GM Financial Trust 2022-4 Reports Servicing Compliance Amid Legal Risks

TL;DR

**This auto loan securitization trust is operationally sound, but keep an eye on the sponsor's and trustee's legal battles, as they could create headwinds.**

AI Summary

GM Financial Consumer Automobile Receivables Trust 2022-4, a securitization entity, filed its 10-K for the fiscal year ended December 31, 2025, indicating no single obligor represents more than 10% of its pool assets, and no external credit enhancement or derivative instruments are used. The trust, sponsored by AmeriCredit Financial Services, Inc. (dba GM Financial), reported no common equity or market value for non-affiliates, as it is not applicable to this registrant. Key business items like revenue and net income are omitted in accordance with General Instruction J to Form 10-K, which is typical for asset-backed securities trusts. The sponsor, AmeriCredit Financial Services, Inc., faces various legal and regulatory proceedings, including potential class actions, which could result in substantial damages or reputational harm. The Bank of New York Mellon, as Trustee, is also a defendant in RMBS-related lawsuits, alleging expansive duties. Despite these legal risks, AmeriCredit Financial Services, Inc. confirmed compliance in all material respects with applicable servicing criteria for the year ended December 31, 2025, as evidenced by Exhibit 33.1 and Exhibit 35.1.

Why It Matters

This 10-K provides a snapshot of the operational health and legal landscape surrounding GM Financial Consumer Automobile Receivables Trust 2022-4, a key securitization vehicle for GM Financial. For investors in asset-backed securities, the confirmation of servicing compliance by AmeriCredit Financial Services, Inc. is crucial for maintaining confidence in the underlying auto loan portfolio's management. However, the ongoing legal proceedings against both the sponsor and the trustee, The Bank of New York Mellon, introduce potential liabilities that could indirectly impact the trust's performance or the servicer's operational focus. This competitive context highlights the inherent risks in the securitization market, where the stability of the servicing entity is paramount.

Risk Assessment

Risk Level: medium — The risk level is medium due to the ongoing legal and regulatory proceedings faced by both the sponsor, AmeriCredit Financial Services, Inc., and the trustee, The Bank of New York Mellon. The filing explicitly states that an adverse outcome in these proceedings 'could result in substantial damages, settlements, fines, penalties, diminished income or reputational harm to the sponsor, and could materially and adversely affect the interests of the noteholders or the servicer's ability to perform its duties.' While the trust itself has no direct financial exposure to these legal issues, the operational capacity and reputation of its key service providers are critical.

Analyst Insight

Investors should monitor the legal proceedings involving AmeriCredit Financial Services, Inc. and The Bank of New York Mellon closely, as adverse outcomes could indirectly impact the trust's performance or the servicer's operational stability. While the trust reports compliance with servicing criteria, the broader legal environment for its key entities warrants caution and due diligence on the servicer's financial health.

Financial Highlights

total Assets

N/A

total Debt

N/A

Key Numbers

• 10% — Maximum percentage of pool assets represented by a single obligor (No single obligor exceeds this threshold, indicating diversification.)
• 2025-12-31 — Fiscal year end date (The period covered by the 10-K filing.)
• 2026-03-03 — Signature date of the 10-K (Date the report was signed by AFS SenSub Corp.)
• 0001944019 — CIK number of issuing entity (Unique identifier for GM Financial Consumer Automobile Receivables Trust 2022-4.)
• 0001347185 — CIK number of depositor (Unique identifier for AFS SENSUB CORP.)
• 001-13329 — Commission File Number of sponsor (Identifier for AMERICREDIT FINANCIAL SERVICES, INC.)

