMENT A
| Attribute | Source Document(s) |
| Existing Credit Enhancement | Provided by Company |
| Additional Financing In Place (existing) (Y/N) (11) | Title Policy, Secondary Financing Documents, Subordinate Debt Analysis Document, Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note, Borrower Loan Agreement, Legal Issues Analysis Document, Credit Memo |
| Additional Financing Amount (existing) (11) | Title Policy, Secondary Financing Documents, Subordinate Debt Analysis Document, Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note, Borrower Loan Agreement, Legal Issues Analysis Document, Credit Memo |
| Additional Financing Description (existing) (11) | Title Policy, Secondary Financing Documents, Subordinate Debt Analysis Document, Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note, Borrower Loan Agreement, Legal Issues Analysis Document, Credit Memo |
| Type of Subordinate Debt Lender (Private/Public) | Provided by Company |
| Hard Subordinate Debt Term | Provided by Company |
| Hard Subordinate Debt Maturity Date | Provided by Company |
| Hard Subordinate Debt Interest Rate | Provided by Company |
| Future Supplemental Financing (Y/N) | Provided by Company |
| Future Supplemental Financing Description | Provided by Company |
| Tax Abatement (Y/N) | Provided by Company |
| Tax Abatement Expiration Date | Provided by Company |
| Defaults or Forbearances? (Y/N) | Provided by Company |
| PIS (Placed in Service) Date LIHTC | Form 8609, Appraisal Report |
| Remaining Tax Credit ($) | Tax Credit Stream Support File, Draft Tax Credit Stream Support File, Audited Financial Statement, Appraisal Report, Form 8609, Tax Credit Schedule, Analysis of Taxable Income Support File |
| Income Average (Y/N) | Provided by Company |
| Bond Counsel Name | Opinion of Counsel |
| Tax Credit Syndicator Name | Provided by Company |
| Tax Credit Investor Name | Audited Financial Statement, Amended and Restated Limited Partnership Agreement, Limited Partnership Agreement, Limited Partnership Agreement Amendment, Amended and Restated Limited Partnership Agreement Operating Agreement, Operating Agreement, Operating Agreement Amendment, Borrower Organization Chart, Borrower Loan Agreement, Funding Loan Agreement |
| Fiscal Agent/Bond Trustee Name | Funding Loan Agreement, Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note, Borrower Loan Agreement |
A- 7
ATTACHMENT A
| Attribute | Source Document(s) |
| Annual Governmental Lender Fee | Funding Loan Agreement, Borrower Loan Agreement, Regulatory Agreement |
| Annual Fiscal Agent/Bond Trustee Fee ($) | Funding Loan Agreement |
| Annual Fiscal Agent/Bond Trustee Fee Payment Date | Funding Loan Agreement |
| First Annual Fiscal Agent/Bond Trustee Fee Payment Date | Funding Loan Agreement |
| Underlying Bond CUSIP | Provided by Company |
| Mandatory Redemption Date | Provided by Company |
| Mandatory Redemption Price | Provided by Company |
| Mandatory Redemption Date Balance | Provided by Company |
| Optional Redemption Date | Provided by Company |
| Optional Redemption Price | Provided by Company |
| Mandatory Tender Date | Provided by Company |
| Mandatory Tender Price | Provided by Company |
| Bond Principal Allocation | Provided by Company |
| Form of Certificate | Provided by Company |
| Tax-Exempt (Y/N) | Opinion of Counsel |
| AMT-Exempt (Y/N) | Provided by Company |
| In-Custody (Y/N) | Provided by Company |
| Issuer Name | Funding Loan Agreement, Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note, Borrower Loan Agreement |
| Bond Custodian | Provided by Company |
| Custodial Receipt CUSIP | Provided by Company |
| QIB Restricted (Y/N) | Provided by Company |
| Interest Rate Index Floor | Provided by Company |
| Interest Rate Cap or Swap | Provided by Company |
| Interest Rate Cap (Lifetime) | Provided by Company |
| Strike Rate for Interest Rate Cap | Provided by Company |
| Interest Rate Cap Term (months) | Provided by Company |
