GM Financial Trust 2024-1 Confirms Servicing Compliance, Faces Legal Risks

TL;DR

**This trust is a clean pass on servicing, but keep an eye on GM Financial's legal woes – they could ripple through.**

AI Summary

GM Financial Consumer Automobile Receivables Trust 2024-1, a securitization entity, filed its 10-K for the fiscal year ended December 31, 2025, on March 23, 2026. The trust, sponsored by AmeriCredit Financial Services, Inc. (dba GM Financial), reported no single obligor representing more than 10% of its pool assets, indicating a diversified risk profile for its automobile receivables. There is no external credit enhancement or derivative instruments altering cash flow characteristics, suggesting reliance on the underlying asset performance. The trust's servicer, AmeriCredit Financial Services, Inc., confirmed compliance in all material respects with applicable servicing criteria for the year ended December 31, 2025, as attested by management and independent registered public accounting firms Ernst & Young LLP and KPMG LLP. The sponsor, AmeriCredit Financial Services, Inc., faces inherent uncertainty from various legal and regulatory proceedings, including potential class actions, which could result in substantial damages or reputational harm, potentially affecting noteholders' interests. The trust's structure, as an issuing entity, means it does not report traditional revenue or net income figures in the same way an operating company would, focusing instead on asset performance and servicing compliance.

Why It Matters

This 10-K filing is crucial for investors in the GM Financial Consumer Automobile Receivables Trust 2024-1 as it confirms the servicer's compliance with applicable criteria, providing assurance regarding the management of the underlying auto loan assets. The absence of external credit enhancement means investors are directly exposed to the performance of the securitized receivables, making servicing quality paramount. For employees of AmeriCredit Financial Services, Inc., continued compliance underscores operational stability, while customers are indirectly affected by the efficiency and integrity of loan servicing. In the broader market, this filing offers a glimpse into the health and operational standards within the auto asset-backed securities sector, particularly concerning a major player like GM Financial, influencing competitive dynamics and investor confidence in similar offerings.

Risk Assessment

Risk Level: medium — The risk level is medium due to the sponsor, AmeriCredit Financial Services, Inc., being subject to various pending and potential legal and regulatory proceedings, including class actions, which are inherently uncertain. An adverse outcome could result in substantial damages, fines, or reputational harm, potentially affecting the servicer's ability to perform its duties and thus impacting noteholders' interests. While the trust itself shows strong servicing compliance, the sponsor's external legal environment introduces a notable, unquantified risk.

Analyst Insight

Investors should monitor the legal and regulatory proceedings disclosed by AmeriCredit Financial Services, Inc., as these could indirectly impact the trust's performance. Given the confirmed servicing compliance and lack of external credit enhancement, a deeper dive into the underlying asset pool's performance metrics, if available elsewhere, would be prudent to assess the direct credit risk.

Financial Highlights

debt To Equity

N/A

revenue

N/A

operating Margin

N/A

total Assets

N/A

total Debt

N/A

net Income

N/A

eps

N/A

gross Margin

N/A

cash Position

N/A

revenue Growth

N/A

Key Numbers

• 10% — Maximum single obligor representation (No single obligor represents more than 10% of the pool assets, indicating diversification.)
• 0 — External credit enhancement (There is no external credit enhancement or other support provider, meaning investors rely solely on the underlying assets.)
• 0 — Derivative instruments (No derivative instruments are used to alter payment characteristics, simplifying cash flow analysis.)
• 2026-03-23 — Filing Date (The 10-K was filed on March 23, 2026, for the fiscal year ended December 31, 2025.)

Key Players & Entities

• GM Financial Consumer Automobile Receivables Trust 2024-1 (company) — issuing entity
• AFS SENSUB CORP. (company) — depositor
• AMERICREDIT FINANCIAL SERVICES, INC. (company) — sponsor and servicer
• Citibank, N.A. (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.
• December 31, 2025 (date) — fiscal year end

FAQ

Risk Factors

• Sponsor Legal and Regulatory Proceedings [high — legal]: The sponsor, AmeriCredit Financial Services, Inc. (dba GM Financial), is subject to various legal and regulatory proceedings, including potential class actions. These proceedings could result in substantial damages, significant legal costs, and reputational harm, which could indirectly impact the trust's operations and noteholders' interests.
• Servicing Compliance [medium — operational]: The trust relies on AmeriCredit Financial Services, Inc. as its servicer. While management and independent auditors (Ernst & Young LLP and KPMG LLP) attested to compliance with applicable servicing criteria for the year ended December 31, 2025, any future non-compliance could disrupt cash flows and negatively affect investors.
• Reliance on Underlying Asset Performance [high — financial]: The trust structure lacks external credit enhancement or derivative instruments. This means that the performance of the underlying automobile receivables is the sole determinant of the trust's ability to meet its obligations. Any deterioration in the credit quality or payment performance of these assets poses a direct risk to noteholders.