Key Players & Entities

• GM Financial Consumer Automobile Receivables Trust 2022-4 (company) — Issuing entity
• AFS SENSUB CORP. (company) — Depositor
• AMERICREDIT FINANCIAL SERVICES, INC. (company) — Sponsor and Servicer
• The Bank of New York Mellon (company) — Trustee and Trust Collateral Agent
• Wilmington Trust Company (company) — Owner Trustee
• Clayton Fixed Income Services LLC (company) — Asset Representation Reviewer
• Ernst Young LLP (company) — Independent Registered Public Accounting Firm
• KPMG LLP (company) — Independent Registered Public Accounting Firm
• Richard A. Gokenbach, Jr. (person) — Executive Vice President and Chief Financial Officer of AFS SenSub Corp.
• $0 (dollar_amount) — Aggregate market value of voting and non-voting common equity held by non-affiliates

FAQ

Risk Factors

• Legal and Regulatory Proceedings Against Sponsor [high — legal]: AmeriCredit Financial Services, Inc. (dba GM Financial), the sponsor, is involved in various legal and regulatory proceedings, including potential class actions. These could result in substantial damages and reputational harm, impacting the trust's operations and stability.
• Trustee Involvement in RMBS Lawsuits [medium — legal]: The Bank of New York Mellon, acting as Trustee, is a defendant in RMBS-related lawsuits. Allegations of expansive duties could lead to financial liabilities or operational disruptions for the trustee, indirectly affecting the trust.
• Reliance on Servicing Criteria Compliance [medium — operational]: The trust relies on AmeriCredit Financial Services, Inc.'s confirmation of compliance with applicable servicing criteria, as evidenced by Exhibit 33.1 and Exhibit 35.1. Any failure in these criteria could indicate operational weaknesses.

Industry Context

The auto finance industry, particularly the securitization of consumer automobile receivables, is characterized by a reliance on robust credit assessment and servicing capabilities. Competition among finance companies like GM Financial is intense, driving the need for efficient origination and management of loan portfolios. The market is sensitive to economic conditions, interest rate fluctuations, and regulatory scrutiny, all of which can impact the performance of securitized assets.

Regulatory Implications

The trust operates under the framework of Regulation AB, which governs the disclosure and reporting requirements for asset-backed securities. The sponsor's adherence to servicing criteria and the absence of significant obligors exceeding 10% of pool assets are key compliance points. Legal proceedings against the sponsor and trustee introduce potential risks that regulators and investors monitor closely.

What Investors Should Do

1. Monitor legal proceedings against AmeriCredit Financial Services, Inc. and The Bank of New York Mellon.
2. Review Exhibit 33.1 and Exhibit 35.1 for detailed servicing compliance reports.
3. Assess the diversification of the underlying obligors.

Key Dates

• 2022-10-12: Indenture, Trust Agreement, Sale and Servicing Agreement, and Purchase Agreement executed — Establishes the core legal framework and operational agreements for the securitization trust.
• 2023-03-01: Amended and Restated Articles of Incorporation and Bylaws of AFS SenSub Corp. — Updates the corporate governance documents for the depositor entity.
• 2023-11-16: Incorporation by reference of AFS SenSub Corp. corporate documents — Makes key depositor documents part of the public record for the trust.
• 2025-12-31: Fiscal year end — Marks the end of the reporting period for the 10-K filing.
• 2026-03-03: 10-K filing signature date — Indicates the date the report was officially signed and submitted.

Glossary

Securitization Entity

A legal entity created to pool assets and issue securities backed by the cash flows from those assets. (GM Financial Consumer Automobile Receivables Trust 2022-4 is structured as a securitization entity.)

Obligor

A party that owes an obligation, typically a debt, to another party. (In this context, refers to the individual consumers who have financed their automobile purchases through GM Financial.)

External Credit Enhancement

Third-party guarantees or support mechanisms designed to reduce the credit risk of a securitized pool of assets. (The trust does not utilize any external credit enhancement, meaning the creditworthiness of the underlying receivables is the primary source of security.)

Derivative Instruments

Financial contracts whose value is derived from an underlying asset, index, or rate, used to manage risk or alter cash flows. (The trust does not employ derivative instruments, simplifying its financial structure and risk profile.)

Servicing Criteria

A set of standards and procedures that a servicer must follow when managing securitized assets, as outlined by regulations like Regulation AB. (Compliance with these criteria by the sponsor (GM Financial) is crucial for the trust's operational integrity.)