| Interest Rate Cap Expiration Date | Provided by Company |
| Interest Rate Cap Provider | Provided by Company |
| Extension Fee | Multifamily Note, Amended and Restated Multifamily Note, Amendment or Allonge to Multifamily Note, Borrower Loan Agreement |
| Servicing Fee | Provided by Company |
A- 8
ATTACHMENT A
| Attribute | Source Document(s) |
| Master Servicer Fee | Admin Fee Rate Schedule |
| Sub-Servicing Fee | Admin Fee Rate Schedule |
| Trustee Fee | Fee Proposal Letter, Admin Fee Rate Schedule |
| CREFC Royalty Fee | Admin Fee Rate Schedule |
A- 9
ATTACHMENT B
RECOMPUTED ATTRIBUTES
| Attribute | Calculation Methodology |
| Cut-Off Date Balance/Unit | Cut-Off Date Loan/Bond Amount divided by Total Units. |
| Occupancy % | Number of occupied units listed on the Rent Roll Source Document divided by Total Units. |
| Monthly Rent Per Unit | Monthly residential rent per the Rent Roll Source Document divided by the number of residential units per the Rent Roll or Appraisal Report Source Documents. |
| % of Cut-Off Date Pool Balance | Respective Cut-Off Date Loan/Bond Amount divided by sum of pool Cut-Off Date Loan/Bond Amount. |
| % of Cut-Off Date Group Balance | Respective Cut-Off Date Loan/Bond Amount divided by sum of the related Freddie Mac Underwriting Group Cut-Off Date Loan/Bond Amount. |
| Maturity Balance (4) | Recompute as the aggregate principal amount that is scheduled to be paid on the earlier of the Mandatory Prepayment Date or Maturity Date, as applicable, excluding the principal component that is included in the Monthly Debt Service (5) that is due on the earlier of the Mandatory Prepayment Date or Maturity Date, as applicable, using the Original Loan/Bond Amount, Interest Calculation, Seasoning, IO Period, First Payment Date (3), Mandatory Prepayment Date, Maturity Date, Gross Interest Rate and Monthly Debt Service (5), as applicable. Assume all scheduled payments of principal and/or interest on the Loans are made and that there are no prepayments or other unscheduled collections. |
| Monthly Debt Service (IO) | Recompute using the Original Loan/Bond Amount, Interest Calculation, IO Period and Gross Interest Rate. Assume all scheduled payments of principal and/or interest on the Loans are made and that there are no prepayments or other unscheduled collections. |
| First Monthly Debt Service In Trust | For Loans that will be in their interest only period on the Payment Date in the month immediately following the Cut-Off Date, recompute the interest only payment amount due on such date using the Original Loan/Bond Amount, Interest Calculation, IO Period and Gross Interest Rate. Otherwise, set equal to Monthly Debt Service (5). |
| Amortization Term (Remaining) | Recompute using the Amortization Term (Original), Seasoning and IO Period. |
| Loan/Bond Term Initial (6) | Number of payments between and including the First Payment Date (3) and the earlier of the Mandatory Prepayment Date or Maturity Date, as applicable. |
| Loan/Bond Term (Remaining) | Recompute using the Loan/Bond Term Initial (6), earlier of the Mandatory Prepayment Date or Maturity Date, as applicable, and Cut-Off Date. |
| Seasoning | Loan/Bond Term Initial (6) minus Loan/Bond Term (Remaining). |
| Cut-Off Date LTV | Cut-Off Date Loan/Bond Amount divided by Appraised Value. |
B- 1
ATTACHMENT B
| Attribute | Calculation Methodology |
| Maturity LTV | Maturity Balance (4) divided by Appraised Value. |
| UW NCF DSCR | UW NCF divided by product of 12 and Monthly Debt Service (5). |
| UW NCF DSCR (IO) | UW NCF divided by product of 12 and Monthly Debt Service (IO). |
| Most Recent NCF DSCR | Most Recent NCF divided by product of 12 and Monthly Debt Service (5). |
| Most Recent NCF DSCR (IO) | Most Recent NCF divided by product of 12 and Monthly Debt Service (IO). |
| Related Borrower Loans (9) | Recompute by grouping Loans by Sponsor Name. |
| Issuer Fee | Set equal to Annual Governmental Lender Fee. |