Industry Context

The automobile finance industry is characterized by significant competition among lenders, including captive finance companies like GM Financial, banks, and independent finance companies. Trends include increasing adoption of digital loan origination and servicing platforms, evolving consumer preferences towards leasing and subscription models, and ongoing scrutiny regarding lending practices, particularly for subprime borrowers. The industry is sensitive to interest rate fluctuations and economic downturns, which can impact loan demand and borrower repayment capabilities.

Regulatory Implications

Securitization trusts, especially those backed by consumer receivables, operate under a framework of regulations designed to protect investors. Compliance with SEC regulations like Regulation AB is paramount. Furthermore, the underlying loan originations are subject to consumer protection laws, and any violations by the servicer or sponsor could lead to penalties and reputational damage, indirectly affecting the trust.

What Investors Should Do

1. Monitor Sponsor's Legal Proceedings
2. Review Servicer Compliance Reports
3. Analyze Underlying Asset Performance

Key Dates

• 2025-12-31: Fiscal Year End — Marks the end of the period for which financial performance is reported in the 10-K.
• 2026-03-23: 10-K Filing Date — Indicates when the annual report was officially submitted to the SEC, providing investors with the latest financial and operational details.
• 2024-01-17: Indenture and Sale and Servicing Agreement Dates — These agreements establish the core structure and operational framework for the trust, including the roles of the trustee, servicer, and issuer.

Glossary

Securitization Entity

A legal entity created to pool assets (like auto loans) and issue securities backed by the cash flows from those assets. (GM Financial Consumer Automobile Receivables Trust 2024-1 is structured as a securitization entity, meaning its financial reporting focuses on the performance of its underlying assets rather than traditional operating revenues and expenses.)

Obligor

A party that owes an obligation, typically a debt, to another party. In this context, it refers to the individual borrowers of the automobile loans. (The diversification of obligors (no single one over 10%) is a key indicator of the pool's risk profile.)

External Credit Enhancement

Third-party guarantees or support mechanisms designed to protect investors from losses in a securitization if the underlying assets underperform. (The absence of external credit enhancement means investors bear the full risk of default from the underlying auto loans.)

Derivative Instruments

Financial contracts whose value is derived from an underlying asset, index, or rate. They can be used to hedge risks or alter cash flow characteristics. (The lack of derivatives simplifies the cash flow analysis for this trust, as payments are directly tied to the performance of the auto receivables.)

Servicing Criteria

A set of standards and procedures that a loan servicer must adhere to when managing the underlying assets of a securitization trust. (Management's attestation and independent auditor confirmation of compliance with these criteria are crucial for investor confidence in the operational integrity of the trust.)

Regulation AB

SEC rules governing the disclosure requirements for asset-backed securities, aiming to provide investors with more transparency. (Specific items from Regulation AB (like 1112(b), 1114(b)(2), and 1115(b)) are referenced, highlighting key disclosure areas for securitization trusts.)

Year-Over-Year Comparison

This filing pertains to the GM Financial Consumer Automobile Receivables Trust 2024-1, which was established in January 2024. Therefore, a direct comparison of key financial metrics like revenue growth, margin changes, or specific risk factors to a prior year's filing for this specific trust is not applicable, as this is its initial annual report. The focus is on establishing its structure, operational compliance, and the risk profile of its initial asset pool.

Filing Documents

• a10-k_gmcar2024x1x2025.htm (10-K) — 72KB
• exhibit311_gmcar2024-1x2025.htm (EX-31.1) — 8KB
• exhibit331_gmcar2024-1x2025.htm (EX-33.1) — 125KB
• exhibit332_gmcar2024-1x2025.htm (EX-33.2) — 25KB
• exhibit341_gmcar2024-1x2025.htm (EX-34.1) — 9KB
• exhibit342_gmcar2024-1x2025.htm (EX-34.2) — 9KB
• exhibit351_gmcar2024-1x2025.htm (EX-35.1) — 6KB
• image_0.jpg (GRAPHIC) — 6KB
• 0002003007-26-000012.txt ( ) — 263KB

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 January 17, 2024, between GM Financial Consumer Automobile Receivables Trust 2024-1 and Citibank, N.A., 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 2024-1 (File No. 333-249515-13) with the SEC on January 22, 2024). Exhibit 4.2 Amended and Restated Trust Agreement, dated as of January 17, 2024, 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 2024-1 (File No. 333-249515-13) with the SEC on January 22, 2024). Exhibit 4.3 Sale and Servicing Agreement, dated as of January 17, 2024, among GM Financial Consumer Automobile Receivables Trust 2024-1, as Issuer, AmeriCredit Financial Services, Inc., dba GM Financial, as Servicer, AFS SenSub Corp., as Seller, and Citibank, N.A., 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 2024-1 (File No. 333-249515-13) with the SEC on January 22, 2024). Exhibit 10.1 Purchase Agreement, dated as of January 17, 2024, between AmeriCredit Fi

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 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.

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 (Citibank, N.A.). 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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