Asset-Backed Securities (ABS)

Securities that are backed by a pool of assets such as loans, leases, credit card debt, or receivables. (This trust issues ABS backed by consumer automobile receivables.)

Year-Over-Year Comparison

As this is a 10-K filing for a specific securitization trust (2022-4), a direct year-over-year comparison of financial metrics like revenue or net income is not applicable, as these are typically reported by the sponsor (GM Financial) and not the trust itself. The filing focuses on the structure, risks, and compliance of the trust's underlying assets and operations for the fiscal year ending December 31, 2025. Key information pertains to the absence of single obligor concentration exceeding 10% and the lack of external credit enhancement or derivatives, consistent with its structure.

Filing Documents

• a10-k_gmcar2022x4x2025.htm (10-K) — 73KB
• exhibit311_gmcar2022-4x2025.htm (EX-31.1) — 8KB
• exhibit331_gmcar2022-4x2025.htm (EX-33.1) — 122KB
• exhibit332_gmcar2022-4x2025.htm (EX-33.2) — 87KB
• exhibit341_gmcar2022-4x2025.htm (EX-34.1) — 9KB
• exhibit342_gmcar2022-4x2025.htm (EX-34.2) — 12KB
• exhibit351_gmcar2022-4x2025.htm (EX-35.1) — 6KB
• capture1a.jpg (GRAPHIC) — 13KB
• capturea.jpg (GRAPHIC) — 13KB
• imagea.jpg (GRAPHIC) — 5KB
• imageb.jpg (GRAPHIC) — 3KB
• 0001944019-26-000012.txt ( ) — 356KB

RISK FACTORS

ITEM 1A. RISK FACTORS

CYBERSECURITY

ITEM 1C. CYBERSECURITY

LEGAL PROCEEDINGS

ITEM 3. LEGAL PROCEEDINGS

UNRESOLVED STAFF COMMENTS

ITEM 1B. UNRESOLVED STAFF COMMENTS None.

MINE SAFETY DISCLOSURES

ITEM 4. MINE SAFETY DISCLOSURES Not applicable. PART II The following Items have been omitted in accordance with General Instruction J to Form 10-K

MARKET FOR REGISTRANT'S COMMON EQUITY, RELATED STOCKHOLDER MATTERS AND ISSUER PURCHASES OF EQUITY SECURITIES

ITEM 5. MARKET FOR REGISTRANT'S COMMON EQUITY, RELATED STOCKHOLDER MATTERS AND ISSUER PURCHASES OF EQUITY SECURITIES

MANAGEMENT'S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF OPERATIONS

ITEM 7. MANAGEMENT'S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF OPERATIONS

QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK

ITEM 7A. QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK

FINANCIAL STATEMENTS AND SUPPLEMENTARY DATA

ITEM 8. FINANCIAL STATEMENTS AND SUPPLEMENTARY DATA

CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANTS ON ACCOUNTING AND FINANCIAL DISCLOSURE

ITEM 9. CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANTS ON ACCOUNTING AND FINANCIAL DISCLOSURE

CONTROLS AND PROCEDURES

ITEM 9A. CONTROLS AND PROCEDURES

OTHER INFORMATION

ITEM 9B. OTHER INFORMATION None.

DISCLOSURE REGARDING FOREIGN JURISDICTIONS THAT PREVENT INSPECTIONS

ITEM 9C. DISCLOSURE REGARDING FOREIGN JURISDICTIONS THAT PREVENT INSPECTIONS None. PART III The following Items have been omitted in accordance with General Instruction J to Form 10-K