| Administration Fee Rate (12) | Sum of Master Servicer Fee, Sub-Servicing Fee, Trustee Fee and CREFC Royalty Fee, minus Servicing Fee. |
| Net Interest Rate | Gross Interest Rate minus Administration Fee Rate (12). |
B- 2
ATTACHMENT C
INSTRUCTIONS
| 1. | For those Compared Attributes with the source document or instruction indicated as “Provided by Company,” we were instructed by the Company to assume the attribute is accurate and therefore, we did not perform any procedure. |
| 2. | For the Compared Attribute “Metropolitan Statistical Area (1)”, the MSA Report Source Document is an electronic data file entitled “FRETE 2026-ML39_MSA Report_2026.09.09.xlsx” provided by the Company. |
| 3. | For the Compared Attributes in Attachment A with Source Document(s) equal to or including ‘Servicer Balance Statement,’ the Servicer Balance Statement Source Document is an electronic data file entitled “Freddie ML 39_Servicer Balances_10.19.26.xlsx” provided by the Company. |
| 4. | For the Loans with the Compared Attribute “Property Name” equal to ‘Two10 Apartments (Tranche A)’ and ‘Two10 Apartments (Tranche B),’ the respective Loans are secured by the same Mortgaged Property. For the Compared Attribute “Number of Properties,” we were instructed by the Company to use ‘1’ as the value for the Compared Attribute for each of the Loans listed above. |
| 5. | For the Compared Attribute “Property Subtype,” we were instructed by the Company to use (i) ‘Garden’ as the value for the Compared Attribute when the buildings had four or fewer stories indicated in the Source Documents and (ii) ‘Mid Rise’ as the value for the Compared Attribute when the buildings had five to ten stories indicated in the Source Documents. |
| 6. | For the Compared Attribute “Property Subtype,” we were instructed by the Company to use ‘Age Restricted’ as the value for the Compared Attribute when half or more of the units at the Mortgaged Property are marketed as age-restricted, as indicated in the Source Documents. |
| 7. | For the Compared Attribute “First Payment Date (3),” we were instructed by the Company to use the First Payment Date (3) following the Conversion Date, as applicable, as the value for the Compared Attribute if the Notice of Conversion Source Document did not define the first permanent period payment date. |
| 8. | For the Compared Attribute “Mandatory Prepayment Date,” we were instructed by the Company to use the defined notice prepayment date in the Source Documents as the value for the Compared Attribute if mandatory prepayment date was not defined. |
| 9. | For the Compared Attribute “Maturity Date,” we were instructed by the Company to use the earlier of the (i) maturity date defined in the Source Documents or (ii) date the Loan is scheduled to be paid in full, as the value for the Compared Attribute. |
| 10. | For the Compared Attribute “Ground Lease Maturity Date,” we were instructed by the Company to use the fully extended ground lease maturity date, as applicable. |
| 11. | For the Compared Attribute “Seismic Insurance if PML >= 20% (Y/N),” we were instructed by the Company to use ‘Y’ as the value for the Compared Attribute if the applicable Source Document(s) indicated the Seismic SEL (%) is greater than or equal to 20% and seismic insurance is in place. We were instructed by the Company to use ‘N’ as the value for the Compared Attribute if the applicable Source Document(s) indicated the Seismic SEL (%) is less than 20% or seismic insurance is not in place. |
| 12. | For the Compared Attributes “Additional Financing In Place (existing) (Y/N) (11),” “Additional Financing Amount (existing) (11),” and “Additional Financing Description (existing) (11),” we were instructed by the Company not to include any taxable supplemental loans, pari passu companion loans, grants or unsecured loans when comparing the values for the Compared Attributes. |
C- 1
ATTACHMENT C