DIRECTORS, EXECUTIVE OFFICERS AND CORPORATE GOVERNANCE

ITEM 10. DIRECTORS, EXECUTIVE OFFICERS AND CORPORATE GOVERNANCE

EXECUTIVE COMPENSATION

ITEM 11. EXECUTIVE COMPENSATION

SECURITY OWNERSHIP OF CERTAIN BENEFICIAL OWNERS AND MANAGEMENT AND RELATED STOCKHOLDER MATTERS

ITEM 12. SECURITY OWNERSHIP OF CERTAIN BENEFICIAL OWNERS AND MANAGEMENT AND RELATED STOCKHOLDER MATTERS

CERTAIN RELATIONSHIPS AND RELATED TRANSACTIONS, AND DIRECTOR INDEPENDENCE

ITEM 13. CERTAIN RELATIONSHIPS AND RELATED TRANSACTIONS, AND DIRECTOR INDEPENDENCE

PRINCIPAL ACCOUNTANT FEES AND SERVICES

ITEM 14. PRINCIPAL ACCOUNTANT FEES AND SERVICES PART IV

EXHIBIT AND FINANCIAL STATEMENT SCHEDULES

ITEM 15. EXHIBIT AND FINANCIAL STATEMENT SCHEDULES (a) (1) Not applicable (2) Not applicable (3) As reported under clause (b) (b) Exhibit Number Description Exhibit 3.1 Amended and Restated Articles of Incorporation, dated as of March 1, 2023, of AFS SenSub Corp. (incorporated by reference from Exhibit 3.1 of the Form SF-3 filed by AFS SenSub Corp. (File No. 333-275606) with the SEC on November 16, 2023). Exhibit 3.2 Amended and Restated Bylaws, dated as of March 1, 2023, of AFS SenSub Corp. (incorporated by reference from Exhibit 3.2 of the Form SF-3 filed by AFS SenSub Corp. (File No. 333-275606) with the SEC on November 16, 2023). Exhibit 4.1 Indenture, dated as of October 12, 2022, between GM Financial Consumer Automobile Receivables Trust 2022-4 and The Bank of New York Mellon, as Trustee and Trust Collateral Agent (incorporated by reference from Exhibit 4.1 of the Current Report on Form 8-K filed by GM Financial Consumer Automobile Receivables Trust 2022-4 (File No. 333-249515-08) with the SEC on October 13, 2022). Exhibit 4.2 Amended and Restated Trust Agreement, dated as of October 12, 2022, between AFS SenSub Corp., as Seller, and Wilmington Trust Company, as Owner Trustee (incorporated by reference from Exhibit 4.2 of the Current Report on Form 8-K filed by GM Financial Consumer Automobile Receivables Trust 2022-4 (File No. 333-249515-08) with the SEC on October 13, 2022). Exhibit 4.3 Sale and Servicing Agreement, dated as of October 12, 2022, among GM Financial Consumer Automobile Receivables Trust 2022-4, as Issuer, AmeriCredit Financial Services, Inc., dba GM Financial, as Servicer, AFS SenSub Corp., as Seller, and The Bank of New York Mellon, as Trust Collateral Agent (incorporated by reference from Exhibit 4.3 of the Current Report on Form 8-K filed by GM Financial Consumer Automobile Receivables Trust 2022-4 (File No. 333-249515-08) with the SEC on October 13, 2022). Exhibit 10.1 Purchase Agreement, dated as of October 12, 20

FORM 10-K SUMMARY

ITEM 16. FORM 10-K SUMMARY None. SUBSTITUTE INFORMATION INCLUDED IN ACCORDANCE WITH GENERAL INSTRUCTION J TO FORM 10-K

(b) OF REGULATION AB. SIGNIFICANT OBLIGORS OF POOL ASSETS (FINANCIAL INFORMATION)

ITEM 1112(b) OF REGULATION AB. SIGNIFICANT OBLIGORS OF POOL ASSETS (FINANCIAL INFORMATION) There is no single obligor that represents more than 10% of the pool assets. ITEM 1114(b)(2) OF REGULATION AB. CREDIT ENHANCEMENT AND OTHER SUPPORT, EXCEPT FOR CERTAIN DERIVATIVE INSTRUMENTS (FINANCIAL INFORMATION) There is no external credit enhancement or other support provider that is liable to provide payments supporting any notes or certificates issued by the Issuing Entity.