| 13. | For Loans with a taxable supplemental loan identified in the Source Documents, we were instructed by the Company to include such when recomputing the values for the following Recomputed Attributes: “Cut-Off Date Balance/Unit,” “Cut-Off Date LTV,” “UW NCF DSCR (IO)” and “Most Recent NCF DSCR (IO)”. |
| 14. | For the Loans with the Compared Attribute “Property Name” equal to ‘Two10 Apartments (Tranche A)’ and ‘Two10 Apartments (Tranche B),’ we were instructed by the Company to recompute the values for the Recomputed Attributes “Cut-Off Date Balance/Unit,” “Cut-Off Date LTV,” “Maturity LTV,” “UW NCF DSCR” and “Most Recent NCF DSCR” on an aggregate basis. |
| 15. | For the Compared Attribute “Remaining Tax Credit ($),” were instructed by the Company to include only 25% of the 2026 portion of the tax credit amount indicated by the Source Documents when comparing the value for the Compared Attribute. |
| 16. | For the Compared Attribute “Zoning Status,” we were instructed by the Company to use ‘Legal Non-Conforming,’ as the value for the Compared Attribute when a certain property characteristic’s conformance status was ‘TBD’ in the applicable Source Document. |
| 17. | For the Loan with the Compared Attribute “Property Name” equal to ‘Lakeland Apartments’ we were instructed by the Company to use ‘N/A,’ as the value for the Compared Attribute “Annual Governmental Lender Fee” when the only annual fees payable to the Governmental Lender were monitoring fees, as indicated in the Regulatory Agreement Source Document. |
| 18. | For the Loan with the Compared Attribute “Property Name” equal to ‘Serenity Apartments,’ the Source Documents indicated that an unscheduled principal payment of $36,268.41 was made prior to the First Payment Date (3). We were instructed by the Company to use the May 31, 2024 period ending principal balance of $8,063,731.59 indicated in the Notice of Conversion Source Document when recomputing the value for the Recomputed Attribute “Maturity Balance (4).” |
| 19. | For the Compared Attributes “Appraised Value” and “Appraisal Valuation Date,” we were instructed by the Company to use the appraised value and appraisal valuation date, as shown in the related Appraisal Report, that are associated with the appraisal valuation type that is identified in the “Valuation Type from Appraisal Report” column of the table below. For the Compared Attribute “Appraised Value Type,” we were instructed by the Company to use the appraisal valuation type listed in the “Appraised Value Type” column of the table below. |
| Property Name | Valuation Type from Appraisal Report | Appraised Value Type |
| Four Corners Apartments | Market Value As-Is (Restricted Rents) | As-Is (Rent Restrictions) |
| Astra | As-Is Market Value | As-Is (Rent Restrictions) |
| Vintage at Everett | Market Value As-Is (Restricted Rents) | As-Is (Rent Restrictions) |
| Two10 Apartments (Tranche A) | As-Is Value | As-Is (Rent Restrictions) |
| Two10 Apartments (Tranche B) | As-Is Value | As-Is (Rent Restrictions) |
| Grand Street Commons | As Is (As Encumbered, LIHTC) | As-Is (Rent Restrictions) |
C- 2
ATTACHMENT C
| Property Name | Valuation Type from Appraisal Report | Appraised Value Type |
| Lakeland Apartments | Market Value As-Is (Restricted Rents) | As-Is (Rent Restrictions) |
| Vista Terrace Apartments | Market Value As-Is (Restricted Rents) | As-Is (Rent Restrictions) |
| Main Street Apartments | Market Value As-Is (Restricted Rents) | As-Is (Rent Restrictions) |
| 1860 Alum Rock Apartments | Market Value As-Is (Restricted Rents) | As-Is (Rent Restrictions) |
| 8th Avenue Family Housing | Market Value As-Is (Restricted Rents) | As-Is (Rent Restrictions) |
| Serenity Apartments | As-Is Market Value | As-Is (Rent Restrictions) |
| Villa Vanowen Apartments | Market Value As-Is (Restricted Rents) | As-Is (Rent Restrictions) |
| Solaris Apartments | As-Is Market Value | As-Is (Rent Restrictions) |
| West Terrace | As-Is Market Value | As-Is (Rent Restrictions) |
C- 3