(b) OF REGULATION AB. CERTAIN DERIVATIVE INSTRUMENTS (FINANCIAL INFORMATION)

ITEM 1115(b) OF REGULATION AB. CERTAIN DERIVATIVE INSTRUMENTS (FINANCIAL INFORMATION) No entity provides any derivative instruments that are used to alter the payment characteristics of the cash flows from the Issuing Entity.

OF REGULATION AB. LEGAL PROCEEDINGS

ITEM 1117 OF REGULATION AB. LEGAL PROCEEDINGS The Sponsor and the Servicer The sponsor is subject to various pending and potential legal and regulatory proceedings in the ordinary course of business, including litigation, arbitration, claims, investigations, examinations, subpoenas and enforcement proceedings. Some litigation against the sponsor could take the form of class actions. The outcome of these proceedings is inherently uncertain, and thus the sponsor cannot confidently predict how or when proceedings will be resolved. An adverse outcome in one or more of these proceedings could result in substantial damages, settlements, fines, penalties, diminished income or reputational harm to the sponsor, and could materially and adversely affect the interests of the noteholders or the servicer's ability to perform its duties under the Transaction Documents. The Trustee and the Trust Collateral Agent In the ordinary course of business, The Bank of New York Mellon is named as a defendant in legal actions. In connection with its role as trustee of certain residential mortgage-backed securitization, or RMBS, transactions, The Bank of New York Mellon has been named as a defendant in a number of legal actions brought by RMBS investors. These lawsuits allege that the trustee had expansive duties under the governing agreements, including the duty to investigate and pursue breach of representation and warranty claims against other parties to the RMBS transactions. While it is inherently difficult to predict the eventual outcomes of pending actions, The Bank of New York Mellon denies liability and intends to defend the litigations vigorously.

OF REGULATION AB. AFFILIATIONS AND CERTAIN RELATIONSHIPS AND RELATED TRANSACTIONS

ITEM 1119 OF REGULATION AB. AFFILIATIONS AND CERTAIN RELATIONSHIPS AND RELATED TRANSACTIONS Information required by Item 1119 of Regulation AB has been omitted from this report on Form 10-K in reliance on the Instruction to Item 1119.

OF REGULATION AB. COMPLIANCE WITH APPLICABLE SERVICING CRITERIA

ITEM 1122 OF REGULATION AB. COMPLIANCE WITH APPLICABLE SERVICING CRITERIA. The following documents are filed as part of this report. Exhibit Number Description Exhibit 33.1 Management's Assertion Regarding Compliance with Applicable Servicing Criteria concerning servicing activities of AmeriCredit Financial Services, Inc. and its subsidiaries for the year ended December 31, 2025. Exhibit 33.2 Assessment of Compliance with Applicable Servicing Criteria (The Bank of New York Mellon). Exhibit 34.1 Report of Independent Registered Public Accounting Firm (Ernst Young LLP). Exhibit 34.2 Report of Independent Registered Public Accounting Firm (KPMG LLP). The Servicer has complied, in all material respects, with the Applicable Servicing Criteria.

OF REGULATION AB. SERVICER COMPLIANCE STATEMENT

ITEM 1123 OF REGULATION AB. SERVICER COMPLIANCE STATEMENT The following documents are filed as part of this report. Exhibit Number Description Exhibit 35.1 Servicer Compliance Statement of AmeriCredit Financial Services, Inc.

SIGNATURES

SIGNATURES Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, AFS SenSub Corp. has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized. By AFS SENSUB CORP., as Depositor By s Richard A. Gokenbach, Jr. Name Richard A. Gokenbach, Jr. Title Executive Vice President and Chief Financial Officer Date March 3, 2026 Supplemental Information to be Furnished With Reports Filed Pursuant to Section 15(d) of the Act by Registrants Which Have Not Registered Securities Pursuant to Section 12 of the Act. No annual report, proxy statement, form of proxy or other proxy soliciting material has been sent to certificateholders, and the registrant does not presently contemplate sending any such materials subsequent to the filing of this report.

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